Prior to requiring CWPD, delineations were being performed by unqualified individuals that were resulting in permitting issues and resulting in lawsuits against both the regulatory authorities and the consultants who perform the flawed work.  Professional wetland delineators must possess skills and technical competencies in four separate wetland areas of technical expertise - botany, soil science, hydrology, and the Virginia tidal wetland definition.  Additionally, knowledge of statewide and local regulations is a required and tested portion towards obtaining a CWPD.  No national certification exists that requires competencies in all of those areas.  There is a false equivalency assumption that the "national" PWS certification is equivalent and provides state assurances that the Virginia CWPD certification provides.