To The Metropolitan North Georgia Water Planning District

RE: REVISION OF THE PLAN FOR MANAGING METRO ATLANTA'S WATER SUPPLY

I represent Apalachicola Riverkeeper, with over 1000 members that either live in those communities along the Apalachicola River and Bay or are citizens from 22 states (including Georgia) that benefit and from the natural ecological functions and ecosystem services provided by the ACF System. These members share the waters of the ACF basin as your neighbors and US citizens. These comments include information that we feel should be considered by the Metropolitan North Georgia Water Planning District (MNGWPD) to ensure that these interstate water resources are shared in a fair and equitable manner, and with recognition of their public value of our shared environment.

We believe that sustaining the Apalachicola System in tact as a healthy functioning river and estuary is in the interest of all citizens including those of your District.

The ACF River System is home to more species of plants, birds, fish, mammals, reptiles and amphibians than any other place in North America.

The Apalachicola River and Bay fuel a regional economy based on sustainable use of natural resources that provide fresh seafood harvested from what one internationally renowned artist dubbed ‘The Last Great Bay’. It has been this way since the 1800’s and continues to feed you and us today.

The United Nations designated Apalachicola River and Bay as one of the world’s few Man in the Biosphere Reserves, where conservation and protection of the natural resources can sustain economic prosperity and a cultural way of life.

This is in peril - due in large part to a reduction of freshwater flowing down the river. During drought periods, the Spring and Summer flows of the growing season have been reduced by 38% since the Corps constructed it dams and the dramatic increase in withdrawals from the Chattahoochee and Flint River basins.

It has been stated by GA leaders and in the media that the withdrawals from a small part of the upper ACF Basin cannot impact the flows in the Apalachicola. In contrast:

1. Comparisons of rainfall for the current drought to earlier droughts show there was greater rainfall in earlier droughts than in the most recent drought;

2. Comparisons of flows for the current drought to earlier droughts show there is less flow for the more recent droughts than the earlier droughts;

3. Causes for the reduction and changes of flows during periods of greater rainfall are linked to:

• Withdrawals (municipal, industrial, agricultural and thermal) from the basin upstream of Florida;

• Cumulative evaporation losses from reservoirs in the Chattahoochee and Flint River basins; and

• Reservoir management practices upstream of Florida.

Based on the information provided, we respectfully request that the MNGWPD change the Draft Water Supply and Conservation Management Plan as follows:

1. Use a basinwide comprehensive and cumulative perspective in planning for water use in the ACF Basin.

2. Adopt a goal for 2035 that reduces water withdrawals from the ACF Basin by 25% of current withdrawals during normal rainfall periods, 30% during dry rainfall periods, and 38% during drought periods.

3. Eliminate new reservoirs from consideration as an alternative source of providing water supply because of the significant evaporative losses associated with them.

To create confidence and eliminate disagreement among stakeholders, states, and federal government agencies regarding the facts presented and other specific facts, we further ask that the MNGWPD support a resolution by all Georgia U.S. Congressional delegates to provide funding for the National Research Council to undertake a comprehensive study in the ACF Basin as outlined below:

(1) A summary of the existing body of scientific knowledge on:

• the ecology, hydrology, geomorphology, and biogeochemistry of the Apalachicola River and the greater ACF River System;

• the ecosystem services provided by the Apalachicola River;

• the impact of variation in freshwater flow on the ecology of the river and downstream coastal ecosystems, including the Apalachicola Bay ecosystem; and

• how to restore the natural hydraulic function of the ACF River System, including restoration of floodplains and wetlands.

(2) An assessment of models that serve as the basis for the master manuals of the ACF River System.

(3) An assessment of water supply needs, water availability, supply options, demand-management alternatives, and socioeconomic factors that influence uses in the ACF River System, including water quality, navigation, hydropower, recreation, in-stream ecology, and flood control.

(4) An assessment of policies, regulations, and other factors that affect Federal and State water project operations.

(5) Recommendations for an approach to determine water limits that recognize the needs of all water users along the ACF River System, including adequate in-stream flow requirements.

(6) Recommendations for any additional measures to address the long-term watershed management needs of the ACF River System as the National Research Council considers appropriate.

We appreciate your consideration of these requests and comments.

Dan Tonsmeire, Riverkeeper
Apalachicola Riverkeeper