I am writing in SUPPORT of continued regulation of Certified Professional Wetland Delineators (PWD) by the Commonwealth of Virginia’s Department of Professional and Occupational Regulation (DPOR).

I hold both a PWD and Professional Wetland Scientist (PWS) certification, the latter of which requires nothing more than a few letters of recommendation and some years of experience. The PWS does not provide any assurance of competency of wetland delineations and can honestly be obtained by just reaching out to a few colleagues for a good word. It can be obtained based on a wide range of educational backgrounds in any specialties related to wetland ecology, management, or regulation. Furthermore, experience can be obtained anywhere in the world and therefore does not require any knowledge of U.S. regulatory frameworks surrounding wetlands nor knowledge of wetland communities specific to the Mid-Atlantic or Virginia.  

Having had worked in several states over my career, I can attest to witnessing countless occurrences of delineations being performed by unqualified individuals, resulting in permitting issues and lawsuits against both the regulatory authorities, landowners, and “professional” delineators. It is my belief, that until the PWS certification (or similar national certification) requires testing and CEUs that all States should be encouraged to seek out State certification, which centers around the regional supplements subject to area of work.

The PWD certification strengthens the credibility and reliability of the work force, it does not hinder.