FWRJ Florida Brackish Water and Seawater Desalination: Challenges and Opportunities

Christopher P. Hill

lorida has historically been the pioneer in face water. As the population of Florida has desalination in the United States. As a grown and the availability of fresh groundwa - Christopher P. Hill, P.E., BCEE, is drinking matter of necessity, it was one of the first ter has diminished, there has been a move - F water technical leader with Brown and states to embrace desalinated groundwater as a ment towards alternative water supplies, Caldwell in Tampa. source of drinking water. Florida installed its including brackish groundwater, surface water, first desalination facility in 1969, which was a and seawater. small electrodialysis (ED) facility in Siesta Key. Today, Florida boasts more than 150 desalina - Desalination and In the mid-2000s, much of Florida was fac - tion facilities, with a combined capacity of more Water Supply Planning ing looming water shortages and the need for al - than 515 million gallons per day (mgd) and ac - ternative water supplies was imminent. As a counting for nearly 25 percent of Florida’s total Florida’s five water management districts result, many water providers maximized exist - water supply (Figure 1). are responsible for sustainable management of ing supplies and began developing alternative From groundwater to seawater, no state its water resources. Each of the districts devel - supplies. Now, in the midst of the national hous - has more operating desalination capacity. ops a regional water supply plan (RWSP) every ing and economic crises, many of these same Florida accounts for more than 50 percent of five years that evaluates the adequacy of exist - water suppliers find themselves flush with un - the U.S. desalination market. There are several ing drinking water supplies and identifies po - derutilized supplies built for growth that has yet reasons for this. Much of the state has histori - tential future supplies. The most recent RWSP to come. In other cases, while the need for alter - cally relied upon groundwater for public water for each of the districts identify a total of 126 native water supplies and desalination still supply. This is due not only to the widespread brackish water and 11 seawater projects with looms, the urgency has been reduced signifi - availability of groundwater resources, but also combined capacities of up to 545 mgd and 290 cantly. The economic downturn has resulted in to the limited availability of reliable, fresh sur - mgd, respectively (Figure 2). Continued on page 24

Figure 2. Brackish and Seawater Supply Projects Contained in Regional Water Supply Plans Figure 1. Florida Desalination Facilities (Northwest Florida Water Management District, 2006; Suwannee River Water Manage - (Florida Department of Environmental Protection, 2010) ment District, 2010; St. Johns River Water Management District, 2009; Southwest Florida Water Management District, 2010; South Florida Water Management District, 2006).

22 September 2012 • Florida Water Resources Journal Figure 3. Deep Injection Well Locations within Florida Figure 4. Map of the Floridan Aquifer Boulder Zone (Florida Department of Environmental Protection, 2012) (U.S. Geological Survey, 1990)

