MFL Peer Review Committee Still Finds problems


SRWMD 2nd peer In: MFL Peer Review Committee Still Finds problems | Our Santa Fe River, Inc. (OSFR) | Protecting the Santa Fe River

The Minimum Flows and Levels (MFLs) Peer Review Committee convened on July 28 for a discussion of the first draft revision of the Suwannee River Water Management District’s MFL plan.

The committee is composed of Drs. Louis Motz, Adam Munson and Chair William Dunn, all recognized scientists.  They were critical of the first plan, and this criticism continued for the revision.

Dr. Dunn identified 58 issues that still needed solutions, Dr. Motz identified 13 substantive problems and Dr. Munson had eight.

A good deal of the faults exposed dealt with incompletion and uncertainty, deemed “substantive uncertainties” which the committee translated as risk.   This serious evaluation states:  “The primary risk is that the water resource values of the Lower Santa Fe and Ichetucknee rivers and their Priority Springs will not be protected from significant harm.”

And that, folks, is the whole reason for the MFLs.  Or it could be that  the reason for the MFLs is to see how much water we can give to water users?  Sort of the same thing.  The case is that at times it seems that the water users getting their water is more important than keeping the river protected.  Why else do we have riverkeepers?

One of the items addressed is one of our pet peeves; the 15 % rule that water managers love.  At one time in the past, water districts decided the number 15% was a safe drawdown, and once used it became an established figure.  The Peer Committee happily said this change cannot be defended, and that there is no reason to arbitrarily pick that number just because it was once used somewhere else under different circumstances.  Extended, if 15% were taken every five years, a point would be reached when there would be no water left.

Interesting to us was the public comment that was discussed at length by the committee as follows:

19.  Priority Springs are not protected.

20.  Karst hydrology not properly addressed.

21. Problematic implementation of MFL.

22. Significant harm & the 2013 Recovery Plan.

23. Existing MFL exceeded.

24.  Proposed MFL will be exceeded.

25 . Moratorium  & rollback on water use.

Committee members identified 19 – 22 as from Dr. Sam Upchurch and praised them as significant.  Items 23-25 were deemed opinion, unvetted or unsubstantiatied and discounted.

We recognize that while the committee has no mandate to review public opinion, the District does and must take it into consideration.  No. 25 was mentioned as from Dr. Robert Knight of Florida Springs Institute, but was echoed in your writer’s oral comments.  What makes us believe that No. 25 would fix the river is that it needed no fixing before we humans started messing with it.  Maybe opinion, maybe not science, but certainly truth.

Again the obvious and available solution is not considered, most likely because the state thinks the cost is too great.  Doing that could even cost the governor and water managers their jobs.


  1. Also truth is if all humans moved out of north Florida, this would also fix the river.


    1. Charles, I understand that you think my suggestion of reducing pumping is absurd but it is not. In Nebraska where I did a little farming long ago, it is almost impossible to get a new permit to irrigate. In other states I believe there are moratoria on permits. This is because there simply is no fresh ground water to pump. I also understand that parts of our aquifer are floating lenses of fresh water with salt water surrounding them. Salt encroachment is not confined to the coasts, and it is becoming worse. All our water management districts predict shortfalls of freshwater in coming years. They know that the current usage is not sustainable, yet rather than bite the bullet to attack the problem, they continue to look for Band Aids which will not be sufficient for our needs. They know this but Tallahassee is not ready to act. The governor who finally tries will be booted until everyone comes out of denial. Charles, where do you think we will find enough fresh water in the future, when even the water districts tell us we will not have enough?

      1. I understand completely that it is almost impossible to get a new permit to irrigate in Nebraska. The Ogallala Aquifer, though one of the world’s largest aquifers, is considered an ‘ancient water’ aquifer where water takes upwards of 100 years to reach and recharge the aquifer. The Floridan Aquifer is quite different in how it is recharged.

        That said, I agree completely that sustainability is the key. It is no different than one’s checking account where the deposits must at least match the withdrawals. To take that into account, I will put my trust in experts that know much more than I claim to know. Additionally, I will continue to advocate for conservation measures that allow agriculture to remain on the land where they can also provide the permeable green space to maximize aquifer recharge. Removing their ability to irrigate when necessary will only quicken their demise wherein they are forced to sell which rarely benefits the ecosystem.

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