Loading...
HomeMy WebLinkAboutEDB 2023-04-01 CCUA CUP Renewal Briefing b Clay County Utility Authority d:,4 ,,.z... •Consumptive Use -Permit . UP z,„ _ _ ,.) a �� - ,..., .. , Renewal Briefing ,‘ ,. . . �P sa ,. • , .___„is ., Jeremy D. Johnston, MBA, PE, Executive Director Nicolas Porter, Esq., de la Parte, Gilbert, McNamara & Caldevilla, P.A. Roberto Denis, PE, Liquid Solutions Group LLC `0 CO UNT ill" April 4, 2023 ' - liMPIr 1 , - - - . : .\\ rioilio introduction 1 Ls 1 '. , . • .,. . ,. c7 .„4 .. • Over the last 29 years, CCUA has grown to serve . `d an estimated 55,000 accounts, totaling 4 approximately 130,000 people • By 2045, this number will more than likely double 5111111,' , ' - 1 • CCUA is taking proactive measures to be well- f - , ly f' 11 0 A '1 positioned for a sustainable future and ensure �'" • • A • , ,. ' f continued deliveryof safe, reliable water to meet - A '' .',• ,' �:� , i , the demands of Clay County's growing V population for decades to come _ - 11 `""7-= . . 4 • ° .:i••:‘ ..-f.z L.:1-44" • . 2 I CLAY COUNTY UTILITY AUTHORITY CUP RENEWAL . i •s e if ;7„. • Why • th ' L, �� _ . .,. 1v,...„-t. .„....4,40 . ,Iiii.„. CUP I m ortant . , : 7} aaaaaa� J `I Tirork- i1C7`;411. .,,,, - .-. . • ;34` •• +,,M1y • The CUP controls the '� �_ N f`. water supply allocations '" 1�.4... . pp Y Y eA. for CCUA's service r territory/customers ,'M ar.a a.....aaar � ...-- f 'twat 144 f.► The water supply " ~�� �' • M wa.M faa It II allocation controls b� ,. -fit n Wa�w. CCUA's planning for ■ Now growth and service „ `� 14 l�,.4.4.,..... u R M availability , " 'YA.:: 1. iii °*:. .....� y...._ . ._ . .. ��^ W.*6 0 L.aa..... M...ea_aar� �.� tt 11 yi_l_•i:..-T— aaa..�. .a a.... Waleaawa um. wMww•..w r tYT a1Ma • a.sa a:a ..i _ — — 3 I CLAY COUNTY UTILITY AUTHORITY CUP RENEWAL CurrentCUP .III. East System CUP #416 CCUA Proposing an Overall Expires: December 2025 Reduction to 24 MGD Current Allocation: 34.073 MGD Consistent with the 24 MGD that was established in the Black Creek Other smaller CUPs Agreement Expire: 2025 to 2031 Consistent with the draft North Current Total Allocation: 4.772 MGD Florida Regional Water Supply Plan CCUA's Current Total Allocation: Proposed reduction is 38% of 38.845 MGD current allocation (tCOUNTY �I 4 I CLAY COUNTY UTILITY AUTHORITY CUP RENEWAL GTTYAUTi, Why Renew the Capital Projects Underway and Projected CUP Now . $300,000,000 The Capital Improvement Program (CIP) $247,493,000 must receive funding for system $250,000,000 • expansion to meet the demands of a • growing population $200,000,000 $158,509,000 The water supply allocation in a the CUP would affect the planned o $150,000,000 $135,314,000, CIP system expansion J $112,119,000 Early renewal of the CUP was $100,000,000 negotiated as part of the Black Creek $76,786,000 $67,182,000 $35,803,000 - $68,132,000 Water Resource Development (Black $50°°°°°° ' Creek) Project cost participation $ , agreement with the SJRWMD $27,958,000 $0 The renewal process can take NNNNNNNNNNNNNNNNN N N N N N N N N N N N N N N N N N N N N N N Y > Z > d > Z > i > Z >" j a 1 -1 .5years � V) Z ' � Z ' HZa � � � MILESTONE DATES 5 I CLAY COUNTY UTILITY AUTHORITY CUP RENEWAL UNDERWAY IN CONSTRUCTION IN PLANNING/DESIGN PROJECTED What Are Our CUP N'��� _ ,..'a 1 .11114A4 -111 7 Renewal Objectives? o 0 A Standard 20-Year CUP: - °- �- . - -,: o-- • Aligns with the IWRP, Rate Study, and the Black . .1.