Action | General Review of Regulations Governing Certified Professional Wetland Delineators |
Stage | NOIRA |
Comment Period | Ended on 12/8/2023 |
The current PWD education, experience, and testing requirements provide sufficient verification of a wetland scientist's ability to accurately identify and field-delineate wetlands. With periodic "Waters of the US" changes due to changes in federal and state administrations, such expertise is valuable to the regulated community and helps ensure protection of these important natural resources. An unfortunate reality is that wetland scientists working for small firms may be at a disadvantage if no other PWD's are employed by the same firms. We in the regulated community should take the initiative to better mentor newer/younger scientists from companies other than our own. I understand the need to reduce experience requirements to three years, and believe that this should not have a significant negative impact to the quality and value of the PWD program, as long as the majority of an applicant's actual workload during those years remains wetland-specific. I am not in favor of other changes to the current PWD certification program. Thank you for this opportunity to provide comments.