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 District
If 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: applicationsupport@sjrwmd.com
and SJRWMD Executive Director Hans Tanzler at htanzler@sjrwmd.com.
(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
