OFFICE OF THE SECRETARY

CORRESPONDENCE CONTROL TICKET

Date Printied: Mfar 20, 2013 15:1 6

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LTR- 13-0237

ED

LOGGING DATE: 03/20/2013To:O

Robert Katkin, PE (CA Leg. Council for PE) r I'J•z(CA

CHRM Allison Macfarlane cc'd

Concerns State Professional Engineers Act that requires all utility company engineering andscience be conducted by a civil engineer

Information

RF

03/19/2013

No

Lead office to publicly release 24 hours after SECY's assignment, via SECY/EDO/DPC.

Two identical letters going to different utilities.

ADAMS

DATE DUE: DATE SIGNED:

IN REPLY PLEASE ADDRESS:

Robert A. Katin. P.E.

Katin Engineering Consulting

P.O. Box 4727

Antioch, California 94531-4727

(925) 755-1150e-m ail b.. katt._.i. k.ati_,' i n L. r ' i.:. ._

ww .c Iclcpe. ru

CALIFORNIA LEGISLATIVE COUNCIL OFPROFESSIONAL ENGINEERS

March 19, 2013

Mr. Christopher P. JohnsPresidentPacific Gas and Electric Company77 Beale StreetP. 0. Box 770000, Mail Code B30ASan Francisco, CA 94177

MemberOrganizations

American Institute of ChemicalEngineers-NorCal

American Institute of Chemical

Engineers-SoCal

American Nuclear Society

American Society of Agriculturaland Biological Engineers

American Society of MechanicalEngineers

California Industrial Engineers

California ManufacturingEngineers

California Society of ProfessionalEngineers

Institute of Electrical & ElectronicsEngineers

Instrumentation Society ofAutomation

Mechanical Engineers Associationof California

Registered Traffic Engineers ofAmerica

Society of Fire ProtectionEngineers

Subject: State PE Act requires all utility company engineering & science be conductedby a civil engineer

Dear Mr. Johns:

I am president of the California Legislative Council of Professional Engineers(CLCPE). It is an organization of engineering societies. The main purpose of CLCPEis to advise the California Legislature regarding laws that impact the engineeringprofession. Because the California Professional Engineers Act (PE Act) provides amonopoly for civil engineers over the development of California's infrastructure, wehave been supporting legislation that would reform that law. California is the onlystate with this type of monopoly.

The PE Act requires competency for all licensed engineers, however its highest priorityis to require all scientific and professional services regarding any geographically fixedfacility to be provided by licensed civil engineers. The requirement to only use civilengineers applies to every component of every facility a utility relies on to serve thepublic.

A civil engineer must design every aspect of every facility necessary to generate,transmit or distribute energy. No licensed engineers, scientists or members of othergenerally recognized professions, can provide such services, unless they are alsolicensed as civil engineers. In every other state, utilities are able to rely on competentexperts without checking to see if they are licensed as civil engineers.

Because of a tragic dam collapse, California enacted the PE Act decades ago to requireany person providing any professional expertise needed to develop any component ofgeographically fixed facilities to be licensed as a civil engineer. It includes allscientific and professional services by defining them to be "civil engineering". Theexemptions to this requirement are narrow, and specific, and the exemption that appliesto public utilities specifies that it does not exempt civil engineering, thereby imposingthe monopoly on public utilities.

State PE Act requires all utility company engineering & science be conducted by a civil engineer March 19, 2013page 2 of 2

Enclosed is the list of the code sections in the PE Act that contain the civil engineering monopoly. Alsoenclosed is a legal opinion issued by the Legislative Counsel Bureau at the request of Senator MimiWalters, the author of legislation that would have reformed the PE Act. That legislation, SB 692 (2011),as amended 1-4-12, was successfully opposed by entities that have an interest in maintaining themonopoly. This is a legislative affirmation of the intent of the PE Act. CLCPE does not foresee anyfurther legislative effort to reform the law.

If you have any questions, I would be happy to answer them.

