I am writing in support of continued regulation of Professional Wetland Delineators.   I am a PWD and a PWS and have been working with wetlands since the mid-1980's, before there was a wetland delineation manual.  Once the Corps of Engineers' 1987 Manual was published we finally all had an approach to follow, but it was very obvious in those early days that there was a great range of delineation expertise (or lack thereof) in folks applying the manual.  The Corps proposed a pilot delineator certification program in 1994 that involved a written exam and field practicum.   I passed both and was certified under that program, but less than 40% of the folks that applied for the certification passed both tests.  The program was never implemented and the PWD program in Virginia filled a role left by the lack of a Federal program.

The PWS certification is not an equivalent, as it only requires experience and recommendations, and is not specific to delineation.  Our firm strongly encourages professional certification and indeed we have many individuals working in the regulatory or restoration/ mitigation fields that have their PWS, but are not wetland delineators.

The complexity and continually changing laws, regulations and manuals--what is a wetland and how is it regulated-- confirms the need for a delineator certification program.  I would go a step further and recommend that the program should include continuing education requirements.

Lastly, under the current Navigable Waters Protection Rule, many areas that were federal jurisdictional wetlands are no longer regulated at the Federal level, though they are still regulated in Virginia--thus a federal program like the PWS certification does not address the needs of wetland delineation in Virginia.

I appreciate the opportunity to provide these comments and strongly recommend retaining the PWD program in Virginia.  Further, we should consider continuing education requirements and explore the idea of making it a mandatory certification for the practice of wetland delineation in Virginia.

Mark Headly, PWD, PWS