I DO NOT SUPPORT the proposed changes to the regulations for Certified Professional Wetland Delineators (PWD) by the Commonwealth of Virginia’s Department of Professional and Occupational Regulation (DPOR).  The existing educational, training, and experience requirements were put in place to ensure high-quality, accurate wetland delineations.  A wetland delineation is often conducted as a first step in the due diligence process because this critical information determines how much land is available for development, the price of that land, the types of permits that would be required, and the length of time required to obtain those permits.  In my over 20 years as an environmental consultant working for both public and private sector clients and on projects of various scopes and degrees of complexity, there has been one common refrain from the folks who build Virginia’ infrastructure: the need for a predictable, low-risk environmental permitting process.  Prior to the PWD certification, there were occurrences of delineations being performed in Virginia by unqualified individuals, resulting in permitting issues and lawsuits against regulatory authorities, individuals performing the delinquent work, and the contractors and builders who were ultimately liable for permit compliance.  Getting this wrong can have significant economic impacts and is not good for growing Virginia’s economy.  The PWD program provides the regulated public with qualified professionals, helping to reduce the risk and harms which can be caused by improper delineation work. Reducing the certification requirements for PWDs could negatively impact the quality of delineations and ultimately, wetland permits, compensatory mitigation, accurate/true engineering plans, and site development in the Commonwealth as a whole. The current educational, training, and experiential components of the PWD regulation are critical to assuring reliable and consistent identification of State Surface Waters and should be maintained in their current form.