September 29, 2020

Commonwealth of Virginia

Board for Professional and Occupational Regulation (BPOR)

Kathleen R. Nosbisch, Board Executive Director

9960 Mayland Drive, Suite 400

Richmond, VA 23233

RE: Professional Wetland Delineator certification

Dear Ms. Nosbisch:

I am writing to inform you of MY SUPPORT of the Commonwealth of Virginia’s Professional Wetland Delineator (PWD) program.  As a resident of Pennsylvania, I can tell you that I wish the Commonwealth of Pennsylvania adopted a similar program as the Commonwealth of Virginia.

There is a huge difference between governmental licenses and professional society certifications.  I am a Senior Professional Wetland Scientist of the Society of Wetland Scientists.  I have been so for close to 20 years.  I did not have to demonstrate to anyone that I understood how to delineate a wetland boundary to receive that certification.  This is because the Professional Wetland Scientist (PWS) certification, and similar organizational certifications, are based on education and general work experience.  Not detailed knowledge and capability of a specific practice.  In other words, I could be an ornithologist who studies birds that breed in wetlands and receive my PWS certification because of my education and knowledge of wetland birds but have no understanding of wetland soils, wetland plants, or wetland hydrology (key elements of wetland delineation science).

To adequately protect wetland resources, wetland scientists with an understanding of wetland delineation procedures are necessary.  Thus, the Commonwealth of Virginia’s PWD program is necessary to protect the Commonwealth’s resources and its citizens and satisfies the 4 criteria required for an occupation to be regulated (§54.1-100):

1. The unregulated practice of the occupation can harm public health, safety or welfare.
2. The occupation’s work has inherent qualities that distinguish it from other occupations.
3. The public needs and will benefit from state assurances of competency.
4. The public is not protected by other means.

Instead of doing away with the PWD certification program, I suggest you do something different – boast about it!  I have been a PWD since its inception (#46).  I routinely wish that other states would adopt a similar program as I understand that it is best for the resource.  And what is best for the resource is clearly best for the Commonwealth and its residents.

Thank you for your time in considering my comments.

Joseph J. Wilson

Wilson Ecological Consulting, LLC

Senior Ecologist, Ecological Society of America

Professional Wetland Delineator, Commonwealth of Virginia

Senior Professional Wetland Scientist, Society of Wetland Scientist

Qualified Botanist, U.S. Fish and Wildlife Service and Commonwealth of Pennsylvania