Top-level talks aimed at allowing architects from the EU and the US to practice freely in each others' markets received a hammer blow last week when the American Institute of Architects admitted that a broad-based reciprocity agreement with all 15 European member states is out of the question.
In meetings and correspondence during the past few weeks, the AIA has told the UK's Architects Registration Board that differences between education, work experience and licensing requirements for architects across the EU are the main stumbling blocks to opening the doors of the world's largest economy to European architects.
In a letter to ARB chief executive Robin Vaughan last week, the president of the AIA's London branch, Lester Korzilius, said: 'There is not a strong common inter-European framework at this time that will allow a broad-based agreement between the EU and the US.' Later Korzilius told the AJ that the US is not willing to accept architects from certain EU countries. 'The differences between Greece and the US are just astronomical, ' he said. Instead it wants to set up an exclusive reciprocity between the US and UK.
But the one-on-one approach was poorly received by ARB and RIBA representatives, who are determined to forge an agreement which opens the USmarket to the rest of Europe as well.Vaughan said the unilateral negotiations 'would sabotage the process we are signed up to. It is our view that we should negotiate as part of the EU team.'
RIBA vice-president for international affairs John Wright said the UK could not consider breaking off from negotiations as part of the rest of the EU because 'it would be seen as driving a wedge in the EU's negotiating position'. Wright added that the UK market is already open to architects from across the EU and that there have never been any problems arising from variations in standards.
Under the American proposals, the US regulator would validate the ARB's own education validation panel, and it would require UK architects to complete an extra year's work experience before working in the US. But to win a licence to work in the US, it is still likely that UK architects would have to take the US professional exam, a task Wright described as 'insulting'. Today, US architects can work in the UK but cannot use the title of architect unless they are registered at the ARB, but UK architects cannot work in the US unless they have passed through the US education system and taken the professional exam.
The Americans' direct approach to the UK regulator comes on top of current EU and US negotiations under the auspices of the Transatlantic Economic Partnership agreement.Vaughan admitted that the TEP negotiations have been 'glacial' and 'disappointing', but said this has partly been because the Americans have proved reluctant to send a delegation to Brussels to hold further talks.