-.,. c5 -11,11,‘ Creek Project cost i _% participation agreement -- — - �l \,,,,, ..: _\ • Minimizes uncertainty in the water supply and capital infrastructure planning efforts . Enables CCUA to participate �n V I in and benefit from regional EXHIBIT.A. , Iu•nuns mo iii water resource development lie �_ _ ti ! projects when available m, d�,`- 1p Exhibit A in the .r�i y Black Creek Cost J �' Participation - tee 1 �7 "' 1,, — 8 6 I CLAY COUNTY UTILITY AUTHORITY CUP RENEWAL 'greement — a , a ,,,,, , - y, I . • W P-, • rocess Meeting with SJRWMD Permitting Staff CUP Checklist ul Demand Projections Completion of groundwater modeling e Conservation Program Field visits to wetlands in Clay County 'ri Reclaimed Water Use Meetings with SJRWMD Executive Staff • Groundwater Modeling ea Wetland Impacts Issues raised by SJRWMD permit staff have iiii All SJRWMD MFLs been addressed r All Other Potential Impacts CUP criteria for 2 MFLs remain open Q 2 MFLs in SRWMD The timeline for completion of a CUP Renewal from the time of application is estimated to be 1-1 .5 years. '�I 7 I CLAY COUNTY UTILITY AUTHORITY CUP RENEWAL Gvelt),AUT O �. What are Minimum Flows and Levels .,.., , _ (MFLs) Regulations? 01,f:.-- k_..1 \• , \. -=e , r- � - _ ,, ^u,,leirt.x.kr. f-{4- i MFLs are the flow or level beyond which further withdrawals ',;�. ' - e `' would be significantly harmful to the water resources or " ' . : ; ~' • t ecologyg y � 7. . 4,. ,,,1:00. _o Established fors ecific water bodies '` "p i .� ems*4001.'' ..• ','-�, .; ,l�Y tc• �, - o Adopted through rulemaking z F. ` If an MFL is currently being violated or is projected to be :�:, = _, \_4 violated within 20 years due to water withdrawals, a strategy ' ` _ �must be prepared by the WMD/DEP that recovers the MFL or - _ �• `' T prevents violation `_, _ 1111011 - o Must be a phased approach of timetable o Must assure that water supplies are available for — all projected reasonable-beneficial water uses _-- - . ---- A CUP applicant must show that its proposed use _ — - _ of water does not violate the MFL, or that it complies with the adopted recovery/prevention strategy . 8 I CLAY COUNTY UTILITY AUTHORITY CUP RENEWAL MFLs Considered in CCUA's CUP Renewal Keystone Lakes MFLs and Recovery Strategy i Orange Park • 111111 LC 15'i Adopted by SJRWMD in July 2021 Middleb :%'r;tikCnrE 301 MFLs determined to be in recovery SJRWMD Recovery Strategy ® Intake Sf Green Cov� s�P Requires water users to offset their share of impacts to MFL tom5prin-- a violation Penney rke Farms Camp Allows for participation in the Black Creek Project to offset Bianding impacts and meet the MFL requirements ®CCUA is in compliance via participation in Black Creek Project at A recovery project established by the SJRWMD for l Recharge compliance with the MFL impacts • Keystone Financial participation is equal to a proportionate share of i "e`gbts project costs and share of MFL impacts - 24 MGD Figure 1 Mar St Jolms Myer ani toes tlx Ham..Ice Model for a regional project MFL solution w ��� Black Creek olanuten may nabe r Water Resource .'--'""`°a,= eau be daramee by �= n , , Development can "b^ Spmms.1 • Project PO Sax 32a Rea Sow, . AppoumNe scae miks 39m> i17a-", iN. &i'.M0,!00 9 I CLAY COUNTY UTILITY AUTHORITY CUP RENEWAL MFLs Considered in CCUA's CUP Renewal Lower Santa Fe/Ichetucknee Rivers & Springs MFLs and Recovery Strategy MFLS Tor the Lower Sa nta Fe and Ichetucknee Water for Nature {fivers antl Priority Sorinl!v Walar fir Panola r Ir ,IrrrI 0 a Md. Located in SRWMD, Interim MFLs adopted by FDEP in June 2015 OLI:SIZE OMF.ER MFLs determined to be in recovery ICUUEIVEKNEE RIVER Interim Recovery Strategy put in place to "hold the line" �,la„.,,p,..WM ternee Spring until a new regional model and new regional water Illyyyyyy(((((( projects could be developed /4;z- 8qhalCnMRae .Santa Fe Rhea Rlas Sprang {8pdng Daly Spnne TreMsae Sprang U \ Hornsby Spring Originally scheduled to be replaced with permanent WEN s.Tan:RIVER� % MFL and strategy no later than December 2019 Darya Ear gprep Rua hand Sprang SRWMD & FDEP are currently working on the re-evaluated MFLs, revised recovery strategy, and identification of \ - LEGEND regional projects to bring the MFLs into compliance • I a Magnitude Spring fZ • Magnitude rie Cos -- Cnunty Boundaries —Hydrograpby — Major Roads Figure 1.2. Priority springs within the Lower Santa Fe end Ichetucknee rivers. NOTE:Ichetucknee Spring Group Includes:Ichetucknee Head Spring,Mission Spring,Devil's Eye,Grassy Hole,and Mill Pond November 22,2013 1-5 10 I CLAY COUNTY UTILITY AUTHORITY CUP RENEWAL