I am a CPWD and support retaining the current regulations surrounding this certification. All the requirements for this certification are necessary for assuring that the delineations are being conducted correctly and consistent with the USACE and DEQ manuals and guidance.  If these requirements are removed it opens up the more risk for incorrect delineations which can lead to project delays and lawsuits and in turn wastes time and funds of government employees. The current educational, training, and experiential components of the CPWD regulation are critical to assuring reliable and consistent identification of State Surface Waters and should be maintained in their current form.