As a holder of a PWD certification, it greatly worries me that it is being considered to reduce the thresholds of qualification for acquiring a PWD. 

The current educational, training, and experiential components of the CPWD regulation are critical to demonstrating the competence of the holder of such a license to perform reliable and consistent identification of State Surface Waters.   Reducing the certification requirements for CPWDs will allow minimally qualified persons to acquire this license, cheapening its value, and ultimately negating its purpose.   Please keep the educational, experience and qualification requirements in their current form to maintain the strength and value of this certification.