The current regime under which licensed uk architects must pass all of the are (Architects Registration Exam) to practise in the us, and us architects the corresponding set of tests to practise in the uk, is an insult to everyone involved.
There was a relatively successful reciprocal arrangement between the two countries until 1990, when the us registration board, ncarb, took the unfortunate step of ending it, mainly because it failed to understand how the uk system actually works. As a result the are has now drifted from its initial purpose - which was to ease the movement of architects between states within the us and to allow experienced individuals without a college degree to gain entry to the profession.
In many us states, eight years' internship alone is acceptable for entry to this registration test. The are provides interns with a standard and systematic induction to professional practice and prepares graduates for the world outside the liberal teaching environment of the us schools. But extending it to uk architects ignores their five years of full-time study at a uk school, their licensed status and their riba Part 3. The uk system goes well beyond the core curriculum that ncarb concentrates into the multiple-choice technical exam (the are) and leaves until the end.
The are is undoubtedly an important gateway for people of a non-architectural, non-university or liberal-arts background but it is not an effective solution for what the California Board refers to as 'architects whose standards and qualifications for...a license to practice architecture are equivalent to those required in this State'.
So why do British-trained us practice directors or professors have to pass the are to use the title 'architect' and why are us architects subject to similar exclusion in Europe? Why not register and integrate these people into their professional peer group with all its support networks? The last thing they need, or have time for, is to re-run the gauntlet of stringent selection tests, the equivalent of which they have already passed.
The California Board acknowledges that the are will take each entrant an average of three and a half years' exposure to 38 hours or so of tests in nine portions. Serious participation requires a huge time commitment and an investment of several thousand dollars. The initial assessment of eligibility takes at least six months.
Some British and Irish graduates are required to take extra tests, for example, to prove competency in English. They receive no credit for having passed the equivalent of riba Part 3 or for the elements of Parts 1 and 2 that cover the are agenda, or for how long they have held a licence. Serious preparation for each 3-7 hour are exam can involve several weeks of spare-time reading, plus the cost of preparation courses, books, travel and lost time from work. (ncarb guidelines suggest 43 hours for all exams).
The us position has a much greater economic imperative in the form of the huge development cost of the computer-administered multiple choice are test. In the late 1980s, with a view to helping pay these development costs, ncarb negotiated a joint venture with the Canadian registration boards in which the are would become the common basis for registration in the two countries.
ncarb's reciprocity arrangement with the uk (1970-1990) was one of the first casualties of this dramatic shift of resources into the are. It gave 12 months unilateral notice of its withdrawal, flying in the face of decades of experience. The absence of any real progress on reciprocity with the uk since 1990 contrasts sharply with ncarb's efforts to establish are 'reciprocity' with other states. China now seems the most likely to buy in.
The more uk and other architects that can be made to take the nine papers of the are, whether or not their home state agrees, the better the chance of paying off the exam's development costs. The more territories that sign up, the larger the market for us architects.
Compare this with the situation in the eu, where licensed architects from any one eu state may become licensed in each of the others (Article 11 of the eu Architects' Directive 85/ 384). The eu system contrasts sharply with the state barriers that still exist within the us. The strength of the eu accord is that it is based on inclusion and continuing support, in contrast to ncarb's preoccupation with entry-level testing.
The success rate of uk licensed architects who take the are indicates that the tests are entirely within the domain of uk study. However, the are imposes a restriction on uk architects' livelihoods by delaying the date by which they can legally practise as an 'architect' in the usa. It is easy to say that if the uk curriculum is similar, the are should be easy. Just like us architects who are already licensed, we have better things to do. No seriously active uk-licensed architect can afford to shut up shop and revert to the extensive programmes of earlier study that are now required under the current us licensing regime.
In the uk there are arguments about whether to maintain a similar barrier against us architects or to set a good example and welcome them to the world of free trade. The English way is to accept diversity, to the extent of making a virtue of it, but the extent to which the us has downplayed our standards means that we must work harder to communicate our common- sense rationale.
The recent row over why architectural services were left out of last year's us Transatlantic Economic Partnership with the eu are a meaningless distraction for those of us who have to live with what is now effectively a licensing trade war. Thanks to a last-minute attack of good sense, the Transatlantic Economic Partnership does now include architectural services, but the details will be negotiated between the eu and the State Department, in consultation with the uk and us registration bodies.
Meanwhile, resources continue to be poured into the pursuit and prosecution of individuals who have been needlessly shut out of the licensing process, while contractors and engineers are allowed to continue to build without architects. These problems in the us are no different from those in the eu, but the system is in denial of the need for reform.
Instead, we could be finding ways to work together to improve the situation internationally and bring the unlicensed flock back into the fold. It would be better to develop common approaches to the provision of continuing education of the profession at work. Comprehensive inter-recognition is the key to a profession that is much less distracted and a public that is much better served.
Hopefully, no one really wants to condemn British practitioners in the us or their us colleagues who work in Europe to professional purgatory, especially when the dream of a seamless licensed profession from one side of the Atlantic to the other could in theory be realised immediately. An offer to this effect has been on the tables of aia and ncarb since autumn 1998. Clearly their leadership is strong enough to set aside worries about paying for the are and accept that offer on behalf of its profession. But will they have the nerve to go on refusing to do so while their own members continue to be marginalised on the European side of the pond?
Tim Clark is president of riba-usa and chair of the California Chapter of the Royal Institute of British Architects. He can be contacted at: firstname.lastname@example.org; tel/fax +1 310 792 8283; or www.riba-usa.org.