Center Comments on Water Management Plan

Comments to the Georgia Water Council by David Kyler on the Georgia Water Resources Management Plan
June 2, 2007

I am submitting the following comments on behalf of the Center for a Sustainable Coast, a membership-supported non-profit organization that represents the public interest in issues related to coastal Georgia's growth, economy, and environment. We have been an active participant in the Basin Advisory Council for the Satilla, St. Marys, and Suwannee rivers. As of this month, the Center is celebrating tens years of successful staffed operation.
  1. We need to ensure broad and balanced representation on watershed and aquifer planning advisory councils. For the water management program to succeed it must have the support of all water users. This requires credibility that can only be achieved through accountability, transparency, and dedication to long-term goals that serve all Georgians. For all of these desired features to be realized, the program must be responsive to various regional bodies yet to be established. The policy framework of the management plan needs to ensure that these bodies will be truly representative of all those who have a legitimate claim in sharing the responsible use of Georgia's waters. We cannot afford to allow the state's water management to be compromised by the political influence of special interests or the dominance of some political jurisdictions over others in their competition for limited water resources. Such compromises must be avoided by forming well-balanced, watershed and aquifer-based advisory councils that are strictly required to conform to sound principles of water management, such as those being proposed in the management plan.

  2. Must thoroughly explore and implement conservation alternatives prior to supporting the development of new supplies. Responsible water management is not easy nor is it inexpensive, especially in such a rapidly growing state. It may be tempting for decision-makers to avoid the tough decisions required in this effort by turning to so-called engineered solutions for expanding and manipulating water supply, instead of dedicating themselves to a comprehensive water conservation strategy. However, these temptations to be misled by false claims of quick solutions for increasing water supply must be rigorously resisted. All such supply alternatives, including inter-basin transfers and desalination, will ultimately cost Georgians far more than an effective water conservation program - and such costs will be not only in dollars but in reduced options for future generations and declining quality of life for the vast majority of our citizens. Most notably, the energy and environmental costs of engineered approaches for expanding water supply make them impractical and unsustainable. At best they are short-term solutions that will cause long-term problems that Georgians will deeply regret.

  3. Adopt specific, measurable standards of performance for tracking and evaluating the management plan to ensure that it serves the long-term interests of Georgians. Any effective management plan must have ways to determine its relative success. In water management, we must have specific criteria such as reduced pollution, improved water-using efficiency and reduced waste, less extreme flow conditions, and improved fish diversity that, combined, will help verify the extent to which goals are being met. The criteria should be carefully considered in terms of their reliability and the degree to which they can be implemented using consistent procedures and data that serve multiple purposes. Using criteria must be integral to administration of the management plan, and serve as a key element in guiding decisions to modify the plan as needed to improve results.

  4. Decision-makers must recognized that state investment in reliable, accountable water management is money well spent, and the program must be fully funded if it is to succeed. Current funding for both water resources planning and regulatory enforcement for water protection is woefully shy of the mark - somewhere around half of what is needed. Unless these costs are fully covered, Georgia's economy and quality of life will both suffer. The effectiveness of the state's water management efforts will be crucial to Georgia's future, and the plan will only be able to achieve its purpose if implementation is adequately funded. Short-changing this program is not an option if we hope to enjoy its benefits. The costs of planning and implementation may require creative methods for financing the costs of plan implementation, but above all we must be sure that selected funding methods are fair, so that the burden of cost is proportional to the legitimate water needs of various user groups.

  5. The less the natural hydrology in our watersheds is altered, the more sustainable and reliable our water supplies will be, the better our water quality, and the healthier the state's diverse fish habitats. This means not only improving protection of in-stream flow, but also, where possible, restoring flow characteristics by re-establishing the native landscapes that help supply and filter water throughout our river basins and aquifers. As many know, it is well established that the ditching and draining of freshwater wetlands, including swamps and bottomland forests, has radically altered the rate at which stormwater runs into waterways. This alteration has produced various adverse consequences for river flow rates, water quality, aquatic habitat, and the destructive effects of the extreme conditions of drought and flooding. Georgia's water management program should include a strong and focused element of land management if it is to succeed, and this will require incentives for restoring natural hydrological features of our landscape.

  6. Georgia must reconcile other state policies and practices with the priorities and objectives of the state water management plan. It is evident that Georgia conducts a wide variety of regulatory and governance functions that have an influence on the use, conservation, and management of water resources. Among these are energy development, now being addressed through a state energy strategy, and economic development programs in both urban and rural areas that can profoundly affect water demands, water uses, and the impact of these on various issues of direct relevance to the objectives of water management. Due to the cost, importance, and difficulty of implementing a statewide water resources management plan, it is imperative that the Governor and Legislature provide the means for ensuring that all state policies are reviewed and revised as necessary to eliminate conflicts with the Georgia Water Management Plan. Ideally, we recommend an annual or biennial policy summit to be hosted by the governor or lieutenant governor as a means for reconciling all state policies with one another, and to use the results of this effort to guide legislative proposals. This will not only improve the effectiveness of state programs, but it will also serve as a prudent step in fiscal responsibility, supporting the financial interests of Georgia by eliminating counterproductive activities.
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