I do not support proposed changes to the CPWD regulations. The current educational and experience requirements for PWD certification are necessary to maintain integrity and accuracy of wetland delineation in Virginia.

Reducing education, training, and experiential requirements would negatively affect the quality of delineations, permits, compensatory mitigation, and site development, and would likely lead to delays in these processes. A high level of experience and familiarity with the region is needed now more than ever, to keep up with the constantly changing regulatory environment that we currently face.

The current components of the CPWD regulation are critical to assuring reliable and consistent identification of State Surface Waters and should be maintained. A reduction in requirements would ultimately remove the value of this certification.