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On Friday, I read the Op-Ed by Jenny Hoffner, Director of the Water Supply Program for American Rivers, describing the pursuit of new reservoirs as reckless  In it, she correctly states that communities across Georgia are concerned with securing reliable supplies in water for the future, and they are challenged to find the best way to secure that reliable supply.  Until any local government is faced with the need to secure a new water supply source, it elected and appointed officials are not generally aware of the various possibilities for meeting that future demand that are available.  All they know is what has worked for the community in the past, what has worked for their neighbors in the past and what is being proposed by their neighbors in similar geographic regions.  But, to assume that state and local government officials jump directly from the realization that they need an additional water supply source to the conclusion that they must build a reservoir is not in any sense correct.  In 17 years of working with local governments to plan, permit and implement water supply solutions, not one has made such an uninformed decision nor would regulatory officials allow them to do so.

 

From the earliest days of the Clean Water Act, advocates proposing new water supply reservoirs have had to demonstrate, pursuant to the section  404(b)(1) guidelines, they have avoided the need to impact jurisdictional waters.  But, when those impacts have been unavoidable, they have to minimize the number and extent of those impacts and then provide mitigation for those impacts.  The process is evolving, both on the state and federal level, but changes over time have only increased the level of study necessary before constructing a new reservoir.  For example:
  • Around 2002 a task force of officials from the Georgia Environmental Protection Division, the US Environmental Protection Agency, the US Fish and Wildlife Service, and the US Army Corps of Engineers developed an outline of alternatives that must be considered in any application for a water supply reservoir.  They specifically include inter alia as alternatives that must be considered:  conservation, ground water, expansion of existing sources, the purchase of water from neighbors.
  • In 2003, the Metropolitan North Georgia Planning District published its first suite of plans, refocusing the spotlight on water supply alternatives.
  • With the passage of the Comprehensive State-wide Water Management Planning Act in 2004, and the subsequent development of the Georgia State Water Plan, the focus on alternatives sources of water narrowed and became more detailed.
  • The drafting and development of regional water supply plans by the Regional Water Councils and the adoption of the Water Conservation Implementation Plan increased local efforts to study alternatives and the availability of water for storage drew much attention.
  • The Water Stewardship Act of 2010 again focused the state’s and regulatory agencies’ attention on minimizing the need for new water supply sources, including reservoirs.  And,
  • In June 2010 the US Environmental Protection Agency developed a checklist of items that must be considered when determining the need for a new water supply source, including reservoirs.
So to say that local governments must focus on other alternatives before determining to build a water supply reservoir is naïve.  The federal permitting process is entirely designed to and requires  local governments and projects sponsors to spend the vast majority of their time and money evaluating alternatives to building water supply reservoirs.
If the goal of the goal of the Governor’s Water Supply Program is to facilitate local governments and project sponsor with the process, the program would focus its attention on the planning, permitting and design phase of the project so that alternatives and new reservoirs are evaluated.  However, all the evaluation will not change the fact that in order to accommodate the estimated 4.6 million new Georgians relocating to all parts of Georgia by 2030, and the physiographic region they settle in  will necessitate that the “capture” and “control” of surface water in storage facilities will remain the most likely option for meeting the State’s long-term demands for water supply.

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