Thank you Peter and good morning.

I originally intended to take a few minutes to review several of the positive high points of the year. But the events of recent days suggest that my time and yours would be better spent on something less positive, interior design legislation, and why I believe we must seek to defeat it.

The issue is not new, only the names and faces have changed.

This Council, and every member board, has at one time or another faced the question of unlicensed practice. In the past, if the difficulty was not the result of outright fraud, it most likely revolved around a registered engineer who had ventured into the practice of architecture. Today, and under a different guise, the attempt to practice architecture without a license is coming from interior designers.

The issue is simple: unqualified individuals are trying to dodge rigorous requirements so that they can practice just a little bit of architecture. Architects first became involved in the issue in the 1980s, when "interior designers" sought the help of the American Institute of Architects in obtaining laws that would allow selected members of the interior furnishing and decorating industry to use the title "interior designer." For a variety of reasons, good faith and professional collegiality among them, the AIA agreed to do so, and formalized that agreement in what has become known as the "Accord."

But there were several caveats to that support; among them the interior designers agreed that:

• Interior designers would seek only title registration.
• Interior designers would require a minimum four-year professional degree.
• Interior designers would have NCIDQ test them.
• Interior designers would have a monitored internship.
• Interior designers would not attempt to limit architects from performing or using the title "interior designer."

Many of you, through experience on your board, know what happened. The interior designers abandoned the "Accord" before the ink was dry. So much for good faith and professional collegiality.

But do not think that NCARB has just entered this fight. Our developing position is founded on work that occurred before, during, and since the signing of the "Accord." NCARB has consistently opposed the licensure of interior designers as contrary to the public interest. Our re-focus on interior design legislation began in late 1999, when "interior designers" announced the formal abandonment of their "Accord" and mounted a well-funded lobbying effort to create "practice acts." At that point the question of how the public will be protected under such circumstances moved to the forefront of the Board's discussion.

In October, I appointed an ad hoc committee of the Board to investigate the issue and develop a comprehensive strategy for dealing with it. The committee was chaired by Pat Ryan of Delaware and included Bill Bevins, Pamela Hill, Lenore Lucey, Carl Sapers and me. Following discussion during the Spring Regional Meetings, the ad hoc committee proposed Resolution 00-1, which was unanimously endorsed by the Board of Directors.

What follows will be said directly. This is not about the goodness or badness of anyone. It is about bad law. It is about bad precedent and, in some cases, it is about bad faith. As architects we collaborate with interior designers, we marry interior designers, and our friends include interior designers. I also collaborate with my wife, but I am not about to recommend that, because I like her and work with her, she should be able to practice architecture. But to speak vaguely, or to wish that things were different, or to act like nothing serious is afoot, is a mistake that I will not make.

For newer members, it is worth recalling the difference between a "title" act and a "practice" act. A "title act" gives individuals who meet certain, minimum, criteria the right to call themselves whatever they decide they want to be called; in this case interior designers. A "practice act," on the other hand, defines activities that require specialized education, training and examination, before an individual is granted the right to perform those activities. Obviously, persons granted those rights must satisfy very rigorous criteria.

The "interior design practice acts" attempt to divide a building, and thus the practice of architecture, into two parts: the outside and the inside, and, where possible, limit what an architect can do on the inside. Interior designers are claiming to have specialized knowledge that should allow them to practice just a little bit of architecture without a comprehensive knowledge of building systems or the need to meet the rigid standards required of an architect.

In the naive belief that the structure is the only life-safety system they might encounter, interior designers include only "non-structural" components of a building in their definition of interior design. But where does the inside and outside of a building begin and end? What is "structural" and what is not?

In the 21st century, the "interior" of the simplest building is a complex mechanism that requires knowledge of more than color and texture to comprehensively design and coordinate its life-safety systems.

If the interior designers' attempt is successful--and untrained persons are allowed to take on tasks traditionally performed by registered architects--I believe this will have a profound effect on public safety, the profession of architecture, and the construction industry. To help you understand why, I will not mince words on the subject.

