Thank you for this opportunity to comment on the proposed Amendments to the Local and Regional Water Supply Planning Regulations (9 VAC 25 780).   As the organization responsible for water supply to serve the City of Charlottesville, County of Albemarle, Town of Scottsville, and Albemarle County Service Authority, the Rivanna Water & Sewer Authority is fully in support of the amendment’s objective to ensure that adequate and safe drinking water is available to all citizens of the Commonwealth.  We would have concern about water sharing projects becoming mandatory in the future.   To strengthen and clarify this effort, we have the following comments on the proposed amendments:

• We expect the VDEQ Planning Staff to provide support in determining who the voting members of the Regional Planning Unit will include (City, Counties, Towns, TJPDC, Authorities (RWSA and ACSA), and the weighting of these votes.   There are five incorporated towns within the RPU including Dillwyn, Louisa, Mineral, Stanardsville, and Scottsville.   We also want to better understand the official role of the stakeholder groups within the RPU.

• Suggest broadening the definition of unaccounted water to match AWWA Water Planning guidance.  (additional categories – metered / billed; metered/ unbilled; unmetered / billed; unmetered/unbilled).

• Does the definition of “water supply risk” preclude rare droughts that may be worse than the current drought of record?      (9VAC25-780-30)

• Definition of “self-supplied user” – Needs to include other users in addition to “person” such as utilities, agriculture, industry, power generation, or industry making a withdrawal of surface water or groundwater from an original source (e.g. a river, stream, lake, aquifer, or reservoir fed by any such water body) for their own use.  Can this list be correlated to the list of users on VA Hydro?

• There is a discontinuity between water supply planning for 30 years via the Water Supply Planning process and the limit of 15-year permits within the DEQ VWP process. (9VAC25-780-30).

• What considerations led to the development of the different RPUs (9VAC25-780-30)”?  Were these RPUs based on watersheds?  If multiple watersheds were in different regional planning areas, what were the factors to include a locality in one RPU over another?

• If a local government does not have the required information and “additional studies shall not be required”, what will be included in the plan for that locality (an estimate or just a note indicating no data was available)? (9VAC25-780-50.C)

• Contact with all community, non-community, agricultural, industrial, power generation and self-supplied water systems should be made by DEQ rather than by the local government. 

• 9VAC25-780-70 (and 80 & 90).  Much of the requested existing information should be provided by VDEQ or VDH.

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