I am a Professional Wetland Scientist (PWS), Licensed Professional Forester (LPF), and Professional Wetland Delineator (PWD) and therefore have extensive understanding of these regulatory programs. I strongly encourage the continued regulation by the Commonwealth of Virginia of Professional Wetland Scientists for the following reasons:

• JLARC study incorrectly concludes the PWS certification is comparable to the PWD license, it is not comparable.  The PWD is solely focused on wetland delineation skills and understanding and application of the methods and science of delineation.  The PWS certification does not require delineation skills to become certified and can be obtained based on references and education in a broad range of specialties (like policy, ecology, etc.).  PWD requires delineation skills and understanding relative to the Commonwealth which includes a broad range of wetland types.
• The U.S. Army Corps of Engineers implemented a demonstration project that would have replaced the need for the PWD Program, it was never funded by Congress after the pilot.  Of the people who took the exam and field practicum, 38% passed.  This demonstrates the importance of a certification program for PWDs and the importance of having qualified individuals complete this work.  Accurate delineations affect property valuation and development potential and are therefore of consequence to individual and commercial property owner interests in the Commonwealth.
• Continually changing regulations, delineation manuals, laws require individuals to remain current with all and further supports the need for a PWD program.  Continuing education requirements should be considered in light of changing laws/manuals.
• Recent changes in Federal law regarding waters of the U.S. and wetlands regulated by the U.S. are in many cases, different than those regulated by the Commonwealth.  Therefore no national level certification can capture the needs specific to the citizens of the Commonwealth.
• DPOR needs to retain the PWD requirement for anyone practicing delineation in the Commonwealth to retain the consistency/accuracy of standard professional practice, adherence to ethical standards that come with licensure to practice in the Commonwealth, and changing laws/complexities affecting the practice in the Commonwealth suggest a need for periodic continuing education (CE) requirements that would come with a PWD licensure program.  Other states and the Commonwealth license PE's and professional foresters under similar programs which include CE requirements.