Sincerely,

Robert A. Katin, PECLCPE President

Enclosures:o legal opinion of the PE Act issued by the Legislative Counsel Bureau dated July 22, 2011o summary of applicable Code Sections in the PE Act

Copy to: Dr. Allison M. MacFarlane, U. S. Nuclear Regulatory Commission ChairmanMr. William D. Magwood, IV, U. S. Nuclear Regulatory Commission CommissionerMs. Kristine L. Svinicki, U. S. Nuclear Regulatory Commission CommissionerDr. George Apostolakis, U. S. Nuclear Regulatory Commission CommissionerMr. William C. Ostendorff, U. S. Nuclear Regulatory Commission CommissionerMr. R. William Borchardt, U. S. Nuclear Regulatory Commission Exec Dir for OperationsMr. Jon Wellinghoff, JD, Federal Energy Regulatory Commission ChairmanMr. Philip D. Moeller, Federal Energy Regulatory Commission CommissionerMr. John R. Norris, JD, Federal Energy Regulatory Commission CommissionerMs. Cheryl A. LaFleur, JD, Federal Energy Regulatory Commission CommissionerMr. Tony Clark, Federal Energy Regulatory Commission CommissionerMs. Kimberly D. Bise, JD, Federal Energy Regulatory Commission SecretaryMr. Michael R. Peevey, California Public Utilities Commission PresidentMr. Michel Peter Florio, JD, California Public Utilities Commission CommissionerMs. Catherine J. K. Sandoval, JD, California Public Utilities Commission CommissionerMr. Mark J. Ferron, California Public Utilities Commission CommissionerDr. Carla J. Peterman, California Public Utilities Commission CommissionerMr. Paul Clanon, California Public Utilities Commission Executive Director

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July 22, 2011

Honorable Mimi Walters

Room 3082, Stare Capitol

PROFESSIONAL ENGINEERS: FIXED WORKS - # 1101097

Dear Senator Walters:

You have asked whether a licensed professional engineer who is not licensed as a

civil engineer may be in responsible charge of designs, plans and specifications, and

engineering reports for a project that has components involving Fixed works as described in

Sections 6731 and 6731.1 of the Business and Professions Code.

By way of background, the Professional Engineers Act (Ch. 7 (commencing with

Sec. 6700), Div. 3, B.& P.C.)' establishes the Board for Professional Engineers, Land

Surveyors, and Geologists (hereafter the board) within the Department of Consumer Affairs

and provides for the licensure and regulation of professional engineers2 by the board. In order

to safeguard life, health, property, and public welfare, the act requires a person who practices,

or offers to practice, civil, electrical, or mechanical engineering in this state to stibmit evidence

All section references are to the Business and Professions Code, unless otherwise

indicated.2 Section 6701 defines the term "professional engineer" for purposes of the act, as

follows:

"6701. 'Professional engineer,' within the meaning and intent of this act,

refers to a person engaged in the professional practice of rendering service or

creative work requiring education, training and experience in engineering sciences

and the application of special knowledge of the mathematical, physical and

engineering sciences in such professional or creative work as consultation,

investigation, evaluation, planning or design of public or private utilities,

structures, machines, processes, circuits, buildings, equipment or projects, and

supervision of construction for the purpose of securing compliance with

specifications and design for any such work."

Honorable Mimi Walters - Request #1101097 - Page 2

that he or she is qualified to practice and requires the person to be licensed by the board as acivil, electrical, or mechanical engineer (Sec. 6730). The act makes it unlawful for a personother than a licensed professional engineer to stamp or seal any plans, specifications, plats,

reports, or other documents with the seal or stamp of a professional engineer or to usespecified titles without a license (Sec. 6732). The act also makes it a crime for a person topractice or offer to practice civil, electrical, or mechanical engineering in this state withoutlegal authorization (Sec. 6787).

Section 6702 defines the term "civil engineer" for purposes of the act, as follows:

"6702. 'Civil engineer' as used in this chapter means a professionalengineer in the branch of civil engineering and refers to one who practices oroffers to practice civil engineering in any of its phases."

Furthermore, Sections 6731 and 6731.1 set forth specific practices that constitutecivil engineering and provide as follows:

"6731. Civil engineering embraces the following studies or activities inconnection with fixed works for irrigation, drainage. waterpower, watersupply. flood control, inland waterways, harbors, municipal improvements,railroads, highways, tunnels airports and airwaj•s purification of water,sewerage, refuse disposal. foundations, grading. framed and homogeneousstructures, buildings 2 bridg:

"(a) The economics of, the use and design of, materials of constructionand the determination of their physical qualities.

