Texas Department of Licensing and Regulations and Texas Legislatures

-----------------------------------------------------------------------------------------------------------------------------
PETITION to the TDLR & TDLR ACR Advisory board and state of Texas Legislatures:

Gentlemen:

We, the undersigned, protest the continuing education program for TDLR ACR registrants and request the following changes be made.

Requested changes are as follows:

1. At present, TDLR allows continuing education credits earned by taking courses over the internet. While this may be a satisfactory means of transferring most information as it concerns TDLR rules and regulations, it does not suffice to provide ACR licensees with up- to- date hands-on technical refreshers and new hardware training associated with our ever- changing air conditioning and refrigeration industry. This is especially true with digital and solid state controls and their proper application. OSHA dictates safety and other matters of greater concern to us than TDLR rules and regulations.
2. If TDLR is to allow ACRs and electricians to design systems and then install them, all such licensees should be required to run load calculations using some recognized open domain software for each design application with calculations submitted to the authorities that have jurisdiction, and are responsible for building permit issuance and for construction inspection. As we dictate that load and sizing calculations be done by engineers and architects as a part of their responsibilities, it is only prudent that those TDLR licensees assume responsibility for designs to be held to a similar standard as it concerns proper, efficient, and owning and operating cost concerns.
3. Technical material cannot be taught over the internet and we respectfully request that continuing education credits be awarded only through contact course offerings, with such course offerings being provided through the Texas colleges, universities, and junior colleges. These institutions, especially those that are publicly funded, have been created to support and provide uniformity in educational content and requirements. We, as taxpayers, recognize and appreciate the benefits that accrue to the trade and professionals because of such educational administration.
4. If knowing TDLR rules is of critical importance to TDLR, we respectfully suggest that refresher training for rules be done through some mechanism involving the internet to include annual licensees review of the rules as posted on the TDLR ACR website complete with tests or via an internet-provided course also complete with tests, but limited strictly to the applicable TDLR rules. Fees for taking and completing the rules portion of annual registration should be included in the annual ACR licensing fee.
5. Finally as TDLR is in the regulation business and not in the education business, thus lacking understanding and the depth of knowledge associated with educational entities, it would seem prudent that education to include curriculum, instruction and means and methods of engineering and technical knowledge transfers would best be gained by delegating such functions to our educational institutions.


It is our view and we respectfully request that state boards should ensure that state or private college and university level educational entities offer or should offer continuing education courses that satisfy state licensing requirements. What better places are there to host such programs while offering state boards overview monitoring of course content to ensure that what is being taught is consistent with the continuing educational goals that a licensing board requires? Furthermore, different state boards should honor such continuing education courses taught in different states. If state boards required CE credits through educational institutions, this would help the college sponsored continuing education programs as they struggle to survive, and would significantly improve the quality of the CE courses and credit offerings.

In summary, ask that TDLR and the ACR and electrical advisory boards consider and adopt policies where:


1. Continued education credits are awarded only though a state institution of higher education that offers technical courses consistent with published board guidelines, and with board acceptance of such credits without further review.
2. Technical societies and trade associations be allowed to formulate and host technical presentations through each states continuing education programs, paying only a slight management fee for coordination of and perhaps hosting such programs (content and instructors provided by the technical society, with some monitoring of the course content for acceptability via the states continuing education group) through the existing education facilities we have with our college and junior college systems.
3. Like kind or equivalent courses offered in other states through their CE programs are acceptable to your boards.
4. Courses allowed to be taught under the control and guidance of some educational institutions CE outreach program in cities and locations. This should also include out of state institutions and at the same time be under the umbrella of the institutions CE program.
5. Establish as a part of a continuing education program a technical weekend refresher prep course for those seeking to sit for the various TDLR licensing course exams. These series of prep courses should be bundled and offered over successive weekends, with courses held from 8am to5pm on both Saturdays and Sundays.
6. Establish as a part of a continuing education program refresher review courses hosted by entities like CAPSO at TAMU that offer engineering and technical refresher review courses where these courses are taught for half a day, for 5 or 6 days a week on a college campus, ideally in a location that will allow participants to bring their spouse or family and with free time each afternoon allowing an educational and family vacation retreat.
7. Establish as a part of a continuing education program courses directed at exposing and training practicing tradesmen, engineers, and architects with regard to some of the highly technical open domain modeling and analysis programs such as EnergyPlus, EPAnet, NEC code, J-LOAD, etc, . Many of the older tradesmen and professionals, while they are the decision makers, have finished their formal educations before such significant and tremendous computer programs have been developed. While their firms can make excellent use of such programs to significantly benefit their clients, they are reluctant to do so because they do not understand or have not used such tools. Also, they are not comfortable with the liability resulting from delegating use of such programs to younger and more computer literate younger employees who lack the intuitive feel, understanding, and order of magnitude analysis for quick review that is gained only from repetition and experience.
8. Establish as a part of a continuing education program courses using some of the very powerful hand held computers, such as the HP 49G hand held graphing calculator that has been developed for advanced math, science and engineering high school and college student applications. Several excellent hand held products manufactured by HP and TI exist complete with libraries that can be purchased with these tools. Educational outreach and training facilities would benefit technical and engineering professionals, especially the senior decision makers that are sorely lacking in this education and training.

We request that TDLR play an active role in re-establishing the concerns and concepts that learning and education provide. Continuing education can be fun, beneficial, and useful and may include benefits derived from networking among fellow tradesmen and professionals. It is time we returned an esprit de Coeur to our tradesmen so that the public sets them apart from others in our society. For many of those that are targeted by colleges and universities, short courses such as those suggested, continuing education represents perhaps the key self-justifying means for exiting ones office where ones focus has to be administration and sales. Presently, one no longer has the joy of creating a design and wrestling with technical issues and problems associated with successfully making the design work.