As an individual who has three years of experience as an environmental scientist, I am in strong support of continuing the regulation of the Professional Wetland Delineator (PWD) Certification in Virginia.  I have obtained my Wetland Professional in Training (WPIT) certification and I am working on gaining the experience and knowledge to earn a PWD certification. To earn the PWD certification, it takes 4-6 years of practicing wetland delineations in the field and education in biology related to wetland science. This experience and knowledge needed to obtain a PWD certification will prepare me to perform wetland delineations properly 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.

• Inaccurate wetland delineations performed by unqualified professionals can be costly to the permittee and delay permit applications and can also cause loss of valuable ecosystem and lack of protection of water resources within the Commonwealth of Virginia.
• There are no federal wetland delineator certifications or equivalent certifications, therefore it is important that Virginia continues the PWD certification program to ensure individuals are competent in preforming wetland delineations in accordance to Virginia and federal regulations.
• 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. 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.
• As the Waters of the U.S. (WOTUS) rule changes throughout the years, it is imperative that qualified professionals with expertise in the delineation of tidal and non-tidal wetlands in Virginia perform this work. The U.S. Army Corps of Engineers currently does not confirm boundaries or permit impacts to ephemeral streams and isolated waters; however, the commonwealth of Virginia regulates and requires permits for impacts of these waters.
• Furthermore, it is essential to have individuals who are qualified to accurately identify wetlands, reduce inaccurate permitting, delays, and costs, and to preserve 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. An individual can receive the PWS certification without preforming wetland delineations and without reading and understanding the U.S. Army Corps of Engineers 1987 Delineation Manual or subsequent regional supplements. Therefore, the PWS certification is not equivalent to the PWD, and does not provide the skills and experience needed to conduct accurate wetland delineations or the proper understanding of Federal and Virginia regulations.

Thank you,

Janelle Bernosky, WPIT