I have been a Certified Professional Wetland Delineator (PWD) in VA since 2006. I understand the Certification is in consideration to get eliminated based on the JLARC study. The study determined that the National Professional Wetlands Scientist Certification (PWS) is the same as the PWD and therefore there is no need to keep the PWD.

DPOR must understand the differences between both programs.

The PWS is very general in scope and a certified individual may have never had any experience or training specifically in conducting wetland delineations. Their background can be 100% research or academic. The PWD is focused 100% on skills and knowledge required in conducting wetland delineations.

The PWS does not keep current with any changes in state regulations and technical delineation method changes. The Federal and State rules that determine if a area is considered to be regulated as a jurisdictional wetland is based on the delineation. However, the jurisdictional requirements to be considered a water of the United States or State regulated waters are different. Thus, the National PWS does not consider the specific needs of the citizens of Virginia.

The PWD dose ensure all Virginia citizens that need delineation services that the risk in  error in the conducting the delineation is low, while National PWS Certification will not.

In conclusion I hope that DPOR will acknowledge the value of the PWD certification and that this certification is specific to wetland delineations which the PWS certification is not.

Please keep the Virginia Professional Wetland Delineator Certification.

Sincerely

Thomas Dombrowski, VAPWD

tdombrowski@pwcgov.org