Editor’s Note: The following letter on APEGGA’s
inclusivity initiative was copied to The PEGG for publication.
Dated March 12, it is addressed to APEGGA President Mike
Smyth, P.Eng., and APEGGA Council. Since then, Council
has decided to postpone a vote on the new category. The
AGM will be used for the discussion of the category only.
We, the undersigned, are very concerned about the proposed
inclusivity model to be presented to the APEGGA Annual
General Meeting in April. We feel that this proposal
is, at best, being rushed to implementation without the
opportunity for due diligence by the membership, and,
at worst, is a serious and irreversible mistake in setting
a new direction for APEGGA and the whole notion of professional
Our particular concern is with the proposed categories
of Registered Engineer, Registered Geologist, and Registered
Regarding due diligence, although there have been presentations
at the branches and more planned via town hall meetings
in the next couple of weeks, we are not convinced that
the membership is being presented with a balance of views
on this issue. Furthermore, we know of many members who
are not aware of this initiative at all. This letter is
receiving a wide circulation to help rectify this.
To our knowledge, the Board of Examiners has not been
officially requested to review the details of this proposal,
has not discussed it at a meeting of the full board (which
includes both public members and representatives from the
minister) and has neither reported to Council nor presented
board members’ views in a public forum. It seems
only reasonable that since the board will be the instrument
of this new policy, it should have the opportunity to know
exactly what is being proposed, to discuss this thoroughly,
and to give feedback to Council and the general membership
regarding perceived problems and concerns prior to its
We fully recognize that the Board of Examiners cannot
set policy at this level. However, with its prime vantage
point on the licensing procedure, it is remarkable that
the full board’s input has not been encouraged or
sought. It is clearly within the board’s terms of
reference (APEGGA website) “to establish and maintain
academic standards,” “to establish and maintain
standards of qualifications,” and to “develop
standards, policies, and procedures that meet the intent
of the [EGGP]
Act.” In regard to these tasks and
the inclusivity initiative, the full board has not been
able to exercise the required due diligence.
As for professional licensing, we feel this proposal is
ill-conceived for numerous reasons. First, a great deal
has been made of how inclusivity would lead to increased
protection of the public. In this regard, we must be careful
to not confuse “qualifications” with “status.” Our
executive director says (March
2004 PEGG) inclusivity will “greatly
reduce the amount of unregulated practice of engineering
and geoscience in Alberta.” Under current regulations,
unregulated practice is sought out and challenged by the
Compliance Department, and in extreme cases can be the
subject of legal proceedings.
Mr. Smyth says (March
PEGG) that inclusivity will “license
qualified individuals to legally do what they are already
doing.” (It might be useful to draw a distinction
between “qualified” and “capable” here.)
This statement clearly implies that what these individuals
are currently doing is illegal – practicing without
Now, it seems, proponents of inclusivity would rather switch
than fight – rather than prevent practice by unregistered
personnel through mechanisms already in place, simply make
them members. This changes their status without changing
How does this lead to greater protection of the public?
This seems to come from the “If you can’t beat ’em,
join ’em” school of professional practice enforcement,
whose main effect would be to increase the membership roster.
With the same people doing the same jobs as before (albeit
now legally), there is no evidence to prove the assertion
that public safety would be improved under the new rules.
Under inclusivity, what is to guarantee that people currently
practicing without a licence would even apply for membership?
Enforcement will still be an issue. Where is the “compelling
reason for change” alluded to by Mr. Smyth? We have
yet to see the connection between inclusivity and increased
In fact, the situation may even be the opposite. The issue
here is qualifications rather than status. There is no
known accreditation system for non-engineering degrees
even within Canada, although geoscientists have an agreed-upon
syllabus that is required across the country for licensing
in geology and geophysics.
There is no system for quality control or assessment of
Canadian four-year science degrees, much less foreign degrees.
There are thousands of these institutions and degrees around
the globe. The board that must evaluate these qualifications
has literally no idea about the quality or content of all
How, then, is the adequacy of these unknown degrees to
be assessed in a way that can ensure public safety? Quite
simply, it can’t – there are nowhere near enough
resources available to individually assess these degree
programs to the level of confidence provided by an accredited
Can an applicant therefore be determined to be academically
qualified or not? Who knows? Inclusivity is simply opening
the doors to any and all comers. If persons with any four-year
degree are to be admitted as members, this truly represents
a “dumbing-down” of the Association (letter
from Horace Gopeesingh, P.Eng., March 2003 PEGG). How can
this possibly serve to increase public safety, much less
So then what is the message APEGGA is sending to universities
with accredited engineering programs, or the students in
those programs? The Canadian accreditation system for engineering
degrees is a model for the world. Why is it to be ignored
by arguably the strongest association in the country?
Since any four-year degree in any of several disciplines
(including science, biology, geography, and presumably
others) is acceptable for registration as an R.Eng., there
is no real need to maintain any form of accreditation,
or for students to endure the rigour of an engineering
Mr. Smyth indicates that the Canadian Council of Professional
Engineers has been consulted (in September 2003) on the “framework” of
inclusivity. Does CCPE realize that, with the proposal
now available in detail, inclusivity will void any need
for a CEAB accredited degree for someone to practice as
a (registered) engineer? We would like to hear CCPE’s
response on this question.
The projection (March PEGG) of only a hundred likely applicants
for the R.Eng. (or R.Geoph. or R.Geol.) in the next five
years is simply not credible. If this is the number required
to “greatly reduce the amount of unregulated practice” (in
a province with more than 30,000 practising members!) then
perhaps the problem is not nearly as serious as presented.
