I SUPPORT the continued regulation of Certified Professional Wetland Delineators (PWD) by the Commonwealth of Virginia’s Department of Professional and Occupational Regulation (DPOR).  I am currently certified as both a PWD (#3402000139) and Professional Wetland Scientist (PWS) since 2011.  I can confidently say that a PWS is not an equivalent certification to the PWD for several reasons.

1) The most important difference is that PWD certification requires an exam focusing on the field skills necessary to perform an accurate wetland delineation.  As a consultant I have seen my fair share of inaccurate delineations conducted by unqualified individuals.  Although the PWD is not a requirement to perform a wetland delineation in Virginia (which it should), this credential provides others confidence that the wetland delineation is being performed by a competent professional.  Obtaining a PWS does not require that you have field experience necessary to conduct an accurate wetland delineation.  I know multiple individuals that have a PWS certification that have never conducted a wetland delineation.

2)  Unlike a PWD, the PWS requires you to obtain references from others that have the certification.  This can be extremely challenging if you work for a small business.  Just because you don’t personally know other PWS’s doesn’t necessarily mean that you lack the knowledge, skill, or qualifications required to accurately delineate wetlands.

3)  The removal of the PWD will have detrimental effects to our water resources.  The unregulated practice of this occupation will result in the unregulated loss of wetlands, thus decreasing water quality and overall ecological health of Virginia.

Thank you for your consideration of these comments. 

Jason Bohdan, PWS PWD