Title: Letter from WCRWSA to SWFWMD
Full Citation
Permanent Link: http://ufdc.ufl.edu/UF00051841/00001
 Material Information
Title: Letter from WCRWSA to SWFWMD
Alternate Title: Letter from WCRWSA to SWFWMD commenting on the "State Water Use Plan --- Draft 76."
Physical Description: 7p.
Language: English
Publication Date: April 27, 1976
Spatial Coverage: North America -- United States of America -- Florida
General Note: Box 3, Folder 6C ( WEST COAST REGIONAL WATER SUPPLY AREA B3F6 ), Item 177
Funding: Digitized by the Legal Technology Institute in the Levin College of Law at the University of Florida.
 Record Information
Bibliographic ID: UF00051841
Volume ID: VID00001
Source Institution: University of Florida
Holding Location: Levin College of Law, University of Florida
Rights Management: All rights reserved by the source institution and holding location.

Full Text

Mr. Donald R. Feaster -7- April 27, 1976

The designer must design for peak loads, which as in power
systems, are critical. Thus the discussions which relate
needs in terms of averages would more appropriately focus
on the critical peak needs.

We look forward to your next draft and appreciate the
opportunity to provide our views.

Since -y

Richard J. Hesse
General Manager


Mr. Donald R. Feaster -6- April 27, 1976

trauma which has been displayed in the past.

The new sources of domestic water supply projected in the draft
appears to focus almost entirely on large remote springs and surface
flows that are highly visible while soft peddling the less visible
potential of more fully developing the resource near the demand
areas. This development could be accomplished by combining the
techniques of;
1) Dispersed and Linear well fields.

2) Salvage from E-T losses in the cones of depression
from groundwater withdrawals.

3) Injection and later retrieval from the saline areas of
the aquifer of excess surface water.

4) Flood detention areas with recharge to the aquifer.

5) Salt water barriers in coastal streams, rivers, drainage
ditches and canals.

6) Fresh water impoundment areas in the coastal salt marshes
where surface water is available and the area of the marsh
so utilized is not an important nursery area.

7) Contour plowing, ditch checks, recharge pits and other
measures suggested in your recent study of the Pinellas-
Anclote/N.W. Hillsborough Basins.

From a careful consideration of these factors and any others we
may have overlooked, a refined water crop or water budget and
potential sources of development can be made and approximate cost
estimates developed. With all of this information on hand for a
particular basin and the adjacent basins, a logical approach can
be made to specify the "maximum reasonable-beneficial use" in
that particular basin. This should be the goal of the SWUP.

Data now being developed for the WRMS (Water Resource Management
Study) by Geraghty & Miller, Inc. and Roy Weston, Inc. should provide
you with much of this information, although to pull it together and
add the environmental factors, will still be a challenging task.

At the outset it is stated that "Florida is blessed with a
bountiful supply of water, although not always in the right place
at the right time." Most of the plan is devoted to moving water
from where it is plentiful to where it is not always plentiful.
Similar consideration should be given to trying to balance peak
demands through various types of storage or usage, such that we can
partially level the cyclical demand or utilize the excess water
available at certain times of the year. From the conceptual manage-
ment standpoint, this is one of the major alternatives available
to meet future needs. It should be fully explained and discussed.

Mr. Donald R. Feaster -5- April 27, 1976

its effects on the SWUP.

This does not appear to be a "Concept or Alternative" for
developing a SWUP and would be more appropriately included
on page 5 under the section "Cultural/Political Description."

Multiple Use of Water Withdrawal Facilities
This concept has great merit and should be expanded to include
surface and ground water supplies. In the power plant/agriculture-
domestic example, during periods of high stream flows, a large
percentage of all demands might be met from surface water that
is not needed to maintain minimum flows and would otherwise be
wasted to the Gulf. Excess flows not used or stored in surface
impoundments, could be injected into the Saline areas of the
aquifer for later use. During the periods of low stream flow,
reliance for supply to the cooperating users would be shifted
to ground water, reclaiming the water previously injected and
drawing from the aquifer as needed. All participants would
probably have to be both conceptually and financially involved
starting with the initial planning for assured success of such
a venture.

