HomeMy WebLinkAbout16.b FYI NFUCG Comments on NFRWSP Final Signed 10.6.2023 `��.t CpUiyTf Clay County Utility Authority Working together to
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October 6, 2023
VIA EMAIL: partnership@sjrwmd.com
Lori M. Burklew, P.G.
Regional Water Supply Planning Coordinator
Bureau of Water Supply Planning
St. Johns River Water Management District
P.O. Box 1429
Palatka, FL 32178-1429
Emily Ducker
Water Supply Program Manager
Suwannee River Water Management District
9225 CR 49
Live Oak, FL 32060
Subject: North Florida Utility Coordinating Group (NFUCG) Comments on the
Draft 2023 North Florida Regional Water Supply Plan
Dear Ms. Burklew and Ms. Ducker:
Please accept these comments on behalf of the North Florida Utilities Coordinating Group (NFUCG) and
its members,' regarding the draft 2023 North Florida Regional Water Supply Plan (the Plan). NFUCG and
its members have been active participants and contributors throughout the Water Management Districts'
Plan development process. We appreciate the opportunity to collaborate with District staff and stakeholders
regarding this important aspect of achieving shared goals of protecting our water resources and assuring
that sufficient water supplies exist to meet our region's water needs.NFUCG supports the joint approval of
the Plan by the Suwannee and St. Johns River Water Management Districts.
Significant Achievements in Conservation and Reuse
NFUCG and its members would like to take this opportunity to commend both Districts for their
commitment to encouraging the sustainability of our region's water resources. As the draft Plan recognizes,
two critical components of this sustainability are continued commitment to conservation and the use of
reclaimed water. The Plan correctly recognizes that public water suppliers expect to achieve even greater
water conservation and greater reuse of reclaimed water over the 20-year planning period. However, we
recommend the Plan recognize the significant achievements that the Districts, public water suppliers and
other users have already realized in both conservation and reclaimed water use.
As reflected in the figure below, since 2006, the population served by NFUCG members has increased by
almost 200,000 people, from approximately 1.09 to 1.26 million. However, during the same time period,
1 City of Atlantic Beach,City of Neptune Beach,City of Jacksonville Beach,City of Orange Park, Clay County Utility
Authority, Gainesville Regional Utilities,JEA,and St.Johns County.
Serving the Community through Accountability,Sustainability, and Commitment
actual water use by NFUCG members declined from 192 million gallons per day (mgd) to 173 mgd. This
water savings can be directly linked to water conservation and water reuse efforts undertaken by NFUCG
members, our customers, and the Districts. If not for these efforts, water use would have risen during this
period up to approximately 223 mgd, which is 50 mgd greater than the actual demand of 173 mgd. We
consider this an important point for the Plan to recognize these past successes, such as the NFUCG's 50
mgd reduction in water use, since the ongoing emphasis and investment in conservation significantly
reduced the amounts of water necessary to meet future demand.
Water Use and Population Served
North Florida Utility Coordinating Group
1,400,0001 — - - 250
1,261,000cu
2 225
to 1,086,000 ♦- -�
_ -A' 223 mgd
° 1,100,000 _ 46-41- -A' (without
to J conservation) 200 °
0 j
a 192 mgd
175 '73
E 800,000 173 mgd cu
to
+, (actual use)
w 150 a)
500,000 —1 -- 125
2006 2008 2010 2012 2014 2016 2018 2020
Year
Similarly, NFUCG members, frequently in coordination with the Districts' cost-share programs, made
significant investments in the increased use of reclaimed water. Since 2000, NFUCG members invested
over $150 million on beneficial reclaimed water projects, resulting in over a 100% increase in both
reclaimed water use and reclaimed water capacity. This commitment to the reuse of reclaimed water
provided significant benefits to the region, by allowing public suppliers and other users to reduce or
eliminate the use of potable water for irrigation purposes providing direct environmental benefits. As
reflected in the draft Plan, NFUCG members remain committed to even greater expansion of all feasible
reclaimed water use in the future, however we believe the Plan should also recognize the significant
achievements that have already been realized by the Districts, public suppliers, and other water users.
Financial Commitment to Implement Regional Water Resources Projects
In addition to the commitment and investment in conservation and water reuse, we appreciate the
opportunity to participate in Regional Water Resource Development Projects which increase the
sustainability of our water supply while addressing potential impacts. We hold the Black Creek Water
Resources Development Project as one such project which will provide benefits across the NFRWSP area.
In the previous 2015-2035 NFRWSP adopted in 2017,the Black Creek Project was identified as a potential
project option with a timeframe for completion of 2035. However due to cooperation between SJRWMD
and stakeholders like NFUCG's members, the Black Creek Project is nearing completion and slated to
provide significant benefits to the region in the near future.As noted in the draft Plan, four NFUCG member
utilities entered into agreements to fund the construction and operation of this project as a way to address
their proportionate share of impacts to several water bodies. NFUCG members committed to contribute a
combined total of approximately $19.2 million toward the Project.
The NFUCG looks forward to continuing to collaborate as additional Regional Water Resource
Development Projects are identified to address potential impacts to other water bodies. These types of
projects can be an equitable way to address regional water resources while allowing all users to address
their proportionate share of impacts.
Public Suppliers' Participation in the Process
Finally, we appreciate the opportunities the Districts' have provided to us and other stakeholders to
participate in the Plan development process. We consider this participation important in allowing the public
to stay informed regarding the Districts' planning initiatives and allowing stakeholders to contribute their
own resources and technical expertise supporting the Districts' efforts.
In the case of the draft Plan, in addition to being active participants in the Plan review and development
process, NFUCG members identified 86.6 mgd of the 87.9 mgd (99%) of alternative water supply project
options included in the Plan, at a total estimated cost of over $800 million. In addition, when factoring in
water resources development and water conservation project options,NFUCG members identified 122 mgd
of the 158 mgd (77%) of all project options included in the Plan, at a total estimated cost of over $1.8
billion. In other words, the contributions of NFUCG and its members are essential to the development of a
successful Plan, and will remain central to the successful implementation of the objectives identified in the
Plan.
Given the critical role NFUCG and it members will continue play in working with the Districts and other
stakeholders in achieving these goals,we look forward to continuing to closely coordinate with the Districts
regarding future planning, modeling, and regulatory efforts. In particular, we look forward to working with
District staff regarding the further development of the minimum flow and level prevention and recovery
plan for the Lower Santa Fe and Ichetucknee Rivers to ensure the sustainability of water supply while
meeting the needs of these water bodies. We also look forward to working with District staff in the setting
and evaluation of minimum flows and levels for the Suwannee River. Each of these endeavors serve key
aspects of ensuring protection of the region's water resources and while providing reliable and affordable
sources of water for our region's needs.
Thank you for your consideration of these comments and we look forward to continuing to work with the
Districts on these important issues.
Sincerely,
CLAY COUNTY UTILITY AUTHORITY, on behalf of
The North Flori•: . • •rdinating Group
Jerei 1 . Joloon, M'.A, PE
xecutive Director
Florida Licensed Professional Engineer
cc: NFUCG Members