The quest to obtain STEM designation for landscape architecture meets the hard walls of the Department of Homeland Security.

By Brian Barth 

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STEM (science, technology, engineering, and math) is all the rage in academia these days. STEM degrees confer significant prestige in a high-tech world, and STEM education is funded to the tune of billions of dollars by the federal government. Privileges afforded to STEM students include eligibility for the National Science Foundation Graduate Research Fellowship Program, which excludes non-STEM students. Minority students are incented to pursue STEM degrees by grants available to those who attend historically black colleges and universities and Latinx-serving institutions.

STEM is also deeply enmeshed in immigration policy. Out of concern that the flow of native-born STEM graduates falls short of labor market demand, the United States offers foreign graduate students in STEM fields an extension on their F-1 student visas to encourage them to remain in the country as high-skilled workers—a boon to the students, but also to firms that are seeking to retain top global talent in a country increasingly bent on tightening its borders. F-1 visa students in any field of study are eligible for 12 months of “optional practical training” (OPT), a form of temporary work authorization that may be used for jobs or internships related to their field. But in 2008, an additional 17 months was offered solely to students in STEM fields; in 2016, the OPT visa extension grew to 24 months, for a total of three years of work authorization.

The three-year OPT visa extension is no small trinket for foreign students who are eyeing U.S. degree programs. The ability to stay in the country after graduation greatly enhances their job prospects, which in turn enhances their long-term immigration prospects: The H-1B visa that typically comes with a job in an American firm is a well-worn path to a green card and, eventually, citizenship. Because STEM figures so heavily in career choices and funding streams, professions of every stripe clamor to get in its tent. But the door is heavily guarded.

The list of federally designated STEM fields is maintained not by the Department of Education but by the Department of Homeland Security—specifically by the U.S. Immigration and Customs Enforcement division, better known as ICE.

The list, which includes more than 200 areas of study, ranges from the four core STEM disciplines and their subdisciplines to subjects with a more tangential relationship, such as archaeology and urban forestry. Environmental health, geographic information science, natural resources conservation, architectural and building sciences, and water, wetlands, and marine resources management—these and many other fields with a nexus to landscape and design are included on the list. Landscape architecture is not.

In June 2016, ASLA submitted a 26-page brief to ICE to make the case that landscape architecture, given its underpinnings by the environmental sciences and close links to engineering and tech innovation, is most certainly a STEM discipline, especially considering ICE’s seemingly broad interpretation of STEM. An analysis by Roberto Rovira, ASLA, the chair of Florida International University’s Landscape Architecture + Environmental and Urban Design program, found that one-third of ASLA’s “Landscape Architecture Knowledge Base” categories contain STEM content. At least one federal agency, the Bureau of Labor Statistics, already considers landscape architecture a STEM profession.

But ASLA received only a short form letter from ICE in response to the request, says Kristopher Pritchard, ASLA’s manager of accreditation and education programs. “When you look at the list, it seems kind of arbitrary why they’ve chosen some disciplines and not others,” Pritchard says.

ICE established the list in 2008, and issued an update in 2012 and again in 2016, just before ASLA submitted its request for inclusion. This pattern suggests that 2020 would be the next opening, but Pritchard and his ASLA colleagues have been unable to confirm that timing with ICE. Nor have they received a response to questions about the protocol for adding disciplines to the list or the criteria by which a discipline is judged to be STEM-worthy or not.

In October, I e-mailed ICE for clarification. “The Department of Homeland Security has been very cautious about creating overbroad eligibility for the STEM [visa] extension[s],” replied Carissa F. Cutrell, in the ICE public affairs office. To be added to the list, a field “must involve research, innovation, or development of new technologies using engineering, mathematics, computer science, or natural sciences.” Who decides? “Subject matter experts within the Department of Homeland Security determine whether a degree program should be added to the list of qualifying STEM degrees,” Cutrell said.

ASLA representatives were told that they will not be notified if or when the profession is added to the ICE list. Simply check the Federal Register from time to time to find out, they were instructed. “It’s frustrating,” says Pritchard of the agency’s black box approach.

Graduate-level landscape architecture programs in the United States are increasingly reliant on international students to fill their seats. This fact has produced a sense of urgency around acquiring STEM designation among program administrators as they field calls from prospective students who wonder whether they’ll be eligible for a visa extension if they choose to enroll.

Landscape architecture enrollment declined following the Great Recession, according to ASLA statistics. Undergraduate programs have rebounded healthily, but graduate enrollment has flatlined. When graduate enrollment is broken down by foreign and native-born students, however, it’s clear that the number of American students continues to trend downward while a dramatic increase in international students has made up the difference: In 2013, 28 percent of MLA students came from abroad; currently, more than 40 percent do. The majority of those international students come from Asia, especially China, where the profession is booming.

Susan Apollonio, ASLA’s director of education and marketing, says that ASLA’s next step will be asking program administrators to sign a letter petitioning the Department of Homeland Security to speed up the process, in hopes of steering even more students toward the profession.

In the meantime, students, faculty, and administrators at some landscape architecture schools have discovered a work-around.

