I am a Virginia-certified Professional Wetland Delineator (PWD) and a Society of Wetland Scientists (SWS)-certified Professional Wetland Scientist (PWS).  It is my understanding that the substantive basis for JLARC's preliminary recommendation to discontinue the PWD certification in Virginia is that it is redundant with the national PWS certification administered by the SWS Professional Certification Program (PCP).  My comments below will focus on this specific topic.

Stated plainly, although the national certification serves an important function among wetland practitioners with respect to ethics, it is not – nor was it ever intended to be – a program that certifies professional aptitude for the practice of wetland delineation.  As such, the national and state programs serve different functions.

The national certificate (PWS) is issued by the SWS-PCP to individuals who qualify based on experience, education, and reference – there is no direct examination of skills and knowledge in the national program, nor any other attestation to a scientist’s technical acumen beyond the application process.  This is the strongest point of departure differentiating the Virginia certification (PWD) from the national program, and it is the primary reason why discontinuing the state program would be a mistake.  Like the national certification, a Virginia-certified PWD must demonstrate education and experience, and provide professional references.  However, once an applicant is approved to move forward with the certification process, he/she must then sit for a state certification exam that assesses his/her knowledge of the wetland delineation process.  A licensed PWD in Virginia carries a strong seal of approval from the state that he/she has achieved a level of technical competency befitting a qualified practitioner in the field of wetland delineation as assessed by a board-administered examination.  The national certification conveys no such assurances and therefore provides absolutely no redundancy with the state program.  

Among the activities that occupy wetland practitioners, I regard wetland delineation as preeminent in that it is the one wetland-related professional task that carries the most risk in the US.  The process of wetland delineation establishes the boundary of surface water features subject to jurisdiction under Section 404 of the Clean Water Act and analogous State Water Control Law.  In permitting programs throughout the US, the statutory authority for protection of wetlands may vary through time or geographic territory, but the baseline understanding of jurisdictional limit – particularly for wetlands – remains the wetland delineation process, and much hinges on the outcome of a wetland delineation. 

The consequences of “getting it wrong” can be severe.  In my 27 years as a professional wetland delineator, I have seen self-proclaimed “wetland professionals” suffer punitive damages for attempting to abuse the system by intentionally misrepresenting wetland jurisdiction.  Likewise, I have seen inexperienced or untrained technicians grossly misidentify the limits of jurisdiction, a scenario that all-too-often costs landowners tens of thousands of dollars in permitting and mitigation fees and unnecessarily occupies the scrutiny of our already overworked agency colleagues.  Prior to the state PWD certification, these so-called wetland professionals had a claim to legitimacy equal to that of even our most seasoned and principled wetland scientists in Virginia, the only mediating factor perhaps being reputation.  On this side of the state certification divide, however, I can say with resolve that the PWD has given Virginia a legitimate means to differentiate practitioners along these lines, and the technical skills and abilities of our wetland delineators has improved because it has given scientists in my field an echelon of achievement to work toward. 

The Virginia Professional Wetland Delineator certification program has and continues to be a success because it provides a unique basis for adjudicating wetland delineation proficiency.  This is evidenced by the fact that practitioners continue to certify in both the state and national programs – there is no overlap between these two, and practitioners recognize this and see the unique benefits provided by both.  Most importantly, for the practice of wetland delineation – an activity for which there is much at stake – it is the Virginia PWD certification, and the PWD only, that adequately levels the field of wetland delineators based on a board-administered examination.  This certification program provides an unconditional benefit to Virginians and should continue indefinitely.