The existing education, training, and supervision/references requirements were put in place as they are essential to ensure high quality delineations with proper application of criteria in determining jurisdictional wetland boundaries.  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.  The PWD program provides the public needing delineation services with qualified professionals, helping to reduce the risk and harm which can be caused by improper delineation work.  Reducing the certification requirements for PWDs 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 PWD regulation are critical to assuring reliable and consistent identification of State Surface Waters and should be maintained in their current form.