MSA, P.C. is a multidisciplinary firm providing civil engineering, survey, planning and environmental services. I have been the only wetland scientist at MSA for many years.  I am a 10 year professional with somewhere north of 80 delineations with Corps confirmations, dozens of wetland permits, several mitigation projects and violation case resolutions in my portfolio.  I am very qualified to obtain a PWD certification, and am interested in doing so.

To obtain my PWD, I need a PWD as a reference in my application.  Again, I am the only wetland scientist at MSA, I have never worked with, for or under a PWD, however, my record is very strong in this field.  The only PWD's in this area are all competitors of mine, and cannot serve as a reference for two reasons:

1) they have no knowledge of my work experience, projects, or professional record (and as such could not serve as references).  As competitors, I make certain they continue to have no knowledge of my work.

2) They would have no professional benefit in certifying me, which would simply make me more effective as a competitor to them.

Without that reference, unless DPOR is willing to make exception to that requirement, I cannot obtain my PWD certification. Would it be possible to make exception to the requirement to have a PWD as reference?  For instance, having Corps project managers as reference? Or those certified by Society of Wetland Scientists (PWS certification)? 

Thanks for allowing me to comment on this matter.

Brian Owen, Wetland Scientist, MSA, P.C.