Continued from page 22 of the state. The “boulder zone” is a deeply minimization and zero-liquid discharge (ZLD) a renewed focus on conservation, even though it buried zone of cavernous permeability in the technologies may not only make sense from a is difficult to quantify in some cases. Although Lower Floridan Aquifer that underlies a 13- water supply perspective, but they may be neces - the need for seawater or brackish water is still county area in southern Florida (Figure 4). The sary in regions with few options for concentrate present, economic necessity has resulted in pro - permeability of the boulder zone is extremely discharge. Utilities in central Florida may see con - tracted project delays. high because of its cavernous nature, which pre - centrate as another (albeit small) source of supply vents pressure buildup in injection wells, and and choose to recover that water rather than dis - Technical Challenges coupled with the fact that the zone contains salt - charge it. Veolia Water has patented zero discharge and Opportunities water, makes it ideal for receiving concentrate. desalination (ZDD) wherein the concentrate is Though many of the possible brackish further processed to improve system recovery to As Florida continues to grow and fresh water and seawater facilities shown in Figure 2 as high as 97 percent (Figure 5). Concentrated water supplies become increasingly limited, the lie within the boundaries of the boulder zone, a salts from the ZDD process can be dried in evap - use of brackish and seawater clearly will play an substantial portion do not. For those facilities, orators/ crystallizers and evaporation ponds (not increased role in its future water supply. How - particularly inland brackish water facilities, likely in Florida), and may even generate a usable ever, there are still a number of technical chal - other alternatives to deep-well injection will be product (such as gypsum). lenges facing public water suppliers and required. Though technically possible and fea - Similar concentrate minimization regulators within Florida, including concentrate sibly permissible, surface water discharges will schemes are already being used in Florida. The management, marine impacts, energy manage - be a challenge for brackish water facilities (FAC City of Palm Coast is utilizing lime softening ment, and pretreatment. 62-4). Surface water discharges could be re - to precipitate hardness from its RO concen - quired to provide dilution between 30:1 and trate and recycle the softened concentrate to Concentrate Management 100:1 and would be subject to toxicity limita - the head of the treatment process. In Califor - Desalination processes, primarily nanofil - tions, as well as antidegradation requirements nia, the U.S. Army is planning to utilize lime tration/reverse osmosis (NF/RO) and electro - of the state. As a result, other methods of con - softening and RO to recover the concentrate dialysis, produce concentrate streams with salt centrate management are likely to be required if from an electrodialysis reversal (EDR) facility, concentrations from two to nearly ten times that brackish water desalination is to comprise any resulting in an increase in recovery from 92 of the source water. Concentrate management significant portion of future water supplies. percent to greater than 98 percent. represents a significant technical challenge to Brackish water desalination facilities may Seawater desalination is frequently co-lo - brackish and seawater supply development. discharge between 15 and 35 percent of the vol - cated with coastal power facilities to take ad - Many of the existing brackish water desalination ume of raw water pumped from the ground as vantage of their cooling water intake and facilities within the state currently discharge to concentrate. Furthermore, not