There’s something going on in north Florida. Water is disappearing. Lakes and rivers are at historic lows. First-magnitude spring discharges have dropped to half their historic average flows.
Is it drought? Or is it over pumping that is allowing water to be permanently taken from groundwater sources that would otherwise support the area’s lakes, rivers, and springs?
How these questions are answered is important to the future of Florida. Are we reaching the limits of our naturally existing water supplies? If so, how are we defining that limit and where are we going to find new sources of water that are not going to cause the “harm” now occurring? This is a crucial dilemma because if we say we have tapped out all existing cheap water supplies and there are no alternatives, economic growth as we know it is going to come to a screeching halt.
Florida’s history over the last 40 years is rife with legal and political battles over water. While the state has continued to flourish economically without being significantly hindered by its rising cost, that time might be over, and new battles with much more at stake could be in the offing.
Over the last 40 years, the state has grown phenomenally. Before environmental laws were passed in the 1970’s and 1980’s, wetlands were routinely drained and “reclaimed” for development. Water was pumped without constraint from groundwater aquifers, lakes and rivers. It was only after the mounting damage became obvious to even the most disinterested observers, and water utility operators found saltwater tainting their supplies, that state leaders realized the growing competition for water needed a referee with the authority of a policeman. If the state was going to continue to grow, it would need to begin seriously regulating water uses in order to, 1) prevent interference between users, 2) prevent the destruction and loss of existing sources, and 3) make certain that all water use would be reasonable, beneficial and consistent with public interest.
Today, however, the competition between economic growth and its boundless need for more and more, cheap water and the needs of the state’s fragile natural systems is growing sharper. Consequently, the relative calm that has been apparent for the last decade due to a nationally recognized regulatory structure mandated by the legislature and instituted by the water management districts may be about to end.
In the past, new water could nearly always be found, albeit a little more expensive. While laws protected the destruction of valuable natural systems, water management districts developed creative funding partnerships with public and private utilities that served to lessen the brunt of having to use more expensive water. Conservation and reuse made original supplies last longer and serve more people. The public began to irrigate their lawns with water reclaimed from sewage and recycled storm water, and laughed when someone suggested the good news is that, one day, we’ll all be drinking poopoo water; but the bad news is that there won’t be enough to go around. It was an educational process brought on by necessity and collaboration between the regulator and the regulated, which was a good thing.
But there’s something different going on now. There seems to be a growing lack of interest, even disdain, for protecting and preserving Florida’s sensitive and unique natural environment. It’s a growing cynicism that says the value of natural resources when found in competition with certain powerful special interests can and will be sacrificed. The mantra seems to be jobs and profit at any cost.
This increasingly acrimonious nexus between protection of the environment and the growing demand of businesses for the right to override that protection is leading to a new round of fighting over the future of Florida.
The enormously important question is becoming, how well are regulatory programs defining the ultimate point at which no further withdrawals from a prized water source will be allowed and how effectively will a regulatory agency be able to prevent exceeding that absolute regulatory limit in the face of strong political winds out of Tallahassee? Simply put, how will the ultimate competition between the water needs of healthy natural systems and the state’s economic vitality be reconciled?
It will take a Solomon, unfortunately not currently available, and the answers will dictate the future of Florida’s quality of life.
What’s Wrong With World Famous Silver Springs
Consider what’s happening within the springshed of Silver Springs which boils to the surface just east of Ocala, one of the most famous first magnitude springs in the world. The water it produces, which used to roil to the surface at the average rate of nearly 500 million gallons every day, flows east to become the Silver River, a major contributor to the base flow of the Oklawaha River. The spring system that comprises Silver Springs is fed from an extraordinary, pressurized aquifer that forces crystal clear water to flow freely from over 900 other artesian springs along the northwestern coast of Florida, the largest concentration of such springs in the world.
The water has historically been so pure old timers tell of scooping it up by hand and drinking directly from the spring with no harmful effects. As long ago as 1878, glass bottom boats plied tourists over the crystal clear boil to marvel at the massive canyon from which the water came and explore the wild swamps through which it flowed for miles before entering the Oklawaha River. It is the oldest and, along with Weeki Wachee Springs, “The Spring of Live Mermaids,” perhaps one of the most revered tourist attractions of Florida’s heritage.
