DEQ's Regional Water Supply Planning Guidance Document provides very little actual guidance. It is mainly a collection of quotes from the regulations. At times, that much is not even provided, and instead, users are only given a reference to the regulations, as if RPUs are not aware they exist. I had hoped to see a plain English step-by-step guide with suggestions that incorporates all the other documents and spreadsheets into a coherent process. This feels more like box-checking to rush the document out to meet a deadline. Overall, we have found this guidance document to be of very little help to our regional planning process, and I strongly urge DEQ to overhaul it, preferably with input from the RPUs.

A letter of comment on the subject guidance has been submitted to Hannah Somers by email from Fairfax Water.

The proposed regulation need to better address two key concerns:

1. Fracture bedrock aquifer of the Blue Ridge Province:  The local concerns, specifically, those areas along the Blue Ridge Province in Virginia, need better attention in the determination of water demands. Specifically, there are about 75,000 residents who are solely dependent on groundwater.  Most are private wells and about 1/3 of the residents rely on small towns and community systems.  Based on the proposed regulations, this leaves nearly 50,000 residents not accurately accounted for in the water demands.
2. Drought impacts: In the Blue Ridge Province the groundwater in fractured bedrock is not accurately assessed and monitored to determine drought conditions.  A significantly greater density of monitoring wells and other metrics are needed.  Simply addressing those wells producing more than 300,000 gallons per month omits and overlooks the residential wells.   There are no meaningful contingencies for these private wells, therefore early warning and public outreach is critical.  This situation is especially true in western Loudoun County where 2/3 of the groundwater in withdrawn from 17,000+ smaller residential wells.

Reference: Assessment of the Groundwater Supply in Loudoun County, VA, August 25, 2025  https://loudouncoalition.org/loudoun-county-groundwater-study/

David Ward

Lovettsville, VA

While much of the Northern Virginia region relies on surface water, in western Loudoun, community wells provide water supply for about 1/3 of the demand on groundwater at more than 300,000 gallons per month. Residential wells account for about 2/3rds of the demand along with wells for rural businesses. 

For comprehensive water supply planning, there should be more direct groundwater data analysis available and included in the plan for the entirety of the demand. Further, a focus on educational outreach as part of water supply planning is needed to help increase awareness of the limitations of groundwater. It is important not only for those individuals and businesses who are dependent on it, but also for decision-makers who must decide on proposals for large commercial uses that are proposed to develop on groundwater resources. A lack of adequate data and a related understanding could result in diminishing water supplies for both the proposed use and for those in nearby areas who may see their wells impacted and may have no recourse but to drill additional wells at great expense.

Drought response strategies for groundwater are different from those for surface water users and so far, are inadequate to help communities avoid risk as climate change impacts precipitation patterns.

A recent independent report published in Loudoun County describes existing analysis and reason for concern about decreasing groundwater levels. It points to the need for more proactive analysis as a risk reduction strategy. The risk of inadequate information is that expensive solutions may become needlessly unavoidable.  

The need for greater groundwater analysis and guidance for usage and drought response planning is true across Virginia, and is appropriate in statewide water supply guidance.  

While we appreciate DEQ’s efforts to strengthen statewide water resource planning, the current draft would benefit from clearer guidance and stronger consideration of regional conditions, particularly within the Blue Ridge Province.

Communities in this region rely almost entirely on groundwater drawn from fractured bedrock aquifers, which behave very differently from the more uniform groundwater systems that have informed much of Virginia’s groundwater management framework. Approximately 75,000 residents in this area depend on groundwater—most through private wells, with about one-third served by small town or community systems. As currently structured, the proposed regulation does not appear to fully account for these populations in its assessment of water demand.

The fractured bedrock aquifer of the Blue Ridge Province is also highly susceptible to drought, yet current monitoring and assessment approaches overlook this vulnerability. A greater density of observation wells and more comprehensive drought indicators are needed to provide accurate early warning and planning data. Limiting monitoring to high-volume wells (>300,000 gallons per month) omits the small residential wells that represent the majority of withdrawals in western Loudoun County and similar areas.

We also recommend that DEQ establish mechanisms for integrating locally generated groundwater studies and monitoring data, such as the Assessment of the Groundwater Supply in Loudoun County, VA (Loudoun Coalition on Groundwater, August 25, 2025 - https://loudouncoalition.org/loudoun-county-groundwater-study/), into statewide analyses. Finally, including guidance on communication and contingency planning for private well owners would greatly strengthen public awareness and resilience during drought conditions.