HomeMy WebLinkAboutFYI CCUA CUP RAI Response Final co(JAI,. Clay County Utility Authority Working together to
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September 25, 2023
Tim Clohisy
Hydrologist
Bureau of Water Use Regulation
St Johns River Water Management District
4049 Reid Street
Palatka, FL 32178-1429
RE: Request for Additional Information (RAI)
Clay County Utility Authority, Consumptive Use Permit 416-52
Clay County, Florida
= Dear Mr. Clohisy:
a)
We received the Request for Additional Information, dated June 30, 2023, for the Clay County Utility
Authority(CCUA) Consumptive Use Permit(CUP)renewal application. We offer the following responses:
1) Please review the service area boundary overlaps outlined below and provide an updated
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service area boundary based on any changes needed to reflect the CCUA service area or provide
an explanation why these service areas overlap:
a. Small portion of JEA overlap in northwest section of service area;
b. Town of Penney Farms & Penney Retirement Community in the southern service area;
and
c. Town of Orange Park at northeast section of service area
[Section 2.2.2 and 2.3(a) of the Applicant's Handbook: Consumptive Uses of Water(August 29,
2018) (A.H.)]
Minor adjustments to the previously submitted CCUA service area boundary were made near the
Town of Orange Park and Town of Penney Farms. An electronic copy of the updated CCUA service
area GIS shapefile will be provided via separate link/attachment.
2) Please provide specific details for the regional water resource development projects CCUA
intends to participate in to mitigate any impacts to the Lower Sante Fe and Ichetucknee Rivers
MFLs in order to be considered for a 20-year duration permit. Include an anticipated timeline
for participation in the projects and assurance that the timeline will be met. Please note the
requirements of the Lower Santa Fe Basin Recovery Strategy section 6.5.d.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
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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.
[62-42.300(1)(d) Florida Administrative Code (F.A.C.) and Section 2.3 and 1.3.7.2.1, A.H.]
CCUA proposes to comply with the provisions of Section 6.5.d.ii of the Recovery Strategy for the
Lower Santa Fe and Ichetucknee Rivers (LSFIR) and associated priority springs through a
combination of existing projects and participation in future regional water projects sufficient to offset
potential impacts associated with CCUA's proposed use.
Section 6.5.d of the LSFIR MFL Recovery Strategy provides that permit applicants seeking a permit
renewal with no increase in allocations are entitled to issuance of a permit for a duration longer than
five years if the applicant proposes to take necessary actions to provide for elimination or offset of
impacts to the MFL water bodies, and a schedule for implementation. CCUA is not seeking an
increase in allocations and is in fact proposing a 38%reduction in its current allocation. As described
in the Groundwater Modeling Technical Memorandum submitted with CCUA's application, CCUA
intends to address any remaining share of LSFIR MFL impacts through a combination of existing
CCUA impact offset efforts, as well as through the adoption of a schedule for implementation of
additional impact offset and elimination actions through participation in the planned regional projects
associated with the LSFIR MFL and regional water resource projects currently under evaluation and
development (the North Florida Regional Water Resource Project(s)), consistent with the
requirements of Section 6.5.d of the LSFIR MFL Recovery Strategy.
Since the submittal of CCUA's application, several developments have occurred regarding the
identification and implementation of the North Florida Regional Water Resource Project(s) intended
to provide for elimination or offset of impacts to the LSFIR MFLs. CCUA, three other north Florida
public supply utilities, St. Johns River Water Management District (SJRWMD), Suwannee River
Water Management District (SRWMD), and the Florida Department of Environmental Protection
(FDEP) (collectively the Sponsors) have coordinated regarding a framework for cooperation for the
development of conceptual regional projects that would sustainably address water supply needs and
protect water resources.
The primary objective of this effort is the identification of feasible regional projects and programs
that can be incorporated into the North Florida Regional Water Supply Plan (NFRWSP) and the
LSFIR Recovery Strategy, and that those potential regional projects or programs provide pathways
for regulated water users to participate in those regional projects or programs in order to address
regulatory requirements, such as those in Section 6.5.d.ii. of the LSFIR Recovery Strategy.
SJRWMD's recent Black Creek Water Resource Development Project and its associated Cost
Participation Agreements provide a model for the joint funding of the North Florida Regional Water
Resource Project(s)through the participation of water users in a manner proportional to their share of
the project necessary to offset associated impacts to impacted water bodies. The Sponsors are
finalizing agreements for the joint funding of a study that would achieve these goals, including the
development and evaluation of a suite of regional projects that can be implemented and integrated in
the planning region to eliminate or offset impacts to MFL water bodies.
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The Sponsors will implement these objectives through the entry of a Memorandum of Agreement
between CCUA and the three other public supply utilities, and the entry of a Collective Funding
Agreement between CCUA and SJRWMD. These agreements provide that CCUA will hire a
consultant to facilitate these efforts and develop a final report that will detail the potential North
Florida Regional Water Resource Project(s)by category and include a matrix of costs and key benefits
to facilitate comparison and implementation of the identified projects.
CCUA intends to present the Memorandum of Agreement, Collective Funding Agreement, and
modification to the consultant scope of work to its Board of Supervisors for recommended approval
at its October 3, 2023, meeting. CCUA's funding share for the North Florida Regional Water Supply
Plan Conceptualization Project is $71,428.57 toward the total cost of$500,000. Upon approval of the
agreements by the remaining parties, it is anticipated that work on these efforts could begin as early
as October 2023 and be completed within eight months. The future approved Memorandum of
Agreement, Collective Funding Agreement, and revised scope of work will be provided in a
subsequent submittal.
