First MFL Public Meeting Heavily Critical

river for mfls In: First MFL Public Meeting Heavily Critical | Our Santa Fe River, Inc. (OSFR) | Protecting the Santa Fe River
Santa Fe River, Nov. 2019 Columbia Co. Photo by Jim Tatum.


Criticism marked the Minimum Flows and Levels (MFL) public meeting on the evening of June 16, as the public, including some respected scientists, expressed many problems with the Suwannee River Water Management District’s (SRWMD, or District) first draft of the new MFL proposal.

The hour-and-a-half-plus telephone meeting started out with a short introduction of the MFLs’ history given by the District’s John Good, followed by  comments from eight interested members of the public. Of these, OSFR was represented by President Mike Roth and board members Merrillee Malwitz-Jipson and your historian. Mike described, among other things, the poor status of the river and thus urged the District follow the Precautionary Principal of striving to err on the side of caution when following uncertain or unknown approaches. This concept was echoed by Lucinda Merritt of Ichetucknee Alliance.  Merrillee spoke as a representative of the owners of the popular river recreation businesses, pointing out that the District has the responsibility of protecting the river to keep it healthy. Several of the principal springs either are no longer used, as in the case of Hornsby since they have a water theme park, or are facing other problems: Poe is now degraded and no longer flows during droughts, Rum has long been out of use for lengthy repairs and the Devil’s Eye System is now facing threat of impairment.

Stacy Greco mentioned that Alachua County had employed the services of Dr. Sam Upchurch, distinguished and prominent expert on MFLs, to submit his detailed comments on the draft. Of considerable weight were the comments of Dr. Bob Knight of Florida Springs Institute. Of his many serious concerns were the over-pumping continuing to be allowed and the inaccuracies of the model used by the District. Dr. Knight says the river’s actual flow is 850 cfs, much lower than the District’s conclusion, and he added “Data don’t lie but models do.” Dr. Bob Palmer echoed concerns of Dr. Knight and urged Dr. Dunn of the Peer Review Panel to elaborate on the impact that reduced flow has on water quality.

Included in the public comments section were representatives from the North Florida Utilities Coordinating Group (NFUCG,) whose first speaker was senior engineer Rick Hutton from GRU. Among his comments was the assertion that the water use of the million-plus people they serve has remained “steady” for 30 years while the population has increased 72 per cent. We are not sure of the definition of “steady,” but he did not say it was a steady increase. GRU is one of the largest water users, as is Jacksonville.

Following the negative (with the exception of NFUCG) public commentary, the three-member Peer Review Panel found plenty more to question. Of the 177 items listed in the proposal, the Peer members tagged over half (92) as significantly serious as to require attention.
Among the most serious flaws pointed out by the panel was the model used by the District. They said the model is poorly calibrated resulting in a 40 to 80 per cent over-prediction at the US 441 gage. This is not minor and echoes Dr. Knight’s statements regarding the inaccuracies of the model.

So serious is this that the panel suggested that the 441 gage cannot be used until it provides more data, and also they stated that the current MFL at Ft. White provides protection.

So we could add, why change it? Surely not so they can re-classify the river as out of recovery? That is one of our concerns which we read in the meeting and as the meeting progressed we saw that it is also the concern of others. Heaven forbid as that would surely facilitate the granting of permits to Seven Springs/Nestle.

Disheartening is that John Good said that any re-classification of the River as out of “recovery” would not happen until months after the setting of the MFL, much too late to help us or the river.  At that point the MFL setting would be history and the river would be vulnerable to even more abuse and depletion.

However we are heartened by the many references  the Peer Review Panel made to the scientists in the public comment, especially Bob Knight and Sam Upchurch, and also the fact that many flaws of a serious nature were identified.

For what that is worth.

A second public meeting is forthcoming and we will keep you posted.

Comments by OSFR historian Jim Tatum.
– A river is like a life: once taken,
it cannot be brought back © Jim Tatum

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