Action | General Review of Regulations Governing Certified Professional Wetland Delineators |
Stage | NOIRA |
Comment Period | Ended on 12/8/2023 |
As a Professional Wetland Delineator, I strongly support retaining the current regulatory framework for the PWD Certification. The existing education, training, and supervision/references requirements were put in place as they are crucial to high quality delineations with proper application of criteria in determining jurisdictional wetland boundaries. The existing education, training, and supervision/references requirements were put in place as they are essential to ensure high quality wetland delineations with proper application of criteria in determining jurisdictional wetland boundaries. Prior to the Virginia PWD certification, there were occurrences of delineations being performed 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, reducing the risk and harm which can be caused by faulty delineation work. Reducing the certification requirements for PWDs will negatively impact the quality of delineations and ultimately, wetland permits, compensatory mitigation, accurate/true engineering plans, and site development in Virginia as a whole. The current educational, training, and experiential components of the PWD regulation are critical to assuring reliable and consistent identification of wetlands and waters and should be maintained in their current form.