Protest of DEQ's Permit Authorizing Caroline County's Water Intake Application

The Virginia Department of Environmental Quality (DEQ) has made a tentative decision to grant Caroline County’s application to build and operate a water intake structure that will initally withdraw on a continuous basis 7.90 million gallons from the Rappahannock River, increasing to a maximum of 13.90 million gallons per day. This is a multi-year permit with a term of 15 years during which period the maximum volume of water authorized by DEQ could be increased.  

The ECCA, Friends of the Rappahannock, the Rappahannock Tribe, and other conservation groups have expressed strong concerns over Caroline’s actions and the impact its water intake structure will have on protected aquatic species of life in the Rappahannock such as striped bass, shad, herring, and sturgeon.

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Caroline’s water intake proposal calls for the use of millions of gallons of Rappahannock water earmarked for an industrial purpose that serves economic and political goals, not the water usage needs of Caroline’s residents or the traditional “municipal public water supply” needs of the county. ECCA has also raised additional concerns in ledtters and FOIA requests to Caroline and DEQ that have largely been ignored. A full list of ECCA’s concerns is attached for your review. Understand clearly that the millions of gallons of water Caroline proposes to take from the Rappahannock is not because the water is necessary for the current public service needs of its residential population or even its projected public service needs for residential growth. Instead, millions of gallons will be used to support Caroline’s goals for industrial development which include massive data centers that on average use hundreds of thousands of gallons of water each day to cool electronic sensors. Data centers are clearly not public service entities and the water they require should not be labeled or disguised as a “municipal public water supply” need. Yet this is exactly what DEQ has done in the draft permit it has tentatively approved. In short, Caroline’s water intake proposal calls for the use of millions of gallons of Rappahannock water earmarked for an industrial purpose that serves economic and political goals, not the water usage needs of Caroline’s residents or the traditional “municipal public water supply” needs of the county. If allowed, Caroline’s permit would establish a dangerous precedent with far reaching consequences to the Rappahannock and other rivers in Virginia. To understand the danger to rural Virginia and its rivers, realize that the data center expansion in Northern Virginia where more than 200 data centers are already located or planned is continuing. It now includes Spotsylvania, Stafford, King George, Caroline, Louisa, and Hanover with no end in sight. Each data center has sensors that must be cooled and water is the cheapest way to do this.

ECCA will file its letter opposing Caroline’s permit application and we are urging our board members and others to take the same action. Individual protest letters by our members are important because they must be accepted and considered by DEQ, whereas a protest letter by ECCA may be viewed as a single protest. The more protest letters filed, the better our chances are of stopping the issuance of the water intake permit Caroline is seeking.

If you share our concerns over Caroline’s water intake proposal and the dangerous precedent it sets, please consider submitting your own protest letter to DEQ by email addressed to Eric Seavey at Eric.Seavey@deq.virginia.gov. Mr. Seavey has replaced Elizabeth Gallup, the person listed in DEQ’s public notice, as the DEQ contact person to receive public comments. Ms. Gallup has left the agency. If you have already sent your protest comments to Elizabeth Gallup, you should consider resending your comments by email or regular mail to Mr. Seavey. Time is of the essence. Your protest comments must be received by DEQ on or before June 18, 2024. ECCA recommends that you also send a copy of your protest letter by email to Randy Owen, the Habitat Manager of the Virginia Marine Resources Commission. Mr. Owen’s email address is Randy.Owen@mrc.virginia.gov. Please be sure to list the VMRC and DEQ case numbers on your letter. The case number for VMRC is JPA #2020-0514 and for DEQ is VWP #20-0514. If you choose to mail your protest letter which may be easier, the mailing addresses for VMRC and DEQ are as follows:

*Randy Owen, Habitat Manager, VA Marine Resources Commission, Building 96, 380 Fenwick Road, Ft. Monroe, VA 23651
*Eric Seavey, Manager, Water Withdrawal Permitting, VA Department of Environmental Quality, P.O. Box 1105, Richmond, VA 23218, street address 1111 E. Main Street, Suite 1400, Richmond, VA 23219

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Your individual protest letter does not need to be lengthy. Your opposition expressed in your own words is what is most important. It is also important that you request DEQ to schedule a public hearing where the concerns of citizens can be voiced and heard.

Thank you.

Lisa Mountcastle 

Hill Wellford

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