"(b) The supervision of the construction of engineering structures."(c) The investigation of the laws, phenomena and forces of nature."(d) Appraisals or valuations."(e) The preparation or submission of designs, plans and specifications

and engineering reports."(f) Coordination of the work of professional, technical, or special

consultants."(g) Creation, preparation, or modification of electronic or computerized

data in the performance of the activities described in subdivisions (a) through

(A."Civil engineering also includes city and regional planning insofar as any

of the above features are concerned therein."Civil engineers registered prior to January 1, 1982, shall be authorized to

practice all land surveying as defined in Chapter 15 (commencing withSection 8700) of Division 3," (Emphasis added.)

"6731.1. Civil engineering also includes the practice or offer m practice.either in a public o privte capacity, all ofthe following:

Only civil engrs cando work onfacilities that aregeographicallyfixed or permanent,like chemicalplants, petroleumrefineries, watertreatment plants,wastewatertreatment plants,foodmanufacturing,biopharm,environmentalremediation, powergeneration anddistribution, etc

Only civil engineerscan conduct workon foundations andstructures. Once afacility ispermanentlyattached to thefoundation orstructure, itbecome part of the"homogenousstructure", andbecomesgeographicallyfixed or permanent.Therefore allindustrial facilitiesare considered"fixed" and anywork at these siteshas to beperformed by a CE.No non-civilengineer orscientist can workon fixed sites.

Honorable Mind Walters - Request# 1101097 - Poge 3

"(a) LocatM. relocates, establishes. reestablishes r trac ealingment oS elvation &r. 2f the fixed works embraced within l s&2-f -c vil .nwwg .....*& aii h~ia4 ia &ssien CIL~

:W DerMines shk configrationur cotor 2fhe wj U uhi rfI or tbhRiI3 gf &Cd o , abkove obM Mr at g4 d& SUAUQf mrsh by applying theprinciples of trigonometry or photogrammerry.

"(c) Creates, prepares, or modifies electronic or computerized data in theperformance of the activities described in subdivisions (a) and (b).

"(d) Renders a statement regarding the accuracy of maps or measuredsurvey data pursuant to subdivisions (a), (b), and (c)."

(Emphasis added.)'

Thus, under Sections 6731 and 6731.1, the practice of civil engineering embracesvarious studies and activities wa Wanecign with Fixed works for irrigation, drainage,warerpower, water supply, flood control, inland waterways, harbors, municipalimprovements, railroads, highways, tunnels, airports and airways, purification of water,sewerage, refuse disposal, grading, framed and hbuildings, or bridges, Tht "r- k i nt Howe ,die wd fixed"cs p , and has been defined as settled, or established (San FranciscoPioneer Woolen Factory v. Brickwedel (1882) 60 Cal. 166, 173)., 'fi x r a ut act may b oof the type set forth inSection 6731.

Section 6734 additionally guides the scope of practice of civil engineers, andsubdivision (a) of Section 6735 specifies requirements regarding the preparation of civilengineering plans. These provisions read, in pertinent part, as follows:

"6734. Any person practices civil engineering when he professes to be acivil engineer or is in responsible charge of civil engineering work."

"6735. (a) All civil (including structural and geotechnical) engineeringplans, calculations, specifications, and reports (hereinafter referred to as'documents') shall be prepared by, or under the responsible charge of, alicensed civil engineer and shall include his or her name and license number.!

' See Section 2 of Chapter 625 of the Statutes of 1983 for another Section 673:1,1,which includes language that has the same effect as subdivisions (a) and (b) of Section 6731.1 setforth above.

' Te trm"reposibe hare'is define in both statute and regu~tion,

of professiewr worko the dit c prct. Regulations(continued..,)

EE and ME aredefined in the StateEngineers' Act,however, they do notinclude activities inconnection with fixedworks. Only CE cantherefore do work atfacilities that aregeographically fixedor permanent, likechemical plants,petroleum refineries,water treatmentplants, wastewatertreatment plants,food manufacturing,biopharm,environmentalremediation, powergeneration anddistribution, etc

The engineer inresponsiblecharge must becapable ofansweringquestions. Theymust betechnicallyknowledgeable ofdoing the workthemselves. TheCE cannot simply"supervise" thework, they need tobe able to do thework themselves.

