Dear Mr. Norris:

The Eastern Shore of Virginia Groundwater Committee supports the efforts to enhance the Water Reclamation and Reuse Regulations in order to promote and encourage the beneficial use in a safe and protective manner.  Because the freshwater resource on the Eastern Shore of Virginia is restricted to groundwater, the EPA has designated Accomack County and Northampton County a Sole Source Aquifer area.  As a consequence, we are very interested in measures that enhance sustainability of our resource including measures that 1) reduce use of the fresh groundwater resource; 2) promote recharge to the groundwater; and 3) prevent saltwater intrusion.  To that end, there are a number of processes and technologies falling under water reclamation and reuse that, with proper implementation, can support these goals.  These processes and technologies were the subject of the Groundwater Recharge Stakeholder Advisory Group facilitated by VDEQ last year, and include underground injection; on-site sewage systems; stormwater recharge; and aquifer storage and recovery.  As discussed by the Advisory Group, many of these have a direct relation to water reclamation and reuse but are not addressed in regulations in a form that promotes or encourages their use.  We hope VDEQ, following promulgation of this amendment, will continue to consider avenues to promote and encourage use of these processes in order to support a more sustainable groundwater resource.

If you have any questions or comments, please do not hesitate to contact me at (757) 787-2936 or csmith@a-npdc.org. 

Very truly yours,

Curtis W. Smith

Director of Planning