DEQ: Water plan alternative fails to meet goals
|Draft letter from DEQ|
|DEQ's draft model summary|
Sunday, July 25, 2010
DEQ analysis finds Norris proposal would not provide sufficient supply
A plan that features dredging as a cornerstone of the area’s 50-year water supply plan falls short of long-term needs and might require costly new permits to be put in place, according to an analysis by Virginia’s Department of Environmental Quality that could be delivered to local officials as early as this week.The analysis comes as local leaders appear close to having all the information they say is needed to make a final call on the components of a water plan that was originally approved in 2006 with a price tag of $142 million but has been the subject of contentious debate over costs and design ever since.
DEQ officials say the plan proposed by Charlottesville Mayor Dave Norris, which combines dredging with a smaller dam at Ragged Mountain Reservoir, fails in multiple ways to meet the community’s water supply goals. Dredging was not a piece of the 2006 plan but emerged as a possible part of an alternative solution.
According to Scott Kudlas, a DEQ director responsible for surface and groundwater planning, the Norris plan does not provide enough water, known as “safe yield,” and water releases from the dams would not meet stream-flow requirements in the community’s previously approved permits.
“Our conclusion is that the safe yield of the alternative will not meet the demand,” Kudlas said in an interview. “In order to meet the in-stream flow requirements in the permit, the locality would have to be in voluntary [water] conservation [mode] all the time, and they still wouldn’t meet the in-stream flows from the original permit during the full range of conditions.”
A year ago this week, Norris and David L. Slutzky, then chairman of the Albemarle County Board of Supervisors, met with DEQ officials in Richmond and asked them to run computer models to evaluate the Norris proposal. The goal was to determine if the region’s 50-year water supply plan could be adjusted to save millions in construction costs without having to restart the state and federal permitting process.
The DEQ’s draft letter accompanying the study concludes that implementing the Norris plan would also “likely require a major permit modification or the issuance of a new permit” for the 2006 water plan.
“When we walked away from that meeting, it was pretty clear to me that the jig was up and that this whole discussion of alternative plans was smoke and mirrors that doesn’t have any grounding in reality,” Slutzky said after reviewing the study. “Now we’ve got some evidence to support that.”
Norris said he needed more time to review the DEQ’s analysis.
“I need to read the report and see how definitively they say … whether or not there might be an acceptable alternative or whether they say nothing short of the current plan is going to pass muster,” Norris said in an interview. “If DEQ comes back and says that the other scenarios that we posited do not meet the requirements, then obviously that’s a major obstacle.”
The draft results were released in response to a Freedom of Information Act request from Charlottesville Tomorrow. DEQ officials said in an interview that Norris had not contacted them in the past year, but that they were actively preparing to submit the study to local officials and could do so as early as this week.
“Frankly, one of the primary reasons there was a delay to providing this information to the localities was that we were really hoping that they would work this out and we wouldn’t have to comment on it,” Kudlas said.
The draft DEQ study provided to Charlottesville Tomorrow indicates that the dredging of South Fork Rivanna Reservoir, combined with a renovation and expansion of the existing 1908 dam at Ragged Mountain, would deliver a safe yield of approximately 16.8 million gallons a day, 1.9 million gallons short of the original goal.
In 2004, the firm Gannett Fleming published a demand analysis projecting that the water supply would require a safe yield of 18.7 million gallons a day by the year 2055 to meet the needs of a growing population and for times of severe drought.
However, the Rivanna Water & Sewer Authority is now restudying the safe yield targets at the request of Charlottesville’s City Council. Norris has said he wants the demand analysis to be updated with three new pieces of information: actual water consumption figures since 2004, data on the city’s conservation measures, and land use decisions made since 2004.
“I have always questioned whether the 18.7 MGD threshold is accurate or not and I have never contended that the alternative scenario that I and others have been pursuing is going to meet [that goal],” Norris said. “I am quite certain it won’t, but the question is whether that is a legitimate goal.”
Norris said his initial reading of the DEQ’s draft letter indicated to him that permit modifications could also be taken under consideration.
“I was pleased to see in the letter that they don’t say outright that changes would require a new permit, that we may be able to amend the existing permit,” Norris said.
Thomas L. Frederick Jr., the RWSA’s executive director, said in an interview that changing the demand projections in the permit could introduce delays in the water planning effort.
“If we were to change that number, I think it’s very uncertain how the regulatory agencies would respond,” Frederick said. “The most severe response would be that you would have to start over again and develop alternatives from scratch.”
“The timing is definitely a concern. We have an opportunity today to construct a project that’s been approved, and has all the permits issued,” Frederick. “It is assured to provide the long term needs of this community, and in the minds of most people it could possibly go well beyond 50 years and at a very good price in today’s market. Why would we want to go back and try to modify the plan with the significant uncertainly in cost and time that that might entail?”
Kudlas said the DEQ had been content with the 2004 demand analysis. It’s up to local officials to decide whether to revisit that analysis, he said, but doing so could carry risks.
“We were very satisfied with the demand analysis they presented to begin with and thought it was well done and was reasonable. It is the locality’s prerogative to take another look at it,” Kudlas said. “One of the risks that the locality will need to balance as they look at that projection is what the incremental cost would be should they significantly underestimate the growth. … If you squeeze down your demand, at this point, to justify a smaller facility, you increase the chances that you might be wrong and you might need to add additional storage between now and 2055.”
“Good judgment would tell you that the demand projection is likely understated,” responded Slutzky when asked about the 50-year demand projections. “What we are really talking about here are delay tactics from people who don’t want to just admit they had good intentions, a good idea, and it just didn’t work out.”
“The problem with just looking at those three things [in the new demand analysis] … is that it doesn’t take into account the long-term implications of the [Albemarle County] Comprehensive Plan,” said Slutzky, who says a greater percentage of the population will live in growth areas on public water.
“With respect to the city conservation efforts, that’s lovely, but the state says we already consume the lowest per capita amount of water than anyone else in the commonwealth,” Slutzky said. “Is it realistic to expect the state to believe that we can lower that further with certainty over the next 50 years?”
“At what point do we have enough information to believe we can make the best decision for this community?” asked Frederick. “The Rivanna Board of Directors, with the advice that they are going to get from the elected officials, is going to have to make a determination at some point … because there will always be more questions about more scenarios that someone can ask if they want to delay the project.”
Norris made clear in an interview that his immediate goal is to get more information on the community’s projected water needs.
Norris said he has “never been one to say we should modify the demand in order to justify a smaller facility.”
“I have always said I want a more accurate picture of the demand, and if that argues for a larger facility, then I will support a larger facility,” he said.
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