I am writing in SUPPORT of continued regulation of the Certified Professional Wetland Delineator (PWD) by the Commonwealth of Virginia’s Department of Professional and Occupational Regulation (DPOR). I am both a Professional Wetland Delineator (PWD) and a Professional Wetland Scientist (PWS) and have been working with wetlands in the Commonwealth of Virginia for nearly 20 years. 

Having a thorough understanding of both the PWD and PWS certification programs, I must say that JLARC is incorrect in their assessment of the two certifications.  They are not equivalent; there is a clear difference between a certified PWS professional and the PWD license. 

The PWS certification, while it has value, is much more broad and is not focused strictly on wetland delineation, but rather the science of wetland resources worldwide.  In fact, an individual can receive this certification without ever having performed a wetland delineation.  As stated on the Society of Wetland Scientists Professional Certification Program website:

The Society of Wetland Scientists Professional Certification Program, serving the public's need to identify qualified individuals to assess and manage wetland resources around the world. This program is intended to meet the needs of professional ecologists, hydrologists, soil scientists, educators, agency professionals, consultants, and others who practice wetland science.

The PWD certification on the other hand focuses strictly on the delineation of wetlands and other waters in the Commonwealth of Virginia. The PWD, not the PWS, certifies the competency and knowledge necessary to accurately delineate such features, as well as the understanding of Virginia’s tidal and non-tidal wetland regulations.  Therefore, in order to protect Virginia’s water resources and the public from poor and inadequate delineations and errors from unqualified individuals, I ask that the PWD certification remain in existence given that it is an integral component necessary to protect the Commonwealth’s resources, the wetland permitting process, and its citizens. 

Furthermore, with recent changes to regulations pertaining to wetlands and other Waters of the U.S. (WOTUS) at the federal level, there will be many instances where wetlands and waters are regulated differently than how they are at the state level. As a result, there is no national level certification program that could capture the specific needs of the citizens of our Commonwealth.

In summary, it is imperative that Virginia regulates its wetland delineators because of laws and regulations that are specific to the Commonwealth.  DPOR needs to make a PWD a requirement for anyone practicing wetland delineations in the Commonwealth of Virginia, just like it has for other professional certifications such as PE, LS, etc.  The growing complexity of this professional practice, coupled with continual regulatory change, simply begs for a mandatory PWD program with continuing education requirements.

Thank you for your attention in the matter,

Amy Connelly, PWD, PWS