The Department of Education assigns each field of study a number in its Classification of Instructional Programs (CIP), a taxonomic system for tracking enrollment data and other bureaucratic purposes, including visa matters. Simply by changing the CIP code (as these numbers are known) of a degree program to one that is on ICE’s list, students in the program are eligible for the coveted three-year OPT extension, effective immediately. Individual schools have wide discretion over their use of CIP codes; consulting the immigration authorities is not required.

When Chelsea Zhou, a recent graduate of the University of California, Berkeley’s MLA program from Nanjing, China, learned of this loophole in 2017, she organized a group of fellow international students in the program to persuade her school’s administrators to make a code switch—to environmental studies, a STEM-designated discipline that overlaps significantly with landscape architecture curricula. The administration declined the request. Undeterred, the students circulated a petition among their peers and collected letters of support from faculty, along with documentation to show that the new CIP code would not have adverse effects on funding, licensure, or accreditation. They also mentioned that other landscape architecture programs, including the one at Harvard, were making the switch. The second time around the university agreed and, in March 2018, the code was changed.

Zhou, who graduated that spring, says about a third of her class was from China. But she insists that their motivations went beyond immigration. “We are not the only beneficiaries of the STEM designation. The department also benefits—the way we approach landscape architecture at UC Berkeley is very scientific and research-driven, and this opens up more opportunities for [STEM-based] funding.”

Derek Lazo, an American student who graduated alongside Zhou, joined the group working to change Berkeley’s MLA CIP code for his own reasons. “Keeping international talent here is super important. But this is also just a really personal thing. I made some dear, dear friends from all over the world at Berkeley, and I want my friends to be able to stay here as long as they want. They’re having immense difficulties getting visas under this administration, so helping them get an extra two years is a no-brainer.”

Some landscape architecture employers have also taken up the STEM cause. “More and more international students are filling up the classrooms at design schools, which means that if we don’t come up with a way to keep that talent in the U.S., we will not be producing enough landscape architects to satisfy [domestic] demand,” says Brian Jencek, ASLA, the director of planning at HOK. “The amount of work we have versus the number of licensed professionals is really out of whack. And it’s only getting worse.”

Part of the business case for the OPT extension, Jencek says, is that it gives employers and employees time to determine if the working relationship is a good fit before they begin the process of applying for an H-1B visa. (Employers must sponsor their employees for the visas.) Plus, obtaining an H-1B visa can be a lengthy ordeal. The office of U.S. Citizenship and Immigration Services conducts an annual lottery for the visas—if you’re not selected, the OPT extension assures that you can continue to work legally until applying again the next year.

“It’s very difficult to get H-1B approvals, and we’ve had to shift many great designers outside of the U.S. to our overseas offices as a result,” Jencek says. “So getting STEM designation is a big deal, with tremendous value for employers. It’s a vehicle for the profession to capitalize on the amazing talent that’s coming from overseas.”

In addition to Berkeley and Harvard, the MLA programs at four other schools have recently made the code switch: UC Davis, the University of Virginia, the University of Pennsylvania, and the University of Illinois.

The University of Illinois, where more than 70 percent of MLA students are from overseas, mostly from China, changed its CIP code to sustainability studies in July 2018. “Our motivation was clear and simple: It supports our students,” says William Sullivan, ASLA, the head of the Illinois landscape architecture program. “We want to provide every opportunity for our students to stay in the United States for as much time as they want, within the constraints of the law. And we feel that this ridiculous misdesignation of landscape architecture as not a STEM degree is arbitrary and capricious.”

Sullivan says he doesn’t worry that Illinois’s sustainability studies designation will confuse anyone—CIP codes are part of the inner workings of academic bureaucracies, after all, not public-facing symbols of degree programs—but he has heard complaints from people in other landscape architecture programs who fear there will be repercussions.

The main concern is that aggregate data about landscape architecture education will become skewed. The Department of Education collects figures on things such as enrollment based on CIP codes, for example. If Illinois’s MLA students are now being counted as sustainability studies students, enrollment numbers for landscape architecture will drop accordingly, at least as far as the federal government is concerned. How much that matters was a point of debate in a panel on immigration and landscape architecture at the most recent ASLA conference.

Sullivan, who participated in the panel, acknowledges the potential risk, but says that, in his view, the benefits outweigh it.

“The idea that rogue schools are threatening the clarity of what a landscape architecture degree is and will confuse the good people at the U.S. Department of Education—and that the confusion will result in costs to us—was raised with a lot of passion. I understand that concern, but at this point it’s essentially a hypothesis. I haven’t seen any data to support it. I’m not convinced we’re going to confuse many people by changing our CIP code, but we will remove a very significant barrier for some of our students who want to stay in the U.S.”

No one argues, however, that getting the landscape architecture CIP code added to the ICE list would be preferable to individual schools’ changing CIP codes. That way, faculty, administrators, and students can spend less time in the labyrinthine halls of the immigration system and more time in the design studio.

“It took more than a year of constant work, trying and trying to change the code,” says Zhou, who now works full-time at a residential design firm while moonlighting as a product designer for Bay Area tech start-ups. “So I think it’s super progressive that ASLA wants to do this for the entire profession.”

Brian Barth is a freelance journalist with a background in environmental planning and landscape design. Learn more about his work at brianjbarth.com and on Twitter @brianjbarth.