This is significantly fewer than the number of cases (155
cases in 2003 alone) involving practice by unregistered
individuals (Compliance Department Activity Report for
2003, APEGGA website). However, the number applying for
R.Eng. (or R.Geol. or R.Geoph.) is more likely to be several
thousand in the indicated time period.
Applications to APEGGA now number over 2,000 per year.
Approximately half of these could immediately benefit under
these relaxed rules for the new category of licensure.
Many would probably pick it rather than the laborious exam
route to full professional registration (especially when
the plan proposed is to treat both designations the same,
as discussed below). This does not even count the potential
flood of new applicants if general four-year degrees are
permitted – this number could grow much larger.
Regarding the equivalence of R.Eng. and P.Eng. designations
(and R.Geol.-P.Geol., R.Geoph.- P.Geoph.), the report to
Council (Feb. 5) indicates that for all intents and purposes
these would ideally be indistinguishable. In the President’s
Notebook (March PEGG), it is indicated that the public
will not (should not?) be expected to know the difference.
Will these be second-class members? “No,” says
Mr. Smyth, “They will be professional members of
APEGGA.” The FAQ attached to the Inclusivity Task
Force Report to Council contains the following response
to the question of possible confusion between the two designations:
A successful title for this category [R.Eng., R.Geol.,
R.Geoph.] is one that avoids unnecessary differentiation
between the two categories. The primary reason for a title
other than ‘professional’ for this new category
is that we must preserve the mobility of individuals who
do meet the national and international requirements for
licensure as recognized under our mobility agreements.”
The implications of this statement are astounding. First,
it admits that R.Eng.’s (and R.Geol.’s and
R.Geoph.’s) do not meet national and international
standards for licensure. Second, it implies that ideally
the public should not perceive any difference between the
two. Is this not an attempt to mislead the public?
Third, it implies that, except for mobility, the two designations
are fully interchangeable. This is not the case for the
R.P.T. designation, to which the operation of the R.Eng.
is often compared (for example, both have a limited defined
scope of practice). The professional members of APEGGA
must be informed of this. What is the likely response of
employers when two applicants apply for the same job: one
with a P.Eng. and the other with an R.Eng.?
A basic premise of the inclusivity proposal seems to be
that, under current policy, many qualified and capable
individuals are “prevented from gaining full professional
licensure.” These fall into the categories of “international
graduates, emerging disciplines, technologists, and others.” Here
lies a serious misunderstanding of the requirements for
registration and the assessment procedures used by the
Board of Examiners.
Let it be made clear that under current rules no qualified
applicant is prevented from registration, as has been implied
by some statements to Council. On the contrary, when evaluating
all academic credentials (especially those from a non-accredited
[non-CEAB] institution), the board operates on a “looking
to exempt” policy.
As much as possible, qualifying or confirmatory exams are
excused with just cause (usually by virtue of suitable
advanced education or outstanding experience). The issue
for many applicants is not about failure to academically
qualify for membership, but the difficulty of evaluating
academic credentials from unknown or poorly documented
unaccredited programs or, in some cases the inability to
adequately document many years of foreign experience.
Under the rules that have been established specifically
to protect the public interest, the Board of Examiners
must exercise due diligence in assessing the academic background
of applicants. If accurate and reliable academic credentials
cannot be provided, how can the applicant be considered
to be qualified?
Due diligence requires positive proof, not the absence
of negative proof. If exams are assessed in order to verify
qualifications, how can these be waived if the experience
record is incomplete or poor?
The board is frequently asked to reconsider decisions to
assess examinations and, with new additional detailed information
concerning the applicant’s background, will often
waive previously assessed exams. It is not the board’s
job to make registration easy but to make sure persons
granted membership are qualified.
Finally, under the proposed inclusivity guidelines, there
is no exam route alternative to obtaining membership in
the Registered category. Assuming that qualification reviews
were somehow feasible under inclusivity, this implies that
if membership is denied on the basis of inadequate or incomplete
academic qualifications (e.g. a three-year degree), the
applicant is out of luck.
This is considerably harsher than the current system whereby
perceived academic deficiencies or questions of academic
qualifications can be overcome by specified or confirmatory
exams. The proposed rules do not indicate what avenues
might be available to these applicants, but we can expect
such decisions (to deny membership) to be appealed frequently
In his column in the APRIL ISSUE of The PEGG, Mr. Smyth
talks of “lengthening the bar” rather than
lowering it. In fact, what inclusivity would do is remove
the bar altogether. It would not, as the AGM advertising
in the same issue of The PEGG indicates, “make the
circle stronger” but make it so big as to be meaningless.
If you make it big enough, a curved arc becomes a straight
line that encloses nothing.
Mr. Smyth also says that, “These changes aren’t
radical.” We do not think this statement could be
We strongly urge that the general vote on the inclusivity
motion planned for the next AGM on April 24 be delayed
until the final detailed motion can be given more serious
study by the general membership. In fact, considering the
far-reaching implications of this change, an appropriate
course of action might be to hold a referendum (preferably
mail-in to receive the broadest participation) during the
Council elections in spring of next year.
This will give considerably more opportunity to hear the
voice of the general membership.
Dr. Roger Toogood, P.Eng.
Dr. Mark Loewen, P.Eng.
Dr. Anil Mehrotra, P.Eng.
Dr. Ken Porteous, P.Eng.
Dr. Warren Finlay, P.Eng.
Dr. Barry Patchett, P.Eng.
Dr. Gary Faulkner, P.Eng.
Dr. Larry Kostiuk, P.Eng.