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  9:21 am
Commenter: tsavage

18VAC145 proposed changes, please don't

Revisions to the existing prerequisites as set forth in the amended changes would dismantle the purpose of having a PWD program in the first place. If anything, the existing perquisites are subpar. Further, other states have varying degrees of professionalism in this field and knowledge in western or midwestern wetlands does not translate to competence in the mid-Atlantic. States have significant differences in the scope of their regulatory authority. A practitioner must need focus on a geographic area for years to become a competent delineator. Extending imaginary expertise to those working in other regions of the country simply because it is expedient for larger corporations or entities is sure to degrade the quality of the current practice. Prior to the PWD certification, there were occurrences of delineations being performed in Virginia by unqualified individuals, resulting in permitting issues and lawsuits against both the regulatory authorities and the individuals performing delinquent work. This will certainly increase in frequency.  The PWD program provides the public needing delineation services with qualified professionals, helping to reduce the risk and harms which can be caused by improper delineation work. Reducing the certification requirements for CPWDs could negatively impact the quality of delineations and ultimately, wetland permits, compensatory mitigation, accurate/true engineering plans, and site development in the Commonwealth as a whole. 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 or require an even more stringent admission process. 

CommentID: 220676