Commenters urge more feasibility and cummulative impact studies, during a public hearing on Caroline County’s plan to pump millions of gallons a day out of the Rappahannock River.
The Department of Environmental Quality (DEQ) held the hearing on November 6, to once again address Caroline County’s application. Currently on its second draft, the request proposes up to nine million gallons of water a day from the Rappahannock River and pumping it approximately 35 miles to a water treatment facility in Carmel Church. Water is to be processed to use as public water supply for residential, commercial and economic development needs in Caroline County.
Remaining waste water will be dumped into the Mattaponi River.
Commenters aired a myriad of concerns regarding the proposed permit as it currently stands.
Revisions were made to the initial application in response to prior public comments, however some aspects of the revised permit were still deemed unsatisfactory in the eyes of those who came forward. Most oft-repeated concerns included the lack of comprehensive cumulative studies to be completed before permit issuance.
This permit draft requires completion of a feasibility study on the possibility of returning water back to the Rappahannock River, or reducing interbasin transfer to the Mattaponi River, within five years of permit issuance.
Commenter Brent Hunsinger, advocacy and coastal programs director for Friends of the Rappahannock, countered available reductions or eliminations resulting from the study should be included in the design and construction process.
“Issuance of the permit beforehand removes any incentive for due diligence regarding the feasibility, and reduces the likelihood that feasible options for returning water to the Rappahannock would likely be implemented,” Hunsinger said.
In this draft, DEQ said prior feasibility study completion is unnecessary because of the overlap in projected timelines. The applicant, Caroline County Public Utilities, predicts completion and implementation of this project will take roughly seven years. The feasibility study is set for five years to study future effects, in theory reflecting the progress of the water pumping project.
Commenter Pat Calvert, Virginia director of conservation for American Rivers, disagreed with DEQ’s previous response. He and other commenters emphasized the importance of completing studies prior to issuance.
“That reasoning is very unclear. That still doesn’t make sense to me. Five years seems like an awfully long time,” Calvert said, in reference to the studies’ completion deemed unnecessary.
Calvert said there needs to be clarity on who determines feasibility listed in the permit.
Additionally, commenters urged cumulative impact studies of surface water intake to influence the permit.
Cumulative impact studies, to be conducted by Virginia Institute of Marine Science (VIMS), aim to measure salinity levels, water quality and fish mortality rates as a result of the overall amount of water withdrawals from the Chesapeake Bay area.
Similar to concerns with the feasibility studies, the VIMS studies are projected to finish by 2028, and commenters argued results should be analyzed before permit issuance.
Hill Wellford Jr., a landowner in Richmond County, has made several appearances at public comment hearings for the Caroline County Water Project. While urging the importance of comprehensive cumulative studies, Wellford pointed out the emergence of industrial data centers built or being built in the Chesapeake region.
“The question I have is, do you know how much water these data centers are going to require?” Wellford asked.
Every data center, he told the DEQ, will source water from the Rappahannock River.
While industrial cooling for data centers was removed from the list of approved water usage for this specific project proposal by Caroline County, Wellford suggested the DEQ should not continue to merely look at each application individually.
This is not the only permit to propose millions of gallons of surface intake from the Rappahannock River. A well informed study would consider the implications of all water withdrawals to the whole Rappahannock River Basin, Wellford argued
“All you have to do is go look, and you can’t ignore that it’s taking place,” Wellford said. “But you are ignoring it in these decisions, because you’re looking at it in isolation, as though it’s the only intake that you have to be considerate of. But it’s not. It’s one of many.”
Considering factors like climate change and other surface intake projects, Wellford argued a hastened analysis of one project’s effects could not reflect potential future impacts.
“We shouldn’t be in such a hurry that we’re going to damage the river and have lasting consequences on people’s water. Let’s get the study done,” he said.
In terms of cumulative impact studies, salinity testing methods were previously developed by the DEQ using multiple linear regression models in coordination with VIMS. Furthermore, VIMS developed a three-dimensional hydrodynamic model of the Rappahannock River to gauge salinity levels while pumping 13.9 Mgal/d, the proposed amount of water in the original permit draft.
The study concluded this withdrawal volume “would not cause significant changes in the salinity distribution within the Rappahannock River,” according to the DEQ’s Summary of Public Comments and DEQ Responses for the Surface Water Withdrawal Permit for Caroline County Project from October 22, 2025.
Some commenters, such as farmer Cory Garrett, countered that this study was conducted in a controlled environment not indicative of the nature of the Rappahannock River.
Joseph McCauley, advisor for the Chesapeake Conservancy, was the last speaker of the meeting. His closing remarks reiterated the need for thorough, comprehensive studies to influence permit issuance.
“I’m very concerned that this permit is about to be issued without the full understanding and information that DEQ should have, and would have, if these studies are referenced were available today,” McCauley said.
The proposed permit for the Caroline County Rappahannock River Water Supply Project will either be approved, revised or dismissed by the DEQ in response to this public hearing. A decision should be reached around December 24, 2025.
DEQ Communications Manager Irina Calos said the organization will carefully consider all public comments heard at the meeting to inform their decision.
“What’s clear is that everybody cares about the environment and about this permit action, I would be on the side of saying ‘We’re all on the same side.’ We all care,” Calos said.
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