Dear DPOR: 

I am have been working in Virginia as a Professional Wetland Delineator (PWD) and Professional Wetland Scientist (PWS) since 2007.  Based on my extensive experience working in wetland delineation and ecology, I strongly support the continued regulation by the Commonwealth of Virginia of wetland delineators through the PWD program.  Although many PWD's also have a PWS, these two certifications are VERY different.  The PWS does not require knowledge of the practice of wetland delineation and does not go through the rigorous process to obtain the certification as does the PWD.  A PWS can be obtained by people solely based on references and education in all sorts of areas related to wetlands ecology – whereas a PWD is focused 100% on the skills needed to perform a wetlands delineation.  I have experienced MANY people obtain a PWS who have never delineated a wetland and have very little background knowledge of wetlands.  The PWS program even allows Rosgen stream classes as part of the continuing education requirements!  A wetland delineation requires extensive knowledge of current and prior federal and state regulations. The continued changing laws (e.g., the new Navigable Waters Protection Rule), regulations and manuals used to determine what a wetlands area is, and which are regulated points to a need to have this certification program. It also demonstrates that its rigor should be increased with continuing education requirements.  Thus, in my opinion, the PWD certification is a justified and necessary state certification.  If you have any further questions on this matter, please don't hesitate to contact me at seans@cri.biz.  

Thanks, 

Sean