I would like to provide the following comments in support of retaining the Wetland Delineators Certification Regulations [18VAC 145-30]:

• The Wetland Delineators Certification is the only state program that provides minimal competency certification for wetland delineators, giving protection to consumers and providing standing to those that have achieved the certification.
• The Wetland Delineators Certification promotes an ethical standard for practitioners in the field.  In a time where truth has become relevant, such ethical standards are worth retaining and promoting.
• While there is a national-level certification (Professional Wetland Scientist), the program is not specific to wetland delineations, does not involve a test, does not certify minimal competency, and does not certify the knowledge necessary to work with Virginia’s specific non-tidal wetland regulations (under DEQ), and tidal wetland regulations (under MRC).  Promoting a national standard over the state standard would dilute the importance of these regulations for state practitioners.
• Continued changes to federal regulations regarding Waters of the U.S. point to a stronger need for individuals that understand the regulations and can thus provide clarity for the regulated public.
• A 2019 national survey conducted by the Benenson Strategy Group found that “75% of voters believe it is important to ensure qualifications for professionals in certain industries. And a majority of voters believe current professional licensing requirements protect the public and should not be reformed…They are deeply concerned by overbroad licensing reform that would jeopardize licensing standards for highly complex, technical professions.”[1]  Wetland delineation fits squarely into this category.
• Recently (June 22, 2020), the Federal Government changed its regulations that determine which Waters of the US, which include wetlands, are regulated by the Federal Government.  These regulations are such that now wetlands and waters regulated by the Federal Government will, in many cases, be different than what the Commonwealth of Virginia regulates. Therefore no national level certification program could capture the specific needs of the citizens of our Commonwealth.

Additionally, I request consideration of the following amendments to the Regulations:

• Strengthen the regulations to require that all wetland delineations in Virginia be certified by a Professional Wetland Delineator, similar to plans prepared by Professional Engineers, Landscape Architects, and Licensed Surveyors.  Doing so would provide further protections to the public while strengthening businesses in Virginia by reducing competition from firms outside the state that are less likely to pursue such certifications (at least for a time).
• Continue to strengthen the ethical standards for Professional Wetland Delineators such that they mirror those found for Professional Engineers, Landscape Architects, and Licensed Surveyors.  See 18VAC10-20-740.  Doing so will provide additional protections to both consumers and regulants.
• Finally, improve the regulations by requiring continuing education for all certified Professional Wetland Delineators.  Doing so would promote the highest standard for regulants and continue to provide regulants that the public can trust for work that is accurate and dependable.

Thank you for your consideration of these comments.  Please feel free to contact me with any questions or for additional clarification