oV (2^ L 'V!C.W Ocala-Mr.on County
'I ^ OFFICE OF THE CITY MANAGER iSar
P.O. BOX 1270, OCALA. FLORIDA 34478-1270
o ",?, (352) 629-8401
C YS Fax (352) 629-8391 Suncom 654-.8401
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October 4, 1296 .
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To: Estus Whitfield, Executive Officer of the Governor
From: Oel Wingo, City of Ocala 0a1j n'
Re: Water Supply Development and Funding Issues
The City of Ocala is extremely pleased with the Governor's Executive Order which addresses
minimum flows and levels and water supply development and funding for the state of Florida.
We believe that the state is headed in the right direction with this executive order and support
efforts to address and implement policies which address the state's water resource issues through
executive order as opposed to the legislative process, particularly given the existing statutory
In response to your request for input regarding the draft of issues disseminated at the September
30, 1996 Water Supply Development and Funding meeting in Tallahassee, I believe the list of
issues should be narrowed and can be narrowed to the parameters outlined by the Executive
Order, particularly to the extent that some of the proposed issues are addressed as
recommendations by the Water Management District Review Commission. In so far as the
Executive Order has directed the DEP "to work with the Districts to develop a report, to be
submitted to the Governor by November 1, 1996, which lists the recommendations of the Water
Management District Review Commission the Department and Districts are implementing or will
implement under their existing statutory authority, and how they are implementing or will
implement the listed recommendations.", I feel it is a duplication of effort and premature for the
work-group to address the same issues, at this point in time.
My preference would be to limit the discussions as per that section of the Executive Order which
relates to the development and the investigation and formulation of "recommendations on
effective means for water supply development and funding and, as necessary, water supply
With that summation of my understanding of the intent and purpose of this working group, the
following summarizes the City of Ocala's concerns and positions on the issues identified
regarding water supply development, funding and planning. I met with our planning and utilities
staff to brainstorm the issues as summarized and apologize for any misperceptions we might
have worked from given the vacuum and the brief description of the issues with which we were
working. But, perhaps these comments will give you a capsulated view of the City of Ocala's
(located in a water rich region and two water management districts) perception of the state's
water resource problem. Surrounded by areas designated as water caution areas, both directly
south and southwest of Marion County, we necessarily have very real concerns about the impact
that this growth to the south of us will have, not only on the quantity of water in our region, but
ultimately the quality. As evidenced by the sparsity of funds that St John's Water Management
District has assigned to "REAL" water supply development issues and their failure to identify
desalination as a viable water resource solution for the coast or to encourage 'local sources first'
as opposed to the 'interconnectedness of water facilities', or transfers, I ask the question have we
truly learned from the experiences of South Florida and the West Coast as regards to effects of
over pumping and the transfer of our water resources. That is why, the city of Ocala is so
heartened to see the governor's office act within their existing statutory authority to direct WMD
policy, strive for solutions and reach consensus on the water supply development issues Florida
is and will be facing in the future.
RESPONSES TO SUGGESTED PRIORITY ISSUES
Sources The potential sources listed in the September 30, 1996, outline, are vague and could
mean different things to different people. The key issue on sources should be their viability as a
source. Viability should be measurable and verifiable using minimum flows and levels that the
source can provide without degradation to the surrounding ecosystem or adjoining water users.
Minimum flows and levels should be based on the best and latest scientific information and
tools available. Conservation and alternative supplies are necessary regardless.
An issue which appears to be avoided is aquifer storage of reclaimed water not as a supply
source but as a method of protecting existing supplies from saltwater intrusion or replenishing
the depth of the fresh water lenses (water tables). Mixing lower quality water with high quality
water is not mentioned.