Maximum Reasonable Beneficial Use
The implementation of this concept should be the major objective
of the SWUP and should be first topic in the section of "Concepts
and Alternates." Definitions of the terms maximum, reasonable
and beneficial as they apply to development and protection of the
resource, should be clearly stated so that their application to
the problem is subject to proper analysis. Application of the
principals contained in the definitions will no doubt lead to
progress in developing even clearer concepts of the original

Plan 76
The basic frame work set forth in this section seems to be limited
to the political boundaries of the counties and parts of counties
included in the SWFWMD. The reason for this may have been the
ready availability of statistical data segregated on this basis
with adjustment needed only for fractionalized counties. We feel
a much better approach for developing of a rational SWUP would be
on the basin concept and would lead to a reasonable development of
the resource.

For example, if the projected domestic, agricultural and industrial
demands were developed by basins, their impact on the water budget
for the particular basin could be appraised in terms of maximum
reasonable-beneficial use and the scheduling, magnitude and direction
of any required inter-basin transfers would become apparent at an
early state of the planning and would alleviate much of the political

Mr. Donald R. Feaster -4- April 27, 1976

controlled" at prohibitive cost to the people for
development of water supplies, with the result that
only a very small portion would be developed and most
areas undeveloped or under developed, far short of the
"maximum" as directed by statute.

4) Another consideration which is not treated in the
water crop theory when it is applied to finite tracts
of land is the lateral movement of the water thru the
aquifer not only to the cone of depression resulting
from pumping but the generalized flow down gradient
from the potentiometric highs to the discharge areas
and the salt water of the bays and the Gulf of Mexico.
Thru both of these lateral movements, the "recharge"
area for any particular withdrawal from the aquifer
could vary greatly. Antecedent rainfall distribution
and the condition of the surficial aquifer can vary the
recharge area limits.

Taking all of the above into consideration, an across the board
1000 gallon/acre water crop theory in a State Water Use Plan should
not be included except perhaps as a historic note.

Regional Self Sufficiency
What is meant by the phrase hydrologicallyy controllable boundaries"
and "this concept may be the most reliable"? Does this mean enforce-
able? The meaning of the last sentence is also obscure.

Desalination and Reuse
These alternate sources of water are limited in either volume available
or location and their utilization will ultimately depend principally
on cost compared to other, either new or existing, sources. These costs
include environmental cost. Projections of advances of technology are
always risky but such projections and the resulting impact on cost and
therefore utilization should be made to include the effect of these
sources in the over-all SWUP.

Demand Control
Population control to tailor demand to water .supply does not appear
"to be a possible solution to the problem" as stated on page 15 and
such a "straw man" should not be included in a SWUP. Allocation
should be eliminated from the plan for its only defensible purpose
is as an emergency measure in case the plan fails to provide an
adequate water supply to some particular area.

Rates billed to users involve both economics and politics the
economics of whether a particular system will make or lose money
and the political results of such decisions, are in our opinion
not an area of legitimate concern for a SWUP.

Interregional transfer, like desalination and reuse, is primarily a
matter of economics, however, projections should be made to estimate

Mr. Donald R. Feaster -3- April 27, 1976

below normal levels of about 6 inches and of about
one foot would cut annual E-T losses from 37 inches
to about 30 inches and 23 inches respectively, and
according to the water crop theory, increasing the
amount of water available for consumptive use from
1,000 to 1,525 and 2,045 gpd per acre respectively.

2) If the water crop theory (P-ET) is applied individually
to the ten basins making up SWFWMD, large existing
variations become apparent. Some figures developed
from the 1966 report by the Florida Board of Conservation
entitled "Florida Land and Water Resources, Southwest
Florida" are listed below as an indication range of
these variations for entire basins.
Average Runoff
Area Sq. Avg. Annual Inches Gal. Per.
Basin Miles Rnfl.-Inches CFS MGD Per Yr. Acre Day ET

Peace 2480 54 2480 1600 13.57 1010 40.4
Myakka 850 53 940 610 15.01 1120 38.0
Manatee 790 55 1030 670 17.70 1320 37.3
Alafia 460 56 550 360 16.23 1210 39.8
Hillsborough 830 55 910 590 14.88 1110 40.1
Pinellas-Anclote 440 55 480 310 14.81 1100 40.2
Pithlachascotee 260 54 100 60 5.22 390 48.8
Coastal Springs 620 55 1640 1060 35.91 2670 19.1
Withlachochee 2020 54 1820 1180 12.23 910 41.8
Waccasassa 1110 50 640 410 7.83 580 42.8

9860 55 10,590 6840 14.58 1080 40.4

The extremes of these basins averages are for the Pithlachascotee
and Coastal Springs areas indicating water crops ranging
from 5 inches or 390 gpd per acre to 36 inches or 2670 gpd per
acre respectively for a ratio of nearly 7 to 1.

