I am currently ready to take my PWD exam here in February and would oppose these changes to the certification program. Virginia has one of the oldest, active wetland delineator certifications in the United States and the only such certification that requires proficiency in botany, soil science, and hydrology, as well as an extensive understanding of Federal and Virginia regulations/methodologies and law.  Botany, soil science, and hydrology are in fact disciplines professionals can individually practice.  No other occupation requires such a diverse set of skills to understand the relationship between three distinct fields of study and apply them on a daily basis.  These skills cannot be gained in three years without additional background education and training. .  Now that the number of years of experience required must be reduced to 3 years, it becomes critical that the requirements for a degree in a natural or environmental science remain in place and the requirement for having taken a basic wetland delineation training course be left in the regulations. 

I personally would not have been ready nor would I have thought that I was ready to take/become a PWD in VA at 3 years. Coming from starting my career in PA, OH, and WV; VA has a very different regime to it. I have never delineated a state that requires more hands-on knowledge to delineate correctly than this state.  Many different soil types and different terrains throughout the state. THIS is why the PWD certification program must be kept at the current parameters that it is. PLEASE do not undermine this incredible certification program.