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Matanzas Riverkeeper “Protecting Florida’S Last, Best, River”

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Matanzas Riverkeeper “Protecting Florida’s last, best, river” July 27, 2015 Bill Young Director, St. Johns County Utility Department 1205 State Road 16 St. Augustine, FL 32084-8646 RE: Comments on the SJC Draft Integrated Water Resources Plan Dear Bill, Thank you for allowing citizens additional time to review the St. Johns County Integrated Water Resources Plan (IWRP). While this letter comes from me, there is a coalition of organizations that worked together on this effort, including Matanzas Riverkeeper, South Anastasia Community Association (SACA), Friends of Matanzas, and the Florida Wildlife Federation. Several of us reviewed the document, but a decision was made to find someone with expertise in water supply planning to provide us with technical assistance and guidance. To that end, the coalition contracted with Jim Gross to review the IWRP. Jim is a licensed geologist with 38 years of water-resources experience. I’m sure you have worked with Jim on water supply planning issues during his 18 year career with the St. Johns River Water Management District. I’ve enclosed Jim’s technical memorandum on the IWRP for your review. It is our hope that once you’ve had a chance to review Jim’s report, all of us can sit down together in the near future to discuss next steps and how we can help moving forward. Once again, thank you for allowing us to be part of the IWRP process. We all look forward to working with you, and your staff, to conserve and sustain St. Johns County’s groundwater resources. For the Matanzas, Neil A. Armingeon Matanzas Riverkeeper MATANZAS RIVERKEEPER ~ 201 Owens Avenue ~ St Augustine, FL 32080 (904) 471.9878 Contributions to MATANZAS RIVERKEEPER are tax-deductible. MATANZAS RIVERKEEPER is a program of FRIENDS OF THE MATANZAS, INC, a registered 501(c) (3) organization. Technical Memorandum To: Neil A. Armingeon, Matanzas Riverkeeper From: Jim Gross, MS, PG, CPG Flicker Ink, Inc. Date: July 13, 2015 Subject: Review of St. Johns County Utility Department Integrated Water Resources Plan, draft of March 2015 Purpose As part of its overall mission, the Matanzas Riverkeeper assesses factors related to protection of the Matanzas River and its watershed. The St. Johns County Utility Department completed a draft Integrated Water Resources Plan (IWRP) in March 2015. The IWRP looks forward to the year 2040 to assess water supply needs, options, and alternatives. The integrated approach taken in the IWRP assesses how a variety of water supply, wastewater, reclaimed water, and stormwater facilities can be combined with other options including conservation, regional partnerships, and other measures to meet future water needs. Matanzas Riverkeeper contracted with Flicker Ink, Inc. to review the draft IWRP and identify any issues that may be of interest to the Matanzas Riverkeeper in fulfilling its mission. Plan Overview The draft IWRP consists of the following documents: Executive Summary (12 total pages) Technical Report (75 total pages) Appendices (A through F, 224 total pages) The draft IWRP was developed by Jones Edmunds and CDM Smith for St. Johns County Utility Department (SJCUD). The objectives of the IWRP were: Define the future water needs of the community Develop an integrated water resources systems computer model - 1 - Produce an integrated plan that includes stakeholder and public involvement Plan Approach The IWRP identified key constraints that will likely limit traditional groundwater supplies. It also presents key drivers that influence the timing and need for future water supplies. Key constraints identified in the IWRP that will likely limit traditional groundwater supplies include: 1. Cost 2. The capacity and age of existing infrastructure 3. Customer acceptance and public opinion 4. Consumptive use permit limits 5. Impacts to water bodies with minimum flows and levels 6. Other impacts to water resources such as wetlands and springs 7. Impacts to other existing legal users of water 8. Deterioration of source water quality (increased salinity) 9. Impacts to finished water quality (both potable and reuse) 10. Regulations pertaining to discharge of treated wastewater to surface water bodies (e.g. total maximum daily loads, numeric nutrient criteria, human health criteria) Drivers identified in the IWRP that will influence the timing and need for future water supplies include: 1. Rate of population growth 2. Economic influences that could change both the types and locations of future land uses 3. Natural variability in climate conditions (not to be confused with climate change) 4. Opportunities for regional partnerships, principally but not exclusively in the context of constraints imposed by minimum flows and levels 5. Regulatory