Stacie Greco from the Alachua County Environmental Protection Department has graciously given us permission to post this letter which she read to the Suwannee River Water Management District Board of Directors on December 12, 2023 in Live Oak.
Scientists for the State of Florida know that there is simply not enough water for our current status let alone the tremendous growth predicted in this Regional Water Supply Plan.
The State has no solution to restore the Santa Fe and its springs and the current policy is to continue to allow them to decline in slow and purity. Yet our water management districts continue to give out pumping permits as if we were not in a water crisis in North Florida.
There is no concern by Florida legislators nor water decision-makers for future generations who will need clean water which will not be there if we continue current policies.
Comments by OSFR historian Jim Tatum.
jim.tatum@oursantaferiver.org
– A river is like a life: once taken,
it cannot be brought back © Jim Tatum
Alachua County Environmental Protection Department
Stephen Hofstetter, Director
December 11, 2023
Florida Department of Environmental Protection, Suwannee River Water Management
District, and St. Johns River Water Management District.
Re: North Florida Regional Water Supply Plan (NFRWSP) Public Comments
To Whom it May Concern,
Alachua County is committed to protecting groundwater resources and continues to provide
input on the North Florida Water Supply Plan (the Plan) and the Lower Santa Fe and
Ichetucknee rivers Minimum Flows and Levels (MFLs). Below are our comments on the final
NFRWSP materials that were released November 2023.
This is a helpful planning tool that documents the alarming scale of the projected growth in
this region – a 49% increase by 2045. The demand on groundwater is expected to increase
by 135 million gallons per day (MGD). The Plan reminds us that our current pumping has
already exceeded the sustainable yields of the aquifer, and that new demand will have to be
offset to prevent further harm.
The Plan illustrates the status quo scenario in which we use substantial taxpayer money to
pay for expensive projects rather than adopt policies to reduce demand. It lists projects to
offset 143.6 MGD as water supply/resource development at an estimated cost of $2,170.4
million and 16.8 MGD as water conservation projects at an estimated cost of $57.5 million.
While we applaud the local governments, utilities, and water management districts for their
efforts to identify these projects, it is clear we are missing an opportunity to shift our approach
and are underutilizing our most cost effective and proven tool of regulatory measures to
reduce demand.
At a fraction of the price of water supply/resource development projects, we could implement
quantifiable water conservation programs to achieve even greater reductions. We now have
tools to easily quantify water savings from conservation efforts and the Plan cites that
enforcing irrigation restrictions saves 36-44 gallons per day (GPD) for each property. For
comparative purposes, a full time Environmental Specialist in Alachua County would cost
around $65,000 and could result in 124,128 gallons per day (0.124 MGD) if they succeeded
in getting just 20% of County residents with irrigation systems to reduce their use through
enforcing restrictions. These are cost-effective and achievable water conservation savings
that should be prioritized in the Plan and in Prevention/Recovery plans for achieving MFLs.
The Plan also documents the success of tiered water rates for reducing discretionary public
supply use. For utilities to fully maximize water conservation from tiered pricing, the water
management districts need to prohibit landscape irrigation wells on properties serviced by
public supply. This authority falls solely on the water management districts as local
governments are preempted from regulating wells. This is the type of action that needs to
coincide with the adoption of this Plan to realize our water conservation potential and reduce
the reliance on expensive projects, which often overpromise, underdeliver, and continue to
increase in costs.
The Plan outlines water conservation strategies and mentions that some are already in use
or could be used in the region. Based on our current overallocation of the aquifer, it is clear
that voluntary water conservation efforts alone are not going to restore flow, and we must
adopt additional regulatory measures. One example is to strengthen requirements of water
conservation plans in the consumptive use permitting process, since most permits currently
only include generic boiler plate language. Public supply providers should be required to
utilize quantification tools (like H20SAV) to analyze water use and to implement targeted
programs to reduce use. Similarly, improved water conservation requirements for agricultural
permits could also reduce use in this sector.
The Lower Santa Fe River Basin Recovery Strategy is referenced many times in the Plan and
is included as part of the strategy to offset demand. The Plan recognizes that this MFL and
Recovery Strategy is in the process of being updated (and has been since 2018). It is
paramount that the revised Recovery Plan is adopted soon with measurable water
conservation policies and regulatory tools to reduce demand. The current version was
adopted in 2014 and this Plan clearly documents that we are still using groundwater at an
unsustainable rate and that projected growth will only increase the pressure on the aquifer.
We appreciate the opportunity to share our concerns about these water resources that are
vital to our local economy, ecology, and water supply. Please contact Stacie Greco, Water
Resources Program Manager, at Sgreco@alachuacounty.us or 352-264-6829 for additional
information.
Sincerely,
Stephen Hofstetter, Environmental Protection Director
SH/SG/sg
CC: Alachua County Board of County Commissioners
Michele Lieberman, Alachua County Manager