And yet, today the spring is struggling to survive against a horrendous drought and the pumping of others from the source-aquifer that feeds it. So severe has been the increased competition for its water from agriculture, homeowners and golf courses in recent years that the average flow from the spring has been in a steep decline starting in the 1980’s. Last year, 2011, the flow dropped precipitously to only 50% of its historic long term average, and now there’s a new proposal to pump even more water from its springshed, a 1200 square mile recharge basin that maintains its flow.
The impacts of growth on the spring have not been limited to decreases in flow. The quality of the spring’s water is deteriorating, probably due to the growing population of Marion County which has increased ten-fold since 1950 and the related massive transition from natural forest to agricultural and urban land uses. In 1957, nitrate loading was measured in the main spring at 47 tons per year. By 2005, it was 529 tons per year and by 2055, loading is projected to be in the vicinity of 880 tons per year. Such massive amounts of nitrates can and will cause the proliferation of lyngbya and other non-native nuisance growth. Algal growth has in fact increased within the spring and fish populations are in decline. Fish population biomass decreased an order of magnitude from 470 pounds per acre in 1952-55 to 37 pounds per acre in 2004-5. This is like going from having 95 5-pound fish in your pond to only eight! (Dr. Robert Knight, Silver Springs Alliance Presentation - April 3 2012 meeting)
On top of this picture of a once magnificent but now ailing natural system, consider that there is now a request for a new withdrawal from the springs’ limited supply of source water. The permit application is for authorization to pump 13.267 million gallons per day (down from the original request for 27 mgd) from within the Silver Springs springshed. The applicant proposes to use the water to grow forage for cattle (12.56 mgd); water cattle (0.48 mgd); cool a power plant (0.16 mgd); plant processing (0.06 mgd); potable water for employees (0.005 mgd); and, pesticide use (0.004 mgd).
Water management districts are required by law to set a “minimum flow and level” (MFL) for specified water bodies. “MFLs are the minimum water flows and/or levels adopted by the District Governing Board as necessary to prevent significant harm to the water resources or ecology of an area resulting from permitted water withdrawals,” according to the St. Johns River Water Management District.
It would seem that, surely, with all that ails the spring to date that any minimum flow and level will have already been exceeded. The district, however, has not set such limits but says it has completed much of the necessary background investigation and analysis which will be available for its use in evaluating the permit.
As of this date, the application is still under evaluation by the district. The applicant has until April 28, 2012, to respond to the district’s request for additional information.
What’s wrong with this idea?
It’s important to put this request to pump more than 13 million more gallons per day from the source waters of Silver Springs in perspective. There is no way to put a positive spin on it.
First, the entire City of Ocala uses about 12.85 mgd. The newly proposed request for another 13.267 million gallons each and every day is a tremendous additional amount of water to subtract from the finite system that feeds the boil at Silver Springs. Certainly this will only worsen the drastically low state of the spring’s current flow.
The verbal legal criterion for the minimum level, as mentioned, is “significant harm.” Significant harm can occur through the cumulative impact of multiple permits if no consideration is given for all other permitted withdrawals, en masse, from the same source. Modern modeling techniques now available are comprehensive and routinely provide cumulative results from multiple withdrawals from multiple points. According to recent email traffic from the district, the district’s analysis will include this much broader computer analysis.
According to Dr. Robert Knight, water management districts have recently defined significant harm to springs when the average flow becomes reduced by 10%. For Silver Springs 10% would equal about 50 MGD. The estimated decline at Silver Springs is currently already about 160 MGD or 32% of historic average flow. This is clearly past the point of significant harm which suggests the district should be looking at instituting a recovery plan and denying any requests for additional withdrawals. (Florida law requires that the water management district develop and expeditiously implement a recovery and prevention strategy when a water body falls below or is projected to fall below its MFL)
The purpose of the water requested in the Adena Springs Ranch Permit is to grow grass to feed an estimated 30,000 head of cattle and operate a slaughter house.
