I’m writing to express my strong support for retaining the Professional Wetland Delineator (PWD) certification.  Virginia has been one of the leading states to develop and implement this type of certification in an industry that lacks a national standard for completing this work.  I implore you to KEEP this certification for the following reasons:

1 – Due to the lack of a national certification, it separates those professionals who have demonstrated that they have the education and experience to provide these services to the general public, from those who do not.  I have witnessed other “professionals” who lack this certification submit incorrect delineations that do not follow the Army Corps of Engineer’s guidance.  Without the PWD certification, which is intended to provide a standard that the general public and regulatory agencies can rely on, it will be much more difficult to distinguish between those who have demonstrated a history of professionalism versus those who are unqualified to provide this highly technical work.  The result of these errors can include impacts to valuable environmental resources and state waters.  Work of poor quality can also create a burden on the Department of Environmental Quality who are already understaffed.

2 – The only national certification (the Professional Wetland Scientist certification) is not specific to wetland delineations.  In fact, there are many PWS certified professionals who have never completed a wetland delineation in their career.  These are two very different certifications and should not be considered equal.  Failure to retain the PWD certification provides no standard for this type of work.

3 – The laws and regulations pertaining to wetland and Waters of the US delineations and permitting is getting more and more complicated.  Most recently we are seeing the growing divide between the federal regulations and those of the State of Virginia.  These are highly technical laws that require a certain level of expertise to provide guidance to the general public.  It is the State’s responsibility, through DPOR regulations, to ensure that the general public are protected from those who are unqualified to perform certain services.  The PWD certification provides a clear distinction between those who have the experience to understand these regulations, and thus provide professional guidance to the general public, and those who do not.

In closing I ask that you KEEP the PWD certification.