Proposed changes to the regulations of Certified Professional Wetland Delineators will not benefit the public. The skills used to competently perform wetland delineations over a spectrum of field sites with diverse physiography are not gained in three brief years of exposure; competence in this field develops with many years of technical field experience, training and collaboration. Additionally, the Virginia State Waters Delineator certification is predicated on the technical competency and experience assured by the current PWD standards and will be jeopardized by weakening of those standards. I urge DPOR to acknowledge the value and reasons for the current PWD standards and to uphold the current requirements for this professional certification.