Comment on the xAI Water Recycling Permit

email advocacy

Dear TDEC,

Dear Division of Water Resources,
Thank you for the opportunity to comment on the draft permit for the proposed water recycling facility at the CTC/xAI site (No. SOP-24025). I appreciate that this draft includes critical safeguards and clearly limits the use of reclaimed water to non-potable cooling purposes.
This project has the potential to significantly reduce groundwater pumping — with a peak demand of up to 13 MGD spared from the Memphis Sand Aquifer — and could set a positive precedent for industrial-scale water reuse in Memphis.
That said, I submit this comment with strong caution given xAI's contentious presence in the community and the need for full transparency and accountability. I encourage TDEC to consider the following points:
 Part 1 – Permit Content
1.3 End User Agreement Conditions
<ul>
<li>Water quality standards are mentioned.</li>
<li>Comment: Will this water quality data be made publicly available? Transparency is key.</li>
<li>Comment: Appreciate that reclaimed water is restricted to cooling purposes only.</li>
</ul>
1.4 Additional Narrative Conditions
<ul>
<li>Comment: Glad to see the explicit prohibition on potable use. Please ensure this is strictly enforced.</li>
</ul>
Part 2 – Oversight and Records
2.1.5 Availability of Report
<ul>
<li>Reports are to be retained for three years.</li>
<li>Comment: Is this standard practice, and will TDEC maintain a public archive? Public access to reports would help build trust.</li>
</ul>
Additional Comments:
<ul>
<li>I appreciate that TDEC uses “purchase” language recognizing the City of Memphis as the source of wastewater effluent. This clarifies the regulatory framework.</li>
<li>I remain concerned about water use and potential groundwater impacts at xAI’s second facility in Whitehaven. Will a similar permit be required there?</li>
<li>I encourage the City of Memphis to determine a rate to sell xAI the effluent as mentioned in the permit draft and consider workforce development and educational tour opportunities.</li>
<li>Lastly, I urge TDEC to incorporate environmental justice considerations into this and future industrial permitting decisions, especially for communities already burdened by pollution.</li>
</ul>
Thank you again for your work and for allowing public comment on this important issue. I urge TDEC to engage the public and protect Memphis’s most vital resource — the aquifer.
Sincerely,

Sincerely,

[Your Name]

[Your City & State]

Send me occasional emails about this issue

Summary

While many community concerns remain about xAI, there has been one piece of progress that could be a win for the Memphis Sand Aquifer — and it needs your input. 🚨 What's Happening? xAI is proposing to build Memphis’ first large-scale industrial water recycling facility, designed to reuse treated wastewater for cooling operations at xAI, TVA, and Nucor Steel — instead of pumping fresh groundwater from the aquifer. This project represents: <ul> <li>Reduced aquifer pumping at an industrial scale.</li> <li>A first-of-its-kind water reuse project for Memphis.</li> <li>A potential model for sustainable industrial water use in our region.</li> </ul> ⚠️ Why We’re Watching Closely We know xAI’s arrival has raised serious concerns, and we share many of them. But we also believe it’s important to recognize steps in the right direction — and hold them accountable to follow through. We have requested a public hearing and expect that to happen in late June. Here's your opportunity to submit a comment and make sure the community has an opportunity to learn and have a say! For more information, check out our fact sheet here: https://drive.google.com/file/d/1sG17vmzt7FrrwK16DbJ0blU98vE1594O/view

Who will receive your email?

Division of Water Resources TDEC