You need to understand what has happened since NCARB began to investigate and challenge the information being put out by interior designers in their effort to gain new legislation or change existing laws. Since the ad hoc committee reported their preliminary findings to the Spring Regional Meetings, this Council received three letters that I characterize as "demands." The first came from the president of NCIDQ, the second from the president of the Association of Registered Interior Designers of Ontario (ARIDDO), and the third from the Texas Board.

The president of NCIDQ demanded an apology for comments she claimed I made during WESCARB. Ontario demanded that NCARB amend or withdraw Resolution 1. And the Texas Board demanded we stop doing things it considers inappropriate.

Then, last Friday, after failing to receive the National Council of Architectural Registration Board's assurance that we would adhere to their demands, the National Council of Interior Design Qualification filed "Portnoy's complaint" with the Justice Department. A copy of their entire "complaint" will be made available, but I want to note a critical part that lays their efforts bare.

Quote: "NCIDQ is concerned that NCARB's actions are directed toward eliminating interior designers as viable competitors to architects or engineers for a wide range of design services..."

Even in Maine, Texas and Nevada, no person can practice architecture or engineering without satisfying the rigorous standards required for entry into those disciplines. An interior designer can no more be a "viable competitor" to an architect or engineer than can a hairdresser, shoe salesman, funeral director or priest. Those attempting to do so are simply unlicensed practitioners, and in some states they would go to jail.

Now, try to reconcile the interior designers' desire to be "viable competitors" to architects or engineers with last week's statement by the president of NCIDQ-and again I quote: "The standards for the interior design profession cannot be compared to the standards for the architectural profession, since interior designers do not practice architecture."

If interior designers cannot practice architecture, architects have as little basis for "fearing" their competition as interior designers have for believing they could compete with architects and engineers. Meet the standards of architects and engineers and then compete with them until the cows come home. But do not think you will practice even a little bit of architecture without being qualified to do so.

Proponents of interior design legislation want a one-way street and will make any argument or use any tactic to stifle debate. And it is equally clear, as I think you will begin to see, that much "interior design legislation" has been, or is trying to be, enacted on the basis of incomplete or plainly wrong information.

Is the formation of a policy on interior design legislation within NCARB's mission? Of course it is. NCARB believes it is. Even NCIDQ believes it is. Otherwise, why would their president want to meet with NCARB so she could "increase NCARB's knowledge and understanding of NCIDQ; enhance NCIDQ's trust and credibility with NCARB, and resolve the conflict that NCARB has with interior designer licensing?" It strikes me as strange how badly the president of NCIDQ wants to talk to us, when she has worked so hard to stop us from talking to each other.

Now, before I complete what I have to say, and as part of my President's Report, I want NCARB's Counsel, Carl Sapers to include a lawyerly response to these recent "demands"/challenges. Carl.

Two weeks later, having had a long conversation with Derrell Parker, an interior design member of our Nevada Board, I wrote again to Lisa Whited's lawyer, reporting what Derrell had told me as well as what others present at the regional meeting had said. On the basis of those reports, I asserted that nothing said by President Giattina was actionable defamation-that is defamation which our law would recognize-and ended with, "With that confirmation, I hope that this issue may now be laid to rest. Please let me know that you concur." Well that was the last I ever heard from Whited's lawyer: no confirmation, but no further argument, either. But the matter did not end there: Ms. Whited sent her own letter to all members of our Region 5 & 6 boards saying that she had learned from her lawyer that she would not get an apology and stating that nonetheless she wanted to work with NCARB.

Then on May 25, the president of the Association of Registered Interior Designers of Ontario sent President Giattina a letter in which she described his conduct as "potentially libelous, and likely interferes in a tortuous" [I think she meant "tortious"] manner with the...business practice of interior designers." And then threatening that if Joe failed to withdraw Resolution 00-1, interior designers would take "appropriate action."

