All,
Several conditions of the JEA CUP Technical Staff Report are of importance and I have reproduced those sections below FYI.
Was pleased to see that Peter addressed pumping location
and advised that the recommendation was for a site some distance from the Lake
Brooklyn at Dupont/Blanding site to avoid certain adverse consequences. If this could be accomplished at Geneva or
other lakes is another matter entirely.
You will see that JEA is limited to the portion of their
impact and that they also must participate in recovery for only any one of the
three lakes at issue -Cowpen, Geneva or Brooklyn. Naturally, I am concerned that this provision
will allow JEA to walk away from participation in any other lake recovery efforts
if the plan is adopted only for Lake Brooklyn.
This situation could have several undesirable consequences that we
should consider and address.
SFLDA will also be addressing the Suwannee and Santa Fe
interlocal agreement, coordination and potential for adverse impacts which have
been completely disregarded or overlooked up to this point.
Terry
Excerpts from the Technical Staff Report JEA Cosolidated CUP
Minimum Flows and Levels
Staff also evaluated the effects of water withdrawals in
northeastern Florida on lakes with MFLs established by the Governing Board in
rule chapter 40C-8 of the Florida Administrative Code, cited as F.A.C. The
District considered the impacts of JEA's proposed use on eight lakes with MFLs
in the region potentially impacted by JEA: Banana, Como, Little Como, Tarhoe,
and Trone lakes in southern Putnam County, Cowpen Lake in western Putnam
County, and Lakes Geneva and Brooklyn in southwestern Clay County. Based on the
model results, staff concludes that JEA's proposed withdrawals will materially
contribute to groundwater declines affecting water levels only in Cowpen Lake
and Lakes Geneva and Brooklyn.
The District is currently moving forward to expeditiously
develop an MFL prevention and recovery strategy for the lakes in the western
Putnam and southwest Clay County, including Cowpen Lake and Lakes Geneva and
Brooklyn. The District is developing this plan after concluding that some lakes
will likely not meet the adopted MFLs, and that Lake Geneva does not currently
meet all of its adopted MFLs, based on historic water level data. The District
concludes that both climatic conditions (rainfall deficits) and water use have
contributed to the current observed conditions. To provide reasonable assurance
that the proposed use is reasonable-beneficial and not subject to the reasons
for denial set forth in section 9.4.1(f) of the Handbook, the permittee must
participate in developing and implementing one or more regional
prevention/recovery strategies to mitigate the cumulative impacts of existing
and proposed water use on Cowpen Lake, and Lakes Geneva and Brooklyn, achieve
recovery to the established minimum levels for Lake Geneva, and prevent the
levels in Cowpen Lake and Lake Brooklyn from falling below their established
minimum levels.
JEA's participation is limited to addressing its portion
of the impact at these lakes, as provided for in a District approved prevention
and recovery strategy. To ensure JEA's participation in the development and
implementation of one or more regional prevention/recovery strategies for these
lakes, staff is recommending a condition limiting JEA's maximum groundwater
allocation to 142.26 mgd until JEA complies with several specified conditions.
One of them requires JEA to participate in developing such a strategy for any
of the three lakes at issue and, once the Governing Board approves such a
strategy, to timely implement its share of the actions to be taken to achieve
prevention or recovery.
Surface Waters
Staff evaluated whether JEA's proposed withdrawals would
cause environmental impacts to the Upper Santa Fe and Upper Suwannee Rivers
in the Suwannee River Water Management District. The District concluded that
due to the hydrologic characteristics of the Upper Santa Fe River, even small
reductions in stream flow could potentially be harmful. The District also
considered impacts on the Upper Suwannee River and concluded that upstream from
Alapaha Rise, harm could potentially result from even small reductions in the
river flow below the median discharge that are exceeded approximately 50 or
more percent of the time in the Upper Suwannee River. Staff concludes that
there is reasonable assurance that the applicant will not contribute to an
unacceptable reduction in flow in the Upper Santa Fe and Upper Suwannee Rivers,
based on the projected aquifer drawdown from JEA's proposed withdrawals near
these rivers, and the recommended permit conditions already discussed above,
which would limit JEA's groundwater allocation until compliance with certain
conditions was demonstrated, including the implementation of any prevention/recovery
strategy approved by the Governing Board for lakes in western Putnam and
southwestern Clay Counties. In addition, staff is recommending that the permit
include permit conditions requiring that JEA submit updated analyses of the
impacts from the permitted use on wetlands and surface waters including the
Upper Santa Fe and Upper Suwannee Rivers, and specifying that if the District
concludes from the monitoring data, updated
analyses, or other information that adverse impacts to
wetlands (or other water bodies) are or are projected to occur as a result of
JEA's withdrawals, the District will revoke the permit in whole or in part to
curtail or abate the adverse impacts, unless the permittee mitigates the impact
pursuant to a District-approved plan.
These measures (along with the overall reduction in JEA's
initial requested allocation of groundwater) provide reasonable assurance that
the proposed use will not contribute to unacceptable harm to the Upper Santa Fe
and Suwannee Rivers.
Terry,
From a Hydrogeologist point of view, we believe that once
Lake Brooklyn is augmented with water from an outside source, the surrounding
water table aquifer will be "rebuilt" as well. Once that happens, the
water table aquifer between Lake Brooklyn and Lake Geneva will also recover and
will start providing surficial aquifer seepage to Lake Geneva. In addition
there is an overflow from Lake Brooklyn to Lake Geneva, so when Lake Brooklyn
reaches that overflow elevation water will flow directly into Lake Geneva.
John and I appreciate the detailed description of the
conditions which was attached to the JEA WUP. It will not be easy to determine
the drop in the groundwater levels in the Keystone Heights area which can be
attributed to the pumpage from the permitted JEA well-field. If the regional ground water flow model
project gets off the ground and delivers a reliable replica of the groundwater
system, John and I can run several modeling scenario's to determine quite
accurately the drawdown caused by the pumpage from JEA.
The next question to be answered is: "What is the
increased loss in surface water from Lake Geneva (or Lake Brooklyn or Cowpen)
for each foot of groundwater level decline in the Floridan Aquifer?". John
and I hope that the newly created ground water flow model can provide a
reliable answer.
Considering all the facts as they are known today, we
both feel confident that the long-term solution to improve lake level is the
importation of water from an outside source. We elected to look for such a
solution within the boundaries of Clay County. We believe that the augmentation
of the lakes with surface water from Black Creek should be a serious contender
for consideration as a solution.
Assuming that such an importation option could be
implemented at a cost which is reasonable, then the lakes would start to add
more water to the Floridan Aquifer. This increase in ground water availability
could possibly be used for an additional ground water supply. This availability
of additional ground water would not cause an impact to the lakes. You might ask who could use this additional
supply? We suggest that the additional
availability of ground water could be withdrawn by the Clay County Water Supply
Authority (CCWSA) and could be made available to JEA at a pre-determined cost.
The income from this delivery of newly available groundwater resulting from the
lake augmentation with surface water from Black Creek could be used entirely or
in part to pay for the cost of moving the Black Creek water to the lakes.
If such a plan could be implemented, the surface and
ground-water water resources in Clay County could provide a long-term and
reliable source to improve the lakes and provide a reliable source of
relatively inexpensive drinking water from the Floridan Aquifer. How this idea
fits in the permit conditions of the JEA WUP is yet to be evaluated and
determined.
Peter
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