No Design Legislation

Opposing interior design legislation everywhere

Why Design Legislation is Bad for Students

Laws regulating the practice of interior design and restricting it to those who have met the pro-legislation cartel’s narrow standards are not in the best interests of the profession as a whole, and particularly not those of current or future students.

According to renowned kitchen design expert Dr. Phyllis Markussen, CKE, CBE, who is a professor of Family Studies and Interior Design at the University of Nebraska, interior design legislation could have a significantly negative effect on interior design students, because the one path route to practice that would result would “effectively ‘dumb down’ the educational programs by creating too-rigid guidelines”.

It is advantageous in academia to provide a “system-approached” education, bringing in a range of other disciplines to help provide students a “broader, more global perspective”. To restrict the practice of interior design to those who have graduated only from CIDA-accredited schools (which do not even include some of the most prestigious schools of design in the country, such as Parsons), would eliminate that opportunity by “…[narrowing] the approach with a single educational experience”.

In addition to homogenizing the educational offerings, specialization could be restricted as well, which could result in a shortage of designers to meet the needs in any given state. This is also because there simply won’t be enough qualified designers around to shepherd the students through the state-mandated process to being able to practice independently.

According to AICAD (Association of Independent Colleges of Art and Design), “We need multiple pathways into creative fields due to their varied and dynamic natures… Society does not benefit by a narrowing of access to creative fields. ”

Far more schools are not CIDA-accredited than are, which would result in CIDA having a virtual monopoly on interior design education, with zero evidence that the CIDA schools have any better record of preparing students than any other programs. A situation such as this would not benefit anyone but those CIDA-approved, programs and the various organizations that support them.

The effects on other academic institutions are readily obvious – the net result would be discrimination against community colleges in particular, and their student bodies.

In addition, if there aren’t enough jobs for students when they graduate (and there already aren’t, particularly thanks to the present economy), then demand for these programs will decrease, which in turn will force a number of colleges and universities to restrict *all* of their offerings. Some programs will have to shut down altogether, leaving existing students high and dry, and effectively eliminating interior design as a career option at all for many who would have otherwise chosen this path.

Finally, and most importantly, students are being fed a line that they will not be able to practice what they are trained to do without design legislation, but a simply look at the present realities will show that to be untrue. The fact of the matter is that the vast majority of interior designers are not licenced/registered/certified, even in states that do have some form of either practice or title act, and yet they are still working and still getting their projects built, the same as they always have.

As I wrote in my post “It Doesn’t Involve Me – Or Does It?”:

It is not illegal to practice interior design now in any state except the three in which the ASID-led cartel have managed to pass legislation that makes it illegal to do so without a license. They claim that the IBC makes it illegal, but it patently does not. What it does is leave the decision up to each jurisdiction, and most places and code officials have no desire to restrict the practice of interior design any more than it already is limited by architectural laws, or to regulate it. Read the code yourself – it’s on page 41. If what we do becomes illegal, it will only be because ASID and their cohorts will have made it that way.

Interior design legislation has been proven over and over again to be a solution in search of a problem. If passed, it will only create the very problem it claims it will prevent. In states that do not presently have any category of “registered design professional”, legislation will create that category – and then restrict the practice of design to those that hold those credentials, where it has never been restricted before.

Do not be misled into believing their scare tactics telling you that you won’t be able to practice what you’re learning now in school, because it’s simply not true. The only way that will happen is if they make it happen. And this is supposed to be protecting you?

Over and over again, this issue has been pointed out to the prolegislation cartel – and in front of legislators, who have been shown the actual code wording, as it’s been pointed out to the cartel people at the same time – and yet these people persist in repeating this blatant untruth, and particularly using it to frighten students into thinking they have no choice but to support legislation, when nothing is actually further from reality.

IDPC puts it most succinctly: “The IBC (Sec. 106.1) does NOT require that all construction documents be prepared by registered design professionals. What it actually says is the following: [C]onstruction documents shall be prepared by a registered design professional where required by the jurisdiction in which the project is to be constructed.” (emphasis added). The IBC defers completely to state law as to whether or not construction documents must be prepared by an architect or an engineer or may be prepared by anyone else including interior designers.”

And now, with the Art Institute of Pittsburgh scandal, we see again the lengths to which these people will go in order to accomplish their ends – faculty members of a design school coercing students into supporting the pro-legislation agenda whether they wanted to or not by giving an extra credit assignment that only offered credit to those who wrote to their legislators to support legislation, and no credit at all to those who wrote to oppose it.

Students, if legislation is brought into academia at all, you deserve an education that teaches you how to research all sides of the issue and make decisions like this for yourself. You deserve as much credit for your work in doing this and opposing legislation, if that is how you feel, if such an assignment is given, as any student who chooses to support it. For an instructor to coerce students into supporting his or her own political ends or risk their grade and academic standing is a violation of academic integrity and standards that is utterly shameful.

This is only one case that we know about. It’s anyone’s guess how many other instructors or schools might be doing the same thing, or something similar.

And you should be asking yourselves, is this what you want your tuition and tax dollars to be funding?

If you don’t already know how to research and evaluate both sides of an issue that is going to dramatically affect you and your future, then you deserve to be taught how to do so, not be railroaded into one point of view or the other like this. You do not deserve to be used as pawns.

It is just flat out unfair and unethical to put students in a position like this where they may have to choose between their own values and their academic standing, and if you are not outraged by this, you should be.

June 23, 2009 Posted by | ASID, Interior Design Protection Council (IDPC), ncidq certification licensing, Nebraska, NKBA, Pennsylvania, Students | , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , | 2 Comments

CIDA College Coerces Student Support of Legislation

We recently became aware of a situation at the Art Institute of Pittsburgh (PA) in which instructor Lauren Musulin offered an extra credit assignment to students in her Revit class if they lobbied legislators in PA in support of passage of proposed legislation HB 1521 – with extra points for getting two other people to also write letters supporting the bill as well – an assignment entitled “IDLCPA Support –  http://www.idpcinfo.org/AIP_Extra_Credit.pdf

This same opportunity was not offered to students who oppose such legislation.  In fact, when a student who opposes legislation objected, she was not given an alternative opportunity to earn the same extra credit by another means.  When the student in question approached the instructor and requested an opportunity to “research and evaluate opposing views”, the instructor flat out denied her request.