In addition to the ongoing joint North Florida Regional Water Supply Plan Conceptualization Project
effort between CCUA, other water supply utilities, SJRWMD, SRWMD and FDEP, the draft 2023
NFRWSP which is currently being finalized by SJRWMD and SRWMD, identifies several regional
projects that constitute potential North Florida Regional Water Resource Project(s)that CCUA would
intend to potentially rely on to eliminate or offset remaining impacts to the LSFIR MFLs. Among
others, the draft 2023 NFRWSP identifies regional projects such as the SRWMD Groundwater
Recharge Ecosystem Restoration Project (9 mgd), SRWMD Groundwater Recharge Upper Santa Fe
Stormwater Capture Project (2.5 mgd), and SRWMD Stormwater Dispersed Storage for Recharge
and Alternative Water Supply (3 mgd). These projects in combination with other forthcoming
projects,would constitute the North Florida Regional Water Resource Project(s) CCUA is committed
to participate in to a level sufficient to eliminate or offset impacts as provided in Section 6.5.d.
CCUA has previously demonstrated its commitment to financially participating in regional projects
intended to offset proportional impact share through its prior contribution of$5,613,112 toward the
construction of SJRWMD's Black Creek Water Resource Development Project. CCUA remains
committed to the Black Creek Project through the $1,651,754 contribution of operation and
maintenance of this important project over the next 20 years. Likewise, CCUA indicated our
commitment to further participation in the regional water resource project(s) identified through the
North Florida Regional Water Supply Plan Conceptualization Project. CCUA has previously stated
its intention to recommend financially participating in the North Florida Regional Water Resource
Project(s) in a briefing to CCUA's Board of Supervisors on April 4, 2023, and most recently in its
Annual Report delivered to the Board of Supervisors on September 5, 2023, reaffirmed its intention
to recommend financially participating in the North Florida Regional Water Resource Project(s) such
as those identified through the North Florida Regional Water Supply Plan Conceptualization Project,
and in the NFRWSP.
Based on the anticipated schedule for the completion of the North Florida Regional Water Supply
Plan Conceptualization Project and other regional project efforts, CCUA identifies the following
potential schedule for implementation in accordance with Section 6.5.d.ii. of the LSFIR Recovery
Strategy:
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Completion of North Florida Regional Water Supply Plan 6/30/2024
Conceptualization Project
Execution of agreements for participation in the development 12/31/2025
of regional project(s)
Regional Project(s)preliminary design report 6/30/2027
Financial plan for funding construction and operation 12/31/2027
Permitting of Regional Project(s) 6/30/2028
Complete final design 12/31/2030
Begin construction 12/31/2031
Initiate operation of project(s) 12/31/2034
3) Please provide an up-to-date spreadsheet that lists all CCUA's wells showing the current status
(i.e. active, inactive, proposed) and associated well construction specifications for each well.
[Section 1.4.4.2,A.H.]
IAn up-to-date spreadsheet that lists all CCUA's wells showing the current status and associated well
construction specifications is included in Attachment A—CCUA wells.
4) Please submit an updated water conservation plan that addresses the following items:
a. Please include a specific schedule for the frequency,duration,and implementation of the
education components currently listed in the Water Conservation Plan as "As
requested" and provide assurance the timelines will be met. A more defined and
proactive water conservation program should be proposed based upon the outline in
section 2.2.2.5.1 of the Applicant's Handbook.
b. Please update references to SJRWMD publications and resources throughout the water
conservation plan to ensure the references are current. Please refer to Water
conservation materials— SJRWMD to access updated water conservation brochures.
c. Please include information describing any local ordinances,development orders or other
requirements, that require or encourage the use of lower quality sources of water, such
as stormwater harvesting,for proposed new development within the CCUA service area.
[Section 2.2.2.5 and 2.3(a) A.H.]
The Water Conservation Plan has been enhanced to address the above items and is included in
Attachment B —Water Conservation Plan.
5) Please provide a site-specific analysis of the local hydrogeology at the Governor's Park DRI
wellfield and Peter's Creek wellfield to determine if there is sufficient local confinement to
prevent the projected regional model drawdowns and the associated need for wetland
monitoring at these locations. This information may include geotechnical data indicating a
greater level of confinement between the Upper Floridan aquifer and surficial aquifer than
what is indicated in the groundwater model. [Sections 2.3 (f) and (g), 3.7,A.H.]
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The requested site-specific analysis was completed and is included in Attachment C. Using several
sources of data, this analysis shows that NFSEG drawdowns are overpredicted and that there is
sufficient local confinement to prevent the projected regional model drawdowns and the associated
need for wetland monitoring at these locations.
6) Please provide a well interference mitigation plan that outlines a process of how CCUA will
handle and mitigate any potential interference complaints by nearby users. [Section 1.3.7.2,
A.H.]
Due to a variety of factors, the potential for CCUA to harmfully interfere with other legal users is
low.Nonetheless, CCUA developed a Well Interference Mitigation Plan to expedite the resolution of
potential issues involving interference with existing legal users that may be due to CCUA pumping.
Please see Attachment D—Well Interference Mitigation Plan.
Respectfully,
LAY COUN Ud
AUTHORITY
JO y , 'ston, BA, PE
Executive Director
Florida Licensed Professional Engineer
Cc: File
Paul Steinbrecher, PE, Clay County Utility Authority
Roberto Denis, PE, D.WRE, Liquid Solutions Group
C. Robert Reiss, Ph.D., PE, CHA Consulting
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