As a Professional Wetland Delineator (PWD) and Professional Wetland Scientist (PWS), I strongly encourage DPOR to not only maintain but strengthen the existing PWD certification program. 

A national certification program such as the PWS can not be compared to the PWD certification program, a standardized testing and certification program required to competently complete delineations in Virginia. JLARC made a poor decision assuming that the PWS and PWD were equitable. 

Evolving regulations on the federal level have recently become in conflict with jurisdictional waters protected by the Commonwealth of Virginia. The PWD program at its core was developed to ensure the proper identification of VIRGINIA'S jurisdictional waters. 

If anything, the PWD program needs to be strengthened to promote accurate delineations in Virginia. 

Sincerely,

Joe Felton, PWD, PWS, CNMP

joeefelton@gmail.com