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  10:36 am
Commenter: Douglas A. DeBerry, PhD, PWD

STRONGLY OPPOSE proposed changes to the PWD regulations

I STRONGLY OPPOSE the proposed changes to the Professional Wetland Delineator (PWD) certification regulations.  I am a licensed PWD and have been an active participant in the development of the program since its inception.  Many of my colleagues have already commented on the importance of the PWD certification to the Commonwealth (to which I categorically concur), so I will focus specifically on the qualifications aspect of the program.

Of the current application requirements, the most important and relevant factor that the program has to adjudicate professional qualifications is the experience requirement.  The reason for this is that the practice of wetland delineation is decidedly experiential – it is not a discipline that one can successfully and competently engage in without time spent “in the field.”  The interdisciplinary nature of the practice requires that delineators be proficient in multiple domains of science, for example, ecology, hydrologic processes, botany, soil science and geology, and atmospheric sciences to name a few.  One would be hard-pressed to find another profession within the DPOR certification portfolio that engages so many different disciplines toward a common occupational objective.  When viewed through the lens of wetland delineation practice, exercising these overlapping proficiencies becomes an extremely nuanced enterprise because the conditions change from site to site.  Put simply: there is no substitute for field experience in wetland delineation, and the PWD certification program has no other way to validate a delineator’s level of preparedness than to observe a minimum standard of multiple years in the field.  Removing this requirement will severely diminish the PWD program.

As noted above, the interdisciplinary nature of wetland delineation demands that practitioners develop proficiency in several different fields.  While it is unrealistic to expect a PWD applicant to hold degrees in each one of these disciplines, having a degree in at least one related field ensures that an applicant has engaged in a course of study that sets a pedagogical foundation for the acquisition of new knowledge.  In other words, a qualified wetland delineator has to know how to learn, and the PWD certification program has no other way to evaluate this aspect of an applicant’s background than the education requirement.  As with the experience requirement, removing the education requirement will weaken the program.

On the last point, I’ll just mention that the current 32-hour professional development course requirement serves an important function in that it ensures that a PWD applicant has had at least one structured experience where all facets of the practice have been synthesized.  In my experience, this serves to galvanize wetland delineators to continue sharpening their skills and, at a minimum, it bears witness to the fact that applicants have been exposed to a delineation-specific curriculum.  This requirement should remain in the regulations: continuing education requirements represent a standard-of-practice for many other types of professional certifications, and by comparison the PWD requirement is minor – especially given the large benefit it provides to the program.

On behalf of my colleagues in the profession, I want to thank DPOR for the hard work being done on a day-to-day basis to ensure that Virginia’s professionals are qualified to do good work in the Commonwealth.  We have the best wetland delineators in the country, and the PWD program has been one of the most important factors in maintaining that standard.  I encourage DPOR to continue that institution of excellence by rejecting and/or modifying the proposed changes to the PWD regulations.  With respect to wetland delineation, we are a truly a model for all other states – let’s keep that tradition intact.

CommentID: 220771