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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12/8/23  10:13 am
Commenter: James E. Irre, Passage Creek Environmental

PWD regulations change

Please do not make the proposed changes as they will render the PWD certification obsolete and no longer of any value to the regulated public.  People rely on this certification to be able to identify those who have the experience and expertise to correctly delineate surface waters subject to federal/state regulation on their affected properties in accordance with current regulations.  If you make the proposed changes there will be a sudden rush of applicants looking for this certification, many of whom will not have relevant experience and educational backgrounds for this field.  These changes will result in my 33 years of experience in this field moot and will make me a less valuable member of certified PWD's that serve the regulated public.  DEQ and the USACE can expect to see an increase in violations resulting from those who are not qualified, and who mis-identify conditions associated with correct delineation of jurisdictional surface waters.  The most important aspect of these delineations is the ability to properly identify vegetation at all times of the year.  Winter identification of vegetation can be especially difficult due to the absence of many of the characteristics visible during the growing season.  

Engineers, Landscape Architects, and others without relevant backgrounds should not be granted PWD status.  Their introduction into this profession will hurt the business model of qualified and practicing PWD's, making our services less valuable.

CommentID: 220765