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  6:13 pm
Commenter: Lee Mallonee

PWD qualifications

I began delineating wetlands in 1988 and still perform delineations which are reviewed and approved by the COE. In my 35+ years of working as a wetlands consultant I have been asked several times to go behind other consultants to review their work.  There have been many instances where the wetland boundary flagged in the field was incredibly inaccurate. Subsequent COE review confirmed that fact.

To reduce the minimum requirements for certification as a professional wetland delineator would be a disservice to the regulated community. In my opinion working with a certified wetland professional in the field is the best way for a beginner to learn.

A person who takes a  few classes and begins doing delineations is doing a disservice to the client. Consultant fees are not inexpensive and for a landowner to incur the expense of a delineation that is inaccurate is bad business. I have had clients tell me that their consultant had to re-delineate a  site two or three times before the COE would approve  the flagged wetland boundary.

The best way to protect the public interest  is to maintain the requirements as written.

CommentID: 220825