The use of government lands within a regional area is an appropriate alternative for
development of new supplies. However, use of these lands should not cause harm to an
ecosystem or adjoining user of the water supply. Use of public lands for transfer outside of
regional boundaries should meet the same criteria mentioned in all related sections above. All
other methods should be tried or fully evaluated as to long term cost (50-years) before transfers
are considered. Again if transfer is chosen, ecosystem and adjoining users should not be
impacted and a minimum 25% surcharge should be charged on all water transfer to build a trust
fund for uses directly related to new water supply development or alternatives.
Treatment technologies Should include alternative technologies such as replenishing a buffer
zone to prevent further salt water or brackish water intrusion into higher quality water supplies.
If wastewater effluent were treated to agricultural or public access standards and injected into
the ground along the coastal zones instead of directed to ocean outfalls as is done in many
facilities, salt and brackish water intrusion could be minimized or stopped prolonging the
viability of existing supplies. In the case of the Everglades, it could reverse the current flow
trend of fresh water from the Everglades toward the ocean. Mixing varying water qualities as
mentioned above is another option.
Cost benefit analyses should be a secondary tool to support far reaching plans (50 years or
more) not just shorter term plans (20 year range). An example is the monies expended on the
Everglades draining only to have that trend reversed now and trying to use it as a storage and
supply area. Cost benefit analysis if used should include the potential costs attached to loss of
economic growth in the area from which water is taken for transfer. If that water can no longer
be used within the region from where it is withdrawn, all growth which could have taken place
as a result of that water is lost, while growth continues in the area where the water is
transferred. The potential loss of revenues to the area requesting the transfer should not be
considered because sufficient natural resources to support that growth should be expected and
required. Use of another region's resources to continue ones own growth desires without some
means of adequate reciprocity to that region is inappropriate to say the least.
Determining appropriate and sound disposal methods of by-products from either RO or
desalinizationn processes is a necessity in that we will become more reliant on those treatment
techniques in the future.
Related Planning and Regulatory Issues Should be clear in their goals and objectives.
Well field protection standards should be established and enforced by the state if it is to be the
sole entity responsible for states water supplies.
Sustainability of water supplies for both people and ecosystems are a must and should be the
highest priority of the state. No entity should be allowed unchecked growth unless it can
sustain itself using the resources within its jurisdiction. Here a regional approach is much
better than a local approach if the funding is there to support those objectives by fully sharing
all the available resources within the region for equitable growth plans by all entities in the
Safeguards for donor areas are a must as discussed previously. Participation by all levels of
government and affected parties is a must if a workable long term water supply plan is to
develop for the state. Safe guards for water transfers should be numerous and not just benefit
the transferring entity.
Recommended safeguards are; 1) no transfer should be allowed until minimum flows and
levels are scientifically established; 2) minimum flows and levels should be measurable and
easily verifiable; 3) the scientific methods used to establish these flows and levels should be
standardized and accepted by a majority of the educational, research, professional engineering,
and regulatory organizations based within the state; 4) should a transfer be allowed, a portion
of the revenues (25%) received from the sale of that water should be directed back to a trust
fund for continued scientific research on flow and level determination methods as well as
developing alternative water supplies; 5) transfers should never exceed established minimum
flows or levels; 6) if a transfer begins to impact either ecosystems or adjoining aquifer users
in the area of the transfer, the transfer amount will be gradually reduced by set percentages until
the trend reverses itself and new minimum flows are established.
Water use permitting and allocations of resources should be issued using clearly defined
regional boundaries by the WMDs.
Every region should fully develop all alternative sources and use cost-effective technologies
available to that region. Feasibility is more of a regional issue, for example, a regional area in
the central part of the state should not be expected to build a desalinization facility and pump
water from the ocean to this facility for potable water purposes if those supplies could be
purchased from elsewhere.
Water management should be directly linked with growth management. Growth should not be
allowed to continue without adequate natural resources readily available within the region to
meet the demands of that growth.
