The strength of the PWD certification is that it is not an easy certification to get without taking the test, references, having the experience and technical training.  It does vary from the Professional Wetland Scientist (PWS) which is a nationally recognized certification through SWS.  The PWS does not require a test on the subject, only experience, training and references.  There are many PWS that may work with wetlands or study them but do not conduct wetland delineations.  The PWD is geared specifically toward professionals who regularly complete wetland delineations.  The test is important for the certification because it makes sure the professional knows wetland regulations and delineation concepts thoroughly.  The changes to the years of experience to get the PWD is concerning.  As a wetland professional who has trained multiple people how to delineate from them coming to us with no experience, it takes years to get the concepts of wetland delineation and be able to apply them correctly.  This is especially true in Tidewater Area of Virginia where the delineations are marginal and difficult.  A certified individual should have enough experience to make difficult calls on their own.  In the same regard, the specific course work in college and training requirements changes weaken the certification allowing people without the proper training to apply for the certification.  Professional references are important to make sure certified individuals are knowledgeable and professional.  

The State of Virginia wetland program recently introduced the Virginia State Waters Delineator program (VSWD).  When getting confirmations from the State (SSWD), VSWD holders get some advantages such as review within 30 days and less sites having site visits.  The State is relying on people with this license to keep their confirmation process moving smoothly.  A PWD certification is a prerequisite to the VSWD.  Weaking the PWD certification also weakens the VSWD certification.  With the State's limited staff to review every SSWD request, they are depending on competent wetland professionals to be conducting accurate wetland delineations.

Please reconsider prerequisites changes for the PWD certification.