All this talk of defamation and tortious conduct sounds like the fulminations of what we in Massachusetts call "jail-house lawyers." But there lurks beneath the surface a serious effort to suppress debate. Whatever they may be teaching in FIDER-approved interior design programs respecting fabrics and color, there obviously is very little about the First Amendment, the meaning of free speech, and the great 1963 case of Sullivan v. New York Times (376 US 254) which overturned a defamation award of $500,000 in damages to an Alabama County Commissioner when the NY Times published an advertisement criticizing Alabama public officials for suppressing civil rights in that state. Here's what the Court wrote:
"[We have] a profound national commitment to the principle that debate on public issues should be uninhibited, robust, and wide-open...." (at p. 270)

Justice Brennan quoted Judge Learned Hand, who wrote:
"The First Amendment presupposes that right conclusions are most likely to be gathered out of a multitude of tongues than through any kind of authoritative selection. To many this is, and always will be folly; but we have staked upon it our all."

And in the simple language of the Justice from Alabama, Hugo Black, in his concurring opinion:
"An unconditional right to say what one pleases about public affairs is what I consider to be the minimum guarantee of the First Amendment." (at p. 297)

Joe Giattina is, like Hugo Black, a son of Alabama and, like his great predecessor, hardly likely to be intimidated by these foolish threats calculated to silence him. But I wanted this audience to understand the specious nature of the threats that were made.

A more sophisticated but equally specious effort is now underway by our friends in the interior design community to oppose Resolution 00-1 by threatening that since their state licenses interior designers, NCARB may not take a position opposing such licensing. The Texas Board began this line of attack with a memo to all member boards. We now know that at least two other member boards with interior design sections have been urged by their interior design members to take the same position as the Texas position. So this argument is now spreading like a brushfire; but if any of you believes for one moment that it is spontaneous combustion, there is a bridge over in Brooklyn I'd like to sell you. Like the first line of attack, this is an orchestrated attack, and like the first line, the concertmaster doesn't understand some fundamental principles about how a democratic system works.

Let's examine the Texas memo. Here's what it says:
"It would be inappropriate for any member board to be a member of an organization which officially and very publicly states that any of the laws implemented by the member board 'undermines the health, safety, and welfare of the public."

Resolution 00-1 officially and publicly makes that statement; therefore, Texas should leave the Council. Texas has a pretty short memory. Take the history of the scope of Texas's own regulation. Until January 1, 1990, Texas had only a title act. On that date, Texas joined 45 other states in prohibiting architectural practice without registration. For years, NCARB had assisted Bob Norris, Cathy Hendrick's predecessor, and the Texas Board in preparing arguments which they could use to persuade the legislature in their state that the public was being disserved by an act which could not prevent unregistered persons from practicing architecture. With NCARB's help, Texas changed its statute from one that did little to protect the public to one that would safeguard the public.

Or does Texas remember its proud announcement in 1998 that they finally persuaded their legislature to require an accredited degree for registration, finally bringing Texas in line with the vote of the Council requiring a degree for certification taken in 1980? Now the Texas legislature for years believed a degree requirement was bad social policy. But time and persistence brought them around.

As a final example, Bob Norris wrote me in 1992 seeking Council assistance to prevent professional engineers in Texas from designing schools. Both Texas school authorities and the Texas engineers' registration board took the position that the design of schools was entrusted by the legislature to engineers as well as architects. The Texas Board of Architectural Examiners disagreed and was prepared, with NCARB's help, to treat engineers as illegal, unlicensed practitioners of architecture.

Did Texas threaten to leave the Council in the first two examples because its legislative mandate did not conform to Council policy? Of course not. Instead, they did their darndest to persuade their legislature to change their mandate.

In the case of engineers engaged in architectural practice, did Texas or any other architectural board across the country sit back and say, "Well, if another state agency says architectural practice by engineers is hunky-dory, nothing we can do!" Of course not. Many of our member boards, often with Council support, argued to their state engineering board, to the attorney general, to the legislature, and even to the courts that engineers were engaged in the unlicensed practice of architecture and should be stopped.

