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.

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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 are different approaches that utilities can take to manage increasing salinity. In general, these approaches involve some combination of increased groundwater withdrawals, increased volume of concentrate, and/or increased concentration of the concentrate. The main challenge for water supply utilities is not so much in removing the dissolved

2 IWRP, Final Report, page 2-1

- 4 - solids from the raw water, but rather in managing the concentrate derived from the membrane treatment process.

The IWRP notes that total dissolved concentrations at the Anastasia Island wastewater treatment facility are approaching an upper limit beyond which it will be difficult to serve reclaimed water customers.3 IWRP reports that this facility is permitted for 4.95 mgd average annual daily flow with up to 0.8 mgd for reuse. Flow not sent to reuse is discharged to the Matanzas River.4

The St. Johns River Water Management District investigated the feasibility of discharging demineralization concentrate to the Indian River Lagoon between Titusville and Cocoa. The study found that salinity in the Lagoon would likely continue to increase over many years, altering the natural ecosystem and adversely impacting native varieties of sea grass and the District’s plans for restoration of the Lagoon.5 Whether or not a similar problem might arise in the Matanzas River is unknown at this time. It would be prudent for St. Johns County to assess this risk, if it has not done so already, before committing to any options that would significantly increase the discharge of dissolved solids into the Matanzas River.

There are a variety of other options in the recommended plan to meet future water demands. These include expanded conservation, use of reclaimed water, and augmentation of reclaimed water supplies using stormwater and additional storage including aquifer storage and recovery. These options are reasonably feasible; however, there are uncertainties and risks concerning the feasibility of aquifer storage and recovery. These risks should be addressed through preliminary feasibility work before the County commits to the larger expenses of permitting, well construction, and testing. Given that there have been public concerns in Florida about the safety and environmental risks associated with aquifer storage and recovery projects, it would be prudent for this feasibility work to be as open and transparent as possible.

The conservation options recommended in the plan appear practical and feasible. The plan notes that St. Johns County recently passed land development regulations (LDRs) for developments that have not yet been approved. The LDRs limit the area of high-volume irrigation.6 However, the recommended plan does not include the SAV3 and SAV5 options. These two

3 Draft IWRP, Appendix A, Existing Conditions, p. 12 4 Draft IWRP, Final Report, p. 3-6. 5 SJRWMD, 2007, Evaluation of Potential Impacts of Demineralization Concentrate Discharge to the Indian River Lagoon, Special Publication SJ2007-SP3. 6 Draft IWRP, Appendix D, Option Fact Sheets, p. D-44

- 5 - options are the most progressive conservation measures identified in the IWRP. They would further reduce outdoor water use by eliminating high-volume landscape irrigation on future development. It would be informative to St. Johns County to see how these options might lessen the need for increased water supplies in the future. Water supply planning in Central Florida is already beginning to consider LDRs that would significantly reduce landscape irrigation for future developments.7

Recommendations

Water resource constraints are a significant factor in St. Johns County and throughout the northeastern portion of the St. Johns River Water Management District. Both the 2010 and 2013 draft District Water Supply Plans recommended that all of northeast Florida be designated as a water resource caution area.8 A water resource caution area is a geographic area identified by a District as having existing water resource problems or an area in which water resource problems are projected to develop during the next twenty years.9 Constraints identified in these plans included water bodies not meeting minimum flows and levels, wetland impacts, reduced spring flows, and saltwater intrusion.

It is not likely that St. Johns County can entirely stop the saltwater intrusion problem with its groundwater supplies from the Floridan aquifer system. However, there are some approaches that might slow it down. There are compelling reasons why the County would want to minimize increases in salinity. Increases in salinity will drive up the cost for treatment, decrease the volume of potable water produced, and increase the volume of concentrate. In addition, finding ways to manage concentrate that can be permitted is sometimes a challenge. For example, not long ago the City of Melbourne abandoned plans to expand its brackish groundwater supplies due to the significant hurdles associated with concentrate management.

One option for addressing increasing salinity might be wellfield management. This approach utilizes additional wells for the same volume of groundwater withdrawals. Wells are rotated into and out service on a periodic basis to minimize saltwater intrusion at any one well location. Some utilities in Florida have reported positive results from well field management approaches.10 It may also be possible for the County to slow the rise in salinity using shallower wells.

7 Mark Farrell, Water Resource Associates, personal communication. 8 These were referred to as Priority Water Resource Caution Areas in the draft 2010 plan and Water Resource Caution Areas in the draft 2013 plan. 9 Florida Administrative Code, Chapter 62-40.210(43), 5-3-2014 10 Scott Laidlaw, SJRWMD, personal communication.

- 6 - This approach could also potentially require more wells for the same volume of water, but may still compare favorably to other options in terms of cost and sustainability. A hybrid approach using both more wells and shallower wells may be even more effective than using just a single approach.

Increased levels of conservation could also reduce the need for additional groundwater withdrawals. The SAV3 and SAV5 options identified in the IWRP further reduce landscape irrigation above and beyond what is required today; however, these options do not appear to be included in the recommended plan. The plan assumes that the County would bear the full cost to implement SAV3 and SAV5 options. This assumption appears to be inconsistent with other costing assumptions in the plan. For example, the SAV1 option, which implements the County’s recent land development regulations for landscape irrigation, does not include any direct costs to the County. It would seem worthwhile to run a few additional scenarios with the SAV3 and SAV5 options, but modified to show no direct costs to the County for these options.

In the past, the St. Johns River Water Management District encouraged all water users in a county to participate in developing a countywide water supply plan. St. Johns River Water Management District has even provided significant funding for countywide water supply plans. Examples include the Flagler Water Supply Plan, the Putnam County Water Supply Plan, and several others. The IWRP demonstrated that the County has urgent infrastructure needs, so it is understandable why the County moved forward expeditiously with its planning. However, the timing, extent, and locations of growth outside of the County’s service areas could well influence what actions the County may need to take in the future. For example, water use in areas served by St. Johns County Utility Department in 2010 was approximately 19.4 mgd11; however, total water use in the County in 2010 was approximately 44.6 mgd.12 Thus, it would be prudent for the County to collaborate with other water users within the County as it refines, updates, and implements its water supply plan.

11 District Water Supply Plan, draft of Dec 2013, St. Johns River Water Management District, Appendix A, table 12 District Water Supply Plan, draft of December 2013, St. Johns River Water Management District, Appendix A, table

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