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/