The James River Association (JRA) supports the Surface Water Withdrawal Intake Design and Operation Standards outlined by the Virginia Department of Wildlife Resources (DWR). These standards, developed in concert with experts over the course of several decades, reflect a commitment to safeguarding Virginia’s natural resources and minimizing the impact of water intake projects on aquatic organisms.

These water intake design standards, including the use of screens with openings no larger than 1 millimeter and approach velocities not exceeding 0.25 fps, are necessary design improvements, aimed at reducing impingement and entrainment, crucial for protecting the earliest life stages of aquatic species. The inclusion of sweeping velocity considerations further underscores a thorough approach to project design, demonstrating a nuanced understanding of the diverse needs of aquatic ecosystems.

Moreover, in circumstances where strict adherence to these standards is not feasible, applicants may engage in site- or system-specific analyses in collaboration with resource agencies. This flexible approach, including literature reviews, empirical data collection, and mitigation methods, allows for adaptation while ensuring the protection of aquatic fauna and their habitats.

Additionally, JRA encourages DWR to consider the cumulative impacts on affected species in the permit issuance process. This step would further foster responsible environmental management and allow the department to make informed decisions that prioritize the conservation of biodiversity. This proactive approach will not only enhance ecological sustainability but also demonstrate a commitment to preserving Virginia's natural heritage for the enjoyment and benefit of current and future generations.

Thank you for the consideration of these comments.