I am in support of the current PWD program requirements and believe the proposed changes could have an overall negative effect on the industry in Virginia.

Education for a grasp of fundamental concepts, 32-hour training for learning appropriate application of the ‘87 Manual and Regional Supplements, and field experience for honing best professional judgement are the pillars of what constitutes a successful wetland delineator.

Wetland delineation experience does not necessarily transfer between regions, highlighted by the development of the Regional Supplements to the 87’ Manual for specific situations unique to those areas. The exam covers concepts reflecting that, and experience in wetland delineating between regions should not be interpreted as 1:1. Therefore, the PWD certification program should not be subject to Universal License Recognition.

The professional community in Virginia is strong and builds its integrity on the collective knowledge that has been gained through years of experience practicing in the field as well as navigating changes in the regulations and interpretations over jurisdiction of our aquatic resources. Removing the requirement to be endorsed by a current PWD holder and changes to the Standards of Practice and Code of Conduct could further threaten the integrity of the program.

The existing education, experience, and supervision/references requirements put in place as is ensure high quality delineations with proper application of criteria in determining wetland jurisdictional boundaries and should be maintained in the current form. Thank you.