This was nothing but a blatant, all-out effort on the part of one instructor to intimidate students into supporting her own political agenda, and to coerce her students into supporting her own legislative views, not to teach involvement in the legislative process.

When the Interior Design Protection Council published this information, department chair Kelly Spewock responded, alleging that “Ms. Musulin’s students had the opportunity to research and evaluate opposing views to this topic, among other projects that were not made available to you or your readers”, and claiming that the Institute does not take a particular position with respect to legislation.  Spewock claims that other extra credit opportunities were offered to students who did not want to support legislation, but has yet to specify what they were.  The specific assignment, to which the link above points, makes it very clear that no alternative option was, in fact, offered, as does the fact that the student who objected was denied other options.

It is an absolute disgrace that an academic institution should in any way attempt to coerce students into supporting any particular legislative position and make it part of their grade, and it should not take publishing the information on a nationally-distributed mailing list or blog to bring the situation to people’s attention to compel that faculty member to offer students other options.

To teach involvement in the legislative process by encouraging students to research the issues, formulate their own opinions, and to write to legislators in support of whatever their own conclusions lead them to support would be an entirely legitimate assignment – but not demanding that they support only the instructor’s own point of view or face loss of extra credit points.

What’s more, the assignment makes several completely false statements, including alleging that “only a registered design professional” may implement the IBC code provisions.  This is out and out untrue, as anyone who can read can verify for themselves on page 41 of the code.  This lie has been repeatedly promulgated all over the country, and is just as repeatedly refuted every time it rears its head, yet the cartel lumbers on, repeating it endlessly, as if so doing will actually make it true.

The assignment also implies to students that a “fair” legislative procedure involves ramming a bill through the process, and by claiming that it must “move quickly”, implies that there may be some deceptive practices involved that may deny the other side a fair hearing.

One could argue that such instruction isn’t even the point of a class in using a software program, too, which makes this all the more bizarre, because the assignment doesn’t even relate to the topic of the class!

Sadly, this is just one more example of the kind of underhanded tactics to which the pro-legislation cartel will stoop in order to promote their point of view.

June 16, 2009 Posted by | Interior Design Protection Council (IDPC), Pennsylvania | , , , , , , , , , , , , , , , | 2 Comments

Florida Design Law to be Challenged!

See press release below:

To view as a webpage: click here

Interior Design Protection Council

Finally!
It’s time for the Florida cartel to face the music!

And your support is needed!
THE INSTITUTE FOR JUSTICE
is taking on
THE FLORIDA INTERIOR DESIGN CARTEL!

This could be the most important event in the future of interior design. Come and be a part of history in the making! Attend the press conference and RALLY. . .

Design Community: Click here for FLYER with rally date, time and details

Media: Click here for PRESS RELEASE

Blog: Click here to COMMENT

Forward this issue to a Friend

Please download and print copies of the flyer and post them EVERYWHERE!

— especially in showrooms and vendor locations —

Colleagues, please join the fight for our rights and freedom to design

With your help, we CAN resist or repeal legislation that restricts your practice or right to call yourself “interior designer” in every state — including YOURS. You can help by joining our team!

If you have any questions, please feel free to contact us at info@IDPCinfo.org.

Patti Morrow
Executive Director
Interior Design Protection Council

IDPC is the only national organization solely dedicated to protecting the rights and livelihoods of ALL designers in our country.
Please support our efforts!
Click here to become a member of IDPC.
Join Our Mailing List!

==============================================================
INTERIOR DESIGN PROTECTION COUNCIL

91 Reserve Place, Concord, New Hampshire 03301 Phone: 603.228.8550 Fax: 603.229.1339 http://www.IDPCinfo.org

FOR IMMEDIATE RELEASE: CONTACT:

May 21, 2009 Patti Morrow 603.228.8550

Florida interior designers victimized by restrictive law to get relief

Lawsuit, press conference and rally on May 27th in Tallahassee

Concord, NH – On Wednesday, May 27th, a public rally will be held at Waller Park in Tallahassee to coincide with a
legal challenge filed against Florida’s interior design practice law.

The Institute for Justice (IJ) is filing suit in Florida on behalf of several small business entrepreneurs whose basic
Constitutional rights have been violated by the most restrictive interior design law in the country. At issue is a Florida
law that restricts residential interior designers from advertising themselves as “interior designers” and prevents them from
legally practicing any type of commercial design. The law also prohibits industries such as office furniture and restaurant
equipment dealers from doing furniture or equipment layouts, an essential practice needed to succeed in those fields.

“Interior designers are already struggling with this difficult economy,” said Patti Morrow, executive director of
the Interior Design Protection Council (IDPC), the national grassroots voice for independent designers. “The last thing
they need is a completely unnecessary law that places an additional burden on their ability to earn a living.”

The proponents of the law, the Interior Design Associations Foundation (IDAF) and the American Society of
Interior Designers (ASID) maintain that Florida Statute 481 – and licensing in general – is needed to protect the health,
safety and welfare of the public, a claim that remains unsubstantiated even after the 30-year pursuit to impose interior
design licensing in all 50 states. Yet, since 2003 more than 600 unreasonable disciplinary actions have been brought
against members of the Florida design community, none of which had anything to do with public safety. When asked
about the aggressive disciplinary actions and increased fines imposed by the regulatory board, Janice Young,
spokesperson for IDAF responded, “We do it [penalize unlicensed design] by making the punishment more painful
and significant.”

“Florida’s restraint of trade and censorship of interior designers is blatantly unconstitutional and represents a
deliberate attempt by a tiny faction within the interior design industry to (1) eliminate their competition by restricting the
type of services they would be free to provide in nearly every other state, (2) silence competitors by preventing people
from truthfully advertising the services they do provide, and (3) improperly burden and discriminate against interstate
commerce,” said Clark Neily, senior attorney with the Institute for Justice. “This law has come from a minority of elitist
insiders within the design industry itself, not as a result of public demand or legislative determinations that such regulation
is necessary for the public good. They are clearly abusing government power to drive thousands of hard-working small
businessmen and women out of business. This law cannot stand.”

