Permit question

Page 6 specifies three “tiers” of water withdrawals and the areas to receive that water. Tier 1 includes Zion Crossroads. Tier 2 is all Louisa. Tier 3 includes “Fork Union, Columbia and Palmyra…”
Page 7 sets deadlines to have infrastructure in place:
“Tier 1: The permittee shall submit to DEQ… by January 1, 2018 written confirmation that capital improvements… are complete…”
“Tier 3: The permittee shall submit to DEQ… by January 1, 2023 written confirmation that capital improvements are complete…”
Capital improvements, says DEQ, “shall include infrastructure such as pipelines, water treatment plants and associated storage facilities.” Fluvanna also requires a sewage treatment plant and an outfall – and, as Nichols stated at the public hearing, “A sewage plant is an expensive proposition.”
Sure, Fluvanna could beg more time in meeting DEQ’s mandates, but there are consequences – the risk of forfeiting some of Fluvanna’s precious water allocation. The permit stipulates, “Any such request will require a modification of the permit… to adjust the withdrawal volumes for a particular Tier.” In other words, use it or lose it.
Even if Fluvanna gained a couple years’ leeway, that’s still major infrastructure in a hurry. And then we’ll face the choice of relinquishing some of Fluvanna’s hard-won water or spending big bucks to keep it.