The article 'US slams door on EU working deal' (AJ 08.03.01) is a gross distortion of the realities of reciprocity, and our suggestions to the ARB.
First, the AIA, like the RIBA, is not a statutory authority. The authority to create reciprocity agreements resides with the ARB in the UK, and with the 50 individual state licensing boards in the US that are represented by NCARB (National Council of Architectural Registration Boards). AIA London was acting as a facilitator in its suggestions to the ARB. As many of our members hold registrations in both countries, we can offer insights to both sides.
You quote us as saying that 'a broad-based reciprocity agreement with all 15 European member states is out of the question'. As our letter makes clear, the range in standards across the EU would probably require country-by-country validation, which will considerably increase the time horizon.
The UIA Accord on Professional Practice, of which the UK was a part, identifies a pathway towards reciprocity based on the components of education, internship, and licensure. Our suggestion was to pursue the education and internship components now. The ARB has advised that EU regulations prevent it from entering into a reciprocity agreement with the USoutside the EU. It was our opinion that this EU constraint applies to licensure (the final step) and that therefore our suggestions to the ARB would be acceptable under EU guidelines.
Your statement that the US is unwilling to accept architects from certain EU countries is incorrect. Just as the UK requires applicants from countries outside the EU to fulfil the requirements of Parts 1,2 and 3, USstates require non-US applicants to fulfil their requirements with regard to education, internship, and professional examination. Given the similarities in education and practice, we felt that agreeing the components of reciprocity would be quicker with the UK than with other EU countries.
With regard to education, we suggested a mutual agreement with the ARB's validation panel and the NAAB (the institution responsible for validating US schools of architecture). With regard to internship, we suggested a direct agreement between the ARB and the NCARB using the RIBA logbook system with the US's In tern Deve lopmen t Programme. We suggested a three-year work experience quotient because there is a one-year discrepancy in the experience required by the two systems. We further suggested that both parties relax restrictions that experience should be within their own countries.
Our proposals stopped short of licensure because of our understanding of the UK's position within the EU. For your article to say that the US would validate ARB's validation panel, but not allow UK architects to work in the US without passing the US licensing examination is a gross distortion. When the final stage of reciprocity - licensure - is being negotiated we would advocate a mechanism that mutually recognises each country's professional examination.
Your article distorts the licensing systems in both countries. The UK's registration system is a protection of title, allowing anyone to function as an architect so long as they don't use the title architect. The system in the US is a protection of function. Many in the UK, including myself when I ran for the ARB board, have advocated that the UK laws be amended to protection of function. The difference in the two systems is not therefore a sinister plot on oneway exclusion as implied.
Finally, you implied that the negotiations are stalled due to the US's recalcitrance. The US Trade Representative and NCARB tell us otherwise, and have been waiting for several months for the EU to come back with a date for the next talks.
The last few years have seen a considerable amount of misinformation in the press implying an air of ill-will which in my experience is non-existent in all but a handful of people with their own personal agendas.
Hopefully future articles in the AJwill meet your otherwise high journalistic standards.
Lester Korzilius, president, AIA/London