We have reviewed Draft #1, District Water Supply
Plan, of the Water 2020 program, and its Appendices and Executive Summary,
and have attempted to evaluate both the assumptions underling the elements
listed, and the total effect of these elements. The following relates specifically
to the Volusia-Flagler area, the EPA designated Sole Source Aquifer, although
many of the items relate generally to all geographic areas included in
the document.
First, we must submit that these documents cannot
be called a plan. Instead of the required action elements we find a set
of "RECOMMENDATIONS". Under these we find a set of "implementation strategies",
each with a set of "Proposed Action". In no place do we find to whom these
are directed, or who will take action, or when action will occur. With
no schedule, no indication of resource allocation and no method of measuring
progress against a schedule, the meat required in a plan is totally missing.
Secondly, we find that many of the elements of the
recommendations and proposed actions to have a flimsy foundation, or to
be outright damaging. For example:
- A projected major future source is stated to be the St. Johns River.
We find no items relating to the impact on the river water quality, no
estimate of effects on riverine life, and no analysis of the impact of
salinity changes on the lower river. We have heard informally that withdrawal
would be limited to high flow periods as a way to avoid such problems,
but long term
availability would require storage: we find no discussion of this,
no cost estimate or plan. Additionally, there is nothing on the disposal
of the used water.
- We find no statement on the minimum level of the aquifer system or
systems.
- We find no information on minimum flows for the Tomoka River or Spruce
Creek.
- We find no statement on the effect of variability of rainfall. While
there is material relating to the 10 year drought, it relates only to the
increase in consumption in dry periods, with no coverage of the decrease
in availability of water during droughts.
Additionally, the documents relate drought in an
obscure way to a 90 percent probability during a year, rather than to the
event which has a 50 percent probability of occurrence during a given 10
year period (there is a 16% probability that it will occur in a 3 year
period, and an 83% probability of occurrence at least once in 33 years).
The magnitude of droughts is not discussed, nor are conclusions presented.
- The structure of the proposed minimum flow and level process allows
drawdown of flow or level at all times, including an event where the flow
or level is less than any historic value. This is not the establishment
of a minimum.
- A portion of the material relates to further drawdown of wetland
water levels. Because of the shape of wetlands, this amounts to a further
decrease in wetland area. It can also mean a change in wetland type, since
the average water level is reduced. There is no listing of the wetlands
which will be affected by this step, nor any listing of the criteria used
in their selection.
We do not find any mention or the fact that the
CUP process has issued permits for much greater consumption than is implied
in the current use figures, nor any comparison of the time impact of the
differences. In this connection, we note that the several tables relating
to water use are inconsistent in both content items and their values. Some
tables do not include units.
We are extremely concerned by the failure to include
and evaluate several components of the water system. Probably the most
important is the effect of the miles of drainage canals in our area of
interest, including the potential benefit of canal flow control elements.
We see nothing on the possibilities of re-hydrating wetlands, to increase
recharge and to increase dry-period stream flow. We also see nothing on
control of surface permeability as a way of maintaining recharge and reducing
flood and stream flow problems.
We do not find any definitive statement on the impact
of aquifer drawdown on vegetation, on stream flow, on effect on minor springs
and seeps, on levels of lakes which are coupled to the aquifer, nor on
the change in fire hazard due to reduced evapo-transpiration. We consider
these items to have high long term importance.
We are unable to find any statement relating to
cumulative impact of all drains on the aquifer system or on the complete
water system. We had understood that the Board had directed that cumulative
impact be evaluated, and appropriately included in planning.
In this connection, the data we have available indicates
that the withdraw from the Volusia-Flagler aquifer system currently exceeds
the recharge to it 3 years out of four, with the recharge in the high-rain
periods insufficient to make up the 3 year deficit. This is confirmed by
the steady decrease in the long-term average levels of key monitoring wells,
1955 to date.
It is implied but not stated that the "baseline"
for consumption, flows and levels and aquifer drawdown is the period around
1993, although this period was clearly stated in meetings on the subject.
We object in the strongest terms to the use of any single baseline year
or any short period, and further to the specific choice. It is our opinion
that the history of the aquifer levels, stream flow, and wetland area must
be presented, the timing of change shown, and the effects of the changes
determined, this as a prelude to establishing the specific action plan.
The data available to us suggests that the 1935-1955 period is important,
since it provides essentially pre-development conditions, an important
baseline.
We have long maintained that a water-budget model
is needed for the Volusia-Flagler aquifer system, this to include the natural
water sources, human uses, storage in aquifer levels and swamps, stream
flow, springs and evapo-transpiration. We are unable to understand how
proper use of water resources can be planned and implemented without this
tool to show total impact.
We further note that the range of action of the
water management districts is not unlimited. A plan must show what action
is to be taken under what conditions, and how the resources needed to accomplish
the action is to be made available.
(Note: Later revisions of this "Plan" has the same defects.)