I am Alexander Jarvis, founder and president of the Society for a Secure and Sustainable Water Future (S4SSWF), a Virginia nonprofit focused on rainwater harvesting and water reuse. Our work includes practical installations and advocacy to reduce unnecessary demand on drinking-water supplies. S4SSWF supports DEQ’s effort to clarify grandfathered surface-water withdrawals. We encourage a consistent, documented method for quantifying these withdrawals, with reporting that clearly distinguishes actual use from infrastructure capacity and projected demand. These distinctions are essential for reliable water-supply planning and protection of river ecosystems.

As DEQ develops the related water-supply planning amendments, we urge the agency to explicitly include rainwater harvesting among the alternative supplies evaluated when addressing increased demand. Captured rainwater, appropriately treated for its intended use, can replace potable water for irrigation, toilet flushing, and suitable cooling applications. Where it displaces water supplied from rivers or reservoirs, it can reduce surface-water withdrawals. This evaluation should be practical and measurable. Plans should identify suitable uses and estimate achievable reductions in withdrawals. They should account for seasonal rainfall, storage capacity, treatment requirements, and backup supplies during dry periods. Annual rainfall totals alone should not be treated as proof that rainwater can reliably meet demand throughout the year. DEQ should also consider cumulative withdrawals and low-flow conditions when developing these amendments. Clearly accounting for existing withdrawals helps communities understand their available supplies and evaluate whether conservation or alternative sources could reduce the need for additional withdrawals.

Finally, we encourage DEQ to clarify how voluntary conservation and alternative-water use affect grandfathered status, consistent with statutory authority. Users should have clear guidance so uncertainty does not discourage investments that reduce demand. Rainwater harvesting will not meet every water need, but it deserves explicit consideration as a practical resource within Virginia’s water-supply planning. Thank you for considering these recommendations. S4SSWF would welcome opportunities to contribute implementation experience as this rulemaking develops.