I would like to express my support for the continuation the PWD program in its current form. This certification protects the Commonwealth and its citizens, and satisfies the 4 criteria required for an occupation to be regulated.

First, unregulated practice of the occupation results in permitting issues and lawsuits, but more importantly, the unnecessary destruction of the Commonwealth's natural resources. The work of delineating wetlands require proficiency in botany, soil science, hydrology, and regulations- this distinguishes it from other occupations which do not require such in-depth knowledge on a wide range of topics. The public needs and will benefit from state assurances of competency because Virginia regulates and requires permits for impacts within wetland and surface water boundaries currently unregulated at the Federal level. The U.S. Army Corps of Engineers does not confirm the boundaries or permit impacts to isolated wetlands or ephemeral streams. There are no certification programs aside from the PWD which can provide assurances of competency in the practice of wetland delineation and regulatory interpretation and permitting in Virginia.

I urge DPOR to acknowledge the value of the PWD and recommend the continuation of the Virginia Professional Wetland Delineator Certification.

Thank you for the consideration