Virginia Regulatory Town Hall
Agency
Department of Professional and Occupational Regulation
 
Board
Board for Professional Soil Scientists, Wetland Professionals, and Geologists
 
chapter
Regulations Governing Certified Professional Wetland Delineators [18 VAC 145 ‑ 30]
Action General Review of Regulations Governing Certified Professional Wetland Delineators
Stage NOIRA
Comment Period Ended on 12/8/2023
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12/8/23  4:05 pm
Commenter: Professional

In agreement with the previous comment
 

"Seeing other commenters talking about how the PWD program protects the public from bad delineations yet, in my experience most delineations are completed by people without the PWD and less than 3 years experience in the field. These are often not field verified by those with a PWD either. So as it currently stands, the PWD is not protecting the public from anything. 

 

The new changes will not protect the public from poor work either. As the state cannot require delineations to be submitted by a PWD (only make the permitting process faster), tons of delineations will be submitted by non-certified delineators and will be approved by DEQ because DEQ does not have reviewers with strong backgrounds in wetland delineation. 

 

The PWD is a great concept and I wish it would actually mean something. But unless having a PWD is required to submit a delineation for review, all it will ever be is a fancy title that holds no real power behind it. 

 

Also DEQ needs people with stronger wetland backgrounds before they can judge the work of others. "

CommentID: 220815