December 15, 2015
Barry Nocks, Ph.D., FAICP
PAB Chair
Professor Emeritus
Department of Planning, Development, and Preservation
Clemson University
2-213 Lee Hall, Box 340511
Clemson, SC 29634-0511
Dear Barry:
The APA Board, AICP Commission and the APA Diversity Task Force of Membership thank you for the
opportunity to review and comment on the proposed PAB Amendment to Preconditions to
Accreditation and Accreditation Standards. Over the past few months each group has met to develop
our feedback.
We support your efforts to address legal issues that have been raised and to ensure that the
Preconditions to Accreditation and Accreditation Standards are legally sound. Our principal concern is
that the proposed changes seem to go further than necessary to address the legal issue the attorney
raised regarding diversity. We talked about how the PAB can monitor and evaluate the success of the
program’s policies to encourage diversity. While the proposed changes are intended to avoid the
problem of measuring outcomes with respect to diversity, we suggest that what should be measured is
the effort to seek diversity in those areas, not the diversity itself. A related consideration is if we
measure the effort to seek diversity, such an approach might unfairly penalize a program whose
outreach in those areas is conducted at the school level, not department level.
This letter reflects our collective input to date organized by the five categories in the Preconditions.
More specific suggestions on language are included in the attached version of the Preconditions with
track changes.
1. Strategic Planning & Progress
 How often should the process of assessment, reflection and correction of each program or
department occur? This process should not only happen before accreditation review but more
continually. (1. First paragraph)
 When programs document participation in their plan development to include faculty, students,
alumni and practitioners, it’s suggested that there is a broad “spectrum of the professions”, but
what does that include? It should be more than just the various disciplines of planning to
include demographic diversity in terms of age, race and gender.(1.B.)
 Feedback from members is that the Programs do not engage the practitioners and employers
in the development of the strategic plan and they are often contacted only in the immediate
face of a reaccreditation site visit. Thus, we recommend that practitioners be included in the
following sentence: “Programs must document participation in plan development by faculty,
students, alumni, and practitioners.”. (1.B.)
 “Goals shall reflect the Program’s intent to achieve and maintain diversity…” – “Intent” is not a
strong enough word. Programs can intend to do things and not do it. We suggest that the goal
shall reflect the Program’s COMMITMENT to achieve and maintain diversity. (1.B.2.)
 When discussing goals and measurable objectives, programs need to incorporate into their
curriculum the following (1.B.2.):
o A clear understanding of the social, economic and environmental forces that keeps
aspiring planning students from entering a program or succeeding after completing the
program.
o The knowledge and skills needed to serve a diverse society.
o “The objectives should ordinarily be measurable and framed…”: what is “ordinarily”?
This language could be less vague. We recommend deleting the word "ordinarily" as
superfluous when the word "should" is used, rather than "shall." The "should" allows for
some flexibility, without undermining the intent of the statement. (Final paragraph in
1.B.)
 Under Program Assessment, the section called “Graduate employment” could be phrased more
appropriately to address current issues, especially in the Midwest. This section implies that all
graduates will be looking for a job when in reality, many will currently hold jobs. There are
students who are currently employed as planners in the surrounding communities but have
degrees in Geography or Public Administration. They return for their masters to be better
equipped to continue in their position. At this time, that level or type of assessment is not
captured. This issue is faced by several of the urban based programs that offer evening classes.
We ask you to consider how to accurately assess a program that has this component. One way
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to clarify what is being measured would be to document the percentage of graduates
previously not employed who secure employment. (1.C.1.b.)
While “Graduate employment” seems like a logical indicator, it is reliant on the plentiful and
regular availability of planning employment opportunities. Unfortunately, there many variables
that affect supply and demand for planning jobs, i.e. geography, economic recession, planners
staying on the job passed retirement age, etc. We encourage the development of this indicator
to take these realities into account so that certain planning programs are not put at a
disadvantage over others. (1.C.1.b.)
Under “Graduate Certification”, a qualitative piece is missing beyond AICP exam pass rates.
Smaller programs, or programs that have people who don’t take the exam, is of concern. If no
one takes the exam that year, then the rate is 0% which reads that no one from that university
has successfully taken the exam. That could be misleading, so we suggest that the pass rate
also indicate the number taking the text so that there is a ‘context’ to interpret the pass rate.
(1.C.1.c.)
Under “Graduate Certification”, should we consider extending these periods to a more
meaningful 5 and 7 years? In many/most cases, graduates are not eligible to sit for the exam
until their 3rd year after graduation, and undergrads their 5th year after graduation. (1.C.1.c.)
