June 2006 will mark a distinct turning point in the architecture profession, at least for firms looking to work on an international scale.
June 2006 will mark a distinct turning point in the architecture profession, at least for firms looking to work on an international scale. Three separate Mutual Recognition Agreements are scheduled for review by the NCARB member board during their June meeting, all of which could potentially be ratified and implemented before the end of the year.
NCARB, the Committee of Canadian Architectural Councils (CCAC), and the Federacion de Colegios de Arquitectos de la Republica Mexicana (FCARM) have agreed upon terms for a tri-national agreement motivated by international cooperation and NAFTA. The agreement, which does not supersede the 11+ year old bilateral agreement between Canada and the United States, will allow for the exchange of licensure for architects from the three countries. The exchange facilitates a transfer of licenses not only between the US, Canada, and Mexico, but between Canada and Mexico as well. Up to this point, there has only been “an agreement to agree” and no official qualifications recognition between the United States and Mexico, says H. Carleton Godsey, NCARB President.
A more complex arrangement, between the Architects Council of Europe (ACE) and NCARB has been tentatively agreed upon on a professional level and is also scheduled for ratification during the upcoming board meeting. The establishment of a Mutual Recognition Agreement between ACE and NCARB will certainly do much to eliminate the troubles inherent in obtaining licensure in the European Union or the United States, for architects from their respective nations, but it is not without its troubles.
The structure of NCARB’s member groups is primarily the issue. With each state requiring, or having the ability to require, their own guidelines for licensure in the state, the NCARB “Blue Cover” certification is only partially sufficient for practice in the United States. A foreign architect wishing to practice in the states must first apply to NCARB for Blue Cover certification and then apply to each individual state for licensure in the state jurisdiction. Education requirements, issues regarding Intern Development Programs and general education discrepancies all play into the difficulty for European architects attempting licensure in the United States. NCARB does offer a Broadly Experience Foreign Architect (BEFA) option for the licensure of foreign architects, but limited publicity and the costs, interview requirements, associated paper work, and work dossier specifications have limited the applicant pool to two individuals.
Under the new MRA with ACE, the contentious issue of general education discrepancies will be circumvented. “The agreement between NCARB and ACE is an architect to architect agreement,” states Godsey. There are, however, practice requirements for each of the agreements, which must be met. The ACE/NCARB agreement, the most stringent of all, requires 14 combined years of education, internship, and professional practice after secondary education; the tri-national requires 10 years, and an Australian MRA (also scheduled for ratification in June and tentatively agreed upon) requires 5 years. “We [NCARB] require different times for different reasons. Some countries require little or no qualifications to be an architect,” says Godsey, “NCARB has the option to require additional qualifications under the agreement.”
Once ratified, the Australian and tri-national agreements could be implemented in as little as six-to-eight weeks, according to Godsey. “The ACE agreement is a little more complex and is considered a first step.” According to Alain Sagne, Secretary General of the ACE: “Pending approval, the MRA will be formally transmitted to the official negotiators in the framework of the Transatlantic Economic Partnership, namely, the European Commission acting under a mandate from the EU Council on Behalf of all EU member states and the US Trade Representative (USTR).” “This could take several months,” says Godsey, “NCARB is ready to go on this.”
While no one expects a landslide of applicants for the exchange, many of the large international firms will surely find this an advantage. “Border states, like California, Texas, and New Mexico, might see an increase,” supposes Godsey, “once the tri-national is ratified. But we don’t expect many US architects in Australia or Europe, except in big firms.” Historically, there are very few US architects registered to work in Europe, “probably less than 10,” according to Godsey. And, most foreign architects working in the states associate themselves with a US firm and sign on as a design consultant. According to Greenway Group research, many US-based international firms operate in a similar manner on their foreign projects, either employing registered architects from the project’s country of origin, or utilizing (in countries like China, Dubai, and Turkey) an “established entity legally recognized to work in that country.”
Despite not having quite reached approval, “The topic [of the pending MRA] did end up on the recent EU-US summit agenda in Europe,” writes ACE Secretary General Sagne, in an e-mail message. Once ratified and negotiated by relevant official negotiators, the ACE/NCARB agreement will, based on provisions in the signed agreements, be transposed into an official, legally binding agreement enforceable under international law, “ensuring the recognition of qualifications of architects between the USA and the EU,” Sagne adds.
Tentative attempts to establish agreements between NCARB and China have been in the works, and stalled for nearly the last decade. A request has been made for a New Zealand agreement, and despite all the development in the regions of the world like Dubai, no agreements are on the horizon. As a member of the Asian-Pacific Economic Cooperation, NCARB implemented an APEC certified architect program last September, but no architects have yet been licensed.
Regardless, foreign architects will still be required to meet minimum education and experience requirements prior to being licensed in the United States. And, they will still have to apply for licensure in the jurisdictions in which they hope to work. The majority of NCARB member jurisdictions accept the Blue Cover certification as adequate, but a few maintain the need for additional requirements. The English language requirements frequently brought to the fore by RIBA and other European entities will be effectively diminished by the MRA, but foreign architects will still be required to submit their applications in English. US architects hoping to work in Mexico will also be required to display a minimum competency in Spanish or establish an association with a Spanish speaking architect. US applicants for ACE certification will not be held to any language restrictions and their certification is good throughout all participating member nations.
“The ACE agreement will expedite the BEFA procedures,” offers Godsey, “but the architects will still be required to meet state board requirements.” Colorado, New Mexico, and New York are the only NCARB member states which will license a foreign architect directly; the rest require at least Blue Cover certification.
NCARB, according to Godsey, is: “thinking globally and trying to facilitate mobility of architects both ways,” with these historic agreements. Godsey anticipates the ratification of all three pending MRA, which can only open the door for exchanges between other nations and licensing boards. Contentious or otherwise, all of these agreements bring the architecture profession to an entirely new level of competence, potentially increases the level of competition across, rather than around, the globe, and enhances the role of architects as sculptors of the new world economy.