Caroline County Water Withdrawal Open Comment

It is well documented that Caroline County needs water to meet the residential growth that is coming to the county. Groundwater levels east of Interstate 95 are declining due to excessive use and the Virginia Department of Environmental Quality (DEQ) is requiring localities to seek alternative sources of water. In this case Caroline County identified surface water withdrawals from the Rappahannock River as the best source.

Accordingly, Caroline County Public Utilities has applied to install a new water withdrawal intake structure located on the south bank of Rappahannock River, a raw water pump station, the installation of approximately 35 miles of water line for the transfer of raw water for the intake to the proposed water treatment plant (WTP) located in the vicinity of Carmel Church, VA. The intake would take an average of 7.90 million gallons of water a day or a maximum of 13.90 million gallons per day (MGD). DEQ’s tentative decision is to issue the permit.

While Friends of the Rappahannock (FOR) acknowledges Caroline County’s need for water, we oppose the draft permit in its current form. After last weeks public hearing at which over 200 citizens attended and 60 spoke (all in opposition)  we remain concerned about the potential impacts of this intake to the health of the Rappahannock River and its aquatic fauna for the following reasons:

Major interbasin transfer of water leading to increases in salinity
This permit proposes to allow a major interbasin transfer of water between two major river basins. The water would be pumped approximately 35 miles across the county to Carmel Church area in the I-95 corridor where it will be treated at a water treatment plant, used for one of three sectors (residential, commercial, industrial cooling), and discharged after treatment at a wastewater treatment plant into the Mattaponi River and Polecat Creek (a tributary of the Mattaponi River).   Not a single drop of water removed from the Rappahannock River would come back to the Rappahannock  River. This will have dire consequences for agricultural producers who depend on the River to irrigate their crops. Salinity levels have been gradually increasing in the Rappahannock River and this will only exacerbate the problem.

Missing Data/Flawed Modeling

DEQ staff has admitted that there is a significant amount of data missing related to capacity for intakes, water treatment plants and infrastructure from grandfathered unpermitted water withdrawal facilities. In meetings in August and September they have stated that their water supply modeling is incorrect and there is a need to pause modeling and update their methodology. There are scenarios in which at low flow conditions some rivers could already be over allocated. This leads us to the logical conclusion that any modeling done for this permit is flawed. All decisions should be put on hold until DEQ can update their water supply models and a cumulative impact study done regarding salinity in the Rappahannock River.

Atlantic Sturgeon
The area where the intake is proposed is known to be potential spawning grounds for the federally designated as an  endangered species Atlantic Sturgeon. Thankfully the Virginia Department of Wildlife Resources has provided valuable input but nowhere can there be found evidence that the federal agencies who are responsible for protecting Atlantic Sturgeon have been consulted on the permit application.

Water Demand
Of the proposed average of 7.9 million gallons a day to be withdrawn from the river 2.63 million gallons would be allocated to industrial facilities, specifically three (3) data center campuses. Only 2.3 mgd are allocated for residential use. Essentially they are using a municipal drinking water project as cover for a cooling water supply to data center projects. 

More information can be found here:https://www.deq.virginia.gov/Home/Components/Calendar/Event/1820/17

DEQ accepts written comments by hand-delivery, e-mail, or postal mail. All comments must be in writing and be received by DEQ during the comment period. Written comments must include: 1) The names, mailing addresses or email addresses of the person commenting and of all people represented by the person. 2) A brief, informal statement on how the proposal affects the person. The public may review the draft permit and application at the DEQ office named below {by appointment}. In addition, all comments should be emailed to the contact below:

DEQ Contact:

            Allison Major, Central Office

         Phone: 804-698-4087

         Email: [email protected]

To download the draft permit package, please click here.

Another public hearing  will be held after DEQ responds to the written comments filed by October 11th and oral comments made at the September 25th public hearing.

The comment deadline is June October 11, 2024.

Additional questions can be directed to Brent Hunsinger our Advocacy and Coastal Programs Director at [email protected]

UPDATED: SEPT. 12, 2024

ORIGINAL POST: MAY 30, 2024

We need your help to submit comments and request a public hearing for the proposed Caroline County water withdrawal intake project!

It is well documented that Caroline County needs water to meet the growth that is coming to the county. Groundwater levels east of Interstate 95 are declining due to excessive use and the Virginia Department of Environmental Quality (DEQ) is requiring localities to seek alternative sources of water. In this case Caroline County identified surface water withdrawals from the Rappahannock River as the best source.

Accordingly, Caroline County Public Utilities has applied to install a new water withdrawal intake structure located on the south bank of Rappahannock River, a raw water pump station, the installation of approximately 35 miles of water line for the transfer of raw water for the intake to the proposed water treatment plant (WTP) located in the vicinity of Carmel Church, VA. The intake would take an average of 7.90 million gallons of water a day or a maximum of 13.90 million gallons per day (MGD). DEQ’s tentative decision is to issue the permit.

While Friends of the Rappahannock (FOR) acknowledges Caroline County’s need for water, we oppose the draft permit in its current form. We remain concerned about the potential impacts of this intake to the health of the Rappahannock River and its aquatic fauna for the following reasons:

Major interbasin transfer of water
This permit proposes to allow a major interbasin transfer of water between two major river basins. The water would be pumped approximately 35 miles across the county to Carmel Church area in the I-95 corridor where it will be treated at a water treatment plant, used for one of three sectors (residential, commercial, industrial cooling), and discharged after treatment at a wastewater treatment plant into the Mattaponi River and Polecat Creek (a tributary of the Mattaponi River).  Not a single drop of water removed from the Rappahannock River would come back to the Rappahannock  River.

Atlantic Sturgeon
The area where the intake is proposed is known to be potential spawning grounds for the federally designated as an  endangered species Atlantic Sturgeon. Thankfully the Virginia Department of Wildlife Resources has provided valuable input but nowhere can there be found evidence that the federal agencies who are responsible for protecting Atlantic Sturgeon have been consulted on the permit application.

Water Demand
Of the proposed average of 7.9 million gallons a day to be withdrawn from the river 2.9 million gallons would be allocated to industrial facilities, specifically three (3) data center campuses. Essentially they are using a municipal drinking water project as cover for a cooling water supply to data center projects.

More information can be found here:https://www.deq.virginia.gov/permits/public-notices/water/water-withdrawal

You may provide comments to VMRC on this joint permit application (VMRC #2020-0514/DEQ VWP #20-0514) at https://webapps.mrc.virginia.gov/public/habitat/comments/ In addition, DEQ accepts comments and requests for public hearing by e-mail, or postal mail. 

Comments can be emailed to Elizabeth Gallup at [email protected]
Submittals must include the names, mailing addresses and telephone numbers of the commenter/requester and of all persons represented by the commenter/requester. 

A request for public hearing must also include: 

1.  The reason why a public hearing is requested.
2. A brief, informal statement regarding the nature and extent of the interest of the requester or of those represented by the requestor, including how and to what extent such interest would be directly and adversely affected by the permit.
3. Specific references, where possible, to terms and conditions of the permit with suggested revisions.

A public hearing may be held, including another comment period, if public response is significant, based on individual requests for a public hearing, and  there are substantial, disputed issues relevant to the application.

The comment deadline is June 18, 2024.