changes that might reduce quantities of groundwater already permitted by St. Johns River Water Management District. - 2 - The IWRP identified a variety of options that were combined into various alternatives. An assumption utilized in the planning process for future scenarios was that St. Johns County Utility Department would be limited to 90% of its current consumptive use permit allocations due to environmental constraints. The plan also assumed that St. Johns County Utility Department would need to implement impact offsets to pump more than 90% of the current allocation.1 A series of objectives were identified to assess alternatives. Objectives included such factors as cost, reliability, and other important factors. Performance metrics were defined for each of the objectives. Most performance metrics had intrinsic numeric values (e.g. cost, reliability) while others were qualitative in nature (e.g. easy to operate and maintain, minimize impact on ecosystems). Qualitative objectives were assigned values from 1 to 5. A multi-attribute rating method was used to convert raw scores (some with units, some without) into standardized, dimensionless scores for purposes of comparison. For example, a low-cost alternative would be scored high for the cost objective. It would also be scored high for high reliability. Weighting factors were also applied to objectives. Weighted scores for all objectives were summed for each alternative to calculate the total score for each alternative. The decision analysis component of the IWRP is not unlike other complex resource planning analyses that consider multiple constraints, drivers, objectives, options, and alternatives. The planning approach taken is sound, and the results are relatively easy to understand. There is subjectivity in applying weighting factors to the standardized scores for each of the objectives; however, the project team conducted sensitivity analyses to test how alternative weighting might influence overall results. IWRP Findings and Recommendations In general, the IWRP found two alternatives ranked higher than others even when weighting factors were varied. These were identified in the plan as the Low Cost alternative and the Low Cost Plus alternative. The Low Cost Plus alternative is essentially the plan recommended in the IWRP with additional options to address uncertainties in the rates and locations of projected growth. The base portion of the recommended plan appears to include an additional 3.5 million gallons per day (mgd) of groundwater withdrawals associated with 1 IWRP, Final Report, page 8-1. - 3 - expanding maximum day capacities at the CR 214 Water Treatment Plant and Northwest Water Treatment Plant. The average annual day withdrawals are shown in the plan as 1.3 million gallons per day (mgd) for the CR 214 Water Treatment Plan, and 2.2 mgd for the Northwest Water Treatment Plant. In addition to the base portion of the recommended plan, there is a recommendation for an additional 5.2 mgd of groundwater withdrawals if demands rise faster than anticipated. This additional amount of groundwater is shown as 3.2 mgd at the Northwest Water Treatment Plant and 2.0 mgd at the CR214 Water Treatment Plant, both shown on an average annual day basis. Groundwater from the Floridan aquifer system is less expensive than most other water supply options available to St. Johns County. However, there are risks and tradeoffs with increasing withdrawals from the Floridan aquifer system. As identified in IWRP, there is a risk that permitted allocations for St. Johns County Utility Department may be limited in the future to address problems with minimum flows and levels.2 Some of these reductions could potentially be offset by partnership options identified in the plan; however, it is not yet clear what magnitude of offsets will be required. Water bodies in the joint water supply planning region of the Suwannee River Water Management District and the St. Johns River Water Management District have been identified as not meeting minimum flows and levels or projected to fall below minimum flows and levels within 20 years. However, neither of these districts has discontinued issuing consumptive use permits for increased quantities of groundwater withdrawals in North Florida. Thus, there is a significant risk to St. Johns County Utility Department that even greater amounts of impact offsets may be required in the future due to continually increasing groundwater withdrawals. There are also tradeoffs associated with increased groundwater withdrawals. Progressively increasing salinity of groundwater produced from the Floridan aquifer system is not a problem that is unique to St. Johns County. Within the St. Johns River Water Management District, areas east of the St. Johns River are especially at risk of increasing salinity. There
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