It is a necessity to establish minimum flows and levels before transfers should ever be
considered. However, the WMD's are not being responsible if those flows and levels are not
continuously monitored and changed as needed to maintain and sustain the ecosystem and its
water supplies. Estimates can be developed for growth patterns with 20-50 year horizons by
using a combination of WMD, state and local projections.
Regional water supply planning should not encroach into other regional supply planning areas
without full approval of both regions. Otherwise, the local approach should remain the priority
as long as its water supplies are sustainable. Regional water supply plans should take
precedence over district plans as long as they do not encroach into other regions.
Review of minimum flows and levels justification data should be accomplished by a combined
effort using professional engineering, university, and research organizations. This approach
will be inclusive and will likely avoid scientific method questions encountered with only a
single agency review.
ASSIGNMENT OF RESPONSIBILITIES
W The state must take the leadership role since it is ultimately responsible for the water supplies
within the state per Florida Statute. Determination of appropriate supply alternatives should be
a multifaceted approach starting at the local level with review at regional and WMD levels.
The regional level can override the local plan, the WMD can override the regional plan and the
state can override the WMD plan. Overriding any plan must be based on measurable and
verifiable scientific grounds not political
General Task The expected role of the WMDs should be clearly defined. Are the WMDs to
identify and monitor available supplies within the district as well as maintaining those levels
and flows thus ensuring that all water using entities within the district are equally represented
and protected? Are the WMDs also the planning agency for their districts with respect to
growth as it is directly related to water availability? One option would be to have the WMDs
be responsible for establishing and monitoring minimum flows and levels within the district's
various regional supply areas, ensuring that the regional water supplies not exceed safe water
withdrawals for its respective regional area and that the regions not intrude into another region
without written agreements by both regions. It would be the regional supply authority's
responsibility to ensure that all water using entities have equitable access to the water resources
within that area. In areas where regions cross district boundaries, all districts affected by the
boundary will cooperatively establish safe withdrawal guidelines based on agreed scientific
evidence along those lines.
Establish minimum flows and levels for all district water supplies. Monitor those flows and
levels and reestablish those values every ten years based on latest scientific evidence supporting
those findings. Identify how those flows and levels affect other districts at their boundaries.
This must be cooperative effort among all districts. Establish minimum flows and levels
between district boundaries. Identify regional water supply boundaries within its district and
attach minimum flows and levels within those areas. Identify how those flows and levels affect
other regions within the district. Establish minimum flows and levels between regional
boundaries. Allocate CUP's based on equitable usage of water within the regions so as too not
cause harm to the ecosystems or other users within the regions as well as not negatively impact
users or ecosystems across regional or district boundaries.
The issues then become:
If the available water resources are known and established as well as the sustainability of those
resources, who will be responsible for limiting growth in those areas that cannot support
continued growth with the existing natural and sustainable resources available to them?
It then becomes the individual entity's responsibility to use available technology to stretch its
available or allocated water resources?
Who will provide the revenues or funding to optimize the available water resources within a
given district or region? Optimization can take place through various combinations of
technologies or practices such as: water conservation, water reclamation usage, recharge,
aquifer storage, replenishing freshwater barriers, desalinization and RO.
Specific Considerations It should be the WMD's responsibility to be the clearing house for
all water supply research, planning, regulation, etc. It can contract services just like any other
agency to perform any of these functions. Local government should retain primacy on water
supply development but would have to meet all of the above criteria set by the WMD's for the
specific region. If there were not sufficient water resources to develop within the region or
those resources were already allocated, the local government would have to seek alternative
avenues to meet its supply needs. This could include conservation, reuse alternatives, new
treatment technologies or even purchase of excess water from another source including
transfers if a sufficient agreement can be reach with other regional sources.
Funding There is a multitude of ways to fund the development of new or alternative water
supplies and those listed under this section are all feasible. The issue is whether all citizens in
Florida should pay for the services, facility upgrades, development of alternative supplies, etc.
where they do not receive direct benefit of those projects. It can be argued that they do benefit
in the overall protection of the environment and their respective water supplies to some extent.
