“[An] office is considered a piece of property, and government rather as a means of promoting individual interests than as an instrument created solely for the services of the people.”

-Andrew Jackson

How do consumers benefit from a title action?  answer, they don't

The mere act of calling one's self anything does not provide assurance to markets.  Consumers attempt to rationalize decisions within the market predicated upon a "backing" or "assurance" from state authorities.  When state authorities breach their social contract, consumers are burdened with the loss of their economic interest, and their governance.    

§Title 54. 1_2208 prohibits anyone from representing themselves "as a licensed soil scientist" unless "he has been so licensed by the Board".  This action in itself does not prevent unlicensed persons from "practicing", but rather restricts usage of the term "licensed soil scientist".  A title act is not synonymous with an act to practice.     

§Title 54. 1 _2208 Unlawful representation as a licensed soil scientist or certified wetland delineator

Exceptions

A. No person shall represent himself as a licensed professional soil scientist unless he has been so licensed by the Board. Any person practicing or offering to practice soil evaluation within the meaning of this chapter who, through verbal claim, sign, advertisement, or letterhead, represents himself as a licensed professional soil scientist without holding a license from the Board shall be guilty of a Class 1 misdemeanor.

Prior to the adoption of a license, the Board for Professional Soil Scientists, Wetland Professionals, and Geologists was required to update it's code to reflect Chapter 777 and Chapter 859 of the 2011 Acts of the General Assembly. 

§Title 54. 1 _2201 Exceptions, states the following:

1. The work of an employee or a subordinate of a licensed soil scientist;

2. The work of any professional engineer, landscape architect, or land surveyor as defined in § 54.1-400 in rendering any services that constitute the practice of soil evaluation; or

3. The practice of any profession or occupation that is regulated by another regulatory board within the Department.

C. Nothing in this chapter shall authorize an individual to engage in the practice of engineering, the practice of land surveying or the practice of landscape architecture, unless such individual is licensed or certified pursuant to Chapter 4 (§ 54.1-400 et seq.).

Reliance upon tenuous arguments for licensure reduces free markets to coin operated governments; such schemes or artifices have been routinely rejected by the Commonwealth.  Rapacious market participants necessitates consumers to obtain alternative solutions. 

Thank you for allowing me this opportunity to comment.

James B Slusser