To whom it may concern,

The Commonwealth’s Professional Wetland Delineator (PWD) certification should not be repealed in favor of the Society of Wetland Scientists Professional Wetland Scientist (PWS) certification for a few reasons. Chiefly among them is that the PWS certification is not Virginia or even regionally-focused, it is more focused on academics and networking than actual application of the trade, and there is no examination to show that those with the credential are qualified to conduct wetland delineations within Virginia.

The PWD certification is bound by Virginia law, has a Virginia-based Board, and provides a framework for the resolution of grievances against those acting in poor faith or judgment. These are essential features of the PWD program that are not met by the PWS program. By obtaining the PWD certification, the qualification holder has shown that they are able to delineate wetlands effectively and accurately within Virginia. Should the PWS certification be adopted instead of the PWD program, it is possible that a PWS from Arizona who has never once set foot in Virginia would be considered qualified to conduct the work. This is clearly not a wanted outcome of any certification program.

Secondly, the credential requirements for the PWS program are more focused on “who you know” instead of “what you know.” For example, the PWS program requires two letters of recommendation from existing holders of the PWS certification. This limits qualification of this certification to those that work in companies where there are already large populations of PWS holders. I have been working in the wetland delineation field in Virginia for approximately 10-years and would struggle to find two PWS to provide references for me. This is not due to a lack of knowledge, skill, or qualification; I have been a certified PWD since 2016. Rather, this is because I work with a small team, of which none are PWS. The PWS program is too focused on who you know rather than what you know.

This is further exemplified in that the PWS program does not have a qualifying examination. This is a key component of the PWD program that would be lost should it be disbanded. The body of knowledge that the examination is based on is vetted through the appropriate Board, is updated as challenges arise in the field and knew knowledge is gained, and is by definition Virginia-specific. The disappearance of this examination could have drastic consequences on the quality of wetland delineations (and therefore, the health of the environment) within the Commonwealth.

In conclusion, I oppose the belief that the PWD and PWS programs are duplicative. Additionally, the potential elimination of the PWD program could have negative impacts on the environmental health of the Commonwealth.

Signed: Sean Gagnon, PWD #3402000156