Following is an email sent from OSFR President Pam Smith to the two water districts that made the North Florida Regional Water Supply Plan draft of October 4, 2016. This is in regard to the input requested by the two districts for comments about the plan. Our advisor, Jim Gross, a professional geologist, gives his comments after the email. The email is a request that the water districts address our suggestions. If we get a response we will post it here.
Here is a link to our earlier post about the water plan http://oursantaferiver.org/water-supply-plan-workshop/
The plan can be downloaded at the link here, and the public is invited to submit comments until Dec. 5, 2016. Please read the plan and tell them they are using too much water.
From: Pam Smith <firstname.lastname@example.org>
Date: Fri, Nov 18, 2016 at 12:55 PM
Subject: North Florida Regional Water Supply Plan draft of October 4, 2016 – Comments Attached
To: Noah Valenstein <email@example.com>, Ann Shortelle <firstname.lastname@example.org>
Cc: Carlos Herd <email@example.com>, Scott Laidlaw <firstname.lastname@example.org>, OSFR Board <email@example.com>
To: Pamela Smith, Our Santa Fe River
From: Jim Gross, MS, PG, CPG
Date: November 18, 2016
Subject: Review of North Florida Regional Water Supply Plan, draft of October 4, 2016.
The mission of Our Santa Fe River, Inc. (OSFR) is to protect the aquifer, springs, and rivers within the watershed of the Santa Fe River. OSFR requested the author of this memorandum to review the draft North Florida Regional Water Supply Plan dated October 4, 2016 (draft plan), and to identify key issues that are of interest to OSFR in fulfilling its mission.
Comments on the draft plan
What’s good in the draft plan
- The draft plan recommends that the entire planning region be designated as a Water Resource Caution Area.
- Some of the water supply options identified in the draft plan are good, particularly those that reduce groundwater withdrawals. Conservation measures and use of reclaimed water are good ways to reduce groundwater withdrawals.
What’s not so good in the draft plan
- From a big picture perspective, the key issue is how much groundwater we are pumping out of the Floridan aquifer system. The draft plan fails to fully characterize the magnitude, regional extent, and cumulative impact of this key issue.
- The draft plan indicates that as of 2010, water use had already exceeded the sustainable yield of the fresh groundwater system. However, the draft plan fails to determine to what extent existing sources of water are adequate to supply water for all existing and future reasonable-beneficial sources of water and also sustain the water resources and related natural systems for the planning period. The magnitude of the problem has not been adequately assessed. If the magnitude of the problem is not known, the magnitude of the solution is not known. The districts should revisit the groundwater modeling analysis for the draft plan and incrementally reduce groundwater withdrawals until they demonstrate that all established and proposed minimum flows and levels can be achieved.
- The draft plan takes a big detour around some key water supply constraints that were already identified in earlier planning efforts by St. Johns River Water Management District (SJRWMD) in its draft 2010 and draft 2013 regional water supply plans. Minimum flows and levels (MFLs) for Lake Brooklyn and Lake Geneva near Keystone Heights were key constraints in those two planning efforts. SJRWMD began to develop recovery strategies for those lakes as early as 2011. These MFLs need to be included in assessing the sustainable limit of groundwater withdrawals for the draft plan. Including them in the analysis could well demonstrate that the sustainable yield is even lower than excluding them.
- Some of the water resource development projects included in the draft plan are little better than smoke and mirrors and have little or no potential to alleviate water resource problems. For example:
- Diverting surface water to recharge groundwater so it can then discharge back to surface water. This is nothing more than a card trick. It does nothing to make more water available.
- Aquifer storage and recovery (or ASR) has little if any potential to address the key water supply constraint, cumulative withdrawals from the Floridan aquifer system. ASR is merely a management technique. It is typically used to store fresh surface water underground in an aquifer that does not contain fresh groundwater. Fresh surface water is stored underground when the supply is greater than the demand, and then recovered when the demand is greater than the supply. ASR is essentially a meaningless option over the western portions of the planning region. There are several reasons why ASR will not be an effective strategy for the western portions of the planning region: i) likely fresh surface water sources are already constrained by MFLs, ii) groundwater in the aquifer is already fresh water, and iii) any water injected underground would not be “stored”. It would simply increase discharge of groundwater back to surface water.
