I do not support the proposed reduction in education requirements for certification as a Professional Wetland Delineator (PWD).  Neither do I support the reduction in the years experience required, but as that has been done legislatively, it makes no sense to reduce the education requirements as well.  I support keeping the requirements for a degree in natural or environmental science as well as successfully completing a 32-hour course in wetland delineation.  The practice of wetland delineation requires knowledge of plants, soils and hydrology and how they are applied in the delineation process.  The 32-hour course in delineation methods is an essential component of one's training and development as a competent practitioner.  

Further, with recent changes to the jurisdictional reach of the federal government, the Virginia Department of Environmental Quality (DEQ) has taken on a greater role in the regulation of the State's waters, including wetlands. DEQ has instituted a new State Surface Waters Delineator certification, which requires a PWD certification before one can take and pass a class in stream identification.  Individuals who have obtained both are granted the new DEQ certification and delineations performed by those Virginia State Waters Delineators are assured an expedited review in the DEQ permitting process.

As a long time PWD, and a recent SSWD, I urge DPOR to acknowledge the value of the PWD and recommend the retention of the existing educational requirements and course hours.

Thank you for your consideration of these comments.