Dr. Robert Knight on Ichetucknee MFLs


Ichetucknee River
Photo by Lucinda Faulkner Merritt

If you read and were concerned about the article entitled “GRU May Challenge Protections for Lower Santa Fe, Ichetucknee” on the front page of The Gainesville Sun on Sunday, Dec. 8, 2013, you are not alone. It seems no one—not the utility companies, probably not the agriculturalists, and not some local water advocates—is happy with the proposed new minimum flows and levels for these two rivers.

Dr. Robert L. Knight, who is president of the Howard T. Odum Florida Springs Institute and on the Board of Directors of the Ichetucknee Alliance, wrote the following email letter to the Gainesville City Commission on December 4, 2013. Dr. Knight has kindly given us permission to reprint his letter below.


Dear Commissioners:

I plan to attend this Thursday’s meeting about the Lower Santa Fe and Ichetucknee MFLs. In advance of that meeting, please read my draft comments below.

The City of Gainesville should consider setting an example for the rest of the communities in North Florida and be leaders in achieving an overall reduction in groundwater use. The North Central Florida Utility Coordinating Group (NFUCG) maintains that the District’s proposed MFLs are too restrictive on future groundwater uses. This is not the case.  For the reasons cited below it is clear the proposed MFLs are too permissive and do not require the necessary reduction in groundwater pumping to return the aquifer, the springs, and the rivers to a healthy condition. It will be an embarrassment if Gainesville is aligned with and helps to fund any utilities who are planning to challenge the Suwannee River Water Management District’s MFLs because they are too restrictive. Such a challenge would be a denial of our collective role in depleting the aquifer and the springs that are dependent upon it. Rather than participate in a legal challenge the City of Gainesville should insist that the District revise the MFLs to make them more restrictive. The City should also ask the District to enact immediate water use restrictions as an appropriate response to reduce the significant harm over-pumping is already causing to the springs and rivers. And finally, the City of Gainesville should lead a collective effort to exceed the recovery goals drafted by the District and FDEP, and agree to a reduced consumptive use permit for the City as an example for JEA and other large users of the region’s groundwaters.

The following provides the conclusions of the Florida Springs Institute concerning the SRWMD’s final MFLs for the Lower Santa Fe River. We recommend that you do not indicate acceptance of the District’s MFLs and Recovery Plan, but rather send a strong message to the District that their MFLs and draft recovery plan are not precautionary and do not adequately protect the natural and economic resources associated with the region’s most important river and spring systems. Here is a brief summary of our rationale behind this recommendation:

  • The District’s final MFL indicates that their analysis found that the Baseline (pre-pumping) median flow in the LSFR was 1,320 cfs (853 MGD).
  • The District’s MFL provides a median flow for the LSFR of 1,214 cfs (784 MGD), a reduction of 8% or 106 cfs (68 MGD).
  • The District estimates that the existing flow deficit (flow reduction beyond the MFL) is 17 cfs (11 MGD) – this is the recovery goal for the LSFR.
  • In their draft MFL analysis the District found that the estimated flow reduction in the LSFR was about 188 cfs (121 MGD) or about 14%, and they initially estimated the flow deficit as 51 cfs (33 MGD).
  • An independent review of the SRWMD draft MFLs by staff of the St. Johns River WMD determined that using the most sensitive indicators, the flow deficit in the LSFR is estimated to be 135 cfs (87 MGD) beyond the point of significant harm. This is 84 cfs (54 MGD) worse than the SRWMD’s first estimate of recovery and 118 cfs (76 MGD) more than their final goal.
  • Wetland Solutions, Inc. also provided an independent review of the existing flow data for the LSFR that found that total flow reductions over the entire period-of-record are about 850 cfs (549 MGD) or 53% of the flows before 1970 and that about 340 cfs (220 MGD) of this reduction in flows is due to factors other than rainfall.
  • Both of these independent reviews, as well as the peer review provided by the University of Florida Water Institute, found that the District’s proposed MFLs are not protective of the resource, not based on the best science, and do not call for an adequate reduction in regional groundwater pumping needed to achieve recovery of the LSFR and springs.

The Gainesville City Commission and the Alachua County Board of County Commissioners have the opportunity to set an example by demanding better protection for North Florida’s aquifer and springs. In doing so we must find the will to reduce our own groundwater use by up to 50%. All other groundwater users in our area will need to follow this example to restore the Santa Fe and Ichetucknee rivers and springs. Otherwise, the best interests of the public will not be protected. Only a significant, region-wide, reduction in groundwater pumping will reverse the continuing trend of declining flows in the Santa Fe River and in its springs. Please take appropriate action on behalf of the public trust.

Best wishes,


Robert L. Knight, Ph.D.
Howard T. Odum Florida Springs Institute
5302 NW 156 Avenue
Gainesville, Florida 32653
352-538-6620 cell
386-462-1003 office