Honorable Mimi Walters - Request*Cl101097 -Page 4

* * *',

Th a ~ dfn *ectri77JIm ad"~h~i nwhwvr

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The board has adopted regulations pursuant to the act applicable to the practice ofprofessional engineering. These regulations, set forth in Division 5 (commencing withSection 400) of Title 16 of the California Code of Regulations, among other things, require aprofessional engineer to practice and perf s .rhsg work ol i tshe Ri d'mUds inwhichs the profissicnal entgineer is by education or experiencse fully competent and proficient(16 Cal. Code Rp4. 415).

Turning now to the question presented, that is, whether a licensed professionalengineer who is not licensed as a civil engineer may be in responsible charge of designs, plansand specifications, and engineering reports for a project that has components involving fixedworks as described in Sections 6731 and 6731.1, we are guided by rules of statutoryconstruction. The primary task of statutory interpretation is to ascertain the legislative Intentso as to effectuate the purpose of the law consistent with the language of the statute (Hsuv. Abbara (1995) 9 Cal.4th 863, 871). The intent of the enacting body, whether that be theLUgislactu•e or the electorate, is the paramount consideration (Lgi.latwur v. Ev (1991) 54Cal.3d 492, 505). Statutory terms are construed in accordance with the usual, ordinaryimport of the language employed, in harmony with the overal legislative scheme (IT Corp.v, Solano County Bd. of Supervisors (1991) 1 Cal.4th 81, 98). Furthermore, statutory principlesof construction also apply to administrative regulations (Duke Molner Wbolesale Liquor Co.v. Martin (1960) 180 Cal.App.2d 873, 884).

As discussed above, a person is practicing civil engineering when the person is inresponsible charge of civil engineering work (Sec. 6734). Thus, to the extent a professionalengineer is in responsible charge of designs, plans and specifications, and engineering reportsfor the fixed work components of a project, the professional engineer would be practicing civil

(...continued)adopted by the board, which further defines "responsible charge,' provide that responsible chargedirectly relates to the extent of control a professional engineer is required to mwnuin wht&

euceam1*std dfr of puA aiol cn&*sring uXcu or creative workand to the engineering decisions that can be made only by a professional engineer (16 Cal. CodeRegs. 404.1(a)). For the purpose of evaluating whether an engineer is in responsible charge, theregulations require the consideration of specified factors, including whether &eprofessionalea#ým who ftns enineeg documets is capabe o eqmclm asked by individualswho arc licenscd by the board in the appropriate branch of professional engineering relevant tothe project (16 Cal. Code RegV. 404.1(b)).

Honorable Mimi Walters - Request #1101097 - Page 5

engineering (Sets. 6731, 6731.1, and 6734). Furthermore, all civil engineering plans,calculations, specifications, and reports are required to be prepared by, or under theresponsible charge of, a licensed civil engineer (Sec. 6735). Of the definitions of civil,mechanical, and electrical engineers set forth in the act, only civil engineering includesprofessional engineering work connected with fixed works (Sets. 6731 and 6731.1). Thus,reading these provisions of the act together, we believe that only licensed civil engineers maybe in responsible charge of designs, plans and specifications, and engineering reports for thefixed works components of projects described in Sections 6731 and 6731.1.

However, with regard to the components of an engineering project that are notconnected with fixed works, subdivision (d) of Section 404.1 of Title 16 of the CaliforniaCode of Regulations provides as follows:

"(d) Portions of Projects. Nothing in this section prohibits a professionalengineer from providing services for portions of or to add to or to modify anengineering project engineered under the responsible charge of another licenseeas long as the professional engineer exercises the requisite extent of control andassumes responsibility for the engineering decisions as required by subdivision(a) and meets the criteria described in subdivision (b), as well as meeting therequirements of the Professional Bngineers Act and Sections 411 and 415.1'9

The professional engineer need only be In responsible charge of the portions,additions, or modifications or the portion of the project affected by theaddition or modification and not of the entire project. Except as provided inSections 6735(b), 6735.3(b), and 6735.4(b) of the Code,(&) i'he oginwllcursis not relieve of ansy responsibiiy arisig from the wen~ierin 4etMces of

Thus, a professional engineer who is not a civil engineer may provide services forportions of, or to add to or modify, a project engineered under the responsible charge ofanother licensed engineer as long as the professional engineer exercises the requisite extent ofcontrol and assumes responsibility for the engineering decisions as specified in Section 404.1of Title 16 of the California Code of Regulations. In our view, therefore, even if an

The CE cannotsimply "supervise"other engineerswho are subjectmatter experts.The CE can'tsupervise unlessthey are competentto conduct the workthemselves.