To many, the interior design issue is identical to the fight against engineers practicing architecture. The public is only protected if the people who design the built environment for human habitation have been educated, trained, and examined so that they are competent to do that work.

In the past, where the Texas Board has found some aspect of Texas law conflicts with the public interest, it hasn't melted into a sea of despond. It has tried to change that law.

But Texas has a second string to its bow. It is wrong, Texas asserts, for NCARB, funded in part by Texas dues, to lobby the Texas legislature. That argument won't wash. While our Bylaws authorize the Council to represent the interests of member boards before public and private agencies, we are explicitly prohibited from representing the interests of a specific member board without that Board giving its approval (Article III of Bylaws). In the three examples noted above, Texas asked for and received assistance from NCARB, but if Texas doesn't want the Council's help in restraining architectural practice by interior designers, our Bylaws prohibit the Council doing so.

That doesn't mean that we can't help other member boards who seek our assistance. To argue otherwise would be to revive the most extreme doctrine of nullification since the Civil War. Is Texas saying that its position would prevent an absolute majority of member boards from adopting Resolution 00-1 and thereafter implementing that resolution for the benefit of the boards desiring that benefit? If so, it does not understand how decisions are made in a democratic system.

A third argument has been advanced that whether or not interior designers win practice acts is none of NCARB's business. The AIA as the professional organization of architects might take a position, but why should the regulators of architects get involved?

Now no one connected with NCARB is more zealous than I in respecting and maintaining the separation between church and state. For over 30 years, I have lectured successive boards until they weary of hearing my voice that our obligation is to protect the public, not the economic interests of architectural practitioners.

When, in 1989, NCARB issued its first white paper on interior design registration, we focused exclusively on appropriate standards for professional licensing. There is not a word in that document lamenting the effect interior design registration may have on the market share of architects. It and all our publications since on the subject are exclusively concerned with public safety. Is it appropriate to permit people with no education or training respecting critical life safety issues in interior build-outs-is it appropriate for such people to take responsibility for the design of those build-outs?

Does our Bylaw mission statement authorize us to consider and act to prevent unqualified persons from practicing architecture? I had always thought that was at the very core of our obligation: we are "to work together as a council of member boards to safeguard the health, safety, and welfare of the public...." What a pathetic regulatory system it would be if we could restrict entry to qualified persons and could discipline rogue architects, but had no power to prevent unqualified persons from engaging in architectural practice.

And, of course, our history is replete with examples of our concern with unlicensed practice. The great struggle in the 80s against engineers who asserted the right to act as prime design professionals on buildings for human habitation is a relevant example. We were able to demonstrate that engineers were not educated, trained, or examined to play that role. We have applied the same analysis to interior designers.

As many of you now know from our visit to the regions yesterday, the struggle against unlicensed practice by engineers was sufficiently successful to cause the engineers to take a drastic course of action. In fact the same drastic actions which the interior designers took last Friday: the engineers in 1995 asked the anti-trust division of the Justice Department to begin a civil investigation of NCARB and AIA alleging that we both were engaged in efforts to suppress competition. As I pointed out to you yesterday, the ensuing investigation was aborted when the Justice Department understood that all the actions taken by NCARB were protected by the U.S. Supreme Court's decision in Noerr-Pennington which held that nothing in the anti-trust laws could inhibit in any way the rights of citizens to support or oppose government action or legislation, of any kind. But the ironic fact was that before Justice called it quits it rapped the knuckles of NSPE (which had instituted the complaint) and others with respect to a meeting held the prior year in Tucson in which NSPE, ACEC, and AIA, in an effort to make peace among architects and engineers, had signed a paper indicating that engineers and architects should agree as to what projects belonged to each profession. Justice was disturbed by that agreement because it smacked of competitors allocating market share-clearly prohibited under the Sherman Anti-Trust Act. When NCIDQ complains that NCARB will not sit down and discuss paths to resolution, I fear they have in mind the same type of discussion of allocating market share. Those are discussions we want no part of.