MFLs Considered in CCUA's CUP Renewal Lower Santa Fe/Ichetucknee Rivers & Springs MFLs and Recovery Strategy What does the current interim LSFIR MFL Strategy provide regarding CUP issuance? d) Renewals with No Increase in Allocations: i. Applications that do not demonstrate a potential impact to the MFL water bodies based on the total requested allocation shall be issued provided the applicant meets the conditions for issuance. ii. Renewal applicants that demonstrate a potential impact to the MFL water bodies based on the requested allocation shall be considered consistent with the Recovery Strategy and shall be issued a permit for a duration of no more than five years provided the applicant meets all other existing conditions for issuance. If potential impacts to the MFL water bodies will be eliminated or offset, the five year permit duration limitation under this subparagraph shall not apply. Permits issued for a duration longer than five years must include the necessary actions to provide for elimination or offset of impacts to the MFL water bodies, and a schedule for implementation. II I CLAY COUNTY UTILITY AUTHORITY CUP RENEWAL MFLs Considered in CCUA's CUP Renewal Lower Santa Fe/Ichetucknee Rivers & Springs MFLs and Recovery Strategy For a 20-year CUP to be issued under current requirements, the CUP "must include the necessary actions to provide `oP QEPARr yE' S6KNs RI, for elimination or offset of impacts to the MFL water bodies, o ti,. �� ,P and a schedule for implementation." ° 7, 7/ CCUA's CUP renewal objectives: i o Identify the actions CCUA will take to participate in '_o 44,� v� \ ,l �4 regional projects options and other CCUA activities �MFNrA►. i' c) °1 '8. �� that provide assurances that future impacts to the AGEMti MFL water bodies will be offset Provide a schedule for CCUA's participation based on project implementation Work proactively with FDEP, WMDs, other stakeholders Obtain 20-year permit - I - C GEMENI 12 I CLAY COUNTY UTILITY AUTHORITY CUP RENEWAL Communications History and Plan Met with representatives Preparing for meeting Met with SJRWMD of the SJRWMD and FDEP between executives of the and SRWMD specific and discussed CUP SJRWMD, SRWMD, FDEP, and L to meeting LSFIR MFL _I renewal concerns j I CCUA, JEA, GRU, and SJRCU 1110— 4— �pd Technical meetings Discussed CUP renewal ' Between CCUA's technical concerns with legislative experts and SJRWMD representatives permitting staff 13 I CLAY COUNTY UTILITY AUTHORITY CUP RENEWAL Why is a 20-Year Permit Important? Max Month Demand Need and Supply (MGD) •Surface Water •Additional Planning for capital infrastructure Treatment for DSM/Ordinances Reclaimed Additional ggenerally has a 20—to-25—year horizon Augmentation Alternative Supply Y20 -and/or- •Indireci •Regional Recharge Potable • Efforts to plan, design, and construct 18 •FDOT Reuse -and/or- Partnerships ©• _ _ _ y Stay the capital infrastructure generally exceeds Augmentation 'AddMional 0 16 -and/or- Shallow Aquifer o 5 years •Floridan Supply Aquifer ©n 0 n. - - . 2 14 Additional o. Stay the Cour. ;lay the Z • Costs for capital infrastructure S�pply- °arse a investments are captured by the 12 •InigationCUP •DSM Pro rams Acquisition for 9 Reclaimed 0 •®• , © capacity fees paid by future customers 10 •Turf Reduction for Augmentation Stay the Course Stay Cours: Stay the New Development Course connecting to the utility system •CUP Optimization •Advanced Metering for Reclaimed 8 Infrastructure Augmentation •On-site Stormwater • Developer Agreements in the Reclaimed Augmentation 0 6 •Shallow Aquifer Supply m Service Availability process can at Peters Creek o •Potable Well/Treatment Capacity Expansion m and often do have longer planning 4 for Lake Asbury and Governor's Park 41111, z and build time frames 2 B. 0 • - 2023 2028 2033 2038 2043 14 I CLAY COUNTY UTILITY AUTHORITY CUP RENEWAL Triggers 0001 Is water demand growth tracking higher or lower?If lower demands,stay the course.If higher demands. then determine supply project feasibility and implement feasible projects. Issues Regardinga 5 - Year a °e„o �7co7, - Ormga Pa k Permit ,/' ./,_..,,i_e \ 0 ,,, v__,,0 i i _ __ t e 7_, ,,, `'c Y te" . , ,, , Water supply allocation would be limited to 2028 K projected demand - . s 7-- _ -- i k• r .