30,000 cattle on 10,000 acres is equivalent to a human population of 330,000 people. The nitrogen loading from this many cattle is estimated to be more than 1000 tons per year (not including a commercial crop fertilization rate of 200 pounds per acre which would double the loading to over 2200 tons). One thousand tons per year over 10,000 acres equates to 2,000,000 pounds of nitrogen every year or 200 pounds per acre per year. A sustainable nitrogen load is estimated to be less than 2 pounds per acre per year or 10 tons of nitrogen per year for the entire 10,000 acres. Consider that the proposed loading of 1000 tons per year, at a minimum, is over 100 times more than is considered sustainable. (Dr. Robert Knight, Silver Springs Alliance Presentation - April 3 2012 meeting)
According to the Draft Restoration Plan for the Silver Springs and River prepared for the Florida Department of Environmental Protection, Ground Water and Springs Protection Section, (Normandeau Associates, Inc., June 16, 2011),
“As recharge occurs relatively quickly in most areas of the Silver Springs basin, nutrients applied to the land surface can reach the Floridan Aquifer rapidly....Livestock waste and commercial fertilizer make up the greatest estimated N load applied to land surfaces as well as to groundwater....”
Already, nitrogen loading of the spring has increased by 2,600% over the period of record of more than 100 years.
Certainly, the additional loading this permit would bring could be calamitous for the spring. Already, water clarity has decreased. Nighttime dissolved oxygen has declined by about 19%. Submerged aquatic plant biomass has declined by 21%. Total algal biomass has increased by 371%. Ecosystem productivity has declined by 27%. Insect productivity has declined by 72%. Fish biomass has declined by an astounding 92% and the flow of the spring has declined by 32% over the past decade and 50% since 1965.
It is noteworthy that the Silver River is an Outstanding Florida Water (OFW), the designation of which has apparently done nothing to protect it. Silver Springs and Silver River are definitely and doubtlessly impaired. One has to question the purpose for such designations if there is no beneficial result in doing so.
The supposed benefit, according to the Florida Department of Environmental Protection (DEP) website (http://www.dep.state.fl.us/water/wqssp/ofw.htm), is :
“Projects … that are proposed within an OFW must not lower existing ambient water quality… DEP also may not issue permits for indirect discharges that would significantly degrade a nearby waterbody designated as an OFW. In addition, activities or discharges within an OFW, or which significantly degrade an OFW, must meet a more stringent public interest test. The activity or discharge must be “clearly in the public interest.”
Also pertinent to the discussion is this. According to the St. Johns River Water Management District 2005 Water Supply Plan, 4th Addendum (http://www.sjrwmd.com/dwsp.html), Marion County is within a Priority Water Resource Caution Area (PWRCA). These are:
“… areas where existing and reasonably anticipated sources of water and conservation efforts may not be adequate (1) to supply water for all existing legal uses and reasonably anticipated future needs and (2) to sustain the water resources and related natural systems.”
If this is the case, then by its own assessment the district should not authorize an additional 13.267 million gallons per day to be pumped each and every day for the next 10 or 20 years from the very same source that feeds Silver Springs. To do so would fly in the face of its own conclusive science.
We will see if the St. Johns River Water Management District, now being run by a new group of Scott-appointed board members and a new executive director with little resource management background, will seriously consider these unmistakably clear words or find a way to ignore them as they decide whether or not to issue the permit.
A Final Cautionary Note
Water law in Florida allows water to be taken and used as long as that use doesn’t interfere with other existing users, doesn’t harm the water resources of the area and is consistent with the interest of the public.
These conditions suggest that when so much water might be permitted from a given source that harm will occur, then that source has reached a limit beyond which no more water should be taken.
Obviously, how harm is defined and measured by the laws and rules of water permitting is crucial because it is at that point the resource will either be protected or damaged from further impacts.
Measuring harm is not easy because in the final analysis “harm” is not a scientific term though it’s supposedly science-based. It is a societal judgment expressed in numerical measurements which can be subject to the environmental or anti-environmental whims of the legislature. The definition of a wetland, for example, can be significantly changed simply by including or not including particular plant species expressed in percentage of coverage.