Over the last year, IDPC spearheaded the effort to raise awareness of this issue in Florida, by conducting town
hall meetings, lobbying the legislative and executive branches to deregulate the law, supporting amendments to FS 481,
opposing changes to the Florida Building Code, exposing blatantly false statements made by IDAF, revealing the
ruthlessly aggressive actions of the law firm retained to prosecute designers, and by publicizing the devastating effects on
the lives of these victims. IDPC’s widespread grassroots support will mobilize to support the IJ legal challenge.
“We value the innovation, creativity and diversity as well as the multiple methods of entry that have been the
cornerstone of this dynamic profession, serving the public without harm. Florida’s once-size-fits-all licensing scheme for
interior designers could not be more contrary to those values,” explained Morrow. “Protectionism, censorship, cartel,
monopoly, domination, control, special interests – you name, it’s all here, and it’s having a devastating effect on the lives
of Florida designers. It’s time to pull the curtains on the interior design cartel.”

May 21, 2009 Posted by | ASID, Florida, Institute for Justice, Interior Design Protection Council (IDPC) | , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , | 4 Comments

Is Your Interior Designer *Really* Putting Your Life at Risk?

Vodpod videos no longer available.
more about “Is Your Interior Designer *Really* Pu…“, posted with vodpod

Reason.tv’s Nick Gillespie went looking for dead bodies, and for an explanation for why the state of Florida launched a legal case against Younts. State regulators demand that she obtain a license, a license she says she doesn’t need, a license that could cost her six years and hundreds of thousands of dollars.

Do licensing laws protect consumers from death and destruction or, as the Interior Design Protection Council argues, do they protect licensed designers from competition? Should Younts be stripped of the career it took her decades to build? Should President Obama be worried about his interior designer, the unlicensed Michael Smith? Watch the documentary below, then you decide…

Written and produced by Ted Balaker. Director of photography is Roger Richards.

April 2, 2009 Posted by | Alabama, ASID, Florida, Georgia, Interior Design Legislation Opposition, Interior Design Protection Council (IDPC), ncidq certification licensing, Texas | , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , | 1 Comment

Report from Annapolis

Thanks to David Merrick of NARI for the following summary of the meeting in Annapolis regarding Maryland’s proposed legislation. Because of intense opposition pressure, the amendment turning the bill into a title act instead of a practice act was circulated, and changed the terminology – and they are going to vote on this on Friday, March 20.

They also want to change the existing title act restriction on “Certified interior Designer” to be “Licensed Interior Designer”, and wanted to even restrict the use of the term “interior designer”, but NKBA and others made it clear to them that this was not OK, either. Even ASID officially agrees with not restricting that use now, but the local Maryland people are still trying to push it through.

So, the fight isn’t over yet, folks – read on, and keep on writing and calling your legislators. This could still pass as amended on Friday – or even unamended.

=======================================================================================================
Yesterday’s hearing in Annapolis was well attended, over 100 people
turned out to testify against this bill. One of the delegates commented
at the start that they had received more emails on this than they did
for the death penalty.

Before the hearing started an amendment was circulated that drops the
practice issues included in the bill and turns the bill into a title
bill for Interior Designers. The original bill would limit the practice
of interior design to Licensed Interior Designers, this would include
kitchens, bathrooms and residential buildings and would greatly affect
design build contractors and people who call themselves Interior
Designers but have no credentials to back that up. The amended bill
would just restrict the title of Interior Designers to people who have
been licensed by the state.

The head of MHIC, Larry Levitan testified in favor of the bill as long
as MHIC contractors were exempted, that helps some of us but would still
affect many of our colleagues. Proponents of the bill say it is needed
to protect the public despite a clean record with no complaints filed
against Interior designers in the recent past.

This is a very political issue and is not dead, the bill could still go
before the legislature un-amended, amended or be killed in committee.
We need it to be killed in committee. If this passes it would be
complete disaster for our businesses.

Use this link to the NKBA website to respond to all of the legislators

http://capwiz.com/nkba/issues/alert/?alertid=12816801&type=ML

It is very important that we stay tuned into what is happening here, I
urge each of you to take a few minutes and write a personal message,
this link is very easy to use and very effective. I received a personal
reply from two representatives.

David Merrick, CR

President, NARI Metro DC

President Merrick Design and Build Inc

301-946-2356

March 19, 2009 Posted by | ASID, Interior Design Legislation Opposition, Interior Design Protection Council (IDPC), Maryland | , , , , , , , , , , , | Leave a comment

ASID – Backpeddling as Fast as They Can

Interior Design Protection Council

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Please forward this email to every interior designer, interior decorator, student, vendor or industry partner who would be negatively affected by regulation

Who is IDPC?

The Interior Design Protection Council is a national, nonpartisan, nonprofit organization whose mission is to protect the rights of interior designers, interior decorators, office furniture dealers, showrooms, suppleirs and other businesses who would be negatively affected by interior design regulation.

We also actively influence legislation germane to protecting the livelihood of our members.

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BACKPEDDLING…..AS FAST AS THEY CAN!

Freedom Tactics Change ASID Mission!

On March 4th, ASID sent a letter to their membership and an accompanying FAQ document in attempt to assuage their members’ fears that the “ASID legislative strategy may be harmful to their businesses.” IDPC has been forwarded a multitude of these documents from ASID members who are just not buying into the ASID party line any longer.

Over the last few months,IDPC has focused much attention and provided factual details, evidence, and empirical data on exactly how ASID-sponsored legislation is hurting its own members. The result is that many, many ASID members have chosen NOT to renew their memberships, hence the reason for this latest ASID piece of propaganda — they need their Allied members (what people are calling ASID’s “cash cow”) back so they can continue to fund their push for anti-competitive, anti-consumer regulation.

Don’t fall for this obvious PR ploy…these documents are nothing more than DAMAGE CONTROL 101! Here’s IDPC’s response to some of their claims:

“ASID will not support title acts that restrict the use of the title “interior designer.”

One one hand this is definitely waving the white flag; however it is also totally disingenuous. The fact is that pure title acts which restrict the use of the title “interior designer” have been taken away from them! Restricting that title is unconstitutional and the Institute for Justice succeeded in removing that barrier in New Mexico, and has filed lawsuits in Texas, Connecticut, and Oklahoma, which they are almost certain to win. Illinois corrected their title act on their own, to avoid a lawsuit. In the past, pure title laws were surreptitiously passed without the knowledge or consent of the design community, but the days of ASID-supported legislation passing under-the-radar are over. To persist in pushing for pure title acts would result in their continued, utter failure, so pragmatically, of course they are going to withdraw their support. This is not the result of an epiphany or sudden stab of conscience. This new policy is equal to an admission that they have failed in their quest to prohibit use of the title “interior designer” to only NCIDQ certified designers.

