Alafia River Minimum Flows and Levels - Southwest Florida Water ...
Alafia River Minimum Flows and Levels - Southwest Florida Water ...
Alafia River Minimum Flows and Levels - Southwest Florida Water ...
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August 25, 2005<br />
Ms. Holly Greening<br />
TBEP Senior Scientist<br />
Tampa Bay Estuary Program<br />
100 8 th Avenue S.E.<br />
St. Petersburg, <strong>Florida</strong> 33701<br />
Subject: Tampa Bay Estuary Program Letter Dated July 8, 2005 with Findings <strong>and</strong><br />
Recommendations on the Draft <strong>Minimum</strong> Flow Determinations for the Upper <strong>Alafia</strong><br />
<strong>River</strong> <strong>and</strong> Tampa Bypass Canal<br />
Dear Ms. Greening:<br />
Your letter to Ms. Janet Kovach, Governing Board Member <strong>and</strong> SWFWMD<br />
representative on the Tampa Bay Estuary Program (TBEP) Policy Board, has been<br />
directed to staff for purposes of preparing a response. The District sincerely<br />
appreciates the TBEP's willingness to conduct <strong>Minimum</strong> <strong>Flows</strong> <strong>and</strong> <strong>Levels</strong> (MFL)<br />
workshops so that staff can present their proposed MFLs to a technical audience for<br />
local peer review. We have prepared a response to your letter both to address as best<br />
we can the TBEP's comments <strong>and</strong> those attachments submitted by others, <strong>and</strong> so that<br />
staff can provide its response to the appropriate peer review panel. Your letter was<br />
forwarded to the <strong>Alafia</strong> <strong>River</strong> peer review panel on July 28, <strong>and</strong> will be forwarded to the<br />
Tampa Bypass Canal (TBC) peer review panel along with this response.<br />
We will begin by addressing TBEP comments relative to the proposed freshwater <strong>Alafia</strong><br />
<strong>River</strong> MFLs.<br />
With respect to issue 1 as referenced in your letter, we are developing MFL criteria for<br />
both the freshwater segment <strong>and</strong> estuarine portions of the river. The District has<br />
consistently maintained <strong>and</strong> continues to do so, that when criteria are developed for<br />
both a freshwater <strong>and</strong> estuarine river segment, the more protective MFLs will apply, as<br />
appropriate. It is important to the District that the freshwater <strong>and</strong> estuarine resources of<br />
a river are protected from significant harm, <strong>and</strong> it is, therefore, necessary to consider<br />
both <strong>and</strong> develop MFLs accordingly. We view both potential sets of st<strong>and</strong>ards as<br />
necessary <strong>and</strong> as complimentary, <strong>and</strong> do not propose that one would "compromise" the<br />
other.<br />
With respect to issue 2, we feel that the currently proposed MFLs do, in fact, effectively<br />
address the duration <strong>and</strong> depth of inundation of off-stream freshwater wetl<strong>and</strong>s that<br />
may be connected via surface water to the river during very high flows. As proposed,<br />
the upper <strong>Alafia</strong> <strong>River</strong> MFLs assume that the actual days of connection between the<br />
river <strong>and</strong> these off-stream wetl<strong>and</strong>s should be reduced by no more than 15 percent<br />
before significant harm occurs. Analysis of these flows indicates that if higher flows are<br />
Appendix D ii