I am a licensed professional engineer in Virginia and Maryland, and have been a geotechnical engineering consultant for the past 43 years. I believe the Professional Wetland Delineator (PWD) Certification should not be eliminated for the following reason:  The PWD certification is not equivalent to the Professional Wetland Scientist (PWS) certification because the PWD certification requires field delineation experience whereas the PWS certification does not.  As a licensed professional engineer, I recognize the critical importance of field experience in wetland delineation.  Without field experience, the chances that a delineation will be accurate are quite small.  A delineation that incorrectly identifies smaller areas of wetlands would not provide the protection needed of our natural resources.  Conversely, a delineation that incorrectly identifies larger areas of wetlands penalizes property owners that want to develop their land.  Property owners include those that own public and private property, including one of the largest being the Virginia Department of Transportation.  I understand the criteria that are required to be met for an occupation to be regulated in Virginia include the following: 1) The unregulated practice of the occupation can harm public health, safety or welfare, 2) the occupation's work has inherent qualities that distinguish it from other occupations, 3) The public needs and will benefit from state assurances of competency, and 4) The public is not protected by other means (i.e. since the PWD and PWS certifications are not equivalent).  Clearly, the Commonwealth of Virginia needs wetlands delineators to have the PWD certification that requires field delineation experience.