CONSERVATION REPORT by Whitey Markle
For this month’s conversation report there are the following letters.
COMMENTS SUBMITTED BY THE SUWANNEE/ST.JOHNS SIERRA CLUB GROUP 8/16/2015 to the ST JOHNS RIVER WATER MANAGEMENT DISTRICT re: The CENTRAL FLORIDA WATER INITIATIVE.
The Suwannee/St. Johns Sierra Club encompasses 16 counties of North Florida. The Central Florida Water Initiative is of grave concern for our 1985 members who will be adversely affected by the Plan if it is implemented the way it is written; The surface waters of our Group’s responsibility will be further degraded and depleted as well as the groundwater.
The solutions to the problem of providing sufficient water for additional growth in the central Florida region proposed in the Plan appear to be mere desperate attempts at supply when there is no supply available, and there is nearly NO water conservation in this draft. Of the projected 250 million gallon per day (mgd) water deficit in the Central Florida region, only 37 mgd is estimated to come from conservation initiatives. This is actually less than the 42 mgd that was originally projected in previous drafts.
The method of “injection” of used water BACK INTO OUR DRINKING WATER is a dangerous and irresponsible attempt at conservation. We think that the people own the water under us, not the influential politicians in Tallahassee, Palm Beach, Palatka, or Brooksville. Some of the “projects” the Water Management Districts are giving away in the form of “cost-sharing” (some are 90% to 10%) are preposterous, and they will NOT accomplish any sort of conservation, only further depletion of the good ground water, and there is not nearly enough funding in the budgets to accomplish sufficient project effectiveness, as well as oversight, milestones, and monitoring.
The truth to the dilemma is that there are simply too many people in Central Florida now and a growth in human population is erroneous policy. Unless new population is carefully planned, including water use, we will be far short of adequate fresh water. At this point, a pound of Nitrogen (our biggest water polluter) costs a farmer, golf course owner, gardener, or homeowner a mere 50 cents to apply, but if we keep applying fertilizers at the present rate , but when the water budget becomes deficient, it will cost the taxpayers and ratepayers $500 per pound to remove. We believe your solutions to Central Florida’s water supply are short-term, temporary, and extremely costly in the long term.
We realize the political nature of your position(s) in the state government, but we emphasize your responsibility regardless of politics. Entities such as Agriculture, municipalities, and development must sooner or later reach the reality that the citizens’ water is not infinite and not free (as it has been to date). There must be a plan to start paying for the water sooner or later. Citizens have to pay for it and so should farmers and developers, and like other businesses, they should foot the bill for monitoring water usage. It is time to get serious, not to “kick the can”.
We believe your weighting of the citizens in the stakeholder analysis, although appearing to be few in their number of representatives (volunteer), far outweigh any of the others. It is the citizens who will eventually pay the extremely high price of reclaimed, recycled, and refined water.
Our Suwannee/St. Johns Group takes pride in being the bastion of ecotourism which is dependent upon clean, fresh water. “Alternative Water Supply” designs, such as declaring Rodman Pool/Reservoir to be a supply source, will cripple the ecotourism industry in Marion and Putnam Counties which is environmentally sensitive, economical, and educational. Conservation by agriculture, development, and the municipalities must be entered into your Central Florida Water Initiative as opposed to further draining and pumping the surface water.
We suggest that you postpone the Central Florida Water Initiative until you can assure the citizens that their fresh water will be protected and conserved in a meaningful long-term.
Sincerely, Whitey Markle, Conservation Chair, Suwannee/St. Johns Sierra Club Group
COMMENTS TO FLORIDA DEPARTMENT OF ENVIRONMENTAL PROTECTION by DR. ROBERT KNIGHT, Ph.D., President of the Silver Springs Alliance.
