Orchid PE
Member? You 'member.
- Joined
- Oct 28, 2019
- Messages
- 6,834
- Reaction score
- 1,620
I figured I would share this with y'all since it's PE related.
On June 26th I applied for licensure in a state by comity using my NCEES profile to transmit all required information. The following day, I was denied licensure.
I originally became licensed in FL on Dec 31, 2019. This was during the time at which the state had not decoupled the experience requirements from sitting for the exam, so I had to gain approval from my board before registering for the exam. I was in an interesting situation since I worked in a field that fell under the industrial exemption. All but 21 months of the 48 required for the application were verified by a licensed PE, and the remaining months were verified by a practicing engineer exempt from licensure as defined by F.S 471.003(2)(d). Shortly after receiving my FL license I created my NCEES profile and applied for licensure in TN. There were no issues after the TN application, and I became licensed in TN a few months later.
A little over a year went by before I needed to apply for other states, the next being NC. I had an updated NCEES profile, 7 references, and licenses in 2 other states. The application process for NC was very easy. I applied on May 17th and received notification I was licensed in NC on May 21st.
Now comes SC. I needed this state in addition to NC for my current job. NCEES released my transmittal to NC and SC on the same day (May 17th). SC required an additional form and registration fee to be mailed, and in the form it clearly identified that I was applying for licensure by comity. On May 26th a representative from the SC board notified me all my documentation and fees were received and processing of my application had begun. The following day, I received an email stating a member of the board had reviewed my application by comity and had denied my application since I did not have 4 years of qualifying experience under the supervision of a licensed PE. They then copy and pasted this section of their statues into the email:
I tried to explain that when I originally applied for licensure in FL they allowed verification of work experience to be completed by a practicing engineer that is exempt from licensure. I asked if the SC board had similar rules allowing for work experience verification. They simply replied, "South Carolina board does not allow that." I'm thinking to myself, you need to work with me a little bit here. I'm already registered in 3 states and have been practicing engineering myself as a licensed PE for almost a year and a half. I started doing some digging and found this paragraph in SC board guidelines for reporting experience:
The part that stuck out to me, and the part I emailed back to the SC rep was:
I figured since I was applying for licensure by comity the person used to verify the remaining 21 months of experience didn't have to be licensed, they only preferred it. I even offered for this supervisor to fill out a new work experience form using the SC board application and have them sign it again.
The email response I received was, "It is at the discretion of the board." They then copy and pasted the same statute section from their previous email. I was starting to get a little impatient with these single line email responses, but I knew if I was going to get through I needed to keep calm and figure out a solution. They also emailed me stating that since the supervisor I would need to use was also listed as a professional reference on my NCEES record, they could not be used to verify work experience. I assumed this to mean that there was the possibility of using that supervisor to verify the work experience. I replied to them saying I currently had 7 professional references, and the SC board only required 5. Please just do not use that supervisor's professional reference and use the remaining 6.
They responded if I chose to use that supervisor to verify work experience, they are not a licensed engineer.
We seem to be going back and forth at this point. To me it seemed they allow non-PEs to approve work experience when applying by comity, yet the SC rep. continued to push I had to have 4 years of experience under a PE. I started to do a little more digging.
I then sent them a lengthy email about how I am currently practicing engineering, why I do not need a licensed PE to verify my work experience per their own guidelines, I asked that they put me in touch with the board member that reviewed my application so that I can discuss this with them directly, I expanded on the 20+ years of engineering experience my previous supervisor had that clearly showed him to be practicing as an engineer, and I stated that there is no question as to my ability to practice engineering as I am already practicing in 3 other states.
I sat on this email for a few days, and while waiting I really started digging into the statues and I found this gem:
I was thinking to myself I wish I found this sooner. Here's the important part:
I copied the full statute to the end of the email, bolded the section above, and said "I am designated as a Model Law Engineer by NCEES, and according to this section I should be eligible to be licensed as a Category A Professional Engineer without further review."
Two weeks later I received an email saying I was licensed in SC.
On June 26th I applied for licensure in a state by comity using my NCEES profile to transmit all required information. The following day, I was denied licensure.
I originally became licensed in FL on Dec 31, 2019. This was during the time at which the state had not decoupled the experience requirements from sitting for the exam, so I had to gain approval from my board before registering for the exam. I was in an interesting situation since I worked in a field that fell under the industrial exemption. All but 21 months of the 48 required for the application were verified by a licensed PE, and the remaining months were verified by a practicing engineer exempt from licensure as defined by F.S 471.003(2)(d). Shortly after receiving my FL license I created my NCEES profile and applied for licensure in TN. There were no issues after the TN application, and I became licensed in TN a few months later.
