Florida Springs Council Supports Citizens’ Challenges to the Proposed Silver Springs Minimum Flows and Levels


The Florida Springs Council has released the following:

Florida Springs Council Supports Citizens’ Challenges to the Proposed Silver Springs Minimum Flows and Levels

Contact: Dan Hilliard
President, Florida Springs Council

Margaret Stewart, Esq.
Legal Chair, Florida Springs Council

May 8, 2017

HIGH SPRINGS, FL – On May 3, Putnam County resident Karen Chadwick filed a petition with

the State’s Division of Administrative Hearings (DOAH) to invalidate Proposed Rule 40C-

8.031(7) – the Minimum Flows and Levels for Silver Springs. Minimum flows and levels are

established for water bodies to prevent significant ecological harm as a result of groundwater

and/or surface water withdrawals.


The Florida Springs Council (FSC) strongly supports Ms. Chadwick’s petition.

Utilizing authority granted in the 2016 water legislation, the St. Johns River Water Management

District Board approved both emergency and permanent MFLs on April 11. On April 28, several

parties filed a petition to invalidate the emergency MFL. Subsequently, Administrative Law

Judge E. Gary Early denied the District’s Motion to dismiss that petition.


Ms. Chadwick’s petition is aimed at overturning the permanent MFL. DOAH will hear the

emergency rule challenge in Palatka on May 11-12, and Ms. Chadwick’s petition will likely be

heard by DOAH this summer. Ms. Chadwick’s petition notes that Silver Springs historically had

the distinction of having the highest long-term measured flow of any spring in the U.S.A. But

over the past four decades it has lost more than one third of its historic average flow. The Silver

River no longer has a white sandy bottom and crystal clear water; flow has diminished so much

that what was shimmering white sand 20 years ago is now a bottom covered by excessive growth

of submerged plants and filamentous algae. As a direct result, fish populations in the Silver River

have crashed and the aesthetic beauty of the springs is greatly diminished. The State’s proposed

MFL attributes very little of the reduced flow to groundwater pumping, while both challenges

assert that pumping is a significant factor in the flow reductions and overall degradation of Silver



Both petitioners will challenge the scientific basis of the District’s conclusions, as well as the

validity of the groundwater models on which the District’s conclusions are based. And, given the

fact that the adopted MFL for Silver Springs has not been met in 15 of the past 16 years, both

challengers will assert that it makes no sense to approve an MFL which would intensify harm to

this priceless natural wonder.


Dr. Robert Knight, the Director of the Florida Springs Institute and a Board Member of the

Florida Springs Council, has studied Silver Springs for nearly 40 years. “The proposed MFL is a

travesty of regulatory capitulation to special interests,” noted Dr. Knight. “The only path to

restoration of the ecological and economic importance of Silver Springs is a regional reduction in

groundwater extractions, not additional excessive depletion of its life blood.”



  1. Thank you Karen, Bob and members of the FSC. I wish I could be there to cheer you on! We tried to stop the MFL on April 11 in Eustis, but failed in spite of the large number of public comments against the continued water withdraw. Litigation seems to be the only way to stop it.

  2. Thank Heaven for people like Karen and Bob. The current political climate in Florida is almost anti-environment. The current administration and legislature has gutted environmental regulation and decimated the staff of responsible scientists that used to offer a degree of sanity and reason in the Water Management Districts, as well as the FDEP. Education of the voting residents of our state is the only way to halt this assault on the environment and the future quality of life for all Floridians

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