This is the last meeting for the MFLs on the Lower Santa Fe and Ichetucknee rivers. The third draft of the Suwannee River Water Management District’s proposed MFLs has now been reviewed by the Peer Review Committee.
SRWMD still gets a failing grade from the Peer Review Committee. There are some parts they agree to, but the most critical component and reason for being of the MFL is to PREVENT SIGNIFICANT HARM to the river and springs. And this is not adequately assured, and was the major flaw criticized in last revision .
More criticism from the Committee:
The MFL setting process is incomplete and must be redone. The District persists with the sole approach to setting metrics for the Water Resource Values being the 15% reduction. This number was used elsewhere once or twice and now the District wants to adopt it as a standard to use everywhere, but there is no reason for that except it helps them reach their numbers, and there is no reason to use it here and no reasons given. This extremely important criticism and others were voiced in the last revision but continue to remain unaddressed. Does this mean the District plans to continue to ignore them?
District should consider “duration and return interval of both low flow and high flow events in addition to cumulative frequency.
Clearly identified water quality concerns are ignored and left out of consideration. This is akin to leaving out information that does not lead to a conclusion that you want. This is intellectual dishonesty and environmentalists and scientists have made these accusations before regarding water district staff.
Climate change is also left out, and this may affect MFL sustainability.
BEST SCIENCE NOT BEING USED. REFERFENCE BOOKS OUT OF DATE. District needs to update their scientific literature bibliography.
Uncertainties not managed nor planned for, adaptive management framework lacking, same criticism as 2013.
Clearly the Peer Review Panel deems the current MFL draft proposed by the District as failing in its primary purpose, which is to protect the Lower Santa Fe and Ichetucknee rivers and primary springs. Serious flaws were addressed in the previous revision of the Peer Review and they continue to be ignored. It is thus apparent that the District has not and will not take advantage of the opportunities to correct the flaws. Given this we can only say that there is no possible way the District can pretend that the Santa Fe River is meeting its required MFLs and therefore its categorization cannot be upgraded.
This an important meeting and the District needs to hear from the public. If the District re-classifies the Santa Fe River as meeting its MFLs, that will make it easier for Seven Springs/Nestle to get their permit. Please go to https://bit.ly/3mxq8Sn and register to speak at the meeting on Thursday, Sept. 29, 2020 and simply ask them to keep the river classified as “in recovery,” which it truly is. It is flowing between 30 and 40 per cent of its historic flows and has already suffered significant harm because of over-pumping, yet the District continues to give out pumping permits.
Comments by OSFR historian Jim Tatum.
– A river is like a life: once taken,
it cannot be brought back © Jim Tatum
On September 18, 2020 at 09:54AM, Suwannee River Water Management District published the following article:
Residents and stakeholders who would like to participate in the Lower Santa Fe, Ichetucknee and Springs Minimum Flows and Minimum Water Levels Peer Review meeting on Sept. 29 at 6:00 PM are able to register on GoTo Webinar at https://bit.ly/3mxq8Sn.