Variations also occur within the individual basins, some areas
having zero runoff (400 square miles of the Waccasassa has no
surface runoff) and other areas have very large runoff.
(Weeki Wachee River with 10 square miles surface drainage
area, discharges about 300 cfs, 200 from the spring and 100
from the surface or 10 cfs/square mile or 10,100 gpd per acre
for the surface not counting the springs, 136 inches per year,
or 2 times the rainfall.) This would indicate the water
crop theory should only be used as a rule-of-thumb in the
individual basins as well.

3) Applied to finite tracts of land the end result is actually
contrary to Chapter 373.036 in that development of "maximum
reasonable beneficial use" could not possibly be attained.
Large tracts of land would have to be "owned or otherwise

Mr. Donald R. Feaster -2- April 27, 1976

information, despite the "political problems" mentioned on
page 10, should be developed and included if this SWUP is
to be fully comprehensive.

On page 15, the Water Crop Theory of 1000 gpd per acre
is put forth, presumably to be included in the SWUP. We do
not feel this is the proper forum to consider this concept for
the following reasons:

1) Applied to large areas such as all of SWFWMD, the
water crop theory use is at best a rule-of-thumb
and should be.modified to have significant rational
value. As stated in the Draft, the water available
for consumptive use is the precipitation less evapo-
transpirational losses or equivalent to the total
runoff. To harvest all of the runoff is environ-
mentally unacceptable as there would be no water left
to flow in the streams, rivers or springs. It has
been variously proposed that 30% to 45% of the water
crop could be harvested, however, there is no assurance
that this particular amount would be environmentally
or politically feasible for all areas nor would it
result in the "maximum reasonable-beneficial use" of
the resource.

Using figures in the Draft, the total District demands
based on the 1000 gpd per acre are approximately the
following percentages of the total "water crop" of the
Total Agricultural,
Domestic Industrial
Domestic Demand & Power Demands

1970 3.3% 13.1%
2020 11.0% 36.5%

The draft also indicates that the projected 2020 domestic
supplies to be at 11.4% of the water crop. This would
indicate that by 2020, over one-third of the runoff from
the total District would be diverted to consumptive use
and to meet the increase in projected domestic demand.
To accomplish this increase within the concept of 1000 gpd
per acre 517,000 acres or 808 sq. miles additional land
"owned or controlled" would be required. This would be
about 8% of the total area of the District.

Large variations from the 1000 gpd per acre are possible,
taking into consideration salvage from E-T losses thru
even slight lowering of the water table. A study published
in 1955 by the Jacksonville District of the Corps of
Engineers indicates that a lowering of the water table

West Coast Regional Water Si .ply Authority



Mr. Donald R. Feaster
Executive Director
Southwest Florida Water
Management District
P. 0. Box 457
Brooksville, Fla. 33512

Dear Don:

In accordance with your letter of March 8, 1976 requesting
comments, we have reviewed the "State Water Use Plan---Draft 76"
and have prepared the enclosed comments.

Many groups, both public and private, are looking forward
to having a "State Water Use Plan" which can be relied upon
and used as specific guidance in developing this most important
natural resource water. The target date of December 1977,
though ambitious, cannot come to soon.

On page 13 under the section "Estuarine Water Requirements"
the needs for fresh water dilution of the salt water of the
estuaries are touched upon. Some reasonable "objectives and
goals" if not "the best methods) to accomplish these goals or
achieve these objectives" (page 2) should be put forth to establish
"the sufficient amounts of fresh water" that "must be available
for fish and wildlife, the preservation of esthetic values and the
environmental balance of nature" (1st para. page 1) which, of course,
should be consistent with "the attainment of maximum reasonable-
beneficial use" as required by FS 373.036(2) (a). No such
"objectives and goals" or "means and methods" as required by the
statute are given. On page 23, "one third of the minimum flow"
appears to be the criterion used to estimate the maximum amount
of diversion from major streams and springs which could be
developed as a water supply. Whether or not this is in fact the
"maximum reasonable-beneficial use" is not indicated. Nothing is
mentioned regarding the many other streams in the district or in
reaches of the major streams where there is zero minimum flow
(periods of no flow) and how these areas might be developed. Such

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