“ASID advocates that the requirements to become a state-qualified interior designer include formal interior design education, experience and passage of the NCIDQ examination.”

There it is, Allied members. They are still advocating that you cannot be a part of their elitist cartel unless you pass the NCIDQ, an exam that historically has had a very low passage rate, takes up to six months to prepare, requires 2 to 4 years of (usually unpaid) internship before applying, costs $2000 or more to take including preparation and materials, and is rarely passed on the first attempt. Not to mention it is considered irrelevant by the majority of interior designers AND consumers.

“Enables all interior designers to practice to the fullest extent of their capabilities.”

This is merely code for distinguishing between the qualifications of those who they believe are fully qualified to practice (i.e., those who have education, experience and the NCIDQ) and those who aren’t — the overwhelming majority of designers in this country. According to the statement, a “state qualified interior designer” must still meet the education, experience and NCIDQ advocated by ASID, so there is no change there.

ASID will support your right to provide “services such as selection of colors, materials and finishes or selection and specification of furniture, fixtures and equipment.”

In other words, they will allow you to be a decorator. Incidentally, don’t think they they are being generous — these services are already exempted in virtually all proposed legislation anyway.

“ASID has grown to 40,000 members”

Yeah, right. And if you believe that, I have a bridge I’d like to sell you. Okay, let’s take out the student members, the members from other countries, the members who have not renewed, the members who are retired, the members who are dead, How many are left? Two years ago, they had 20,000 practicing members (8000 professional and 12,000 Allied). But that was before the downturn in the economy and before IDPC entered the arena to bring the truth about anti-competitive regulation to the design community. Most professional organizations that are not involved in controversy are down by 25 – 35% or more this year due solely to the difficult economy. ASID’s membership fee of $440 is higher than most, and they are embroiled in the backfire of their regulatory scheme, yet they claim they’re growing and not losing members? Absurd! IDPC gets emails and phone calls every week from Allied members who have not and will not renew! We report the facts — you will have to come to your own conclusion.

ASID is no longer the organization it once was. Their power is only perceived. Allied members are fleeing in droves because ASID refusal to acknowledge them as the “professionals” they truly are.

“Be assured that if the interior design services you offer are legal today, ASID will not support any law that makes it illegal tomorrow.”


This statement is so important, that it deserves it’s own section…

So, this would seem to indicate that ASID is not going to support ANY practice act legislation, because practice acts make it illegal to practice some aspect of interior design. Right?

Wrong. You have to read EVERY WORD very carefully, and sometimes even between the lines. Take a look at this loophole:

“ASID will not support legislation that restricts interior design services that do not affect building codes or other statutes.”

So, this gives them the option to support this type of legislation, even if you are already successful in that area, which would make it illegal for you to practice. This loophole leaves the door wide open for ASID to support, behind the scenes, any practice act bills they choose.

Remember, the IBC does NOT require that all construction documents be prepared by registered design professionals. It is up to the local code officials to determine whether or not plans meet with their approval.


If you are facing an ASID-supported practice act in your state, be sure to use the statement at the top of this section to expose the utter hypocrisy between what they SAY and what they DO.

What’s Missing?

Health, Safety and Welfare

Conspicuously absent is any indication that regulation is being pursued to protect the health, safety and welfare of the public.

This is clearly an [unintended] admission by ASID that there really is no issue of health, safety and welfare in providing interior design services in residential or commercial applications.

Therefore, there is no reason for any state-imposed regulation whatsoever.

IDPC is the only national organization solely dedicated to protecting the rights and livelihoods of ALL interior designers.

Click here to become a member.

New ASID Video

ASID has a new 3-minute video on their homepage, reiterating the information sent on March 4th. It’s really just the same old rhetoric, but I do want to address a couple of statements that are misleading.

Mr. Alin states that 80% of the ASID members surveyed support “legal recognition” (aka “licensing”) interior design.

Actually, the number is 77% who agreed that designers should be licensed, but aside from that technicality, Mr. Alin fails to mention that this is NOT the will of their entire membership, ONLY 2,200 members even bothered to respond!

So less than 1700 of their alleged 40,000 members have given them the thumbs up to continue pushing their anti-competitive regulatory scheme!

Clearly they do NOT have a mandate from their OWN membership to continue to use their money to fund legislation, but hey, why let a little thing like MAJORITY VOICE affect policy decisions when you can get away with a dictatorship.

ASID, you do not speak for the design community — you don’t even speak for your own membership.

If you are an Allied member, “professional” member, or student member:

PLEASE CONSIDER THAT YOUR MEMBERSHIP DUES AND MANDATORY LEGISLATION ASSESSMENT ARE FUNDING INITIATIVES THAT YOU MAY NOT AGREE WITH OR THAT WILL HARM YOUR FUTURE LIVELIHOOD!

No dues = no legislation. Could it be any more simple?

Another thing Mr. Alin failed to mention is that according to the same survey, 82% said that “clients seldom or never ask them if they are licensed.” That’s because they don’t care! Consumers are NOT confused about interior design services and they do not need a NANNY state to dictate who they may or may not hire.

Mr. Alin goes on to further state that ASID is “fighting to expand your scope of work” that you are “trained and educated to do but are restricted from performing.”

More false information. The only thing that restricts the performance of interior design work are practice acts themselves! In 47 states, it is legal to do ANY kind of interior design work. Clearly, ASID is fighting to expand the scope of interior design into interior architecture.

A new trend is beginning to develop in which interior design educators are now beginning to questioning the abandonment of the aesthetic nature of design for the “interior architecture” model that the design schools have been teaching, which is a real disservice to the students who are being told that they can be one thing (an interior architect) when in fact, that is not occurring in the real world.


Oh, one more thing…

If ASID was sincere about their Allied members right to the use the title “interior designer,” why does the new policy state “ASID does not intend to pursue amendments to existing interior design statutes”?

Because the whole thing is just lip service. If they were truly advocating for all their members, including Allied members, they would use the dues and legislative assessment to UNDO laws which prohibit ANY of their members from using a title that accurately describes what they do, and which makes it impossible to market their services truthfully and effectively, like the current Florida law, and the proposed practice act in Tennessee.