So, in sum, the note sent last Friday by NCIDQ that they seek an investigation of NCARB by the Justice Department should, like all of their misguided legal thrusts, not act as a deterrent to your evaluating Resolution 00-1 on the merits.

When you debate Resolution 00-1, I hope that these contrived legal questions will be wiped aside and that the focus will be where it should be: Does the licensing of interior designers undermine the public health, safety, and welfare?

NCARB President Joseph P. Giattina, Jr., FAIA:

Thank you Carl. And now I will continue.

How does the NCIDQ differ from NCARB? We are a voluntary Council representing the interests of the regulatory bodies of all fifty states and five jurisdictions; thus NCARB has only 55 members. When we refer to a member board member, we refer to an individual appointed by the Governor of their state to serve on that state's member board.

What NCIDQ calls a "member board" is quite different. Only 15 of 21 jurisdictions with some form of regulation are members of NCIDQ. Arkansas, Connecticut, Michigan, Missouri, New York, and Wisconsin are not. But the ASID, the Interior Designers of Ontario, the Interior Designers of Canada, the Interior Design Education Council, and the International Interior Design Association all are. Quite a difference from NCARB.

The NCIDQ has a serious and undeniable confusion between the public interest and their own-a concern that the president of NCIDQ recently tried to explain away by saying, "The associations [meaning ASID, et al] represent a small minority of NCIDQ's membership and as such are not able to unduly influence the decisions of NCIDQ."

Are we to believe that Maine's 28 registered interior designers are a real powerhouse against the ASID's 33,000 members and 7,500 "industry partners"? I don't think so.

There is nothing at all wrong with the ASID serving their members or being supported by "industry partners." It is only when they step into a quasi-regulatory role, such as that sought by NCIDQ, that there is a problem. The NCIDQ purports to represent the public interest. But it does not and cannot, because that mission is blurred to the point of extinction by the overriding pressures from their professional members. And that is why it is virtually impossible to have an intelligent conversation with the NCIDQ. When it comes to public interest versus their interest, the public loses every time.

What is an "interior designer?" NCIDQ explains that "Interior Design as a profession achieved recognition in the early 1930's when it was known as interior decoration..." Think about it; interior design achieved recognition when it was interior decoration; ergo interior design is interior decoration with a new name. Yet the only folks that "interior designers" show more disdain for than architects are the parents of their "profession," interior decorators. Go figure.

However, in 1960, only 30 years later those same "decorators" discovered the need to address human concerns and found the increasing complexity of interior environments something that led them to think about "interior design education." (NCIDQ exam manual, seventh edition, pg. 2)

Why it took them 30 years to discover what architects had done for centuries is a mystery. But it is clear today that changing their name from "interior decorator" to "interior designer" may increase prestige, but it does not enhance the ability to practice architecture.

Are there significant differences between the qualifications for licensing of architects and those for interior designers?

Yes. Most states require a minimum NAAB-accredited five-year degree and three years of a structured internship before allowing a candidate to sit for the 36-hour Architect Registration Examination, which is entirely directed at health, safety and welfare issues. Of the 21 jurisdictions that license interior designers (only four have "practice acts"), most require only two years of post-high school education, have no requirement for structured training, and allow licensure after passing a twelve-hour examination, less than a third of which covers life-safety issues.

Let's look briefly at the standards for education, experience and examination. As almost everyone here understands, NCARB has always viewed the three-legged stool of education, experience and examination as the basis for licensure. The NCIDQ apes the same pattern, but they couple a nonsensical education standard, (either none, or two years post-high school), with a non-existent training standard and a weak examination to produce a weak standard.

Let's look for a moment at how standards affect the licensure for interior designers when we simply compare them with each other. Florida, with a "practice act," accepts a two-year "FIDER accredited" degree, four years of "training" and the NCIDQ examination as satisfying their requirements. Florida has 2,563 registered interior designers. On the other hand, Nevada, also with a "practice act," but with more rigorous standards than NCIDQ's, has 56 registered interior designers.

Is there a relationship between low standards and high registration rates; or high standards and low registration rates? Of course there is.

