To Whom It May Concern:

I would like to voice my support in continued regulation of the Professional Wetland Delineator (PWD) Certification in Virginia.  I obtained my PWD in August of 2020. I have spent years practicing wetland delineations in the field, and prepared for my exam by studying materials necessary to perform wetland delineations for many months. I can confidently say that the PWD certification has prepared me more than ever to perform wetland delineations confidently, correctly and in accordance with the U.S. Army Corps of Engineers 1987 Delineation Manual, subsequent Regional Supplements, and state regulations, including those applicable to tidal and non-tidal areas.

The unregulated practice of the occupation can harm public health, safety or welfare.

• Wetland delineations performed by unqualified professionals can cause permitting issues, lawsuits, and environmental issues. Through working with a PWD, stakeholders can expect the highest level of professional conduct, proficiency in delineating, and knowledge of Virginia’s wetland ecology and regulations. In addition, poor wetland delineations performed by unqualified professionals can lead to loss of wetlands, increased wildlife habitat degradation and habitat loss, increased risk of flooding, and degraded water quality.  
• The PWD certification differs greatly from the Professional Wetland Scientist (PWS) Certification provided by the Society of Wetland Scientists (SWS). The PWS certification requirements on the SWS website states that “Wetland Scientists will have an extremely broad range of technical specialties” – this can include 5 years’ experience of data analysis, which, combined with education, will qualify an applicant to receive the PWS certification. In order to qualify to sit for the PWD exam, applications must have an education in biology related to wetland science, completed a comprehensive wetland delineation training course, and 4-6 years field experience in delineating wetlands in Virginia. When comparing the two certification requirements, a PWS may never have delineated a wetland, and certainly may not possess the skills and knowledge to delineate tidal and non-tidal wetlands in Virginia, or have familiarity with Virginia’s regulations regarding these waters.

The public needs and will benefit from state assurances of competency.

• The public and state of Virginia benefits from the assurances of the PWD certification because the Virginia Department of Environmental Quality regulates and permits wetland impacts, in addition to the U.S. Army Corps of Engineers.
• With recent changes in the Waters of the U.S. (WOTUS) rule, it is even more imperative that qualified professionals with expertise in the delineation of tidal and non-tidal wetlands in Virginia perform this work. Under the recent WOTUS rule change, ephemeral streams (i.e., streams with flow after storm events), and wetlands that are separated by uplands from downstream Traditionally Navigable Waters are now excluded. Although these are excluded at the federal level, the Virginia Department of Environmental Quality still regulates these waters at a state level.
• Furthermore, now more than ever, the Virginia Department of Environmental Quality can rely on PWD’s to provide accurate, reliable delineations that are in accordance with their professional code of conduct. These determinations at the state level play a role in preserving the integrity of our state waters and the Chesapeake Bay.

The public is not protected by other means.

• There are no certification programs aside from the PWD which can provide assurances of competency in the practice of wetland delineation and knowledge of state regulations and permitting in Virginia. The PWS certification does not require competency in areas that PWD’s are well-versed in and have studied throughout their careers - botany, soil, hydrology and Virginia regulations. Furthermore, all wetland delineators in Virginia should be required to have the PWD certification to ensure delineations are performed correctly by qualified professionals in accordance with federal and state regulations.

Thank you,

Alexi Weber, PWD