Letter to the Editor

THIS IS FOR ALL YOU ALLIED MEMBERS – STOP PAYING THOSE DUES! I attended the legislative meeting in MN. The pro-legislation people I will quote as saying, “We are not just good at decoration., we do more than just pick out colors.” “You, Senators, may call yourselves designers too.” “We do not teach style or trend at the U of M. We know where to place Exit signs,” (isn’t that what the contractor is licensed to do, let alone the architect that knows where the doorway is?” Personally, I went to school to learn (among other things in interior design) color, trend, and style, not to learn where an Exit sign is placed, that profession is already taken!
Those are just a handful of the comments that were very snide and full of contempt to any of you out there that went to school for interior design especially if you are an Allied Member of ASID. By paying your dues to ASID you help to support their contempt of you by not being a Professional. If you have no plans, such as myself after 16 years, of going back to school, spending $thousands (it is only $800 according to testimony–they must have forgotten the cost of books, the cost of the study program, the cost of travel, and the cost of your time) you need to wake up and stop sending money to ASID. They will allow you to use the word Designer (in MN) but yet you clearly are not as they said at the legislative meeting. You are a decorator and you choose color, you have a knack for selecting decorations unless you are licensed!

Suzanne Hynan, NKBA, WFCP, ASP
Former Allied ASID

Dear Colleagues,

I trust you have benefited from our ongoing effort to seek the truth, cut through ASID’s rhetoric and misleading information, and expose their duplicity. This latest PR effort is merely an attempt to soften their position in the public eye, without truly changing their legislation scheme.

I am still receiving many emails from Allied (and even some “professional”) members who are NOT renewing their ASID memberships. Good! Your message is coming through loud and clear! Without YOUR money to fund legislation, ASID will be forced to pull back their support to their state chapters and coalitions.

Patti PR headshotPlease consider joining OUR crusade — your future to design tomorrow could depend on action you take today.

Best regards,

signature-black

Executive Director

IDPC

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March 11, 2009 Posted by | Interior Design Legislation Opposition, Interior Design Protection Council (IDPC) | 2 Comments

Press Release – Group Resignation from ASID

Press Release

superheroGROUP RESIGNATION FROM ASID

SENDS A STRONG MESSAGE:
STOP THE PUSH FOR REGULATION

On December 19, 2008, Michael Alin, Executive Director of the American Society of Interior Designers (ASID) was sent a letter via Fed Ex with the signatures of 27 Allied and Professional members resigning their membership with ASID, designated as “Group One.”

Among the reasons outlined in the letter was the groups’ pronouncement that legislation supported and funded by ASID is not in the best interest of the Allied members, and has requirements so restrictive that they would be denied the right to practice. Allied members in states where licensing has been enacted have suffered terrible persecution and lost their right to earn an honest living. The group expressed concern that in a failing economy such as this, ASID should be using all its resources to support and market designers, not to destroy them through legislation.

The group resignation was coordinated by Jayne Rosen, a long-time Allied ASID member, in response to colleagues voicing their desire to resign. Rosen commented that she has seen ASID’s focus shift from education and networking to pushing a legislative agenda that does not include their own Allied members and that she feels is dangerous to the future of the profession.

The Interior Design Protection Council (IDPC), a nonprofit organization whose mission is to protect the rights of interior designers, has led the national movement to expose and neutralize ASID’s lobbying efforts to monopolize the interior design industry. “Interior design is a dynamic profession that celebrates innovation, creativity and diversity,” stated Patti Morrow, Executive Director of IDPC. “ASID’s attempt to impose its one-size-fits-all occupational licensing scheme on the profession is not only contrary to those values, but also hurts Allied Members, the majority of ASID’s own constituency, who while successfully working as professional designers, do not possess or wish to poses ASID’s self-mandated credentials which it claims are necessary to be considered a “professional” or to work as an interior designer.”


Diane Plesset, a “professional” member of ASID who resigned her membership earlier this year also added her name to the protest letter. “I’ve passed the NCIDQ exam required for licensing, but I cannot in good conscience support legislation that will put many honest, hard working designers out of business,” said Plesset. “A true professional is always confident enough to compete based on the merit of the work they produce.”

Rosen expects the news of the multiple-signer resignation will be a wake-up call to ASID’s Allied members, and could even be the catalyst for more resignations to take place before the December 31st renewal deadline. “The more resignations, the stronger our message becomes,” said Rosen. “ASID has neither a right nor a mandate to dictate who may or may not practice interior design.” ASID members interested in participating in another group resignation can reach Rosen at libertyforpadesigners@yahoo.com.

Morrow reported that she has been flooded with emails from Allied members indicating they do not intend to renew their 2009 memberships. “Allied ASID and independent designers need to wake up and smell the coffee,” said Morrow. “2009 could be a financial disaster for them if they do not support and join IDPC’s effort to stop the insidious spread of anti-competitive interior design regulation that may put them out of business.”

Click here to read the Resignation Letter sent to ASID.

ASID Renewals Lapse

chartIn our last newsletter, we extended an invitation to anyone not planning to renew their ASID membership to tell us why.

We have been astonished at the incredible number of responses flooding our office! Even more amazing is that unbeknownst to each other, most designers said basically the same thing. You can read a small sampling of these messages in our Letters to the Editor section below.

If you are also not planning to renew your membership in ASID, please feel free to voice your concerns and opinions at pmorrow@IDPCinfo.org. Your name and email address will be held strictly confidential and used only for IDPC internal survey purposes.

If you are interested in adding your name to an additional group resignation letter to send a message to ASID, please contact libertyforpadesigners@yahoo.com.

ASID President’s Letter
December 18, 2008

superheroIt appears that IDPC’s newsletters are reaching thousands of their Allied members, causing them great concern and prompting them to contact the ASID national offices. ASID recently wrote to their members attempting to assuage the growing fears of their membership. As usual, ASID provided nothing substantial or empirical as backup to their rhetoric. Below are some of their statements followed by IDPC rebuttal.

“ASID is working tirelessly to advocate for the right regulation that enhances your right to practice.”

Wrong. ASID, through the coalitions it funds, initiates and funds legislation which puts their Allied members’ right to practice in jeopardy. Just look at the laws already in place as well as every single bill proposed. They have three lobbyists working to enact and expand legislation, and they charge a $15 mandatory assessment, whether or not you agree with their agenda

“ASID is actively recruiting Allied members and welcomes new Allied members into ASID each and every day.”

Of course they do! Dues from Allied members make up the majority of their income. If Allied members decline membership, the money available to push for licensing drastically declines.

