To Whom it May Concern:

I am writing in support of the Professional Wetland Delineator (PWD) certification currently offered by the State of Virginia’s Board of Professional and Occupational Regulations (DPOR).  I obtained my PWD certification in 2011 by successfully passing the PWD certification exam.  I, like many in my field, did not work for a large, corporate firm that had numerous wetland professionals on staff.  Instead, I was hired to start an environmental division within a small, local engineering firm.  One of the reasons stated for removing the PWD certification program is the presence of a national certification program already in existence.  However, based on the requirements of that program, I was ineligible to obtain that certification because I did not know other PWS professionals who could vouch for me.  I had a degree in Environmental Science from the University of Mary Washington, had completed the 36 hour course in wetland delineation methods, attended numerous trainings and seminars to increase my knowledge and understanding, and had been practicing delineations for 5 years using the Corp’s technical guidance, but was still ineligible.  So I was thankful for the opportunity that DPOR provided that allowed me to apply without having trained under another PWD.  This allowed me to obtain a certification that I was qualified for and had worked hard to obtain.  I had obtained many delineation approvals from Army Corps of Engineer (USACE) staff who gladly vouched for me and my experience performing delineations.  I was in a situation that the creators of the certification had anticipated and planned for, and I was grateful. 

One of the primary reasons that this certification should be kept is that it is specific to the State of Virginia and the performance of delineations in our state.  As others have discussed, the PWS certification can be obtained by a wide range of professionals that are not specific to the practice of wetland delineations.   A PWS certification can be obtained without ever having performed a delineation.  Clearly this should not be used to replace a certification that is specifically tailored to the practice of performing delineations.  Having a license to practice medicine does not make a heart surgeon a good brain surgeon.  There are highly technical distinctions within the field of wetland science that must be taken into account when making this decision. The PWD certification and exam is specifically tailored for the practice of wetland delineations for the wide range of conditions found within Virginia.  This is a matter of public health and safety as the protection of natural resources is critical to protecting the resources that many Virginians use on a daily basis.  Wetlands play a key role in protecting our streams and rivers and it is vital that the public knows that qualified professionals are performing this work.  The PWD certification is the only true standard for which wetland delineations can be performed by a professional in Virginia. 

Case in point, I was recently made aware of a firm that had a staff person perform a delineation and submit it to the USACE for review.  However, this staff person was incredibly inexperienced and uncomfortable performing the work.  The individual was new to the firm and, as the only environmental professional on staff (whose specialty was not in wetland delineations), was told by her superior to put wetland flags in the same location as the previous delineation that had been performed over 15 years ago by another firm.  This site was over 40 acres in size and had wetlands and streams located on it.  The work was completed and submitted to the USACE for verification.  Thankfully, the USACE representative recognized the work did not meet the standards and required additional field work and evidence of the wetland boundaries.  While the PWD certification is not required to perform delineations, my concern is that by removing this standard, more of the practices described above will become commonplace.  By equating the PWS certification with the PWD certification, others will be encouraged to take a similar approach by employing, or hiring as a consultant, unqualified individuals to perform this highly technical work.  It is unfair and dangerous to rely on USACE staff to try and identify those who are unqualified.  And it is certainly not in the best interests of the State of Virginia and general public to rely on this method.  It sends the wrong message and will be abused.  By having this certification, that is overseen by a board of professionals, it sends a clear message that this practice is critically important and should be performed by skilled, qualified individuals.

Finally, as I stated previously, I was ineligible for a PWS certification, despite having focused a significant amount of time and energy on the practice of wetland delineations.  By not having the proper connections, I would have been excluded from obtaining this certification, while others who have no experience performing delineations would be considered qualified simply because they had a PWS certification.  This false equivalency will leave qualified professionals like myself without an option and will allow unqualified individuals an open door to provide services in an area they are unfamiliar with, leading to situations like I previously described.  But unlike the previous example, it will be done with your blessing.

In closing, I urge you not to throw away a first of its kind certification program.  The program established in the State of Virginia has been used by other states who are interested in creating their own programs.  With concerns over climate change and the need to provide further protection to our critical natural resources, it sends the wrong message to eliminate this certification.  Many of my fellow PWD professionals urge you to keep this certification and protect the wetlands that are a critical component of our ecosystem. 

Thank you for your consideration.

Michael W. Blake, PWD

Director of Environmental Services,

Sullivan, Donahoe & Ingalls, P.C.

10720 Columbia Drive

Fredericksburg, Virginia 22408