THE WISCONSIN PG – More than 10 Years Later
Progress in Recognizing the PG Designation Disappointing
It has been approximately 11 years since the Wisconsin Professional Geologist (PG) registration
was enacted in November 1994. The hope was the registration would give geologists a more
equal footing with the Professional Engineers, and that it would establish a legally defined
standard of professional conduct and quality in the performance of work involving the geological
sciences. Unfortunately, some of the most basic goals of the registration have yet to be realized.
While most geologists working in the environmental and groundwater fields have obtained the PG
registration when eligible, the success in establishing the registration as the standard for
geological work in the State has been disappointing. Nor does it appear to have significantly
enhanced the standing of geologists with respect to that of engineers.
A number of important State regulations mandating work that falls under the Practice of Geology,
as defined under the Statute (Chapter 470) and implementing Administrative Code (Chapter
GHSS 1) that established the registration, do not even recognize the existence of the PG (or the
Professional Hydrologist and Professional Soil Scientist for that matter). Instead, they reference a
considerably weaker, almost meaningless, definition of what constitutes qualifications to perform
this work. A review of State of Wisconsin Statutes and Administrative Code illustrates how far the
State has to go in recognizing its own regulations.
State Definition of PG
Just to review, according to 470.01(2) Wisconsin Statutes (WS) the
“’Practice of professional geology’ means the performance of or offer to perform any geologic
service or work in which the public welfare or the safeguarding of life, health, environment or
property is concerned or involved. “Practice of professional geology” includes the collection of
geological data, consultation, investigation, evaluation, interpretation, planning or inspection
relating to a service or work that applies geology.”
Furthermore, (with allowances for the overlapping areas with the practices of Professional
Hydrology, Soil Science, and Engineering stated elsewhere), 470.02(1) WS states that a person
may not
“(1) Engage or offer to engage in the practice of professional geology, designate himself or
herself as a professional geologist, use or assume the title "professional geologist " or any
other title, letters or designation which represents or may tend to represent the person as a
professional geologist unless the person is licensed by the professional geologist section
under this chapter.”
Recognition of the PG in Wisconsin State Code
Presently, Wisconsin Administrative Code (WAC) specifically requires this type of work be
performed by a registered PG for the following types of work:
Certification of a marketable non-metallic mineral deposit or termination of registration of a
depleted mineral deposit (NR 135 WAC).

Oversight of lagoons used solely for research purposes (NR 213 WAC).

Prepare or oversee the preparation of initial site reports, feasibility reports, plans of operation,
site investigation, remedial action options reports and any other reports where interpretation of
geology or hydrogeology is necessary for solid waste facilities (NR 500.05(4)(b) WAC).
For solid waste facilities:
1. Prepare or oversee the preparation of initial site reports, feasibility reports, plans of
operation, site investigation, remedial action options reports and any other reports where
interpretation of geology or hydrogeology is necessary for solid waste facilities (NR 500
WAC).
2. Observe and direct the drilling of all borings and the installation, development and
abandonment of all wells at solid waste facilities (NR 503 WAC; NR 507 WAC; NR 510
WAC; NR 512 WAC).
Lack of Recognition of the PG in Wisconsin State Code
In contrast, there are far more Wisconsin Department of Natural Resources (WDNR)
regulations that explicitly require work that falls under the Practice of Geology definition,
but instead indicate a person may perform this work only if he or she meets the WDNR’s
vague and outdated definition of a hydrogeologist:
“’Hydrogeologist’ means a person who is a graduate of an accredited institution of higher
education and who has successfully completed 30 semester hours or 45 quarter hours of
course work in geology. At least 6 semester hours or 9 quarter hours of the geology course
work shall be in hydrogeology, geohydrology or groundwater geology. This person shall also
have acquired through education and field experience, the ability to direct the drilling of
borings and the installation and development of wells, describe and classify geologic samples
and evaluate and interpret geologic and hydrogeologic data.” (NR 600.03 (98) WAC)
Not only are the educational requirements of this definition anemic and the experience
requirements essentially meaningless, but there is neither a mechanism for determining if a
person truly meets the requirements, relying on self-certification (how often have you seen
someone call themselves a “Wisconsin Certified Hydrogeologist”?), nor one for addressing
instances where the person has falsely claimed this qualification. The above definition of
hydrogeologist clearly falls under the Practice of Geology, which includes the following type of
work:
“(i) Hydrogeology, including design and interpretation of hydrologic and hydrogeologic testing
programs, utilization of physical and chemical data to evaluate hydrogeologic conditions,
development and interpretation of groundwater geologic maps and sections, application of
geophysical methods to analyze hydrogeologic conditions, determination of the physical and
chemical properties of aquifers and vadose zones, determination of groundwater resources and
quality, design of wells and drilling programs, development of groundwater resource
management plans, and development of remedial action programs.” (GHSS 2.04(2)(i) WAC)
A recent college graduate with a few months of experience, if he or she felt qualified under the
“Hydrogeologist” definition, could conceivably do the following:
Perform a hydrogeological investigation to be included as part of a sewerage facilities plan, and
prepare plans and specifications as required for the purpose of determining groundwater
conditions for the engineering report and for WPDES permit requirements for a sewerage
facility (NR 110 WAC).
Prepare plans and specifications for groundwater monitoring systems for land treatment of
industrial liquid wastes, by–product solids and sludges (NR 214 WAC).