only have they ex - discharge. For example, the Tampa Bay Water deep injection wells (Figure 3). pended considerable capital and operating cost to Seawater Desalination Facility is co-located with Discharge to deep injection wells is possible withdraw that water, but it can be expensive to a Tampa Electric Company (TECO) power primarily due to suitable hydrogeological and discharge it to a deep well that is several thousand plant. The TECO plant utilizes more than 1.4 water quality conditions in the southern portion feet deep. From that perspective, concentrate billion gallons of water per day and provides a

24 September 2012 • Florida Water Resources Journal nearly 70:1 dilution for the concentrate dis - charged from the Tampa Bay Water facility when operated at its design capacity. Co-loca - tion, however, will not always be an option. There is, for example, no existing power facility near the planned Coquina Coast seawater de - salination facility centered near Flagler County. In this case, the Coquina partners are investi - gating off-shore dispersion fields as the most likely, most environmentally-friendly method of concentrate discharge.

Marine Impacts For seawater facilities, there are two signifi - cant opportunities to impact the marine envi - ronment: construction and operation of the intake, and construction and operation of the concentrate discharge. Co-location with existing power facilities has proven to be advantageous and can minimize the potential for adverse envi - Figure 5. Zero Discharge Desalination Schematic ronmental impacts, but, as previously men - (Courtesy of Veolia Water, N.A.) tioned, co-location is not always feasible. Minimizing the impacts of seawater intakes fective; in fact, smaller and bait fish actually use methods. is relatively straightforward. Impingement and the intake as a shelter from larger predators. Disposal of concentrate from seawater de - entrainment represent the two most significant Wedgewire screens are also being considered for salination facilities represents a much more sig - seawater intake challenges. Beach wells and sub - intakes (Figure 7) and West Basin Municipal nificant potential challenge. Concentrate must surface (i.e., below the seafloor) intakes can vir - Water District in California is currently con - be managed to minimize the potential for ad - tually eliminate the potential for impingement ducting demonstration testing. The primary verse environmental and marine impacts. In or entrainment; however, they require specific concern with regard to the wedgewire screen is south Florida, deep-well injection may be possi - hydrogeological and bathymetric conditions to fouling of the screen and reducing the feed water ble; however, in many cases, ocean discharges be technically feasible. For open ocean (either volume. will be necessary. With regard to ocean dis - onshore or offshore), minimizing the intake ve - With regard to construction impacts, less charges, the key is to dilute the discharge so as locity is critical. Figure 6 shows an open ocean obtrusive construction methods are preferred to prevent any significant impact to ambient intake at the Gold Coast seawater desalination where possible and economical. For example, water quality. There are several options available, facility in Queensland, Australia. In that design, tunneling can minimize disruption of the ma - including near-shore surface discharges, sub - it was determined that intake velocities at the rine environment; however, it requires specific surface (below the seafloor) discharges, and off- screen should be less than 0.1 m/s (0.3 fps). Dur - geological conditions and can be expensive shore discharges below the water surface. ing operation, it was found that this was very ef - compared to conventional marine construction Continued on page 26