Regarding Education: During a Region 3 debate on the subject, a North Carolina architectural professor explained that she could think of no course an interior design student might take that set them apart from architects as specialists with respect to the public good. None of the interior designers present could think of one either. True, a well-developed color sense is an asset on either the inside or the outside of a building, but that knowledge or lack of it, does not put the public at risk.

Regarding Experience: Architects are required to have three years of experience working under architects, engineers and others professionals with expertise in construction. Yet an interior designer can gain experience working under an "NCIDQ qualified" furniture salesperson who learned at the knee of another furniture salesperson. What role does selling furniture have in the protection of the public health, safety and welfare? None, unless reading a furniture label is a special talent.

Regarding Examination: Interior designers claim there is no relationship between the length of an examination and its quality. It is a claim that avoids issues of content or the body of knowledge to be tested. An example of that point is found in the NCIDQ Examination Guide, which gives this preamble to the question that follows. "The following question requires the candidate to solve a problem for a difficult situation."

The question:

"Due to improper installation, a chandelier fell and damaged a table.
How could the designer have limited his liability for the accident?"

1. Required a shop drawing from the installer.
2. Requested instructions and inspection from the manufacturer.
3. Stated on the drawings that the general contractor is responsible for secure installation.
4. Provided a design drawing from a structural engineer.

One might think that a chandelier heavy enough to damage a table might also be heavy enough to damage a head. Yet the question is not about life safety; it is about how a designer (who knows nothing about what is above that ceiling) might protect himself from liability.

There is a message in that.

Now analyze the correct answer. Surely a competent designer would require manufacturer's data to determine the weight and other characteristics of the chandelier. Surely a competent designer would consult with a structural engineer about the capacity of the structure to hold the chandelier. And surely a competent designer would require a shop drawing. All of these would be necessary to protect life and property.

But if that is what you think, you are wrong!

To meet the NCIDQ standard, all the designer had to do to protect himself was to assign his responsibility to the general contractor.

Isn't interior design a distinct profession, requiring separate and distinct education and training?

No. We must not confuse an intense interest in a particular area as a need for licen-sure. Otherwise we will find ourselves licensing artists and poets. But to understand the question requires an understanding of the diversity of practice conducted under the umbrella "interior design."

Decorating is a distinct occupation, but there is no evidence that anyone has been harmed by a bad color scheme. So decorators require no licen-sure to protect the public. On the other hand, a 30,000 squa-re foot tenant build-out requires a broad range of architectural skills, including knowledge of structural, mechanical, and electrical design to coordinate and integrate those components into a comprehensive working whole that incorporates all the elements of life safety.

Architects are educated, trained and examined for those skills. Interior designers are not. The president of NCIDQ recently said that FIDER (Foundation for Interior Design Education & Research) accredited 118 "professional level programs." Doesn't that offer assurance of their desire to improve their field?"

No. What their president failed to mention was that FIDER also accredits an additional 20, two-year "pre-professional" programs that churn out twice as many "accredited" degree holders as four-year programs.

Nor was any mention made that 28 of what are described as "professional level programs" are in the "social science" departments, 32 are in Fine Arts departments, seven are in Visual and Performing Arts programs, and eight of the FIDER accredited "professional level programs" are in Apparel, Merchandising and Textiles.

How can anyone with a Bachelor of Fine Arts legally do any thing that affects the public health, safety and welfare? They cannot, and to pretend otherwise, is simply that, a pretense. Keep in mind, architecture is practiced within the building construction industry where the laws of gravity hold sway. Even on the inside of a building.

If interior design isn't a distinct profession, what is it? If interior design is anything, it is a sub-specialty of architecture.
And, like any sub-specialty-medicine, for example, where every specialist must first become a M.D-the would-be sub-specialist must master the specialty first; in this case architecture.

"Isn't there a clear distinction between the inside and outside of a building?" If so, where is it? Common sense suggests that "inside" is everything that is not "outside."

