Virginia Regulatory Town Hall
Agency
Department of Professional and Occupational Regulation
 
Board
Board for Professional and Occupational Regulation
 
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9/30/20  10:42 am
Commenter: Laura Callens, CFM, PWD

Support PWD
 

I strongly support the continued regulations by the Commonwealth of Virginia of Professional Wetland Scientists for the following reasons:

  1. The JLARC study based its decision on factually incorrect information - a Professional Wetland Scientist (PWS) certification is not like a Professional Wetland Delineator (PWD) Certification.  A PWS can be obtained by people solely based on references and education in all sorts of areas related to wetlands ecology, whereas a PWD is focused 100% on the skills needed to perform a wetland delineation.  A PWS does not even have to have such skills. 
  2. The PWD Certification requires an exam to be passed, unlike the PWS which does not require an exam.  The exam is a challenging comprehensive test of knowledge.  Passing the test demonstrates a full understanding of wetland delineation skills and policy. 
  3. The two programs are also different in the PWS is geared towards delineation experience only, and the PWD covers the broader science so someone with a focus on policy can get certified.
  4. The continued changing laws, regulation and manuals used to determine what a wetland area is, and which are regulated again points to a need to have this certification program.  It also demonstrates that its rigor should be increased with continuing education requirements. 
  5. Recently (June 22, 2020), the Federal Government changed its regulations that determine which Waters of the U.S., which include wetlands, are regulated by the Federal Government.  These regulations are such that now wetlands and waters regulated by the Federal Government will, in many cases, be different than what the Commonwealth of Virginia regulates.  Therefore no national level certification program could capture the specific needs of the citizens of the Commonwealth.
CommentID: 87058