More Than Maximum Pollution and Minimum Flows: True Health for Springs

CEJ director Patricia Siemen and CEJ staff attorney Rob Williams have submitted comments to Richard Hicks, P.G. of the Florida Department of Environmental Protection on the Draft TMDL (Total Maximum Daily Load) for Silver Springs.  In the comments, they call for an immediate moratorium on consumptive water use permitting, until a plan is in place to restore the historic springsheds and until there are minimum flow levels for Silver Springs and Rainbow Springs that fully protect and restore the springs’ healthy aquatic ecosystems.

They also asked the Department to take specific actions to reduce the nitrogen load immediately, rather than relying on the historically slow and ineffective management planning process.

From the text of the letter:

Our current, failing approach to protecting the springs derives from an operative—and faulty—perspective that the precious water of the aquifer is a “resource” to be extracted, manipulated, and controlled solely for human benefit. . . . We have an outmoded, injurious perception of our ability to predict and control the natural world and our right to use the natural world to feed human desires. As long as our environmental laws rest on these assumptions they will be ineffective in stopping or reversing the environmental degradation we see all around us. We need to choose a new path.

. . .

Many of our springs are on life support. They can’t wait for another round of studies, reports, and “stakeholder” meetings. We know that water quality as indicated by increasing nitrogen concentrations is degraded in the majority of Florida’s artesian springs. We know that flow has declined in many springs because of consumptive use permitting in the springshed. We know that climate change is likely to make droughts more frequent in the future. We know that these factors and others, such as direct human disturbances from recreational use and the occurrence of invasive plants and animals, are altering the basic ecology of many springs. In short, we know enough to take action to prevent the situation from becoming worse.

We need an immediate moratorium on consumptive water use permitting and action to reduce the nitrogen load now, not decades from now.

Read the full letter here.  Read the letter’s Appendix A documents here. 

Read CEJ’s supplemental letter to Hicks here.

Silver River (photo by Jane Goddard)