Local governments rely on the professional wetland delineator certification program to vet wetland delineators so that Local Government Staff and Officials can be confident in the reviews and approvals they make of proposed development plans receive, as well as all the proper permit applications and permits obtained.  Decisions made during the development review process are deeply dependent on accurate mapping of these natural resources.  If you ham sting the quality of work with regard to wetland delineation you will ham string the efforts this state and local governments programs have pursued for years such as the Chesapeake Bay Program, the E&S, and water quality programs.  Not every local government has a CPWD on staff.

Wetland delineation is not always black and white. You could rely on the USACE Wetland Confirmation Field Review and Letter, but I have news for you, not every site is visited.  Desktop reviews are conducted by USACE; they are simply stretched thin as is everyone else.  So now local governments cannot 100% rely on USACE.  With the loss of this program I truly believe it will lead to a cascading effect that will result in a loss of the quality of work which could also result in loss of overall wetland acreage and water quality leading to the Chesapeake Bay.  

Doing away with the program will empower every Tom, Dick, and Harry to go out there and muck around in wetlands thinking they know what they are doing.  Local governments do not have the man power to run around looking at every violation because someone decided to do something stupid.  We have enough violations because people make uninformed decisions to wetlands and CRPA.  We do not need less qualified individuals as wetland consultants/experts trying to assist these folks.

As far as the SWS, it is an international program, it is not a local program having local members who know local laws, and the local environment.

Thank You,