To Whom it May Concern,

I am currently an active Professional Wetland Delineator (PWD) through the Commonwealth and a Professional Wetland Scientist (PWS) through the Society of Wetland Scientists (SWS). I strongly support the continued regulation by Virginia of PWD’s due to the lack of the PWS certification to adequately prepare a professional with the necessary tools or skills to conduct a wetland delineation. SWS acknowledges that there is a broad range of wetland science and relies on education and experience to obtain a certification. No examination to determine if you are competent in conducting delineations is necessary.  The Virginia PWD certification requires specific knowledge, skills, and abilities in the fields of wetland soils, wetland hydrology, wetland botany, and wetland regulation; and further, it requires the passing of a competency exam in addition to the 4 years of applied experience. These two certifications are NOT equal.

In addition, holding a PWD certification also provides a base point for local governments to adhere to when requiring plans that reference waters of the US and/or state waters. When you have qualified persons conducting valuable delineations, both the environment and any stakeholders are better off. Having a state regulated license ensures that the people of the Commonwealth are protected and have professionals that are bound by a code of ethics.

I also support the strengthening of the PWD program by requiring continuing education requirements to ensure that people remain on top of the everchanging environmental landscape.

Thank you for your consideration.

Alison Robinson, PWD, PWD