Reducing the certification requirements could negatively impact the quality of delineations, wetland permits, compensatory mitigation, accurate/true engineering plans, and site development. I supports the current educational, training, and reference components of the CPWD regulation which are critical to assuring reliable and consistent identification of State Surface Waters. Inaccurate delineations can lead to higher costs to business from punitive regulatory actions. It can lead to higher costs to the Commonwealth by increasing the workload of regulators who must review poor quality delineations. It can also lead to detrimental impacts to public health, safety, and welfare by having an adverse effect on water quality.