I am a Certified Professional Wetland Delineator for the Commonwealth of Virginia (PWD) and have held my certification since September 27, 2010.  It's an honor and a privilege to hold this certification, as I am recognized by the Commonwealth as one of the few who is a known Certified Professional in the field that I have chosen.  To eliminate this program, just take that away, lessens the value and importance of not only what I do, but all those that are currently certified, and those that are in the process of seeking certification. Certification of PWDs is necessary to protect the Commonwealth and its citizens.   Therefore, I STRONGLY support the continued regulation of the Certified Professional Wetland Delineators (PWD) by the Commonwealth of Virginia's Department of Professional and Occupational Regulation (DPOR).  

This program is just as important, if not more important, now with the most current changes with federal and state regulations in regards to regulated and non-regulated jurisdictional features.   Without this knowledge, there may be time delays and additional costs encountered even before project design and could delay project development.    

I believe that the VA DPOR Certified Professional Wetland Delineator Program satisfies the four (4) criteria required for an occupation to be regulated in Virginia (54.1-100).  

1.  The unregulated practice of the PWD occupation can harm public health, safety, or welfare.  As we understand public health, safety, or welfare, is only for humans, we should include this with the health of the overall environment, wetlands, and other water resources of the Commonwealth and how identifying the jurisdictional features that are unique to Virginia should include avoiding or minimizing impacts to those features.  The approach of avoidance and minimization will have a long term benefit for the overall public health, safety and welfare for those living in VA and/or enjoying Eco-tourism in the Commonwealth.  We have a positive impact on all that enjoy, rely upon, or use the water resources of the Commonwealth.
2. This occupation work has inherent qualities that distinguish it from other occupations.  The standing argument is that this program is "redundant" and can be covered under the Nation program such as the Society of Wetland Scientist Professional Certification.  This is not a valid argument.  The PWD is very different and the Commonwealth holds this certification to a higher standard than the National PWS certification.  This Certification is specific to the regulations governed by the Commonwealth of Virginia, and is not an all inclusive "society".  The DPOR requires education and experience be satisfied prior to being able to sit for the proficiency exam.  This proficiency exam includes real world applications, problem solving skills, field techniques, atypical situations that are to be thoroughly evaluated before obtaining a certified jurisdictional determination from the Corps and DEQ.  Under the PWS program, there is no proficiency exam to show competency in your field, just proof of completed education and paperwork for at least 10 years.  By the time I was able to become a PWS, I opted to become one of the few who are a VA Certified Professional Wetland Delineator.    
3. The public needs and will benefit from state assurances of competency.  Performing accurate delineations can save time and thus costs associated with a project being developed by both private and public sectors.  An inaccurate delineation can be extremely costly to a project, from the regulators disagreeing with limits of jurisdiction, remapping, or calling something jurisdictional and mistakenly mitigating for it, when it should have been excluded.  This can also affect how the project is permitted under federal and state regulations.  An accurate delineation is the foundation for successful project development and successful construction.  
4. The public is not protected by other means.  Again, the Certified Professional Wetland Delineator Program regulated by DPOR cannot compare with the National program.  There is currently no federal guidance that requires a certification to perform delineations.  There is no other program to fall back on.  

In conclusion, this certification symbolizes the hard work and dedication of my professional career and development as a wetland delineator for over 21 years.  When I had the education, experience and was able to sit for the proficiency exam just over 10 years ago, obtaining this certification was not an easy feat.  My professional reputation, value, and confidence with the federal and state regulators are important.  I believe that this Certification is valued, that the letters behind my name acknowledges I am proficient and trustworthy in the work that I provide for the Commonwealth in my current position.  Therefore, I urge DPOR to acknowledge the value of the PWD and recommend the continuation of the Virginia Professional Wetland Delineator Certification.  

Thank you for your consideration of these comments.

Tiffany S. Tweedy, PWD

Natural Resources Specialist, VDOT Lynchburg District