Dozens Speak At DEQ Permit Hearing
A proposed state permit that would allow the Tribrook Club to withdraw millions of gallons of water annually from Woods Creek drew a wide range of public responses last week, from support for increased regulation to sharp criticism over environmental risks, data gaps and public health concerns.
The Virginia Department of Environmental Quality (DEQ) held a public hearing April 23 at Rockbridge County High School, following an information session outlining the draft permit and the agency’s review process. The hearing, which drew over 100 people, marked a key step in a months-long review that is expected to conclude with a final decision in September.
What The Permit Would Do During the information session, DEQ officials described the water withdrawal permitting program as a regulatory framework intended to balance human use with environmental protection.
“The intended purpose is to protect water resources and beneficial uses, which are defined as any instream or off-stream use of a water resource,” said Bryant Thomas, director of DEQ’s Water Resources Division.
Under Virginia law, any surface water withdrawal exceeding 10,000 gallons per day requires a permit. These permits typically run for 15 years and are designed to ensure that withdrawals do not harm aquatic ecosystems, drinking water supplies or recreational uses.
The Tribrook Club, formerly the Lexington Golf & Country Club, is seeking such a permit as part of a broader course renovation and modernization project. According to DEQ staff, the permit is required now due to increased withdrawal volumes, changes to infrastructure and the scope of the redevelopment.
“The requested water withdrawal volumes, changes to surface water infrastructure, and the proposed impacts of the course modernization project are required to have a permit,” DEQ staff member Kaelen Close said.
The draft permit would allow the club to withdraw up to 375,000 gallons per day, with a monthly cap of 9 million gallons. Annual withdrawals would be limited to 45 million gallons during the first two years — a turf establishment period — and 30 million gallons annually thereafter.
It also includes a requirement that a minimum flow of 0.19 cubic feet per second be maintained downstream in Woods Creek, unless inflows drop below that level. In that case, the club would be required to release whatever water enters the system.
DEQ officials emphasized that the permit addresses only water withdrawals and associated construction impacts. Other issues raised by the public, particularly stormwater management and erosion, fall under separate regulatory authority, primarily at the county level.
Still, those issues have been a major focus of community concern.
The permit process began with an application submitted March 28, 2025. A draft permit was released for public comment earlier this year, drawing 110 written comments and 102 requests for a hearing. The option to submit written comments remains open through May 8, after which DEQ will issue responses and hold a second public hearing before making a final decision, expected in September.
What Tribrook And Supporters Say At the hearing, Tribrook representatives framed the permit as a step toward greater environmental responsibility.
Jason Melvin, speaking on behalf of the club, said the permit introduces limits and safeguards that did not exist under previous regulatory conditions.
“The permit we elected to pursue limits the daily, monthly and annual withdrawal amounts and requires flow to Woods Creek at all times, both of which we felt were important to maintaining and preserving the waterway,” Melvin said.
Peter Danaher, the club’s golf course superintendent, echoed that view, describing the previous system as effectively unregulated.
“Under the previous conditions,” he said, referring to when the club was in operation as Lexington Golf & Country Club, “stream flow would be completely mitigated to nothing, and I didn’t feel like that was justified for downstream neighbors that were enjoying the creek.”
Supporters of the project, though few in number that evening, pointed to those changes in permitting and regulation as evidence of progress.
A small group of speakers backed the permit or the club’s overall direction, emphasizing improved technology, responsiveness to concerns and potential economic benefits.
Enrico de Alessandrini praised the club’s modernization efforts and described the permitting process itself as a positive shift away from “an era of zero accountability.”
Steve Chapin, who lives near the course, said Tribrook had shown a willingness to listen and adapt, calling the club “good listeners” making “significant efforts” to be environmentally responsible.
Fundamental Objections
Most speakers, however, voiced opposition, several of which challenged the premise of the project itself.
Ann Nelson, a certified water monitor, described Woods Creek as a shared community resource already under strain.
“I think that Woods Creek is one of the gems of Lexington. And I enjoy walking the stream, which is often, very, very often, barely a trickle that goes through our town,” she said.
“I think that any organization that can spend $25 million to $30 million on building a brand new golf course should be able to spend money to get water, rather than taking it from a community resource that is already impaired and depleted.”
Others framed the issue in moral or communal terms.
“Woods Creek was there before the golf course was built. Like me, [the course] is the creek’s neighbor, and good neighbors take care of their neighbors,” said Connie Janine, a longtime resident of that area.
