The Aggregate Producer Members of the Virginia Transportation Construction Alliance (VTCA), respectfully submits the below comments relating to the proposed elimination of the Professional Wetland Delineator Certification:

The 30 Aggregate Producer Members of VTCA account for 91% of all metal/nonmetal mineral production in the Commonwealth. Aggregate production operations generally employ large tracts of land with an ever-changing topography. In order to permit and remain within regulatory compliance, aggregate operations must constantly assess their sites, including identifying and delineating wetland areas.

One resource that aids aggregate operations remain in environmental regulatory compliance is the ability to employ the services of Certified Professional Wetland Delineators (PWD). PWD’s offer aggregate producers an efficient professional resource equipped with expertise to accurately identify and delineate wetland areas of their operation. Inaccurate delineations of wetlands can lead to potential financial penalties and/or cessation of operations.

 The Aggregate Producers of VTCA strongly encourages the BPOR to consider retaining the certification process for Professional Wetland Delineators.