Generally, I support maintaining high standards for PWD certification to promote exceptionalism in the profession. However, there is one change I would support, likely influenced by my location in the Commonwealth. I support eliminating PWD as one of the three required references for certification. 

Currently, we are preparing for our PWD exam scheduled for fall 2024. However, securing a PWD reference has proven challenging. We have clients who are P.E.'s and P.G.'s, willing to vouch for our skills and abilities in preparing JD's and 404/VWPPs over the last 20+ years. Unfortunately, this doesn't align with the current requirements. PWDs appear to be scarce in our region (Wytheville, VA and west).

Our location is in far southwest Virginia, specifically Abingdon/Bristol, with many clients in the Cumberland Plateau where streams, rather than wetlands, are the primary concern. It is my opinion that due to the focus on streams in our region, DEQ never promoted the PWD in our area until 2023. While we are keen on becoming PWDs and upholding high professional standards, we have concerns about the reference requirements acting as a barrier to entry, especially in our rural part of the Commonwealth, where existing certified PWDs appear to be few.