Several speakers also highlighted the creek’s visibility and role in daily life, particularly for children.
“There are two schools on the creek: there’s a preschool, there’s an elementary school. There are two universities on the creek. This is going to impact a lot of people, said Caroline Coons.
She added: “I work with children … When I told a group of people I was coming, a 10-year-old spoke up and said that he had been with his class testing the water last week and he found high nitrates. And he said, ‘That means there is fertilizer in the water.’ And then he said, ‘And we found a lot of dead waterpenny beetles.’”
Technical Critiques
A larger and more technically detailed set of comments focused on the permit’s specifics, with several scientists and environmental professionals arguing that it is based on incomplete or flawed assumptions.
Barbara Walsh, a hydrogeologist, summarized a central concern shared by multiple speakers.
“In this case, of an already impaired stream … the permit must take into account that water volume is not independent of water quality,” she said.
“As currently drafted, the permit appears to continue past practices and may even allow greater withdrawals without adequate safeguards.”
Several speakers questioned whether the withdrawal limits were appropriate given the creek’s actual flow, with multiple comments pointing to the data and modeling used to support the permit.
John Pancake, a certified water monitor, pointed to the proposed increase in annual withdrawals.
“This permit allows 30 million gallons a year. And in the first two years, 45 million gallons — two and a half times the historic use, even though there may be less water coming in,” he said.
Underlying those concerns was a broader critique raised by several speakers: that DEQ’s modeling relies in part on flow data from Kerrs Creek, a different local waterway, rather than sitespecific measurements from Woods Creek itself.
Geologist David Harbor argued that comparison may be fundamentally flawed due to differences between the two watersheds.
“The low flow stream statistics for the seven-day, 30-day, 10-year drought flows are well below the 0.19 cubic feet per second that would be necessary to keep Woods Creek supplied,” Harbor said. “So the golf course would not be required to release that, because I don’t think that kind of flow is coming in.”
Harbor and others said Kerrs Creek differs significantly in both geology and hydrology, including its underlying rock structure and base flow characteristics. Woods Creek, by contrast, flows through a “karst landscape,” which means water movement between surface and groundwater systems is more complex and less predictable.
That concern was echoed by multiple speakers, including Morris Trimmer and Jamie Goodin, executive director of Rockbridge Conservation, who called for direct flow measurements within the Woods Creek watershed rather than reliance on extrapolated data.
Without site-specific data, several argued, the permit’s withdrawal limits and minimum flow requirements may be based on assumptions that do not accurately reflect real conditions, particularly during droughts, when stream flow is already limited.
Public Health Concerns
A third category of comments focused on contamination issues that fall largely outside the permit’s scope but remain central to public concern.
Multiple speakers cited testing showing pollutants in groundwater wells on the property.
“Evidence of legacy chemical pollution has been found in recent testing of the two wells on the property. One is contaminated with extremely high levels of lead and the other with extremely high levels of PFAS,” said Gretchen Succo.
“Although the latter well is being decommissioned, the polluted water remains and will likely continue to make its way untreated to the rest of the aquifer.”
Cathryn Harbor, a physician, emphasized the potential health implications.
“PFAS are called forever chemicals because they do not break down in the environment. They do not break down in our bodies,” she said.
Toxicologist Joe DiNardo raised additional concerns about how contaminants could spread.
“All of this water, as it comes up out of the ground contaminated and reused, revolatilizes these chemicals, so they will aerosolize and can travel as far as 25 miles in the air,” he said.
Other speakers described visible environmental changes in the creek.
“It’s been very disturbing to see the rise of sediment levels in the creek and to learn about what we can’t see: the effects of chemical pollution on aquatic life and on the safety of local wells,” said Cinder Stanton.
Throughout the hearing, speakers repeatedly returned to the broader question of whether the permit, as drafted, fulfills DEQ’s stated goal of protecting water resourced.
“Literally hundreds of local citizens have volunteered countless hours for years to try to improve the health of the creek and the ecosystems that depend on it,” Succo said.
“I don’t think anyone here can say they believe the golf course has had a positive or even a neutral influence on the health of the creek.”
With written comments accepted through May 8, DEQ officials said the agency will review all submissions and issue formal written responses to all commenters. A second public hearing, focused on those responses, will then be scheduled, intended for anyone who previously submitted comments to give their own responses. The agency is expected to make a final decision on the permit in September.