Figure 7. Wedgewire Ocean Intake Structure (Photo courtesy of West Basin Municipal Water District) Figure 6. Ocean Intake Structure (Photo courtesy of Sinclair Knight Merz)

Florida Water Resources Journal • September 2012 25 Continued from page 25 the diffusion field, such that sensitive marine ergy. One of the most significant hurdles to Near-shore discharges, absent a power life are able to grow and thrive on and around achieving public acceptance of seawater desali - plant cooling water system for dilution, are likely the diffusers themselves. As with the other nation is its greenhouse gas (GHG) emissions to be problematic, but several of the large sea - types of discharges, extensive hydrodynamic and carbon footprint. In Australia, for example, water facilities in the Middle East utilize this type modeling, and biological and water quality although renewable energy does not directly of discharge. Tidal patterns can seriously alter sampling, are required for such a discharge. power the large seawater desalination facilities flow volume and direction, and dispersion of the One last potential challenge facing seawater constructed there, wind farms were constructed concentrate may be difficult. Wave action could desalination in Florida is the ban of wastewater to supply equal power to the grid for a net zero cause discharged concentrate to “roll” back to outfalls in south Florida. The Florida Depart - increase in GHG emissions. Incorporation of re - the coastline, further impacting coastal water ment of Environmental Protection (FDEP) has newable energy into the project design, or to off - quality. Nearby estuarine waters and outstand - indicated thus far that the ban does not apply to set GHG emissions, will go a long way to ing Florida waters also represent a potential con - seawater concentrate. However, it merits con - increasing public acceptance of these projects. cern. Significant hydrodynamic modeling, water sideration and should be monitored as a possi - quality, and ecological studies would be required ble water supply issue in the future. Pretreatment to get such a discharge permitted, as it would Pretreatment remains one of the most crit - with the other options. Energy Consumption ical factors to successful desalination facility op - Subsurface discharges may be promising, Desalination requires considerably more eration. A fully developed source water quality depending upon local bathymetric, hydrogeo - energy than more traditional fresh water sup - profile, including a clear understanding of logic, and hydrodynamic conditions. If the plies. The energy required to desalinate brack - source water quality variability and seasonal is - seafloor characteristic is such that it would ish groundwater can range from 1.5–4 kW/1000 sues, is critical to continued successful long-term allow for dilution, and hydrodynamic condi - gallons, depending on the technology and operation. For brackish water, chemical suppli - tions would prevent rolling back to the coast - source water quality. Both NF and RO generally ers continue to develop more effective anti- line, it may be possible to construct such a require slightly less (1.5–2.5 kWh/1000 gallons) scalants, and the long history of brackish water discharge relatively near the coast. Further, en - than EDR (4 kWh/1000 gallons). Seawater de - desalination in Florida has provided a solid un - gineered seafloors of filter bed-like sands may salination requires substantially more energy, derstanding of pretreatment requirements. be promising, provided local climatic and tidal approximately 10–15 kWh/1000 gallons. For seawater, understanding the potential conditions are such that there is little danger Great efforts have been made to improve variability in source water quality is the key to of washing away the engineered floor. energy efficiency in desalination. The incorpo - effective pretreatment. Biological fouling, red Open ocean discharges, which are below ration of newer, more efficient energy recovery tide events, and turbidity and temperature (de - the water surface and above the seafloor, may devices has resulted in significant reductions in pending on intake location) can vary signifi - be the most practical option available, short of energy consumption. Early seawater facilities re - cantly. Designing an intake to minimize source co-location with a power plant. In this appli - quired up to 80 kWh/1000 gallons (Huehmer, water variability, and a pretreatment process to cation, a pipeline or network of diffusers is 2011), but this has been reduced by a factor of deal with these fluctuations, is critical. Oxidant- used to quickly disperse the concentrate. Fig - nearly 10 over the past forty years. Although de - tolerant membranes (for biofouling control) ure 8 shows one such design for the Gold salination still requires approximately three to and other advances in low-fouling membrane Coast facility. This particular installation was five times the theoretical minimum required en - materials would go a long way to improving sea - approximately 200 meters long and was able ergy, the industry is nearing its best efficiency water desalination performance. to disperse the concentrate to nearly back - point (Chaudhry, 2010). Future advances in ground concentrations within several meters membrane materials and more efficient recov - Technical Opportunities of the discharge. Similar experiences in Perth, ery devices will further reduce energy demands; The economic downturn has delayed the Australia, have demonstrated that it is possi - however, what is needed in Florida, and the de - need for, and implementation of, brackish and ble to diffuse the concentrate to near-back - salination market in general, is investments in seawater desalination within Florida. This pro - ground quality in the immediate vicinity of renewable energy—solar, wave, and wind en - vides significant opportunity to the drinking water community. The technical challenges discussed previously are not new; they are the same challenges that faced the industry during the rapid growth of the 1990s and early 2000s. They are also the same challenges that slowed implementation of every brackish or seawater project conceived over the last 10 or more years. The slowdown in the economy has given Florida the opportunity to take steps to address these challenges, to seize the opportunity to de - velop strategies to overcome them, and be pre - pared to better implement brackish and seawater desalination when the need for these alternative water supplies returns in the future. In the meantime, there are several actions that can be taken by public water systems, reg - Figure 8. Concentrate Discharge Diffusion Structure ulatory agencies, and the engineering com - munity: (Photo courtesy of Sinclair Knight Merz)

