Virginia Regulatory Town Hall
Department of Professional and Occupational Regulation
Board for Professional Soil Scientists, Wetland Professionals, and Geologists
Regulations Governing Certified Professional Wetland Delineators [18 VAC 145 ‑ 30]
Action General Review of Regulations Governing Certified Professional Wetland Delineators
Comment Period Ended on 12/8/2023
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11/21/23  8:46 am
Commenter: Robert Wright, Sr. Assoc Reg. Specialist, WSSI

The Integrity of the Virginia PWD Process & Program

To all Board Members:

Increasing pressure is being exerted to irreparably alter the existing Virginia PWD process and program.  The new Universal License Recognition legislation as being applied in this action is not an answer to ensure fair and appropriate professional licensure and changes to licenses that come with a huge amount of responsibility and liability (i.e., wetland delineation) are not being appreciated nor recognized for the applied science application that has been successful to date without regulatory tinkering. A licensed person from another state (very few of those programs) cannot simply waltz into VA and take up their craft without experience and boots on the ground here. The existing program requirements are not onerous or even contentious. The current educational, training and experiential parts of the PWD regulations are critical to assure reliability to the regulated public, and to remain full consistent with the DEQ's new State Surface Waters requirements that align 100% with the PWD.  The Board must reject these proposed changes to protect professionals who operate in 9 VAC 25-210 and the ever-changing federal Clean Water Act.  The current proposal does NOT reduce risks in proportion to the added existing benefits of a demonstrably successful regulatory licensure system in VA. The proposed action does nothing but reduce quality control and increase risks. I urge you all to reject proposed changes. 

CommentID: 220669