On behalf of the American Society of Landscape Architects (ASLA), I appreciate the opportunity to provide comments on the Board for Professional and Occupational Regulation's study of the continued need to regulate select professions, including landscape architecture.

Founded in 1899, ASLA is the professional association for landscape architects in the United States, with 49 Chapters representing the 50 states and U.S. territories. Landscape architects are design professionals licensed in 52 jurisdictions who plan and design community master plans, multimodal transportation corridors, parks and outdoor recreation spaces, water and stormwater management projects, and projects that help communities prepare for, and recover from the impacts of climate change and other natural disasters. Landscape architects are also stewards of the environment, which guides them to create these critical infrastructure projects in a manner that limits the negative impacts on the environment.

ASLA believes that the licensure of the practice of landscape architecture in every state, the District of Columbia, and U.S. territories is essential to protect public health, safety, and welfare. Licensure is a critical government function necessary to ensure the public's protection from unqualified or incompetent individuals who engage in professional practice. Reducing regulation or moving to voluntary certification of landscape architects in Virginia would increase the potential for public and environmental harm, increase costs to consumers, severely limit a landscape architect's ability to practice both in and out of Virginia, and reduce professional degree seeking students studying the profession in the State.

A substantial body of evidence proves landscape architecture significantly impacts the public in terms of potential for physical injury and property damage. A study of relevant cases includes the following:

• Poor stormwater design and management can and has resulted in excessive flooding causing severe property damage;
• Poor design and use of materials in parks and playgrounds can and has resulted in injuring and the death of children;
• Obstructed views at intersections can and has resulted in collisions killing and injuring pedestrians, cyclists, drivers, and passengers; and
• Inappropriate specification and supervision of grading can and has resulted in excessive fill, erosion problems, and even landslides.

For these reasons and many others, licensure is the appropriate form of regulation for the profession of landscape architecture. Regulating the profession under voluntary certification or other lesser forms of regulation does not ensure public health, safety, and welfare. Only state licensure can ensure that landscape architects fulfill education, supervised training, and examination requirements that prepare professionals to protect the public.

Professional licensing, as an indicator of qualification, is particularly critical in highly technical professions for which lay people do not have the specialized knowledge needed to evaluate qualifications and performance. O*NET's Job Zones classifies landscape architecture, along with architecture and civil engineering, under Job Zone Four: Considerable Preparation Needed, indicating the need, typically, for formal higher education and several years' experience to gain the ability to practice. Additionally, landscape architects are required to pass the four-part Landscape Architecture Registration Exam, which helps to ensure individuals have a basic knowledge of project and construction management, site design, inventory and analysis, and grading, drainage, and construction documentation, prior to beginning practice.

Reducing regulation or eliminating licensure will also negatively affect Virginia's consumers. Removing landscape architects from competition against architects and engineers will likely result in increased fees and decreased choices for public and private consumers. For projects requiring the seal of a licensed professional - "not a "voluntarily certified" individual - consumer choice will be reduced, and/or consumers may incur extra costs required to have another design professional seal the project.

Lesser forms of regulation would also cause financial harm to Virginia's landscape architecture firms, many of which are small businesses that provide much needed jobs and economic development to their communities. Outlined below are several key economic opportunities that would be lost:

• Licensing provides a way for consumers and clients to identify qualified individuals. Losing one of the primary ways to judge qualification would give out-of-state licensed landscape architect a competitive advantage over in-state non-licensed landscape architects.
• Without licensure, landscape architects would be at a competitive disadvantage or unable to compete for projects against architects and engineers.
• Landscape architects would not have the ability to practice significant portions of the scope of the profession including designs for grading and drainage, stormwater management, siting and layout of vehicular, bicycle, and pedestrian circulation systems, and site structures.
• Landscape architects could not compete for prime contracts awarded by municipal, state, or federal governments, because of the inability to stamp work.
• Landscape architects would be unable to become owners and principals of regulated design firms.
• Landscape architects would encounter limitations on professional liability insurance coverage.

Public and private clients increasingly insist upon retaining licensed professionals in order to reduce their risk and liability and to ensure projects are designed to function safely and meet desired outcomes. A 2019 national survey by Beneson Strategy Group indicated widespread public support for maintaining rigorous professional licensing standards for professions that have a clear impact on public health, safety, and welfare, including landscape architecture. The survey yielded these key findings.

• Seventy-five percent of voters believe that it is important to ensure qualifications for professions in certain industries. A majority of voters believe that current professional licensing requirements protect the public and should not be reformed.
• More than seventy percent of voters believe that regulating professionals in architecture, landscape architecture, engineering, accounting, and related fields with high impact on public safety and welfare is important.
• Seventy-one percent of voters believe professional licensing should be required unless it can be proven that eliminating licensing will not have a negative impact on public health and safety.

Landscape architecture impacts the life of Virginians and visitors to the state every day - from projects designed to manage stormwater, protect water quality, and address climate change, to planning and designs of hospital grounds, shopping centers, college campuses, parks, neighborhoods, riverfronts, and downtown streetscapes. These landscape architecture projects should be designed by qualified professionals proven to have met at least a minimum core competency in key areas that affect the public's health, safety, and welfare. For the protection of the public and economic well-being of Virginia's landscape architects, ASLA strongly urges the Board of Professional Occupational Regulation to support continued licensure of landscape architecture.