26 September 2012 • Florida Water Resources Journal
Develop strategies to deal with inland Southwest Florida Water Management District mentation. Though NEPA itself is not a permit, brackish water desalination, including in - (SWFMWD) determined that a water use per - compliance with the requirements of NEPA has creased focus on concentrate minimization mit was not required for the Tampa Bay Water potentially significant impacts on the success of and the value of concentrate as a water re - seawater desalination facility because it had future seawater desalination projects. The NEPA source, demonstration of ZLD technolo - coastal water with total dissolved solids (TDS) compliance is required for federal funding. gies, and development of new more concentrations in excess of 10,000 mg/L. Con - Given the need for an intake and concentrate efficient membrane processes. versely, St. Johns River Water Management discharge, USACE has its own NEPA regulations
Develop requirements for hydrodynamic District (SJRWMD) determined in its review at 33 CFR Part 230, which governs actions di - modeling, and water quality and ecological of the Coquina Coast project that it will in - rectly undertaken by the USACE, including dis - assessments. Conduct marine and ecologi - deed require a consumptive use permit and cretionary regulatory actions such as issuance of cal studies to determine concentrate toxic - will be responsible for its issuance. The state permits for major projects. ity and establish dilution requirements for needs a consistent policy regarding water/con - seawater concentrate discharge. sumptive use permitting for seawater. It is also Financing and Governance
Conduct investigations to determine feasi - assumed that beach wells would fall within the A significant hurdle to desalination imple - bility of wind, solar, wave, and other re - purview of the water management districts, mentation within Florida is funding, particu - newable forms of energy. Encourage power but clarification and consistency are required larly in these economic times when utility and companies to invest in renewable energy in - regarding this issue. consumer budgets are limited. The water man - vestment and work with them in siting of With regard to intake construction, FDEP agement districts have historically provided new power facilities to consider co-location will be the lead agency and issue construction funding support for alternative water supply of seawater desalination facilities. permits within three miles of the coast. If it is projects, and SWFWMD provided 50 percent
Investigate alternative seawater intake and located beyond this distance, responsibility co-funding of the Tampa Bay Water seawater de - concentrate disposal alternatives that min - will fall to the U.S. Environmental Protection salination facility. The districts have stated that imize pretreatment requirements and ma - Agency (USEPA) and the U.S. Army Corps of they intend to continue to provide financial sup - rine impacts, such as subsurface and well Engineers (USACE). However, even if the in - port to alternative water supply projects; how - alternatives. take or discharge terminates beyond three ever, given state budget issues and a reduced tax miles, it will still traverse the boundaries of base, those funds may not be as significant as in Non-Technical Challenges FDEP jurisdiction. In addition, intakes are also the past, despite the fact that more expensive al - and Opportunities subject to the requirements of Section 316(B) ternative water supplies are needed. of the Clean Water Act (40 CFR 125 and Outside funding sources (i.e., those outside Implementation of brackish and seawater 125.90[b]) as provided in FAC 62-620.100, a typical utility’s budget) can minimize water desalination in Florida not only includes the which protects against impingement and en - rate impacts on customers, which is particularly technical challenges previously discussed, but trainment for cooling water intakes. important during the current economic reces - also a number of potentially significant non- Similar to the seawater intake, FDEP sion and downturn in the housing market. technical challenges. These challenges, including would be the lead agency for any concentrate There are a number of state and federal vehicles permitting, financing and governance, water discharge within three miles of the coast or at that provide funding for alternative water supply rates, and public acceptance, may represent an depths of less than 90 feet. The USEPA would projects such as seawater desalination, including even more significant barrier to water supply de - be the lead agency beyond three miles or in grants and loans, legislative appropriations, and velopment than the technical ones. depths greater than 90 feet. Within three miles bonds. The difficulty is that these sources of and 90 feet, discharges are referred to as coastal funds are rarely sufficient to significantly impact Permitting discharges; discharges beyond this are consid - the overall project cost. For example, SJRWMD Florida has established permitting require - ered ocean discharges. has appropriated more than $26 million for the ments for brackish water facilities. Responsibil - At this time, FDEP has not yet permitted a construction of the Coquina Coast project—a ity for the supply (the water management coastal or ocean discharge of concentrated sea - substantial sum of money. Unfortunately, that districts), the treatment process (FDEP), and water. The Tampa Bay Water desalination facil - money will likely account for less than 10 per - concentrate discharge (FDEP) are consistent ity is co-located with a power facility and its cent of the total project cost. and well understood throughout the state. The discharge is diluted by the Tampa Electric Com - Legislative appropriations at the state and same cannot be said for seawater. The very na - pany (TECO) cooling water discharge. Most of federal level are truly needed to provide sig - ture of a seawater project makes the issue of per - the existing rules are written around discharge nificant funding for desalination. The Water mitting much more complicated. Seawater of concentrate from brackish groundwater, Resources Development Act (WRDA) is one projects move beyond the typical state bound - which has a much higher concentration factor potential source of funds, but no authoriza - aries and into marine and coastal environments (relative to the source water concentration), but tions have been given under this program over which statutory authority can vary. Though lower overall concentrations. Further, the con - since 2000 and there is now a backlog of some Florida regulatory agencies have seemingly been centrate discharge rules are written around dis - 500 authorized projects awaiting appropria - able to accept and permit seawater facilities posal to more conventional surface waters (e.g., tions. It is time for Florida and the United much more readily than some other states, there rivers and streams) rather than ocean discharges. States to step forward and provide financing are still several inconsistencies in the way in Requirements for permitting of concentrate dis - for water infrastructure. which permitting is handled within Florida, and charge are defined in FAC 62-4. The foundation of any funding applica - there is a need for revised regulations designed The most significant individual permitting tion is greatly dependent on the organizational to address seawater desalination. activity associated with a seawater desalination makeup or governance. Governance estab - There is no firmly established permitting project is likely the preparation of required Na - lishes ownership and accountability. The sig - process for seawater within the state. The tional Environmental Policy Act (NEPA) docu - Continued on page 28

