WATER CONSERVATION?

Reading the Post’s recent editorial titled “Keep Twice Weekly Watering – the Region is Still Drying Up”, it is clear that South Florida’s public water suppliers have allowed myths of looming water resource shortages to perpetuate far too long.  Over time, the unsubstantiated but unchallenged urban legend of diminishing area water resources has evolved to “conventional wisdom” status. As long as the only impact of this flawed perspective was that adherents voluntarily curtailed their own water use, the public consequence was minimal.

Recently however, it appears that South Florida Water Management District (“SFWMD”) has set aside what it knows in favor of what it feels, by developing the proposed Year Round Water Conservation Rule, which is scheduled for public hearing before the SFWMD governing board on February 12.  By this rule, SFWMD proposes to permanently and by force of law restrict landscape irrigation to two days per week, despite clear and compelling evidence that there is no resource-based need for such costly and consequential restrictions District-wide.  Conservation feels right and sounds good, but for what purpose is the water being conserved, and at what cost?

Having increased its customer base by 60% while trimming its staff from 144 employees in 1986 to 125 full-time and 4 part-time employees today, Seacoast Utility Authority lacks the public relations wherewithal of larger governmental entities. Thus it is left to water system administrators like me to disclose local water supply facts that have been thus far absent from SFWMD’s public dialogue.

THE SHALLOW (SURFICIAL) AQUIFER SYSTEM IS NOT RUNNING DRY

There is no evidence that local water resources are being depleted – only unfounded fear and unsubstantiated assertions.  Despite the fact that our region’s population is at an all time high (though growth has indeed virtually stopped in certain locales), surface water and shallow aquifer ground water supplies are brim full. According to SFWMD rainfall data, in every year this decade except for 2001, Jupiter has experienced below average, drought, or worse than 1-in-10 year drought conditions.  Rainfall to date this year in Northern Palm Beach County has been equal to an average year, which according to SFWMD rainfall data totals about 62 inches. Such data demonstrate that it takes less than one year of average rainfall to re-fill slightly depleted water storage basins, even after an extended period of below average or drought conditions.

When drought returns as it always does, –water levels within our canals and shallow aquifers will decline.  When the rains return as they always do, they will quickly refill to overflowing – witness the recent stunning return of water levels to Lake Okeechobee!  Given the relentless, public pronouncements of those who either willfully or unknowingly confuse Southeast Florida’s water environment with that of, say Las Vegas, both the media and the public can be forgiven for losing sight of the difference.
 
LAKE OKEECHOBEE IS NOT THE BACKUP WATER SUPPLY FOR ALL OF SOUTH FLORIDA

Most local public water supply wellfields, particularly those from Riviera Beach northward, are recharged primarily by local rainfall.  From a hydrological perspective, whether water in Lake Okeechobee is at historically low levels or overflowing, the water supply for residents living in these areas is unaffected.  Contrary to what has been publicly disseminated, Lake Okeechobee is decidedly and demonstrably not the backup water supply for all of South Florida.  Those who doubt that should ask SFWMD when it last delivered water from the lake to recharge Seacoast, Jupiter, Tequesta or coastal Martin County wellfields.

FAR MORE FRESH WATER FLOWS TO THE OCEAN THAN IS CONSUMED
 
Coastal Palm Beach County receives approximately 60 inches of rainfall per year.  Unrestricted public water use equates to approximately 10% of that – most of what’s left flows to the Atlantic Ocean.  Such fresh water discharge to tide is comprised primarily of essential flood control releases and gravity seepage along the coastline.

SFWMD should not be criticized for storm water releases to tide.  Such releases are necessary when all ground water and surface water storage is full as it is today, and they are critical to protecting persons and property from flood.  At the same time, the citizens of South Florida, should not be criticized for or prohibited from protecting their properties by irrigating with available and renewable water resources, particularly when the only alternative is disposal of such resources to the ocean.  Public policy that favors fresh water disposal over beneficial use by Florida’s citizens is bad public policy.

YEAR ROUND RESTRICTIONS ARE NOT NEEDED – AUTHORITY TO RESTRICT WATER USE ALREADY EXISTS
    
 SFWMD already possesses the legal authority to restrict water use whenever and wherever it finds a region’s water supply to be threatened.  The proposed Year Round irrigation rule simply lightens SFWMD’s workload in that it imposes restrictions on everyone, all the time, regardless of whether there is any resource-based reason to do so.  “One size fits all” regulations serve the regulator more than they serve the public because they are easier to enforce.  In this case however, simple regulatory expediency is the least of the problems with the proposed Year Round Irrigation rule.  Read on.

CONSERVATION – FOR WHAT PURPOSE?

SFWMD reports that restrictions are “conserving” 138 million gallons of fresh water per day, but has not yet identified where that “conserved” water can presently be found.  In northeastern Palm Beach County, most if not all of it has been wasted to the Atlantic Ocean, not used for wetland or river restoration or any other responsible environmental purpose.  Nature, including our geography, local topography, hydrology, and geology, has conspired with the irreversible 20th century encroachment of man and his drainage systems to make it so.  Wishing, or even believing otherwise does not alter the harsh reality that particularly in certain regions, the water that we conserve simply can not be stored or used for any other purpose.  

