I am a Professional Wetland Scientist (PWS) and a Professional Wetland Delineator (PWD) – and thus have intimate knowledge of these regulatory programs and the field skills necessary to perform wetland delineations.  I currently serve on the Society of Wetland Scientists' Professional Certification Review Panel.  I was appointed to the original Board of Wetland Professionals by then-Gov. Mark Warner, and subsequently re-appointed by then-Gov. Tim Kaine.  I served on the first subject matter expert panel to develop DPOR's first exam for wetland delineators.  

I strongly support the continued regulation by the Commonwealth of Virginia of Professional Wetland Delineators for four significant reasons:

1. The JLARC study based its decision on factually incorrect information – a PWS certification is not like a PWD Certification, though educational requirements are similar.  A PWS can be obtained by people solely based on references and education in all sorts of areas related to wetlands ecology; whereas, a PWD is focused 100% on the specific skills needed to perform a wetlands delineation.  A PWS does not even need to have such field skills for wetland delineation.  If a PWS has wetland delineation experience, the PWS certification does not require a test for wetland delineation field skills.  The critical distinction is that the Commonwealth's PWD program tests the field skills necessary to perform accurate wetland delineations.
2. The continued changing laws, regulations and manuals used to determine what a wetlands area is, and which are regulated – again points to a need to have this certification program. It also demonstrates that its rigor should be increased with continuing education requirements.
3. Recently (June 22, 2020), the Federal Government changed its regulations that determine which Waters of the US (WOTUS), which include wetlands, are regulated by the Federal Government.  These regulations are such that now wetlands and waters regulated by the Federal Government will, in many cases, be different than what the Commonwealth of Virginia regulates. Therefore, no national level certification program could capture the specific needs of the citizens of our Commonwealth.
4. As the Commonwealth of Virginia will now regulate more of its wetland resources than the Federal Government, it is critical that qualified individuals have the education and field skills required to perform this work.

The citizens of Virginia need, and will benefit from, the Commonwealth's assurances for qualified wetland delineators, and citizens are not protected from unqualified work by any other means.  DPOR must retain the PWD certification at a minimum.  DPOR should further consider the PWD a requirement for anyone practicing wetlands delineation in the Commonwealth of Virginia, just like it has for other professional certifications such as Professional Engineers and Land Surveyors.  The growing complexity of this professional practice, coupled with continual regulatory change, simply begs for a mandatory PWD program with continuing education requirements.