[ASID provides] “Listing on the national designer referral service.”

Until recently, the ASID website had been changed so that the default said “Show Professionals Only.” Clearly, this was demeaning to Allied members, demoting them to second-class status, and made it difficult for consumers to find the Allied listings, not to mention subliminally indicating to consumers that they would be choosing an “unprofessional” designer.

IDPC brought this matter to the attention of the design community, many of which are Allied ASID, and in response to what must have been (should have been) outrage by the Allied members, it appears that the default has now been changed back to “Show All Practitioners.”

Another victory for IDPC, the only national organization that truly looks out for all designers!

“Use of the ASID Allied Member appellation” [as a benefit]

We have received copious amounts of email from Allied members as well as unaffiliated designers stating that their clients neither know about nor care whether they are ASID members. They care only about the quality of work they produce.

“Each state is defining interior design – and no two definitions are the same.”

Misleading and disingenuous. There are of course subtle differences to comply with the detailed process in each state where ASID is supporting legislation. But in virtually every proposed bill, the requirement for licensure, registration, or certification has and continues to be passage of the NCIDQ exam. Most successful, practicing Allied designers do not possess the criteria needed to even sit for the exam, thus excluding them from qualifying.

“We have not and do not seek to restrict others’ livelihoods.”

The legislation they support and fund HAS and DOES restrict the livelihoods of the majority of interior designers in this country who are not NCIDQ certified, including ASID’s own Allied members. Just take a look at the situation in Florida, as just one of many available examples. Many, many Allied ASID members and independent designers in Florida have been fined or ordered to Cease and Desist. Their names will appear on Google forever as having been prosecuted. This is a foreshadowing of what will happen in every state if practice acts are allowed to be enacted unchecked.

“Currently, interior designers in many jurisdictions are prevented by existing laws from offering services within their scope because the profession is not legally recognized.”

Absolutely false. As we have reported many times, the IBC’s actual language is: “[C]onstruction documents shall be prepared by a registered design professional where required by the statutes of the jurisdiction in which the project is to be constructed.”

The International Building Code (IBC) establishes common code and other safety requirements for various building types. It does not regulate any design profession, nor does it require that any design profession be regulated or not be regulated. Nor has the International Code Council (ICC) ever taken a position to the effect that “interior design services must be regulated in order to protect the public.” It is telling that there is no citation or reference whatsoever supporting the false statement that it has.

For detailed information on why the IBC is a non-issue, click on these two newsletters:

Don’t Let Codes Scare You

10 False Statements About Licensing

“If your state does have an interior design law on the books, it may not affect you or the type of work you do.”

Nonsense! States with a practice act take away your occupational freedom to practice to the full scope of your abilities — they allow only work with “surface materials,” i.e. “decorating.” States with a title act take away your free speech right to accurately describe your work or yourself, thus making it more difficult or impossible to market yourself

“Our Society is what it is today because of you.”

The membership dues and mandatory legislative assessment you pay to “your Society” ARE FINANCING THE LOBBYING EFFORTS THAT MAY PUT YOU OUT OF BUSINESS!

Isn’t it time for YOU to stop “YOUR” society from using YOUR dues to push an agenda YOU do not agree with?

Isn’t it time for you to join IDPC?

Tattletales
And other despicable creatures..


ratDid you know that under the Florida interior design practice law, licensed designers are legally required to turn in other designers, decorators, architects, employers, co-workers, competitors, anyone they see or know of who is just trying to earn a living but is in violation of the Florida law?

That’s right. Here’s the statute:

455.227 Grounds for discipline; penalties; enforcement.
(i) Failing to report to the department any person who the licensee knows is in violation of this chapter, the chapter regulating the alleged violator, or the rules of the department or the board.

Is this how you want your life to be? Constantly looking over your shoulder for (1) someone to turn you in for just trying to put food on the table, or (2) in constant fear that they’ll come after you, in spite of your license, because you failed to rat out one of your colleagues…?

This is the kind of KGB-like state you will be faced with if the cartel is successful in getting more practice acts like Florida’s.

And it doesn’t only affect interior designer and decorators — the office furniture and restaurant equipment industries are also being targeted and prosecuted in Florida!

It’s time for Florida designers, decorators, office furniture dealers, restaurant equipment dealers, kitchen and bath designers, architects, etc. to join our movement and help us create a plan for your state for 2009.

It’s time for the design community in the rest of the country to join IDPC and stop practice acts from getting enacted in your state.

Your future is in your hands.

ANTI-licensing article
Insurgence of the Independents by Patti Morrow

Window FashionWindow Fashion Vision is the second national, unaffiliated magazine this year to publish an article from the point of view of the resistance movement. Click here to read Insurgence of the Independents, an exposition on why unaffiliated designers — the vast majority of practicing designers — are resisting the effort led by ASID to regulate the profession, in the November issue of magazine.

Click here to subscribe to Window Fashion Vision.

www.wf-vision.com

Letters to the Editor

“I am not planning to renew my ASID Allied membership. They have not listened to my objections to licensure. I have made my voice clear for twenty years and they are still trying to regulate a profession that does not need it. I have also felt that they haven’t given me anything for my dues money as an Allied member. Clients and prospective business contacts never ask about my membership, so what’s the point?”

* * *

“All this licensing really comes down to is money. Money for NCIDQ, money for ASID, money for the legislation………and lots of it! It would take over $2,000 for me to get my license (with the STEP course, hotel and travel, the test, registration fees, and purchasing extra practicums and templates – from ASID, of course). It’s not worth it at this point in my life to become licensed. It will benefit me none. I believe my work speaks for itself. Plus, the multiple choice part of the test material is irrelevant to real-life daily practice…even in the commercial world (for which I work). They do not deserve my hard-earned money. I do not currently believe in this process to be licensed.”

* * *

“I am one of those allied ASID members who is NOT renewing my membership. The economy is only part of the problem. I do believe that ASID’s push for legislation is self-serving, and does not help me, as I am always on the bottom of any referral lists, because I have not sat for their exam, although I graduated at the top of my Interior Design Curriculum. I have NEVER been asked by a client whether or not I belong to ASID. My work and referrals speak for themselves.”

* * *

“I have decided not to renew for a few reasons, most importantly because I do not agree with their proposed legislation of interior designers. Secondly, I do not feel that it is currently worth $400+ for the benefits that they offer.”