Comments on the Draft Silver Springs BMAP (Basin Management Action Plan):
The draft Silver Springs BMAP applies to a spring basin that totals approximately 989 square miles or 632,960 acres. The Silver Springs Alliance does not agree with the springshed covered by the draft BMAP. At the beginning of the BMAP process the Florida Springs Institute (FSI) provided convincing evidence for using a larger contributing area of about 1,300 square miles or 832,000 acres. This is the total area that has been shown through scientific analysis to contribute groundwater flows to Silver Springs and is nearly one third (31%) larger than FDEP’s BMAP basin area. It will be impossible to achieve the Silver Springs nitrate TMDL of 0.35 mg/L while omitting nearly one third of the contributing basin from any source control responsibilities. The Silver Springs TMDL requires a 79% reduction of nitrate nitrogen concentrations in Silver Springs and the Silver River to achieve the 0.35 mg/L concentration target. Based on FDEP’s analysis described in the draft BMAP document, achieving this legal requirement will entail the elimination of more than 8 million pounds of existing nitrogen loads in the Silver Springshed.
The Silver Springs Alliance believes that all controllable sources of nitrogen in the basin, including agriculture, septic tanks, urban fertilizer use, and wastewater and stormwater disposal, will need to be part of this effort. The only fair way to apportion this effort is with the initial assumption that all of these sources will share equally by reducing more than 79% of their existing nitrogen load (assuming that the nitrogen load from atmospheric deposition is not part of the TMDL). Based on the draft BMAPs estimated loading by source, this equates to the estimated target nitrogen load reductions by source summarized in Table 1 below. SILVER SPRINGS ALLIANCE, INC. 3 The draft BMAP provides for a very small fraction of the required nitrogen load reductions. For example, agricultural sources, the largest category of nitrogen applied to the land surface is only required to clean up 2.6% of their estimated load. Nitrogen loads from the estimated 66,000 septic tanks in the FDEP BMAP area only have to be reduced by an estimated 1.5%. The overall nitrogen load reduction described in this BMAP document is less than 6% of the total estimated load. Consequently, it is the conclusion of the Silver Springs Alliance that the draft Silver Springs BMAP does not even come close to providing the legally-required roadmap for timely recovery of Silver Springs water quality. Table 1. Summary of estimated loads of total nitrogen to the land surface in the Silver Springs BMAP area and target load reduction goals by source based on the FDEP TMDL of 79% nitrate reduction. Source Category TN Loading to Land Surface (lbs N/yr) TN Load Reduction Goal (lbs N/yr) Agriculture 7,596,510 6,001,243 Atmosphere 2,454,844 N.A. Septic Tanks 1,588,491 1,254,908 Urban Fertilizer 1,028,106 812,204 Municipal Wastewater 581,895 459,697 Drainage Wells 40,298 31,835 Totals 13,290,144 8,559,887 Marion County Groundwater Wells Nitrate Map While restoration and protection of Silver Springs and the Silver River are the primary goals of the Silver Springs Alliance, our group is equally concerned for the health of the residents of Marion County and the surrounding areas. Nitrate is not only a primary cause of ecological imbalance at Silver Springs but is also a toxin to humans when elevated in drinking water. Achieving compliance with the nitrate TMDL at Silver Springs equates with improving the quality of life for all residents in the Silver Springs groundwater basin. Numerous lines of evidence indicate that existing elevated nitrate concentrations throughout much of the Florida aquifer may be harmful to humans in addition to their noxious effects on the ecology of the springs. The Environmental Protection Agency (EPA), on its’ website states that “nitrate may cause problems if present in public or private water supplies in amounts greater than the drinking water standard set by EPA.” The maximum contaminant level (MCL) for nitrate nitrogen is 10 milligrams per liter (mg/l). The same EPA website states that “infants below the age of six months who drink water containing nitrate in excess of the MCL could become seriously ill, and if untreated, may die.” SILVER SPRINGS ALLIANCE, INC. 4 The President’s Cancer Panel Report (2010) states that the : “…most likely known mechanism for human cancer related to nitrate is the body’s formation of N-nitroso compounds (NOC), which have been shown to cause tumors at multiple organ sites in every animal species tested…”. The report goes on to say: “In humans, NOCs are suspected brain and central nervous system carcinogens”; and that in an Iowa study, older women drinking water with elevated nitrate concentrations had increased risk for bladder cancers. The authors conclude that nitrate in drinking water at concentrations less than 10 mg/L MCL (the “safe” human drinking water standard) could be carcinogenic and that further research is warranted, especially