I Section 411 of Title 16 of the California Code of Regulations establishesrequirements relating to an engineer's seal and, as described above, Soction 415 of theseregutatos reuire atanengeaw a pradctie only in d l in which he or she i fuogycomupeternt MProfiient,

' These sections provide that a civil engineer, electrical engineer, or mechanicalengineer is not responsible for damage caused by subsequent changes to documents prepared by,or under the responsible charge of, the respective licensed engineer if the subsequent changes oruses are not authorized or approved by the engineer, provided the engineering service rendered bythe engineer who signed the documents was not also a proximate cause of the damage.

Honorable Mimi Walters - Request #1101097 - Page 6

Only a civil engr cando work ongeographically fixedsites, or permanentfacilities. Since MEsand EEs are notallowed to do workon fixed or permanetsites, MEs and EEscannot be inresponsible chargeof geographicallyfixed or permanentsites. Only CEs canbe responsible fordesign of fixed work,that means non-civilengineers may notdo any engineeringon facilities that aregeographically fixed!

engineering project contains fixed work components, a professional engineer who is notlicensed as a civil engineer may be in responsible charge of a portion of the project that doesnot involve those fixed work components if the criteria for the exercise of responsible chargeare otherwise met.

Accordin ly, it is our opinion that only a .licnse civil et mni agny-fbe ini

wof an engineering project, as described in Secrions 6731 and 6731.1 of theBusiness and Professions Code. However, a licensed professional engineer who is not a civil

engineer may be in responsible charge of designs, plans and specifications, and engineeringreports for the components of an engineering project that are not fixed works.

Very truly your,

Diane F. Boyer-Vine

Legislative Counsel

BySergio B. Carpio

Deputy Legislative Counsel

SECsktn

Summary of applicable Code Sections in the PE Act March 19, 2013Page I of 2

PROFESSINAL ENGINEERS ACT

Chapter 7, Sections 6700 - 6799, Business and Professions Code

Civil engineering is defined in Sections 6731, and 6731.1.

6731 defines "civil engineering" as the act of providing all engineering, scientific, and other

professional services, in connection with "fixed works". Fixed works are permanent

geographical structures including "foundations, grading, framed and homogeneous structures,

buildings or bridges." 6731 subsections (a) through (g) describe the engineering, scientific, and

other professional services that are civil engineering. Every component that is attached to or part

of the fixed work is subject to the definition. All considerations of the materials used in

construction, supervision of construction, studies of the laws of nature, valuations, designs,

plans, specifications, reports, and developing any data relating to these activities, are defined as

civil engineering.

673 1.1 defines "civil engineering" to include activities to determine the location, and

geographical information, of fixed works.

CIVIL ENGINEER MANDATE

6704 protects public health and safety by requiring any person who is performing civilengineering to be licensed as a civil engineer.

6730 repeats the need to protect the public stated in 6704, and emphasizes that any person

performing civil engineering must be licensed as a civil engineer.

6731.5 defines "electrical engineering" as studies and activities relating to electrical energy. The

definition does not include "fixed works" which would be needed to allow electrical engineers toperform "civil engineering."

6731.6 defines "mechanical engineering" as that branch of engineering that deals with energy in

the thermal and mechanical form. The definition does not include "fixed works" which would be

needed to allow mechanical engineers to perform "civil engineering."

6737.2 provides that a civil engineer may practice any type of engineering. There is noreciprocal provision for electrical, mechanical, or any other licensed engineer.

6740 prohibits subordinates to civil engineers from performing civil engineering, unless licensed

as civil engineers.

6747 states that the PE Act does not apply to engineering work performed by utilities or

industrial corporations, except for "civil engineers and civil engineering."

