WHITE PAPER for Georgia Water Management Planning
Submitted by:
David Kyler, Executive Director, Center for a Sustainable Coast
Focus of this White Paper: Improving Protection of Coastal Water Resources
1. Make
more extensive use of information and scientific expertise in evaluating environmental permits under
various programs.
2. Minimize flow disruptions in river systems.
3. Restore
wetland functions and provide adequate buffers to protect water quality.
4. Consider
potential impacts on all down-stream users when making permit decisions by applying the
precautionary principle.
5. Conclusion
1. Make more extensive use of information and scientific expertise in evaluating environmental
permits under various programs.
Because of budgeting limitations, the expertise needed
to sufficiently evaluate complex permitting situations is often unavailable on the EPD staff, and
stress tends to be placed on reaching expedient decisions. In such cases, assumptions have been made
that were intuitive and unsubstantiated, and which could place important resources in jeopardy
without more complete analysis and assessment.
Moreover, due to the demands of daily operations, it is difficult for EPD staff to keep up with
emerging analytical techniques that are more familiar to many of those who work in academic and
research institutions. We believe there are promising opportunities for bringing valuable expertise
and better information to bear on permitting decisions that affect, or could affect, Georgia's water
quality.
Using staff of other organizations and institutions would have several kinds of benefits. First, it
could help upgrade and integrate the use of information by EPD staff through new research findings
and methods. Reports by research teams on various facets of hydrology, geology, ecology, and
biology, for example, would also raise public awareness about the limits and implications of
available information, and the inherent risks of issuing permits for proposed activities prematurely
or without sufficient conditions. By making the terms of such trade-offs more explicit,
decision-makers, with appropriate technical advice, would be in a better position to impose and
monitor conditions under which permitted activities should be conducted and properly tracked through
targeted data collection and assessment. Involvement of researchers in questions related to
permitting would also bring much-needed realism and relevance into the planning, synthesis, and
application of new research. Field studies in environmental research could be specially designed to
help resolve pressing problems raised in permitting decisions, and scientific studies would
therefore become more useful in resolving important issues.
We realize that funding constraints are a serious problem in implementing the alternatives available
for resolving water quality issues. There may be additional federal funds (such as the National
Science Foundation, NOAA, and EPA) and/or federal agency staff that could be used to help augment
state resources, including possible support of scientific expertise as described above. Imposing
reasonable permit processing fees proportional to the cost of permit review also seems quite
justifiable as a means for generating at least some of the needed revenues.
2. Minimize flow disruptions in river systems.
Withdrawing water from one river system and
discharging it into another (so-called inter-basin transfers), and consumptive uses of water (such
as evaporation loss from spray irrigation, steam-generated energy production, industrial cooling, or
reservoirs) should be minimized as much as possible. Even before the current period of drought,
salinity in the inter-tidal areas of coastal rivers had been increasing, putting various species of
fish at risk in their earlier life stages. Increased salinity is believed to be due to several
historic factors, including (1) conversion of wetlands by ditching for forestry, agriculture, and
other land uses, and (2) reduced groundwater outflow resulting from the great decline in artesian
pressure caused by excessive and concentrated water withdrawal for industry. Remaining fresh water
flowing into Georgia’s estuary system is needed to retain the function of this highly valuable
habitat, which supports thousands of jobs in commercial fishing and seafood processing. Moreover,
marine biologists estimate that some 80% of marine species depend on the estuary ecosystem to
sustain it, either as habitat or through the food web. The economic importance of these coastal
resources is on the order of $1 billion annually, and putting them at further risk by reducing river
flow is directly contrary to the public interest.
3. Restore wetland functions and provide adequate buffers to protect water quality.
Complete
restoration of the natural flow of our river systems is not possible for a number of reasons, but
there are alternatives for achieving at least partial recovery of water resource functions. For
example, critical water storage and flood protection functions of swamps that were drained and
filled could be restored through selective acquisition of undeveloped land, enhanced with
appropriate landscape contouring and replanting of certain native species. Likewise, along
waterways with impaired water quality or impinging activities that threaten non-point source
pollution, land could be acquired to serve as additional buffer areas. This would not only add
water filtration and flood-protection benefits, but it would enhance nature-based tourism and
commercial recreation activities within these waterways, supporting and diversifying income and
business growth potential. Long-term public interests will be best served by state and local
governments learning to regulate the use of resources within sustainable limits of natural
processes. The sooner these actions are taken, the less Georgia taxpayers will ultimately have to
pay for improved water resources.
4. Consider potential impacts on all down-stream users when making permit decisions by applying the
precautionary principle.
Water withdrawal and discharge permits should be based on decisions that
encompass full analysis of the consequences to others users of the same resource systems. Such
impacts may include increased health risks (with associated medical costs), as well as damage to
businesses that depend on resource quality and productivity. If current scientific understanding
does not support a conclusive assessment, the relative risk should be determined using the best
available information and expertise. Delay of an action pending more complete information,
consistent with the precautionary principle, should be seen as the most acceptable alternative when
risks are potentially significant. Presently, a permit may be issued because there is no conclusive
or overwhelming evidence of public threat, even though uncertainty is great and risks are reasonably
substantiated. The more we consider system-wide environmental factors in making decisions about
economic development and other human activities, the greater the benefits for future generations.
When risks are taken, monitoring must be extremely reliable and openly evaluated.
5. Conclusion.
Protecting existing jobs, businesses, and communities that depend on the diversity and
health of natural resources, as well as stewardship of ecosystems themselves, must be viewed as an
essential function of government, which is even more critical during periods of economic and
environmental stress. These businesses are especially important to families of modest means, and if
conducted responsibly, they are sustainable. For governmental policy to do otherwise would, in
effect, result in a takings by improper regulated use of natural resources to benefit exploitative
users at the expense of existing activities being conducted at a proportional, reasonable scale.
Unlike many large, resource-intensive industrial users that are, and have been, permitted to pollute
and/or mine natural resources to the ultimate detriment of the public, responsible nature-based
businesses work within the restorative capacity of natural systems. Such practices must be protected
and encouraged. If they become infeasible due to environmental conditions, our policies have surely
failed and fully functioning ecosystem conditions will be increasingly difficult, if not impossible,
to restore.
For Georgians to attain our economic potential over the long term, while also enhancing the quality
of life for future generations, we must do so within the sustainable capacity of natural systems.
This can only be realized with adequate regulatory agency staffing and principled leadership, which
in turn requires the vision, integrity, and resolve of key decision-makers, such as the members of
this study committee and the General Assembly. The Center urges you to take whatever steps necessary
to improve enforcement of all applicable Georgia laws – not only to safeguard the public interest in
natural resources, but also to enhance our common economic future. Above all, we must seek policies
that provide motives and opportunities for pursuing self-interest that fully complements the public
trust.
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