No reasonable definition of “conservation” implies that a resource, particularly a renewable, sustainable resource, should be conserved so that there will be more of it to throw away.  Insofar as 60 inches of oil do not fall from the sky here every year, those who equate conservation of non-renewable energy sources with water resources renewed tenfold by nature are clearly missing the point.  It will either be beneficially used and continue its journey through the planet’s hydrologic cycle, or it will not be used and continue the same journey.   

CONSERVATION – AT WHAT COST?

Pursuant to SFWMD guidelines, water utilities frequently sell water to high volume users at a rate that is substantially higher than the price at which it is sold to more conservation-minded users.  Historically, the resulting revenue has been used to offset fixed utility operating costs (debt, asset renewal and replacement, insurance, etc.), costs which would otherwise be borne by more conservative and generally less affluent customers.  By curtailing higher volume use of available, renewable, sustainable water supply by financially able and willing customers, SFWMD’s new rule transfers the rate burden of such fixed costs to those who can least afford it.  This disproportionately impacts lower income customers, and thereby runs afoul of the principles of Environmental Justice. South Florida water utility customers, your bills are going up, and in substantial part, that is attributable to misguided regulatory policy.

WHO BENEFITS FROM UNRESTRICTED WATER USE?

We often hear that public drinking water providers oppose water use restrictions for purely economic reasons.  The implication is that somehow such entities profit from profligate water use.  The truth is that private, “for profit” water suppliers are few and far between in Palm Beach County.  Like Seacoast, most are public agencies whose only “shareholders” are the public they serve and whose rates are based on cost recovery alone.  Perhaps ironically, from an economic perspective, unrestricted water use benefits only those public utility customers who use the least water, including citizens living on fixed incomes, for it permits those using more to subsidize fixed costs that would otherwise be borne by more conservative water users. 

WHO DECIDES HOW WATER SHOULD BE USED?

Whether SFWMD staff thinks it is a wise use of fresh water or not, the fact is that landscape and crop irrigation is explicitly recognized by Florida law as a reasonable and beneficial fresh water use.  In fact, SFWMD issues and/or renews hundreds of water use permits each year for surficial aquifer and surface water withdrawals expressly for that purpose.  The water resources of this state belong to its citizens, and subject to reasonable and scientifically defensible standards of environmental preservation, they are entitled to beneficially use such resources.  The regulation of water use must necessarily bear some relationship to its availability – it should not be governed by the regulators’ personal preference.

ETHICS LESSON

Rather than provide a detailed, region by region hydrological analysis supporting the need for the proposed District-wide Year Round irrigation rule, SFWMD staff instead supports its recommendation by noting that the rule will inspire a “conservation ethic.”  First, SFWMD’s statutory charge is to manage the water supply, not to impart conservation ethics to its employers, the citizens of South Florida.  Second, what is there about the public’s response to the current declared water shortage emergency that leads SFWMD to conclude that they don’t get it, that they need a lesson in conservation ethics?  Statistics related to the current restrictions confirm that the public will curtail use when justifiably called upon to do so.

A WATER SUPPLIER’S RESPONSIBILITIES

Public water suppliers are and should be responsible stewards of our natural resources.  For example, Seacoast’s progressive and very “green” reclaimed water program converts 100% of Seacoast’s 7.8 million gallon per day of sewage flow into irrigation water which is delivered to high volume commercial users (golf courses, property owners associations, etc.) throughout the service area.   However, this program is founded in a desire to recycle, to alleviate the ecological burden that society’s waste would otherwise impose, not to address a perceived water availability concern.

Seacoast believes that public water suppliers and regulators alike are obligated to fairly and scientifically evaluate water resource availability, work cooperatively to efficiently distribute available supply among environmental and consumptive uses, and to be completely honest with the public.  Fear is indeed a great motivator, but it is no substitute for truth.  History is littered with the tragic consequences of public opinion driven more by fear than by facts.

Current and proposed water use restrictions impose an environmentally unproductive economic burden on citizens who can least afford it.  Until such restrictions are demonstrated to yield a measurable and meaningful environmental benefit, Seacoast is compelled to oppose the economic hardship they impose on Florida’s citizens.

As a local native, and having served the public water supply needs of Palm Beach County residents for nearly 40 years, I am supremely confident that, given facts and figures rather than anecdote and rhetoric, my neighbors will respond appropriately.  I know of no public water utility official that believes that the public must be frightened into doing the right thing.  Our customers are intelligent and insightful, and given all the facts in proper context, they will guide public policy makers wisely.  Sacrificing the whole truth for regulatory expediency or to advance an agenda is worse than wrong – it is an unforgivable affront to those we serve. 

  Creating unwarranted public anxiety and cost disrespects the citizens we serve, and it is unworthy of the trust that they have placed in us.  SFWMD already possesses the legal authority to restrict water use wherever and whenever water resources are truly threatened.  The proposed Year Round Irrigation rule visits an economic impact on those who can least afford it, yields immeasurably small resource benefit if any, and unnecessarily constrains Florida’s citizens from beneficially and responsibly using their renewable and sustainable water resources. 

Seacoast Utility Authority therefore respectfully requests that Governor Crist and the SFWMD Board reconsider its plan to adopt the proposed Year Round Irrigation rule.

 

Rim Bishop, Executive Director
Seacoast Utility Authority