Friends of the Rappahannock (FOR) appreciates the opportunity to comment on the proposed amendments to the Local and Regional Water Supply Planning Regulation (9VAC25-780).

FOR is a a 501-c3 nonprofit organization who's mission is to be a voice and active force for a healthy and scenic Rappahannock River.

FOR believes these amendments are a positive step towards comprehensive water supply planning at a time when the Rappahannock River basin faces increased pressure on its ground and surface water resources as populations grow, new land uses (such as data centers) are considered and the effects of climate change are brought to bear. We are glad to see that public participation will be encouraged in the development of these plans. We agree that it is imperative that we take into account all beneficial uses, including aquatic habitat, when planning for water supply needs.

FOR has several concerns regarding the proposed amendments.

1. The amendments divides the Rappahannock River basin into 5 regional water supply planning areas (Northern Coastal Plain 1, Northern Coastal Plain 2, Northern Coastal Plain 3, Northern Piedmont 1 and Northern Piedmont 2). This ignores the fact that river basins are interconnected systems where decisions made in one region can have a profound effect on other regions. A whole basin approach would be beneficial to ensure that future water needs are accounted for. The regional water supply plans should be combined into a dynamic plan that is adjusted as conditions in the watershed change.
2. Regional water supply plans need to take into account new land uses and industries that will use large amounts of water. Demand for surface water withdrawal permits are increasing as reliance on groundwater is limited, especially in the Potomac Aquifer.
3. The fiscal capacity of the Department of Environmental Quality (DEQ), local governments and Planning Districts are already strained. Additional funding should be authorized and allocated to help cover facilitation costs for the development of these plans and to combine the plans into a comprehensive dynamic basin wide plan.

FOR looks forward to working with all stakeholders to ensure adequate water supplies exist for all beneficial uses. Comprehensive basin wide planning is essential to achieving these goals.

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