As a Professional Wetland Scientist, I am in support of retaining the current regulatory framework for the PWD Certification. The existing education, training, and supervision/references requirements were put in place as they are critical to high quality delineations with proper application of criteria in determining jurisdictional wetland boundaries. 

The PWD program was initially put in place to protect the public from incorrect delineations that led to lawsuits, issues with wetland permits, etc. 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.