- The Lower Floridan aquifer is identified as an alternative source of water supply. This is hooey and hydrologists know it. The Lower Floridan aquifer is simply part of the Floridan aquifer system as is the Upper Floridan aquifer. The two aquifers act as a single water-yielding unit. There is a very limited potential to strategically utilize the Lower Floridan aquifer to mitigate existing water resource problems, but that potential comes with a risk of creating new water resource problems.
- Brackish groundwater is identified in the draft plan as a water resource development option. However, it is more appropriately designated as an alternative water supply option. Regardless of how it is classified, the salinity of groundwater has little bearing upon the key constraint for this draft plan. If we are already pumping too much groundwater from the Floridan aquifer system, it really doesn’t matter whether it’s fresh or brackish.
- The draft plan identifies optimizing groundwater withdrawals as a potential option. SJRWMD looked extensively at optimizing groundwater withdrawals in previous planning efforts using optimization algorithms in conjunction with groundwater flow modeling. The results of the optimization analyses were informative and clear: a) optimization can only marginally increase sustainable yields, and b) the infrastructure and unit production costs for most of the optimization scenarios exceeded the costs for other alternatives.
- The draft plan states that the groundwater model is good enough for planning but not good enough for regulatory evaluations. That’s a somewhat obtuse conclusion, but possibly irrelevant. The draft plan concludes that withdrawals already exceed sustainable limits. It’s all one aquifer system. What further modeling is really needed for regulatory evaluations and decisions?
- The section on climate change discusses uncertainties but ignores significant work looking at likely outcomes of climate change with respect to water supply sustainability. A report by Tetra Tech concluded that large portions of Florida are at high or extreme risk of exceeding sustainable supplies even without climate change. With climate change, most of Florida was identified to be at high or extreme risk of exceeding sustainable water supplies.
- The Sufficiency Analysis in Chapter 6 of the draft plan is predicated only on the MFLs for the Lower Santa Fe and Ichetucknee rivers. As noted above, key constraints in the St. Johns River Water Management that have been ignored in this draft plan also need to be considered.
- The draft plan fails to consider other potential strategies to decrease groundwater withdrawals. For example, there does not appear to be any discussion of seeking legislative authorization to levy fees for the withdrawal of water. Such fees could: a) serve as an economic incentive for further water conservation, b) help maximize reasonable-beneficial use, and c) provide an equitable revenue stream for funding alternative water supply development projects and water resource development projects.
- There appears to be no consideration of coherent and credible regulatory strategies to balance reasonable-beneficial uses while sustaining water resources and related natural systems. In all cases, credible strategies must cap withdrawals at some defined level. Previous examples in Florida include: a) the water use caution areas in SWFWMD, b) the Central Florida Coordination Area rule that capped groundwater withdrawals at a defined withdrawal horizon, and c) the cap on withdrawals from the Biscayne aquifer in southeast Florida. While a regional water plan cannot implement such strategies, there should be some reasoned discussion of approaches that can be taken both on an interim and long-term basis.
- Language in Appendix G, the Recovery Strategy for the Lower Santa Fe River Basin, provides an example of a strategy element that is not credible: “Applications that do not demonstrate a potential impact to the MFL water bodies shall be issued provided the applicant meets the conditions for issuance.” This language seems to indicate that it is incumbent upon the applicant to demonstrate an impact, and that in the absence of such demonstration it is presumed that there is no impact. A demonstration of impact is clearly not in the interest of the applicant. Rather, it should be incumbent upon the applicant to demonstrate that the proposed withdrawal of water will not cause a potential impact.
The draft plan does not contain sufficient information, analyses, and recommendations to provide assurance to OSFR that the aquifer, springs, and rivers within the watershed of the Santa Fe River will be protected.
 373.709(1), FS
 Williams, L.J., and Kuniansky, E.L, 015, Revised hydrogeologic framework the Floridan aquifer system in Florida and parts of Georgia, Alabama, and South Carolina: U.S. Geological Survey Professional Paper 1807, 140 p., 23 pls. http://pubs.usgs.gov/pp/1807/index.html
 “NFSEG version 1.0 meets the requirements to be used in water supply planning in the NFSEG domain. Version 1.0 of the model will not be utilized in regulatory evaluations or in the establishment of MFLs. However, the model may be used to determine the status of MFLs.”
 Sujoy B. Roy, Limin Chen, Evan Girvetz, Edwin P. Maurer, William B. Mills, and Thomas Grieb, 2010, Evaluating Sustainability of Projected Water Demands under Future Climate Change Scenarios; prepared by Tetra Tech Inc. for the Natural Resources DefenseCouncil.