I am a Professional Wetland Delineator (PWD) and Professional Wetland Scientist (PWS). I am writing to support the continued regulation of PWDs by the Commonwealth of Virginia’s Department of Professional and Occupational Regulation (DPOR).

The JLARC study incorrectly concludes the PWS is comparable to the PWD. A PWS can be obtained by people solely based on references and education in areas related to wetland ecology. The PWS certification does not require any experience delineating wetlands, and since it is a national certification, it does not promote proper delineations for conditions unique to Virginia. The PWD is focused on wetland delineation skills, understanding and applying the methods and science of wetland delineation, and federal and state regulations. The PWD certification requires experience delineating wetlands and passing a written exam, in addition to references and educational requirements. Since the PWD is a Virginia certification, it requires understanding of Virginia regulations and promotes proper delineations for conditions unique to Virginia. Knowledge of Virginia regulations is particularly important, given the current Navigable Waters Protection Rule. Under this rule, many areas that were federal jurisdictional wetlands are no longer regulated at the Federal level but are still regulated in Virginia. Therefore, a federal program like the PWS does not address the needs of wetland delineation in Virginia. The PWD certification provides assurance that wetland delineations are conducted by qualified professionals that are knowledgeable about Virginia regulations and wetland environments.

Thank you, 

Emily Drahos, PWD, PWS