Impacts occur anytime when water is removed from a natural water body, or when any unnatural chemical is added to the water column, or when less water is available, for whatever the reason, to support water-dependent biomass. The difficult question is, at what specific numerical point will no further impacts be tolerated? Does harm occur when permitted water withdrawals cause a 25% reduction in biomass, or 45%, or 65%. It is at that precise, measured point that “harm” becomes defined and it is the regulators, directed by legislative policy that set that number.
While understanding the numbers may seem relatively simple, setting the policy is not. The difficulty might be illustrated, for example, by placing the decision between an environmentalist and the owner of a phosphate mine. Agreement would be hard to reach. Consider also if once reached, however, how easy policies can be changed by a conservative, business oriented legislature or a more environmentally sensitive legislature, depending on which is in power at any given time. Any good policy, it seems, can be as ephemeral as a raindrop on a sand dune in today’s treacherous political winds.
In any case, any rational, thinking person will conclude that a 32% reduction in average historic flow and an order of magnitude reduction in biomass for Silver Springs are well beyond any tipping point.
Florida’s springs are among the most unique water features in the world. Unlike great falls that roar and create memorable vistas, springs gurgle quietly from vast underground canyons and limestone aquifers as porous as Swiss cheese, cover thousands of square miles and are hundreds of feet deep. But while their waters were at one time tremendously bountiful, crystal clear and completely drinkable, today they are flowing at alarmingly lower rates and are clouded by silt and slime-like algae that feed on nutrients leached from fertilized crops, golf courses and septic tanks. Their flows have, in some cases like Kissingen Springs, even ceased or, like Silver Springs, become seriously diminished.
It is time to start accepting the evidence that is as clear as the palm of one’s hand. We simply cannot continue to ignore what we see and disparage the growing concerns as just more environmental nonsense. We are past that. This is not tree hugging. The state’s economic future is as much at risk as our children’s quality of life if we arrogantly ignore the signs. Some argue Silver Springs is just suffering from drought. Therein lies the real nonsense.
What To Do?
Submit Your Concerns to the St. Johns River Water Management DistrictIf you want to comment to the district about how you view this situation, here is how to access the permit application, supporting documents, and correspondence:
1. Go to the SJRWMD permitting page. https://permitting.sjrwmd.com/epermitting/jsp/Search.jsp?option=permitNumberOption
2. Select "search by Application/permit number" in the right-hand column.
3. Enter the application number 129419 and click submit.
4. Then, click on the Permit Number in far left cell to access the permit documents and to comment and receive notifications.
5. Click "To comment or receive notifications" in the middle of the page to receive updates and to voice your opposition.
You can also send comments via email to: email@example.com and SJRWMD Executive Director Hans Tanzler at firstname.lastname@example.org.
(You may have to copy and paste these into your email "to" box.)
(You may have to copy and paste these into your email "to" box.)
Resources & Additional Information
· Dr. Robert Knight, Silver Springs Alliance Presentation - April 3, 2012
· Silver Springs 50-Year Retrospective Study (SJ2007-SP4) http://www.sjrwmd.com/technicalreports/pdfs/SP/SJ2007-SP4.pdf
- SJRWMD page for this permit application: http://floridaswater.com/facts/AdenaSpringsRanchCUP.html
- Missing water has the experts all at sea, Ocala Star-Banner 2/11/12 http://www.ocala.com/article/20120211/ARTICLES/120219927
- Editorial: 13 million gallons of water a day!, Ocala Star-Banner 2/8/12 http://www.ocala.com/article/20120208/OPINION/120209739?p=2&tc=pg
- Objections raised on permit, Ocala Star-Banner 2/3/12 http://www.ocala.com/article/20120203/ARTICLES/120209885/1005/sports01?Title=Objections-raised-on-water-permit
- Cattle call: 13M a day, Ocala Star-Banner 1/6/12 http://www.ocala.com/article/20120106/ARTICLES/120109806?p=1&tc=pg