There is time for architects to submit comments.
The California Architects Board (CAB) is holding a virtual meeting on Friday, February 18, from 3:00pm to 4:00pm, to receive public comments on its proposed regulation to require architects to include their name and license number on “all forms of advertisement, solicitation, or other presentations made to the public in connection with the rendition of architectural services … including any advertisement, card, letterhead, telephone listing, Internet Web site, written solicitation to a prospective client or clients, or contract proposal.”
No vote will be taken at the February 18th meeting. The meeting is only to hear public comments. A later meeting will be scheduled when the CAB will vote on the proposed regulation.
Fortunately, architects do not have to attend the February 18th meeting to submit comments. Written comments can be submitted via email. Instructions on how to submit written comments can be found at the bottom of this article.
For your information, here is the actual language of the proposed regulation:
Proposed Regulation Section 135
(a) An architect shall include their name and license number in all forms of advertisement, solicitation, or other presentments made to the public in connection with the rendition of architectural services for which a license is required by the Architects Practice Act, including any advertisement, card, letterhead, telephone listing, Internet Web site, written solicitation to a prospective client or clients, or contract proposal.
(b) For purposes of a business entity that contains or employs two or more architects, the requirements of subsection (a) shall be deemed satisfied as to such business entity’s architects if the business entity’s advertisements, solicitations, or presentments to the public include the name and license number of at least one architect who is (1) in management control of the business entity and (2) either the owner, a part-owner, an officer, or an employee of the business entity.
(c) For the purposes of this section, “management control” shall have the meaning set forth in section 134.
AIA California and several local Chapters will submit written comments opposing the proposed regulation. The points we will raise include:
- The assumption that updating marketing materials (business cards, letterhead, website updates) may cost up to $100 is not accurate. These costs will be higher.
- This will make it easier to steal and illegally use an architect’s license number.
- Focusing on the non-licensed individuals who illegally call themselves architects would protect consumers
- The proposed regulation has a lack of clarity on what it covers; the real world implications are not yet known or understood. For example, how do architects comply when making social media posts about projects?
- This proposed regulation, intended to protect consumers from unlicensed practice, puts all responsibility of compliance on licensed architects.
- Only one other state has this requirement, as it does not increase consumer protection.
Architects can submit written comments to the CAB prior to the February 18 meeting. If you want to submit a written comment expressing your opinion about the proposed regulation Section 135, please send it to:
Kim McDaniel, Regulations Manager
California Architects Board
2420 Del Paso Rd. #105
Sacramento, California 95834
Email: kimberly.mcdaniel@dca.ca.gov
Please feel free to contact AIA CA Director of Government Relations Mark Christian, Hon. AIA CA at mchristian@aiacalifornia.org if you have any questions.