However, it is unlikely that citizens living in regions with plentiful water supplies will ever be
eligible to use these funding resources or if they became eligible, the funding would probably
be exhausted by the major water suppliers in the state through their upgrading of their systems.
The fairest solution, but least palatable to the larger utilities is to pass those costs onto their
customers. The costs associated with providing that service is the actual cost of living in the
respective community. Those costs should not be subsidized by the general population of the
state. I fully support a surcharge on all transfers of water. Whether the funds raised by the
surcharge are returned to the region from where the transfer is withdrawn or into a trust fund for
development of alternatives supplies are a matter that requires further debate. I would think it
inappropriate for the money that is being paid on the surcharge to go back to the community
receiving the transfer because ultimately only they benefit and not other communities in need
nor does the region from which the transfer is taken receive any form of benefit for the potential
loss in future growth related to water supplies.
Identification of long-term funding mechanisms -The WMD's could set aside some of their
revenues to assist in critical shortage area. This could take the form of matching monies or
fixed allotments. However, the majority of the cost of developing new supplies should be the
burden of the rate payer. This is essentially the cost of living and related services for any
specific location within the state. It is inappropriate to pass on additional costs for people
living in one area to others not living there. Additionally, economics should be part of the
controlling factor for growth. To spread the cost for continued growth for one area on the
citizens of the state is not appropriate in that those citizens do not benefit from the costs they
are paying to subsidize growth elsewhere. It also directly inhibits growth and the associated
economic benefits in other areas of the state to benefit the major metropolitan areas.
Other Funding issue Federal or state funds should be available to help defer the cost of
major capital improvement programs to meet new regulatory requirements including
environmental reclamation projects or programs (i.e., no unfunded mandates). As discussed
earlier, surcharges on water transfers are an excellent option if all other conditions can be met
to protect the ecosystems and adjoining users. Those monies could be used as a funding source
for implementation of alternative supply technologies or supply methods. Guidelines if used
should be very specific and simple using a prioritized system based on critical need or locations
where the public health is a major concern. It should not be used to promote or sustain growth
in a specific area.
Incentives The best incentive is to pass the actual cost of the service onto the customer. This
should drive innovative approaches to keep cost down for those services and should slow
growth in areas which cannot support that growth with the resources available in that region.
Incentives by the WMDs are already being discussed such as longer duration CUPs when a
utility is operating efficiently and effectively in the use of its available water resources. 20-year
term permits may be allowed based on the entity meeting specific conservation, resource
development, and other conditions. Finally, cost distribution should be placed on the end users
not the general population of the state. Bonds, federal or state grants, loans, etc. should be
based on the ability of the individual utilities to derive revenues from their customer base to
support those avenues of capital funding for projects. The most forceful incentive is
economics. As long as it is cheaper to transfer water from one area to another to maintain
growth and inexpensive services, there will be no incentive to use alternative technologies,
conservation, or other innovative supply techniques.
Specific Considerations Permits should be based on current and future availability not
demand unless alternative supplies are being fully used (desal, RO, etc.).
Economics/Cost Issues The cost of developing and suppling the water should be borne by the
individual customer of the specific utility. Subsidizing other utilities is not cost effective, nor
does it promote efficiency and effective operations by those utilities being subsidized. The cost
of producing the end product will dictate innovation and effective operations (contract
operations, etc.) by any business or organization. This is also true of utilities. There isn't any
reason why public utilities shouldn't compete to provide competitively priced services. I get
the impression that the real concern of the older and larger utilities is, they do not want to see
their cost of service increase because they do not want to compete fairly as the bottom line will
be slower or no growth.
Cost-distribution Issues There should be no question that all customers being served by the
specific utility should share the full cost of the new sources and related service as part of their
monthly bill. There is no reason why others not receiving the benefit of the service should be
required to fund new supplies elsewhere.