* * *

“I have chosen to not renew my ASID membership this year. The high membership dues in this economy are coupled with the fact that I do not feel that I am getting anything out of my membership. That is magnified by their apparent lack of concern for allied members (with the legislation they are pushing for, etc). It is outrageous that a professional organization like ASID supports a move toward licensing that excludes those who have chosen to take an alternate path of education, and practical, professional experience, rather than paying to take an exam to become a ‘Professional Member’ of ASID.

Thank you for the thoughtful and researched material. I plan to forward this e-mail to design & construction colleagues who are affiliated with other professional organizations”

* * *

“I’ve been a professional designer for 30+ years (Allied Member ASID for about ten years) and have never been responsible for any harmful circumstances to my clients. It seems to me that this is an attempt to make the public view Interior Designers as having expertise beyond our scope of training/education/experience…such as architects/electricians/plumbers and building contractors……Not so!!! If those are the credentials they want to present, then they should achieve the education/training and accredidation necessary to qualify them to attach those titles to their names…..passing the NCIDQ does not nearly come close to filling that level of expertise.”

* * *

“Why align myself with an organization that is costly to maintain and may put me out of business?”

* * *

“I am not renewing my ASID membership for 2009 because ASID has done nothing to promote my business or assist me in any way. I just read the list of ten reasons a licensed interior designer is necessary and I laughed it was so absurd. I am not licensed and I am fully aware of all code requirements, ADA specifications, etc. as I regularly pull permits for jobs. Every time I read something from the IDPC I get madder! I will be joining your organization in January. Thank you for all you do.”


-Letters may have been edited for length only-

Special thanks

superheroOn behalf of the Board and Staff of IDPC,

we’d like thank our

troops and veterans

for their selflessness and courage in protecting that which we hold most dear:

OUR FREEDOMS

Please do not let their sacrifices be in vain. Do not let the pro-regulation Cartel take your economic liberty from you without a fight. Help IDPC protect your Constitutional rights to occupational freedom and free speech.

giftAsk for a membership to IDPC for Christmas.

Or better yet, why not give yourself the gift you richly deserve?

$100 a year for Members of the design community and supporters

$ 20 a year for Students

CAN YOU AFFORD NOT TO JOIN?superhero

Happy holidays and a prosperous and regulation-free new year.

signature-black
Executive Director
Interior Design Protection Council

info@IDPCinfo.org

In This Issue

ASID Allied Resign

ASID Renewals Lapse

ASID’s President’s Letter

Tattletales…

ANTI-licensing article

Letters to the Editor

To our Troops and Vets

Quick Links

Our website

About Us

Rebuttal to ASID Strategy

Join IDPC!

logo

The next job we save could be YOURS!


Membership Information

Case Statement

Recommended Reading

Insurgence of the Independents

Designing Freedom

Designing Cartels through Censorship

Misinformation

Lawsuit in Connecticut

Design Regulation: Coming to a State Near You?

Lawful Enterprise

Watch Out for That Pillow

Wallpapering with Red Tape

The New Unions

Don’t Regulate Interior Designers

Join Our Mailing List

Please forward this email to every interior designer, interior decorator, student, vendor or industry partner who would be negatively affected by regulation

Who is IDPC?

The Interior Design Protection Council is a national, nonpartisan, nonprofit organization whose mission is to protect the rights of interior designers, interior decorators, office furniture dealers, showrooms, suppleirs and other businesses who would be negatively affected by interior design regulation.

We also actively influence legislation germane to protecting the livelihood of our members.

For more information on IDPC, please visit our website at

www.IDPCinfo.org

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Click here for information on becoming a sponsor.

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December 24, 2008 Posted by | California Designers Against Legislation (CADAL), Interior Design Legislation Opposition, Interior Design Protection Council (IDPC) | , , , , , , , , , , , | Leave a comment

ASID MEMBERS RESIGN IN PROTEST OF ASID LICENSING EFFORTS

We just received a copy of the letter below sent to ASID Headquarters. Thanks to the Interior Design Freedom Coalition http://www.interiordesignfreedom.org/blog.html for posting it.

Please see the links on this blog in the Interior Design Legislation Opposition section to the Interior Design Protection Council and the Interior Design Freedom Coalition for more information on licensing efforts and how to protect your real right to practice in your state, and how ASID efforts will put thousands of designers out of business.

=======================================================================================================
ASID RESIGNATIONS
-GROUP ONE-

December 19, 2008

Michael Alin, Executive Director
The American Society of Interior Designers
608 Massachusetts Ave., NE
Washington, D.C., 20002

Dear Mr. Alin:

Over the last several years, we have watched as ASID has recklessly spent our dues and MANDATORY legislative assessments on a failed policy falsely proclaiming to “raise the level of the profession” and to cull what you have decided are the “real designers” from those not following the path you dictate. The legislation you support has requirements so restrictive that most designers would not be able to comply and will therefore be denied the right to practice.

Over and over… we have watched as ASID’s president, members and board repeatedly mislead their own ASID colleagues about the EFFECT of legislation on our right to practice, while currying support from the very designers who would be put out of business by your legislative actions. And we have listened as Allied Members were described as the “Cash Cows” of the organization – too stupid to understand that we were being used to fund our own demise.

Over and over… we have watched as ASID betrayed its own ethics to push its own agenda – an ego-driven agenda that has the potential to destroy more than half of its own membership.

Over and over… we have listened as ASID members said sweetly, “We’re not trying to put you out of business.” [Subtext: as long as you forego your practice to go back to school for at least 2 years, do a supervised internship with an NCIDQ certified designer – if you can find one who also happens to be hiring – and intern from two to five years while being paid virtually nothing; then if you have any money left, pay about $2000 to take step workshops, purchase study materials, and take and pass the NCIDQ test (which is rarely passed on the first attempt), and then prove to the satisfaction of your own competitors that you actually are a designer, and comply with any regulations they happen to write.] But nobody’s trying to put you out of business; after all, there’s grandfathering. And from what we’ve seen of the way “grandfathering” is often written into the legislation, that’s just as bogus a claim as the rest of the pro-legislation argument.

Legislators have told us that representatives (either ASID and/or IIDA members) have misrepresented the content, objectives and design support for their legislation while governors of four states have clearly understood it to be anticompetitive and protective.