-/k t z Current Developer Agreements obligate nearly all water in that i ar.E.,,M J it- planning horizon 6LMb , i . 1 LaAr Limits the abilitytoplan longer-term capital infrastructure "'°'" ` �°�•�,�pa'i�= 9 i-" g p I • Presents cost burden of capital infrastructure intended for II `'‘._._...- `-Mk '%� ., future customers to the existing customers -, 1 6> 1 ��'ke v�. Green Cove C''''-n Springs \ yC Cob Potential for breach of contracts relating to existing Developer I i - °��'�y -Penney F 3rma- i • ' _-• o .,< Agreements and Master Utility Agreements Insufficient water supply allocation to meet Clay County's Legend ai i% gar rd P / Conscrvalion Arc: CuW SA.,AC IENs�w C E.p<r-n. jt . population growth and demand over the next 20-25 years E.arM'.CIY wn<oa ..s.aaY ° 1�, Perks and Consmaeon Land \ Provides a lack of regulatory certainty regarding addressing . ," ° \ future recovery strategy obligations and associated financial tea° < - First Coast Expressway ROW +w impacts to customers tix; ' wlthProposedInterchangeLocations ,,�' ,� _ Clay County,Florida What Has CCUA Been INVESTIGATION FINDINGS_ Doing to Address MFLs -=== While Providing for Long - -_ - Term Water Supplies? - _ ti �, s � ..... _ r,::n.,wun Kimky•N • Financially participated in the Black Creek Project with INTEGRATED WATER Clay county Ubldy AulMnty the SJ RWMD RESOURCES PLAN Treatabany Study and Pilot Design Technical Memorandum 5 u BASIS OF DESIGN Participating in the North Florida " Regional Water Supply Planning a (NFRWSP) effort with the North 000 � 1. -ii CCUA c_ cPM,.^ Florida Utility Coordination Group Strategic (NFUCG) '` Flan li k °nth - Conducting a phased J*6114 implementation of Alternative ` Water Supply projects ~ °ith 16 I CLAY COUNTY UTILITY AUTHORITY CUP RENEWAL 5-YEAR CIP PAR C � Examples of CCUA's me Project ii) i DDnDerI g Investments to Sustain Advanced Metering Infrastructure ■ ■ the Environment and On-site Stormwater Reclaimed Augmentation ■ 5-Year CIP Shallow Aquifer Supply at Peters Creek WRF ■ Community Irrigation CUP Acquisition for Reclaimed Augmentation FOOT Stormwater Augmentation 10-Year (WRF Treatment)' CIP IIndirect Potable Reuse ; • Willing partner in WRF-Water Reclamation Facility •Design&Permit •Construction •Operational 'FttOT planned as three phases with design and permit continuing to the second phase while the first phase is in construction. regional water resource development projects DSM Optimized/New Stormwater/ Shallow Indirect Surface Water Portfolio Programs Floridan Aquifer Storage Aquifer Potable Reuse Treatment Max DSM •• • • Proposing nearly a 38% Low Cost ��� � � reduction in permitted d.E Treatment • • • • water supply allocation a Focus - Storage ••• • Focus a Low Cost • •• • c,E_ V m Treatment • ••• Focus Hybrid 6 6 DSM = Demand Side Management 17 I CLAY COUNTY UTILITY AUTHORITY CUP RENEWAL What are the risks of the CUP process? x i Regulatory Legal rit. • • • Goodwill Public Perception 18 I CLAY COUNTY UTILITY AUTHORITY CUP RENEWAL Issuance of a 20-Year Permit to CCUA How Can Both CCUA's Development of regional water resource Objectives development projects that address the MFL issues with the springs and rivers and Long -Term o _ Environmental CCUA's commitment to participate in future regional Su sta i n a b i l ity water resource development projects and other efforts to address MFL liabilities up to CCUA customers be Achieved? proportionate share or responsibility 000 Continued coordination with regional and regulatory stakeholders by CCUA's management team to ensure all regulatory requirements are met 19 I CLAY COUNTY UTILITY AUTHORITY CUP RENEWAL ���y C O UNTL DISCUSSION G ♦ � TY A UTNO�`� 20 I CLAY COUNTY UTILITY AUTHORITY CUP RENEWAL