since groundwater nitrate concentrations in many agricultural areas continue to increase. Figure 1 provides a map of recent groundwater nitrate nitrogen concentrations measured in drinking water wells located in Marion County. Nitrate “hot spots” occur throughout much of the county. The Silver Springs Alliance believes that nitrate in drinking water may be a serious health threat to the residents of Marion County, even if it is less than EPA’s MCL. This is a compelling reason, in addition to Silver Springs restoration, to significantly lower human-caused nitrogen loads to the Florida aquifer. Figure 1. Map of groundwater nitrate concentrations in public and private potable supply wells in Marion County, Florida for the period from 2010 to 2013 (data from FDEP and Florida Department of Health). SILVER SPRINGS ALLIANCE, INC. 5 Conclusions The Silver Springs Alliance is determined to achieve its goals related to Silver Springs restoration and protection. The draft Silver Springs BMAP prepared by FDEP and other local and state governmental agencies does not comply with the will of the people that it affects. For this reason, the Silver Springs Alliance rejects the insufficient nitrate reduction strategy presented in the draft BMAP document. The Silver Springs Alliance recommends that FDEP:
1) Increase the BMAP area to include the maximum-extent contributing area;
2) Include a mandatory reduction in nitrogen loading rates of at least 30% by all agricultural operations located in contributing areas listed as Vulnerable, More Vulnerable, and Most Vulnerable within the next five years, at least 50% in the next ten years, and at least 79% in the next 20 years; and
3) Hook up at least 30% of all septic tanks on properties of two acres or less, located in the Silver Springs contributing basin within the next five years, at least 50% in the next ten years, and at least 79% in the next 20 years.
These recommendations have an honest chance of achieving the TMDL legal requirement of a 79% nitrate load reduction. Anything less does not. Finalizing a BMAP plan that has no chance to remediate the existing widespread groundwater nitrate contamination is not an option for Silver Springs or for the Marion County residents who are drinking and bathing in this tainted water. In a spirit of cooperation, members of the Silver Springs Alliance are willing to meet with FDEP staff to discuss how to best incorporate these recommendations. If FDEP chooses to ignore the Silver Springs Alliance’s recommendations to cure the problems in the draft BMAP, then the Silver Springs Alliance requests to be removed from the list of BMAP stakeholders.
We think DR. Knight’s leadership in writing this letter is exemplary, and demonstrates the inadequacies of the BMAP process.
LETTER TO FDEP re: SILVER SPRINGS BMAP and ORANGE CREEK BASIN BMAP
The following is a copy of my letter to The FDEP Working Group coordinator on August 18, 2015
VIA ELECTRONIC MAIL: firstname.lastname@example.org
Re: Comments on the 2015 Draft BMAP for Silver Springs and the Silver River
Dear Ms. Paulic:
As a stakeholder in the Silver Springs Basin Management Action Plan Working Group and the Orange Creek Basin Working Group proceedings and having provided input on several occasions during the process, the Suwannee/St. Johns Sierra Club Group contributes the following comments:
As was discussed with Dr. Palmer, myself, and yourself after the last OCB BMAP meeting (August 6), we believe the spirit of the statute is being ignored if not evaded:
The mandate in the law concerning “New Projects” (especially in the 5 year review process) is being redefined. The “New projects” in the recent plans are actually continuations of the old projects (that obviously haven’t achieved better water quality in the Basin).
Statutorily mandated funding for projects and monitoring has not been adequately provided. It appears to us that the Department’s reliability on the (precarious) legislature for such funding is quite undependable, especially in view of the legislature’s handling of Amendment 1 funding this last session.
Sadly, the fact remains that volunteer organizations face an insurmountable obstacle in assuring that your agency (and others) adequately protect our natural resources. That obstacle is money. Our tax dollars appear to be used to subsidize the entities we think are causing the environmental harm (agriculture, development, and municipal industry), leaving us with no choice but to attempt to remedy the issues with our voluntary donations. This is a staggering disadvantage.
As you are well aware, I have personally (along with other environmental advocates) pointed out several times in the hearings that we believe the objectives and spirit of the statute(s) are not being attained nor attempted, and that the BMAP process is not working.
The Suwannee/St. Johns Sierra Club believes that the Basin Management Action Plan Working Group process(s) for both the Silver Springs BMAP and the Orange Creek Basin BMAP are unproductive if not nonproductive.
Whitey Markle, Conservation Chair,
Suwannee/St. Johns Sierra Club Group