6748 specifies that nuclear power plants are subject to the PE Act.

Summary of applicable Code Sections in the PE Act March 19, 2013Page 2 of 2

EXEMPTIONS

There are exemptions to the mandate that civil engineers must be used in the performance ofcivil engineering. They are specific and narrow. Examples are:

6737 allows a licensed architect to perform civil engineering when practicing architecture.

6737.1 allows any person to perform civil engineering when building codes are followed in smallresidential buildings and related structures. Agricultural structures are included in theexemption, unless the permitting agency determines there is a threat to public safety.

6739 exempts employees of the federal government, when acting in their official capacity, frombeing licensed.

6742 allows real estate licensees to provide valuations, 6731 (d), when acting within theirlicensed profession.

GENERAL EXEMPTION

There is no general exemption that would allow persons not licensed as civil engineers toperform civil engineering. The perception that there is an ability to use professional expertise inthe same manner as in all other states is contradicted by the PE Act.

The Legislative Counsel Bureau reviewed the PE Act and the regulations implementing it, aswell as case law, to determine whether certain engineers could perform civil engineering. Itsopinion concludes that, in the absence of a specific exemption, every person who performs "civilengineering" must be licensed as a civil engineer.

Joosten, Sand y

From:Sent:To:Cc:

Subject:

Attachments:

Bob Katin [rakatin@pacbell.net]Tuesday, March 19, 2013 3:35 PMRonald L. LitzingerCMROSTENDORFF Resource; CMRAPOSTOLAKIS Resource; CMRSVINICKI Resource;CMRMAGWOOD Resource; Macfarlane, Allison; Borchardt, Bill; Jon Wellinghoff, JD; Philip D.Moeller; John R. Norris, JD; Cheryl A. LaFleur, JD; Tony Clark; Kimberly D. Bose, JD; MichaelR. Peevey; Michel Peter Florio, JD; Catherine J. K. Sandoval, JD; Mark J. Ferron; Dr. Carla J.Peterman; Paul ClanonState PE Act requires all utility company engineering & science be conducted by a civilengineerletter to SCE President.pdf; legal opinion of the PE Act issued by the Legislative CounselBureau.pdf; summary of applicable Code Sections in the PE Act.pdf

Mr. Litzinger,

I am president of the California Legislative Council of Professional Engineers. The attached letter andenclosures have been mailed to you. In order to expedite your ability to consider these important documents, Iam sending this email.

If you have any questions or comments do not hesitate to contact me. You can reach me at (925)755-1150.

Thanks,

Bob Katin, PEPresident, CLCPEphone (925) 755-1150fax (925) 754-8524cell (925) 813-2922rakatinpacbell.netwww.clcpe.org

1

Joosten, Sandy

From:Sent:To:Cc:

Subject:

Attachments:

Bob Katin [rakatin@pacbell.net]Tuesday, March 19, 2013 3:31 PMChristopher P. JohnsCMROSTENDORFF Resource; CMRAPOSTOLAKIS Resource; CMRSVINICKI Resource;CMRMAGWOOD Resource; Macfarlane, Allison; Borchardt, Bill; Jon Wellinghoff, JD; Philip D.Moeller; John R. Norris, JD; Cheryl A. LaFleur, JD; Tony Clark; Kimberly D. Bose, JD; MichaelR. Peevey; Michel Peter Florio, JD; Catherine J. K. Sandoval, JD; Mark J. Ferron; Dr. Carla J.Peterman; Paul ClanonState PE Act requires all utility company engineering & science be conducted by a civilengineerletter to PG&E President.pdf; legal opinion of the PE Act issued by the Legislative CounselBureau.pdf; summary of applicable Code Sections in the PE Act.pdf

Mr. Johns

I am president of the California Legislative Council of Professional Engineers. The attached letter andenclosures have been mailed to you. In order to expedite your ability to consider these important documents, Iam sending this email.

If you have any questions or comments do not hesitate to contact me. You can reach me at (925)755-1150.

Thanks,

Bob Katin, PEPresident, CLCPEphone (925) 755-1150fax (925) 754-8524cell (925) 813-2922rakatin(pacbell.netwww.clcpe.org

1.