In states where practice acts have been enacted, designers have suffered terribly – persecuted for what they have done successfully for years, sustaining huge fines and legal fees for miniscule “infractions” and in some cases, bankrupted and driven out of the state in order to earn a living.

Florida designers bear witness to the travesty of your actions, and we hear more and more from them every day. The disgraceful behavior of Florida ASID members who deliberately work to expose and report their own members, as well as others, and help to put them out of business tells us what we need to know about ASID as an organization and about how legislation really works to
destroy designers’ rights to practice. And Florida is not the only state where this happens or has happened: try Alabama, Texas, New Mexico, Connecticut and others.

There are estimated to be between 200,000 and 400,000 interior designers in practice in the U.S. today. ASID claims membership of only about 20,000 practicing designers, the majority of
whom don’t even care about “raising the level of the profession”. Many are not even aware of your legislative agenda. They just want to practice design successfully as they always have.

We have personally spoken to Allied designers all across the country, and have found the vast majority to be opposed to your actions. As we’ve said before: the only designers who benefit from your tactics are the so-called professional designers who have passed the NCIDQ – and those are few and far between.

You do not represent independent designers as you have claimed, hence the title independent. They don’t want ASID’s interference in their right to practice, and have told us that they resent ASID’s efforts to dictate policy in which they have no say. Even ASID members are not welcome to disagree with your policies as the invitation to the Arkansas conference clearly shows, where attendees were carefully vetted to make sure that there would be no discordant voices.

ASID HAS NO RIGHT AND NO MANDATE TO DICTATE TO HUNDREDS OF THOUSANDS OF DESIGNERS ALL ACROSS THIS COUNTY WHO WILL BE ALLOWED TO PRACTICE AND WHO WILL NOT. YOUR LEGISLATION IS BEING DEFEATED BECAUSE DESIGNERS DO NOT SUPPORT YOUR OBJECTIVES.

It is clear to us that ASID no longer advocates for all of its members. This is illustrated in the make-up of the board which is ponderously commercial, in the membership of your pro-legislation coalitions across the country, where the majority are often commercial designers and in your undue influence in the schools, where students are pushed toward architectural/commercial design and where residential design gets short shrift. Students have told us that ASID has misled them, pushing them into commercial/architectural design on the premise that jobs at the commercial or architectural firms would be awaiting them when they graduate, and that ASID would help them get those jobs.

Even before the economic downturn, commercial jobs were very hard to come by – by ASID’s own statistics, only 15% of the market – and the few students who manage to land those jobs do so without ASID’s promised-but too often undelivered assistance. Many students, unable to secure those jobs have wound up selling commercial furniture and other commercial products. And most residential designers cannot hire them, as designers who have, have told us that they can draft, but cannot do other things that are crucial to residential design.

ASID’s preferential conduct is also apparent in the way Allied Members are treated on the national website’s “Find a Designer” page, where potential clients searching for referrals are offered a choice of “Show Professionals Only” (listed as the default) vs. “Show All Practitioners” which they have to search for [note: this appears to just have been changed]. This is insulting and clearly shows a bias toward “professional” members, which is especially unjustifiable considering that many so-called “Professional” designers have never passed the NCIDQ test and have just been allowed in. Allied Members pay the majority of dues and mandatory legislation fees, are no less professional in their work, and do not deserve a lesser marketing effort than any other members.

Additionally, by promoting its single-entry method as the one true path to design, ASID has created a rift between practicing designers and those who take ASID’s EEE path, with the younger designers evincing rudely worded disrespect for their more experienced elders – a situation which is not conducive to job creation.

Interior Design is a creative field. Yet ASID is determined to legislate creativity out of it by restricting the many paths of entry into the field that have nurtured that creativity and vision for years, producing brilliant designers – down to one path that is engineered to produce – engineers.

In a failing economy such as this, ASID should be using all its resources to support and market designers, not to destroy them through legislation. And make no mistake, we completely understand your actions and your intent.

We are ashamed and deeply disappointed by this organization. We can no longer support a Society that deliberately destroys its own membership and endangers the future of design and designers in its unending desire for power and dominance. And because of your exclusive policies, we know there is no hope of changing the trajectory of your actions.

ASID had a slogan: PROTECTING YOUR RIGHT TO PRACTICE. You are, in fact, subverting your own raison d’etre by deliberately trying to destroy our right to practice. And that is unethical, unconscionable and unacceptable.

And so we are resigning.

Jacqueline Bazaar, #1533586, Pennsylvania
Margaret H. Benson, #1504190, Texas
Gayle Beyer, #1519494, Colorado
Loraine Brown, #1250453, Georgia
Christine Colman, #1534167, Washington
Ellen Fernandez, #1239917, Maryland
Diane Foreman, #61436, Oregon
Debbie Gersh, #1485135, Texas
Noreen Dunn Gottfried, #1502827, Pennsylvania
Carol Gumpert, 1550669, California
Karen K. Hartley, #75601, Georgia
Nancy Hartsing, #1559067, Arizona
Henrietta Heisler, #1859365, Pennsylvania
Elizabeth Kauermann, #97269, Pennsylvania
Nancy Phillips Leroy, #1231856, Pennsylvania
Christie Meehan, #1201627, Pennsylvania
Tonya Morrison, 1487732, Pennsylvania
Jayne Rosen, #78935, Pennsylvania
Rebecca Ruediger, #1250458, Missouri
Carly Sax, #1500172, Illinois
Anne-Marie H. Schimenti, #1504255, Florida
June Shea, #1486996, Virginia
Nadia T. Tanita, #1542001, Hawaii
Terri Temple, #18099, Connecticut
Mary Sue B. Wiedmer, #1215131, Pennsylvania

Resigned earlier this year for the above reasons:

Janice Onsa, Pennsylvania, former Allied Member
Diane Plesset, Oregon CMKBD, CID #5818, C.A.P.S., former ASID

cc: Bruce J. Brigham, President
Board of Directors:
Bruce Goff
Charrisse Johnston
Doug Hartsell
Lisa Henry
Mary G. Knopf
Rachelle Schoessler Lynn
Stephanie Clemons
Sybil J.B. Van Dijs
According to a survey by Interior Design Magazine as quoted in the New York Times, January 29, 1987

December 24, 2008 Posted by | California Designers Against Legislation (CADAL), Interior Design Legislation Opposition, Interior Design Protection Council (IDPC), ncidq certification licensing | , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , | 1 Comment