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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12/6/23  10:08 am
Commenter: Jennifer Van Houten, Davey Mitigation

Not in support

I do not support the proposed changes to the regulations of Certified Professional Wetland Delineators (PWD) by the Commonwealth of Virginia's Department of Professional and Occupational Regulation (DPOR).  The Universal License Recognition legislation mandates that the number o years of experience that a PWD applicant must show to demonstrate their experience be 3 years, I strongly disagree that 3 years of experience is sufficient to demonstrate a PWD's competency.  The "years of experience" change should end.  The skills needed to effectively delineate wetlands cannot be gained in three years without additional background education and training. Now that the number of years of experience required must be reduced to 3 years, it becomes critical that the requirements for a degree in a natural or environmental science remain in place and the requirement for having taken a basic wetland delineation training course be left in the regulations.  This should not be viewed as being more restrictive of out of state applicants because college degrees in environmental sciences and wetland delineation training classes are widely available throughout the country.  The PWD certification is necessary for the Commonwealth of Virginia because it protects the public from inadequate delineations, avoids costly errors in development, reduces permitting backlog for regulators, and ensures protection of wetland resources and the Virginia economy.  The integrity of the program is highly dependent on the qualifications of individuals that are certified PWDs.  There are no other certification programs that can provide assurances of competency to perform this work.  I urge the DPOR to acknowledge the value of the PWD and recommend the retention of existing educational requirements for course hours, the 32-hour delineation course, mentorship, and oversight by existing PWD's of applicants and of the Virginia Professional Wetland Delineator Certification.  Thank you for your consideration of these comments.

CommentID: 220727