For monitoring of hazardous waste facilities (NR 635 WAC):
1. Certify that an alternate hydraulically downgradient monitoring well location can be
utilized to monitor groundwater.
2. Prepare, or direct the preparation of, and sign a groundwater quality assessment
program for the facility, based on determining: whether hazardous waste or hazardous
waste constituents have entered the groundwater; the rate and extent of migration of
hazardous waste or hazardous waste constituents in the groundwater; and the
concentrations of hazardous waste or hazardous waste constituents in the groundwater.
3. Observe and direct the drilling of all borings; the installation, development and
abandonment of all wells and all in-field hydraulic conductivity tests.
4. Visually describe and classify all geologic samples.
For plan reviewing and licensing of hazardous waste facilities (NR 680 WAC)
1. Sign reports where interpretation of geology or hydrogeology is necessary.
2. Inspect the drilling of all borings, the installation and development of all wells and all
infield hydraulic conductivity tests for new landfills and surface impoundments (if
employed by the Department of Natural Resources).
For actions taken under the NR 700 series
1. Conduct or supervise sampling, field work and development of plans for field activities for
response actions (NR 712.05(1) WAC).
2. Collect or supervise the collection of samples of air, soil, water or other media for field
measurements or analytical laboratory analysis for remedial actions and interim actions
that involve treatment or engineering controls (NR 712.05(3) WAC).
3. Prepare or supervise the preparation of submittals that are prepared to satisfy the
requirements of s. NR 708.11 (4) or 708.13 or chs. NR 716 to 726, which require the
performance of engineering services or scientific evaluations (NR 712.07(1) WAC).
4. Prepare or supervise the preparation of submittals prepared to satisfy the requirements
of ch. NR 722 or 724 or s. NR 708.11 (4), including free product response actions taken
to address groundwater contamination jointly with a professional engineer.
Certify that submittals prepared under NR 700 contain information that is correct, that the
submittal was prepared in accordance with all of the applicable requirements of chs. NR 708
to 726, and that the conclusions and recommendations in the submittal represent the
certifier's best professional opinions and judgments. (NR 712.09).
Do WDNR Regulations Conflict with State Law?
Ironically someone performing the above activities without the qualifications or supervision of a
Wisconsin Registered PG could conceivably be subject to the following penalties:
“A person who violates this chapter (470 WS) or any rule promulgated under this chapter may
be required to forfeit not more than $5,000 for the first offense and may be required to forfeit
not more than $10,000 for the 2nd or any later offense within a year. Each day of continued
violation constitutes a separate offense.” (470.09 WS)
Obviously, as far as I am aware, no one is or has ever been prosecuted for illegally practicing
geology in the State of Wisconsin by performing any of the activities that WDNR regulations
specify are to be performed by a “hydrogeologist”.
Some might argue that the WDNR’s definition of the term Hydrogeologist implicitly assumes
that a qualified Hydrogeologist is also a Wisconsin Registered PG, and that it actually narrows
the range of qualified people by requiring hydrogeological education and experience. While I
am not a lawyer that seems unlikely for three reasons:
1. The WDNR only vaguely defines the experience qualifications of a Hydrogeologist under
its regulations and does not require those qualifications to conform to any recognized
system of certification like the Professional Geologist,
2. If the regulations referencing the Hydrogeologist definition were written and enacted prior
to implementation of the PG registration they could not have been written with the PG in
mind, and if they were enacted afterward, they obviously ignored it, and
3. Some WDNR regulations explicitly require a Professional Geologist while making no
reference to the WDNR definition of a Hydrogeologist indicating that the WDNR does not
consider the Hydrogeologist definition to be a blanket definition implicitly incorporating the
PG.
What Can We Do
It would seem that since the State of Wisconsin does not take its own law seriously, the term
Professional Geologist is little more than window dressing for resumes and business cards. It
certainly does not come anywhere near carrying the weight or significance of the designation of
Professional Engineer.
At one time the WDNR had someone working on integrating definition of Professional Geologist
into its regulations, at least those for the NR 700 series. But for whatever reason that effort seems
to have stopped. Perhaps it is time for organizations such as WGWA and the Wisconsin Chapter
of the American Institute of Professional Geologists to bring this oversight to the attention of the
State, and to push to have Professional Geology finally get the recognition it was supposed to
receive under the original legislation.