Florida Water Resources Journal • September 2012 27 Continued from page 27 environmental groups, to participate in the well-documented, and the water industry has nificance of the governance decision lies in its planning so that their input is included and they spent millions of research dollars to investigate effect on the funding process, including the understand the project, rather than rely on oth - and develop solutions for these issues. total dollar amount available to the project, in - ers as their source of information. The industry is very adept at identifying terest rates, and the speed with which the The most commonly asked question is, and resolving technical challenges; however, de - funding process may proceed. Governance “Why can’t we conserve our way out of this?” Be salination presents a number of unique non- can include self-ownership and financing, or prepared with an answer, including details re - technical challenges. For example, permitting of creation of a special district or authority. garding the steps that have already been taken to desalination facilities is not necessarily a techni - reduce water consumption. Be prepared to ad - cal challenge; it is more likely that the lack of es - Rate Impacts dress questions about impacts to growth and de - tablished permitting requirements for Typical fresh groundwater within Florida velopment, water rates, location, GHG and desalination make it difficult for regulators to may cost $1.00-2.00/1000 gallons. Brackish energy consumption, concentrate discharge, en - evaluate and permit desalination projects. and surface water may cost $2.00-4.00/1000 vironmental impacts, and construction impacts. Public acceptance is another challenge gallons. Seawater generally costs between ap - Listening to the public, answering questions (or typically facing desalination projects. While proximately $3.50 and $8.00/1000 gallons, de - telling them you will have the answer to a ques - opponents of desalination are constantly send - pending on the size of the project and tion), and incorporating their feedback into the ing questionable information to the public and infrastructure required. Depending on the process can help to eliminate opposition and to politicians, the industry is slow to react due proportion of brackish water or seawater gain support for the project. to lack of available resources documenting the within a utility’s water supply portfolio, addi - environmental benefit and success of similar tion of one of these new sources can signifi - Non-Technical Opportunities desalination efforts in Florida and worldwide, cantly impact customer water rates. It is Non-technical challenges likely represent or an unwillingness to engage in public debate. therefore imperative that utilities 1) maintain the most significant barrier to implementation The result can be catastrophic for a project and a well-balanced water supply portfolio, 2) seek of desalination within Florida. The technical the industry as a whole. financial support to lessen the rate impacts to challenges will be addressed out of necessity, customers, and 3) truly understand the impact or by entrepreneurial spirit, but the non-tech - References of the addition of desalinated water to the nical challenges have the ability to derail a de - water supply portfolio and the impact to their salination project. The downturn in the • Chaudhry, S. (2010). Energy Challenges and customers. It only takes one misinformed cus - economy has provided the following opportu - Opportunities in Desalination, U.S. Depart - tomer or media outlet to seize upon a value nities to address some of these challenges, such ment of Energy Industrial Water Use and like $8.00/1000 gallons and begin touting the that when the need for these alternative water Desalination Workshop, Tampa, FL, Febru - “eight-fold water rate increases over current supplies returns, implementation will face ary 24-25, 2010. rates.” fewer obstacles: • Florida Department of Environmental Pro -
Establish consistent regulatory policy re - tection (2010). Desalination in Florida: Public Acceptance garding the permitting of seawater desali - Technology, Implementation and Environ - Perhaps the most significant challenge to nation, including water/consumptive use mental Issues. desalination, and seawater desalination in par - permitting requirements. • Florida Department of Environmental Pro - ticular, is public opposition. For this reason,
Revise concentrate management regula - tection (2012). Map of Class I Injection Wells, the public cannot be ignored in the planning tions to include seawater, including estab - last updated November 2003. Last accessed on and implementation process. Today’s water lishment of hydrodynamic modeling and March 19, 2012 at www.dep.state.fl.us/ customer is better informed than at any time toxicity testing requirements. water/uic/docs/Class_I_map11_2003.pdf in history. Information (and unfortunately,
Engage the state and federal legislatures to • Huehmer, R. (2011). Optimization and Mod - misinformation) is readily available to anyone enact legislation, provide appropriations eling of Energy Recovery Devices in Reverse with computer access in this age of electronic through existing legislation, and otherwise Osmosis, American Membrane Technology media. The Internet is a fabulous source of in - support and provide funding mechanisms Association/Southeast Desalting Association formation, but is also a source of misquoted, for alternative water supply development, Joint Conference, Miami, FL July 18-21, 2011. misinterpreted, and deliberately misleading and specifically, desalination. • Northwest Florida Water Management Dis - information. Special interest groups and other
Educate, engage, and inform the public, and trict (2006). Regional Water Supply Plan, organizations use the Internet to distribute be proactive in being the first and best September 2006 Update. anti-desalination information under the guise source of information—because the oppo - • Suwannee River Water Management District of consumer or environmental protection. It sition is. (2010). 2010 Water Supply Assessment. is important for utilities to understand this • St. Johns River Water Management District and be the first and best source of information . Summary and Conclusions (2009). 2005 District Water Supply Plan, When developing a desalination project, it Fourth Amendment, May 12, 2009. is important to involve the public early and Brackish water and seawater desalination • Southwest Florida Water Management District throughout the planning and implementation will play a significant role in Florida’s future (2010). 2010 Regional Water Supply Plan. process to determine what their concerns are water supply. The economy will rebound and • South Florida Water Management Dis - and develop solutions that address those con - growth will eventually return; when they do, the trict (2006). 2005-06 Consolidated cerns. If the project requires NEPA compliance, conditions that drove the need for desalination Water Supply Plan. USEPA will require that the public be included will still be there. The technical challenges, for • U.S. Geological Survey (1990), Ground Water in the planning process. Invite key local organi - example, concentrate disposal, marine impacts, Atlas of the United States: HA 730-G Alabama, zations, such as homeowner associations and energy consumption, and pretreatment, are Florida, Georgia, and South Carolina.

28 September 2012 • Florida Water Resources Journal