Virginia should continue to regulate the licensure of Professional Wetland Delineators as the occupation meets the 4 criteria set in the Code of Virginia.

The Commission is incorrect in the finding that a national certification program in place equals the state certification.  The state certification program evaluated individual work (10 delineation reports and subsequent Jurisdictional Determinations from the USACE) as well as issuing the compentency test.  The PWS certification does not evaluate completed work nor does it test the level of knowledge of the individual.  

The state should be aware that many Cities and Counties rely upon the seal of a professional wetland delineator with submission packages required under Chesapeake Bay laws as well as construction site plans.  Much in the way planning offices rely up a PE or a surveyor stamp these stamps ensure that the plans submitted to the County/City are valid and can move forward.  Removing the state licensure will cause a cascade effect upon Federal, state, and county officers and the workload therein.