To: Becky Roland, Mark Molinari, and Bruce Hilton
From: Ken Fergason
Date: March 19, 2009
RE: Joint Task Force Areas of Practice (JTFAP)
Draft Engineering and Geology Practice Guidelines
Arizona Section Meeting
Heather Hespeler, R.G., AEG Member, Arizona Section Secretary
Mark Edwards, G.I.T., AEG Member
Jeff Rodgers, R.G., AEG Member
Scott Neely, P.E.
Concerned members and professionals of the Arizona Section of AEG met to discuss the JTFAP Draft Engineering and Geology Practice Guidelines document (document). The consensus of the group is that AEG should not endorse this document in its current form. The primary objection of the group is the inclusion of the Areas of Practice Matrix (matrix, pages 11 and 12). The matrix encourages misuse and misinterpretation of the document and will serve as a de facto executive summary that will likely be used out of context of the text of the document.
The other major objection to the document in its current form is the lack of clarity regarding its intent. The group recommends inclusion of a one- to two-sentence Statement of Intent at the beginning of the executive summary. The lack of clarity of the document’s purpose resulted in our group questioning the ‘real’ purpose of the document. We simply want to know who the intended audience is, why this document exists and what benefit members of AEG receive from its existence. In its current form, the document fails to provide these answers.
Below is a bulleted list of other issues the group had with the document.
- The document seems to be a solution in search of a problem.
- The document is focused on Professional Civil Engineers, Professional Geotechnical Engineers, Professional Engineering Geologists, and Professional Geologists – particularly the matrix. This causes confusion for the vast majority of states where all four of these professional registrations are not present – only California seems to have all four registrations. The document needs to better reflect other states which only have registration for engineers and geologists or only engineers. This also produces confusion regarding what seals are necessary for what documents – for example, does any report that contains a geology section require a stamp from geologist (regardless of how large, small, or significant)?
- The specialties and other professionals excluded from this document don’t make much sense and raise further implications regarding the intent, benefit, and audience of the document. These exclusions include Geological Engineers, geohydrology/hydrogeology, environmental engineering/geology, and engineering geophysics (several of which are mentioned in some way in the matrix regardless of their exclusion).
- The group unanimously feels that the matrix should be removed from the document and that without the matrix the document is much more palatable. The group also has disagreement with many of the details within the matrix summarized below.
- Why are PGs excluded from landslide subsurface investigation?
- Why are PEGs and PGs excluded from subsurface exploration for portions of projects involving earth/structure interaction?
- Why are PEGs and PGs excluded from ground deformation analysis? How is ground deformation defined in this context? For example, is ground subsidence ground deformation?
- Why are PEGs and PGs excluded from man-made fill disposition assessment?
- Why are PGs excluded from slope stability analysis?
- Why are PEGs and PGs excluded from many of the construction observation and documentation entries?
The exclusions mentioned above are often in contradiction to the text of the document. The matrix creates absolute distinctions which are also in contraditiction to the document.
- The final sentence in the first paragraph of Section 4.2 states “In developing this guidance document, the JTFAP has not attempted to establish individual practice standards or specifications.” This begs the question “then why is the matrix included” and it is especially puzzling that the matrix immediately follows this statement. Another apparent contradiction of the matrix is its title: Overlapping Areas of Practice Matrix. As presented, the matrix draws lines between areas of practice rather than indicating overlapping areas.
- If AEG decides to move forward with the document, how will final approval of the document be reached? A majority vote of membership? Of the BOD? The group advocates membership vote for eventual approval/disproval of the finalized document.
- The 30-day comment period is inadequate and the group feels that a longer review time is appropriate – especially considering that the document was originally posted at the AEG website which is very user un-friendly. This caused the document to be largely ignored until other AEG members advocated distribution via a PDF document attached to email messages.
- The document should be aware of who will use it, how they will use it, and will they use it as intended. If satisfactory answers to these questions don’t exist, then it seriously questions whether the document should exist.
In summary, the group does not feel that the document should be endorsed in its current form. The strongest objection is the presence of the matrix, which the group feels should be removed. The group also feels that the intent and benefits of the document should be better clarified throughout the document and that a statement of intent should be included in the executive summary.
If you have any questions regarding this memorandum, please contact me and I look forward to sharing the group’s concerns with the document at the upcoming mid-year Board of Directors meeting.
Ken Fergason, R.G.
Arizona Section Chair, AEG