Why is the cost (tuition and fees) an outcome? If deemed as such by the programs and PAB,
would we not want these costs in relation to the cost in the recent past (e.g., 5 years)? Also, if
tuition and fees are an outcome, it seems that scholarships and other assistance would need to
be included as an outcome as well. (1.C.1.e.)
“Core Knowledge, Skills, and Values of the profession” could include a note that they are listed
in the PAB standards under standard 4. Curriculum.(1.C.2.a.)
When discussing graduates servicing the community and the profession, please clarify the
meaning of "community." Does this mean the academic/university community or the
community in which the graduate works? How will this be defined? (1.C.2.c.)
How can you accurately track contributions to meeting community needs and service to the
profession 2 and 5 years after graduation? How do you gather the data? What is the anticipated
performance metric here? Hours in pro bono? Grants obtained? Number of plan commission
meetings attended? (1.C.2.c.)
Faculty research/scholarly contributions to the profession needs more clarification. We
understand that there must be a balance between the need for academic research and
applicable research. Not all research is immediately useful in application, but contributes
toward the larger body of knowledge that improves the profession’s impact. With that being
said, distribution outside of the academic community is necessarily a metric of value. There
should be some consideration given to the extent to which faculty research is disseminated
outside of the academic community. (1.C.2.d.)
2. Students
 The last sentence in the introductory paragraph is stricken, but it is not clear how that sentence
would violate legal requirements.
 Item 2.B. Student Diversity: the entire paragraph B has been replaced. It would appear that only
the last two sentences are a problem with respect to the legal issue that has been raised.
 PAB should be very clear on what they want to report on diversity data.
3. Faculty
 Under “ Faculty Quality Guidelines”: Eliminating the guideline about adjuncts, lecturers, and
guest speakers adding perspective removes opportunities for students to be exposed to
diverse, valuable and experienced voices that come outside the academic world. This guideline
should not be removed. (3.A.Guidelines)
 Under “Faculty Size Guidelines”: There was some concern over stating that a program should
have a minimum of 5 full-time faculty members. What if budget concerns dictate that the
number be lower than 5? If this is in fact a guideline, then the accreditation team should have
flexibility when evaluating the program. (3.C.Guidelines)
 Too many programs appear to assemble their 5 FTEs from dozens of adjuncts teaching a single
course. (3.C.Guidelines)
 When discussing “publication outlets”, JAPA should be specifically cited as a journal through
which publications will be disseminated. Also, some portion of the output of the faculty must
be accessible to the profession of planning outside of the academic community.
(3.E.Guidelines)
 When stating that the faculty should “progress toward meeting the needs of the broader
community”, define “broader community.” University community? Local community? (3.F.)
 We do not encourage academic isolation of the faculty and the changes in 3.F to reduce the
inward focus of faculty endeavors are welcomed. We have suggested changes to 3.G. to
reinforce the value of professional practice. (3.F./3.G.)
4. Curriculum and Instruction
 Equity needs to be mentioned. When discussing that curriculum must “prepare students to
practice planning in communities with diverse populations”, we also need to add “and to
develop skills necessary to create equitable and inclusive planning processes”. (4. First
paragraph)
 Under the “Values and Ethics” section, we need to add “Health and the Built Environment: the
vast implications of our profession on individual and community health in the places where we
live, work, play and learn.” (4.A.3.)
5. Governance
 Regarding “Program autonomy”: Programs should invite and encourage the involvement of
adjunct faculty but when the word “shall” is used, it is a requirement, and adding hours into the
time adjunct faculty spend may be unreasonable. Most are not paid much to start so requiring
additional hours of time could narrow the pool of willing instructors. (5.A.)
General comments
 In general, we'd like to see more emphasis on community engagement and recognition of
students interested in community development and urban affairs, since we think that is where
we can find more diversity. Also, we think the PAB accreditation focuses too much on strategic
planning and the concept of urban planning as a term; and not enough on community
engagement, outreach, equity and improving the lives of others.
 We are concerned that the proposed revisions weaken the commitment to diversity that the
current standards exhibit, and we urge the Board to keep a strong commitment, while
remaining consistent with applicable law
 We would like to see more examples formatted in the language when mentioning racial
and ethnic minorities, or cultural differences. For example "Policies shall be in place that proactively seek to expand opportunity for under-represented minorities, including racial and
ethnic minorities (Ex. black, white, Hispanic, etc.), and that foster a climate of inclusivity that
appreciates and celebrates cultural differences (Ex. Sexual Orientation, Religion, etc.)".
Sincerely,
Carol Rhea, FAICP
President, APA
Valerie J. Hubbard, FAICP
President, AICP
Angela D. Brooks, AICP
Chair, APA Diversity Task Force of Membership