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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11/22/23  7:31 am
Commenter: Mike Blake, PWD, Rappahannock Environmental Group

Reject the proposed changes to the PWD certification

I'm writing to urge you to reject the proposed changes to the PWD certification.  As many others have and will convey, these proposed changes gut the intent and purpose behind the PWD certification.  By removing and/or modifying the training, education, and experience requirements, this opens the door for unqualified individuals to obtain a certification that citizens, localities, and businesses across the Commonwealth have come to rely on for professional, and highly technical, guidance related to wetland and surface water protection.  If these changes were to be made, valuable environmental resources would be at risk of being inaccurately mapped and impacted due to the lack of professional understanding by those that are "certified" to perform the work.

There are very few states that offer this type of certification.  As such, Virginia has been and continues to be a leader within the United States with respect to environmental protection.  Many other states look to Virginia as a model for effective, common-sense regulations that protect environmental resources.  The PWD certification is one of those tools that the State of Virginia has used to protect these resources.  This certification protects unaware citizens, government entities, and businesses, who rely on professionals to provide highly technical services to protect their land and their interests.  The PWD certification communicates to these individuals and companies a level of understanding and professionalism that gives them a peace of mind that they are in good hands and will be protected.

I have personally witnessed uncertified, unskilled "environmental professionals" provide guidance and services that have resulted in impacts to streams and wetlands that could have been avoided had the owner used a professional with a PWD certification.  These mistakes resulted in unnecessary impacts to wetlands and streams, thousands of dollars spent to fix the mistake, and countless hours of time spent by DEQ staff to address the violation and mitigate for it.  By lowering the standards required to obtain the PWD certification, I can guarantee that more of these types of situations will occur.  In addition, it will cause additional strain on the already limited resources of DEQ and the Corps of Engineers.  It is imperative that the current education, training, and experience requirements for PWD certification REMAIN.

CommentID: 220701