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 wetland jurisdictional 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 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.

Additionally, VA DEQ has implemented the VSWD Certification with the prerequisite of being a CPWD to obtain. To remove the education, training, and supervision/references requirements from the CPWD would negatively affect not only the strength of the PWD program but also the VSWD program which relies on it. These certifications and the strength of them, based on the education, training, and supervision/references demonstrating adequate expertise, are honored in expedited processing of stream and wetland permitting state-wide within the DEQ VWP Program. The removal of these requirements would negatively affect both the effective processing of permit requests and the quality of work offered to the development community and citizens of the Commonwealth.