2008 WAS Report Comments
From Water Wiki
Comments from the public meeting on the draft report, Dec. 18, 2008
Written comments submitted between 12/18/2008 and 1/9/2009
Note to all commenters:
Summarizing these comments succinctly is obviously challenging; while we intend the summary only to be a guide or index into the actual comments for the benefit of other interested persons, we understand that some of you may feel our summary misses important details. Please review the summary and either post suggested revisions here, or email them to us. We expect to present this summary information and to review the comments with the Environmental Review Commission on January 22, 2009. If you have suggestions for improvements in the summary and get those to us by Friday, January 16, we will be much more likely to be able to make changes prior to our next ERC presentation. Thanks, and thanks to all the commenters for weighing in on these important public policy issues...~Richard and Bill
The following are the actual comments, summarized above, filed on behalf of:
Comments on the report left directly on this website
General comments on the study and on water allocation in N.C.
- This report is an excellent and long overdue look at how to address water issues in NC. A key strength is in taking a cohesive approach to linking existing law/policy as well as lessons from other places. Having moved here from the southwest, I do hope NC leaders will heed the lessons learned from the long-term efforts related to water supply in the west. A weakness in the report is in the connections among education/knowledge, water use measurement, and financing (alas, these also continue to be tricky issues in the west). The report does an excellent job in supporting a permitting process for large-scale users (although it seems to assume a measurement/monitoring system that is not explicitly defined and there is always the potential for a permitted amount to not match an actual use amount!). The assertion, however, that it is more important to focus on the large users over the smaller users is not substantiated in the report - especially in light of the evidence presented about the unusually large number of small water providers in NC. As more people install wells (certainly a trend in the mountains) this may be adding up to significant water use! This issue is directly related to public knowledge/education. Water suppliers work very hard to remain "invisible" so that the public does not think much about their water - it is just there (see Rayner, Lack and Ingram 2005). Therefore, people do not pay much attention to water until it isn't there. Even then, they do not see their individual role in water issues - shortages etc. are someone else's fault - often a large, anonymous user. Not addressing private, household use (often one of the largest uses as a percent of total water withdrawals) or other small uses we simply perpetuate the idea that water is someone else's problem. Additionally, the lack of understanding among the public (as well as water managers/planners) about the physical realities of water (e.g. hydrocycle, surface and ground water connections) means that we get new ground water use (unmetered!) during drought. Although politically unpalatable, measuring all water use is necessary if we truly want to know what the water budget is, what the groundwater situation is and if we want to increase the general understanding of water. This is connected to financing. The report rightly concludes that the current approach is flawed and must be revamped. Experience elsewhere, however, does show dire consequences for public officials if pricing issues are not handled appropriately. Because people do not understand water, and do not see their role in its use/waste, it is difficult to justify increased rates. The report does note rightly that people do see their water bills as a tax rather than payment for a service (see Griffin and Mjelde 2000). If we can increase the level of understanding about water perhaps we can generate increased support for more research and different funding mechanisms/approaches. Education is touched on in the report, but not given the attention I think it needs. Although certainly not a panacae, education for all players is essential to improved water management. All of these points are better expressed as a systems diagram, but I don't know how to post one of those here! The report does touch on systems ideas in the section on IWRM - I think this should be taken even further. Looking at water as a fully interconnected system better reflects the reality and might help raise awareness and support for policies that reflect the system.
--Kristan Cockerill, Appalachian State University
Comments on the Background, Scenarios and Findings of the study (Part 1 of the report)
Recommendations of the study (Part 2 of the report)
Clearly state policy goals to guide administrative and judicial decisions.
1. Water (surface and groundwater) is a public trust managed by the state to protect its lands and waters for the benefit of all its citizens.
2. Administrative and judicial decisions about water should ensure efficient and productive use of water and water conservation.
3. Legal security for water rights and property rights and procedural protections for water rights.
4. Protection of instream flows and groundwater levels.
5. Flexibility through adaptive planning to ensure that water extraction does not exceed the budget of water that is available; conservation of water; coordination with water quality.
6. Pricing water to fully cover the costs of its capture, treatment, distribution, collection, scarcity, and reuse rather than to keep rates as low as possible.
7. Efficient and equitable allocation during shortfalls in supply and procedures for resolving disputes between water users.
8. Reasonable use and unreasonable injury.
9. No prohibition of use based on location of use.
10. Regulating interstate and interbasin water transfers to achieve these goals on a regional, not just a state, basis.
Establish a permit for large water withdrawals.
Conform existing laws to each other and to policy goals.
Establish proactive, adaptive, river basin water supply planning.
- "Proactive" water supply planning within river basins is definitely needed and the way to progress toward a water budget that is fair to local governments that manage water systems, their residential and business customers and other future water users. But a 'top down' approach will not work very well. Regional Councils/Councils of Government have a role to play as a facilitator and convener of local governments to engage with State officials.
- Some regional councils are already quite active in multi-jurisdictional water alliances (Lumber River COG in the Southern Coastal Plain, Centralina COG and Western Piedmont COG in the recent Duke FERC relicensing), TJCOG and PTCOG in the Jordan Lake rules issue, and several COGs in the Cape Fear Assembly). Others are prepared to ramp-up to support basinwide water planning on behalf of their member local governments.
Simplify and integrate water and water-funding information.
Address critical research and study needs.
Ensure that water infrastructure is maintained.
Reward and spread best practices and leadership efforts in water efficiency.
Create more storage
- I don't think a comprehensive study on Water Supply and allocation can be complete without a indepth analaysis of the potential for desalination as a supply for other than just coastal communties. Recent data of river flows will probably show that they will never again be what the were in the prior century, so diiging bigger or more holes to store it may not help.
We have some info on desalinationhere in the wiki.It has promise for coastal communities that don't otherwise have a drinking water source that costs less than around $7-8/1000 gallons. As that page shows, there are some desal plants already operating here. But desal plus pumping back to the inner coastal plan and Piedmont communities appears to us not likely to be cost-competitive in the near term, given energy costs. There is already a high quality source of freshwater from the dewatering of the PCS Phosphate mine in Aurora that a private firm has been trying to market for several years, without success. ~Richard