If, as interior designers would have it, an architect is to design the outside and an interior designer the inside, shouldn't interior designers be educated, trained and tested on everything inside? On stair-s, elevators, structural systems, demising walls, floor-to-floor fire separations, heating, cooling, energy conservation, air distribution, lighting, electrical power systems, fire protection, security, smoke control, and plumbing? And if they were tested on all of these, wouldn't they be architects? Sure, but proposed "interior design" licensing laws exclude electrical, mechanical and structural systems from the scope of "interior design." Is that adequate protection of the public?"

No.

Interior designers say they will call on consultants to supplement their limited knowledge. But that begs the question. How will an interior designer who knows nothing about post-tensioned slabs know that putting an electrical outlet in the wrong place could get the electrician killed? Or that moving a "non-structural" wall could violate the integrity of a smoke barrier and leave the occupants vulnerable to death from smoke inhalation?

Clearly, if interior designers don't want to learn about inherent parts of construction, how will they know when they have undone that part? Simply put, they cannot, and therein lies the danger to the public.

Regarding "grandfathering": What effect does "grandfathering" have on interior design? A detrimental effect. Interior designers always include a generous "grandfather" clause in their proposed acts. The AIA estimates that individuals licensed without taking any examination comprise 80 percent of the license holders in California, 83 percent in Minnesota, and 67 percent of the license holders in Connecticut. And with their generous reciprocity provisions, those same unqualified persons can be licensed in other states.

Who funds the lobbying for these proposed acts? We cannot be certain, because those lists don't seem to be entirely public. But if it is the same people who sponsored NCIDQ's 25th Silver Anniversary Celebration, they would include the American Society of Interior Designers, the International Design Association, Masland Carpets and SMED International. If it is the same people that funded the Illinois Interior Design Coalition, they would include BASF, USG Interiors, and the Steelcase Design Partnership.

In a recent panel discussion, representatives of the interior design industry admitted that they have spent more than $5,000,000 "fighting architects" to obtain licensing. Somebody is putting a lot of money into the effort. Why? I can think of a number of reasons. But so can you.

If interior designers are denied licensing, won't they lose their livelihood? No. Most large architectural firms have interiors departments which employ both architects and interior designers, in which case the architect provides a comprehensive overview of all the construction disciplines and takes responsible control of the exterior and interior work.

Many independent interior designers offer their services to architectural firms as specialized consultants where, again the architect takes responsible control. No one suggests these arrangements be changed; no interior design licensing is required in either case. It is when an interior designer attempts to design an interior without an architect in responsible control that a problem arises, because they cannot get a building permit for the work. That is the problem they want to solve, and they are willing to jeopardize the public to do so.

Why, as NCARB President, have I not encouraged discussion with representatives of the NCIDQ? Because we do not speak a common language or share a common objective. The NCARB mission is to safeguard the health, safety and welfare of the public. The NCIDQ mission is "to increase interior designers' knowledge and expertise regarding issues affecting the public health, safety and welfare."

NCARB safeguards. NCIDQ "increases knowledge." NCARB serves the public. NCIDQ serves interior designers.

NCARB's funding comes solely from NCARB services and member board dues. We do not rely on manufacturers, suppliers, professional societies, or others in the construction industry for our funding. We are independent. And when the public's interest is in conflict with the architect's interest, NCARB has a long history of protecting the public interest.

On the other hand, NCIDQ is funded and run by organizations like the ASID whose mission is to serve interior designers. NCIDQ's president recently stated that the NCIDQ is supported solely through NCIDQ services and member board dues, and that they receive no financial support from the furniture and finishes industry, nor from the ASID except for membership dues.

Surely, the president of NCIDQ does not expect us to believe that ASID pays member board dues with no expectation of influencing the decisions or gaining benefit of the "services" of that would-be quasi-regulatory body.

And finally, as the president of an organization that has spent 80 years and millions of dollars developing a system of education, training and examination designed solely to protect the public, I do not want to have our name and reputation co-opted by those who hold views that are contrary to the public interest.

Thank you.