A little over a year went by before I needed to apply for other states, the next being NC. I had an updated NCEES profile, 7 references, and licenses in 2 other states. The application process for NC was very easy. I applied on May 17th and received notification I was licensed in NC on May 21st.
Now comes SC. I needed this state in addition to NC for my current job. NCEES released my transmittal to NC and SC on the same day (May 17th). SC required an additional form and registration fee to be mailed, and in the form it clearly identified that I was applying for licensure by comity. On May 26th a representative from the SC board notified me all my documentation and fees were received and processing of my application had begun. The following day, I received an email stating a member of the board had reviewed my application by comity and had denied my application since I did not have 4 years of qualifying experience under the supervision of a licensed PE. They then copy and pasted this section of their statues into the email:
49-200 (B)(2) Engineering Experience. (a) The applicant should have meaningful design experience under the supervision of a registered professional engineer in designing components or processes that meet a public need. This experience should include exposure to the formation of design problem statements and specifications, consideration of alternative solutions, feasibility considerations, analytical calculations and detailed systems descriptions. If the experience was not gained under the direct supervision of a registered professional engineer, then the indirect supervision should be explained with clarification of the degree of supervision received.
I tried to explain that when I originally applied for licensure in FL they allowed verification of work experience to be completed by a practicing engineer that is exempt from licensure. I asked if the SC board had similar rules allowing for work experience verification. They simply replied, "South Carolina board does not allow that." I'm thinking to myself, you need to work with me a little bit here. I'm already registered in 3 states and have been practicing engineering myself as a licensed PE for almost a year and a half. I started doing some digging and found this paragraph in SC board guidelines for reporting experience:
Since qualifying work for approval to take the PE exam requires supervision by a licensed engineer, the person verifying the experience should be licensed and should so indicate on the verification board. For applications for licensure by comity, the person verifying the experience should preferably be licensed, but could also be someone who was closely involved in the work and can verify that the description of the work is accurate. An example would be a contractor, owner, or governmental agency.
The part that stuck out to me, and the part I emailed back to the SC rep was:
For applications for licensure by comity, the person verifying the experience should preferably be licensed, but could also be someone who was closely involved in the work and can verify that the description of the work is accurate.
I figured since I was applying for licensure by comity the person used to verify the remaining 21 months of experience didn't have to be licensed, they only preferred it. I even offered for this supervisor to fill out a new work experience form using the SC board application and have them sign it again.
The email response I received was, "It is at the discretion of the board." They then copy and pasted the same statute section from their previous email. I was starting to get a little impatient with these single line email responses, but I knew if I was going to get through I needed to keep calm and figure out a solution. They also emailed me stating that since the supervisor I would need to use was also listed as a professional reference on my NCEES record, they could not be used to verify work experience. I assumed this to mean that there was the possibility of using that supervisor to verify the work experience. I replied to them saying I currently had 7 professional references, and the SC board only required 5. Please just do not use that supervisor's professional reference and use the remaining 6.
They responded if I chose to use that supervisor to verify work experience, they are not a licensed engineer.
We seem to be going back and forth at this point. To me it seemed they allow non-PEs to approve work experience when applying by comity, yet the SC rep. continued to push I had to have 4 years of experience under a PE. I started to do a little more digging.
I then sent them a lengthy email about how I am currently practicing engineering, why I do not need a licensed PE to verify my work experience per their own guidelines, I asked that they put me in touch with the board member that reviewed my application so that I can discuss this with them directly, I expanded on the 20+ years of engineering experience my previous supervisor had that clearly showed him to be practicing as an engineer, and I stated that there is no question as to my ability to practice engineering as I am already practicing in 3 other states.
I sat on this email for a few days, and while waiting I really started digging into the statues and I found this gem:
49-203 (A)(3): A Model Law Engineer applicant may be licensed as a Category A Professional Engineer by making application on the prescribed form and having the NCEES Council Record sent to the Board. To be considered, the Council Record must be submitted directly to the Board by NCEES. Upon receipt of the proper documents and payment of the fee established by the Board, a Model Law Engineer applicant may be licensed as a Category A Professional Engineer without further review.
I was thinking to myself I wish I found this sooner. Here's the important part:
Upon receipt of the proper documents and payment of the fee established by the Board, a Model Law Engineer applicant may be licensed as a Category A Professional Engineer without further review.
I copied the full statute to the end of the email, bolded the section above, and said "I am designated as a Model Law Engineer by NCEES, and according to this section I should be eligible to be licensed as a Category A Professional Engineer without further review."
Two weeks later I received an email saying I was licensed in SC.