Virginia Regulatory Town Hall
Agency
Department of Professional and Occupational Regulation
 
Board
Board for Professional and Occupational Regulation
 
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9/30/20  10:17 pm
Commenter: Taylor Sprenkle, Whitman, Requardt & Associates, LLP

strongly support continuation of the Professional Wetland Delineator certification program
 

I am a Professional Wetland Delineator (PWD) with 18 years of experience delineating wetlands and securing environmental permits for various projects in Virginia, including residential development, energy transmission, water/wastewater transmission and treatment, and roadways.  Timely, cost-effective delivery of infrastructure is critical to Virginia’s robust economy. 

Federal and state environmental regulations require that projects be designed and constructed in a manner that avoids and minimizes wetland impacts to the greatest extent practicable.  As such, the results of a wetland delineation can significantly impact project design and implementation.  An inaccurate delineation can result in the inappropriate use of costly design elements such as bridges, retaining walls, bottomless culverts, etc. that are commonly used to minimize impacts to wetlands.  An inaccurate delineation could result in the loss of valuable buildable land.  An inaccurate delineation discovered by regulators during the permitting process can cause costly project delays costing millions in lost opportunity and/or wasted money.

JLARC incorrectly concluded that the PWS certification is comparable to the PWD certification.  Obtaining a PWD certification requires the applicant to demonstrate a minimum number of years of experience and pass a rigorous technical exam.  A person who holds a PWD certification possesses the required technical skills to accurately delineate wetlands that are unique to Virginia.  By contrast, the PWS certification is a nationwide certification that is not specific to Virginia, does not require technical skills or knowledge regarding wetland delineation, and applies to a broad range of specialties not specifically related to wetland delineation (e.g., policy, ecology, etc.).

I strongly encourage the Commonwealth of Virginia to continue regulation of Professional Wetland Delineators to ensure that a critical element of infrastructure development in Virginia is conducted by qualified professionals.

                

CommentID: 87167