Comments from the FRWA on the Draft State Water Plan

Below are FRWA’s comments on the Draft State Water Plan.  For more information on the Draft State Water Plan and how to submit your own comments, please visit the Rivers Alliance of CT’s website by clicking here:

Comments from the Farmington River Watershed Association on the Draft State Water Plan

The Farmington River Watershed Association (FRWA) has a special interest in the outcome of the state water planning process.  It was public outcry in 2012 over the possible sale of water from the Farmington River Watershed (specifically the Metropolitan District Commission’s Barkhamsted Reservoir) to the University of Connecticut in Storrs that provided the political pressure to finalize a state water plan after years of hiatus.  Farmington Valley residents were surprised that MDC could propose a sale to such a distant customer, and objected to what seemed to be an ad hoc approach to solving UConn’s water supply problem.  They realized that without a state water plan, there was a lack of readily available information about water resources statewide, and a lack of guidance as to whether any proposed water sale made sense for the state as a whole, or for water as a public trust.

FRWA participated as a stakeholder in the preparation of the Draft State Water Plan, serving on the Water Planning Council Advisory Group’s Science and Technical Committee, attending meetings of the Water Planning Council and the Water Utility Coordinating Committees, and participating in workshops hosted by the consulting firms CDM Smith and Milone and MacBroom.  As a river advocacy organization, FRWA looked for a planning process that would

  1. clarify the state of Connecticut’s water resources;
  2. set forth the needs and the options for balancing in-stream water requirements with human water consumption demands;
  3. propose fair mechanisms for deciding how water could be extracted, sold, and moved by water utilities vs. allocated for other essential purposes;
  4. fully recognize the value of maintaining aquatic ecosystems such as rivers, streams, and wetlands, since these are not only valuable in themselves, but also tied closely to human well-being;
  5. be transparent and have mechanisms for input from a broad range of stakeholders and the general public.

In reality, the Draft State Water Plan does not, and cannot, fully address these concerns, but it does make some progress in the right direction.  The following comments expand on that remark.

  1. Clarifying the status of CT water resources. Overall, given its tight timeline and its budget constraints, the Draft State Water Plan is an impressive compilation and presentation of information, and a useful framework for next steps.  The Water Planning Council, the supporting Committees, and the consulting firms are to be thanked and congratulated on reaching this point.

Even though this summary of Connecticut’s water resources is perhaps the most broad and comprehensive to date, the water data in its basin summary sheets should be interpreted with care.  For some estimates on those sheets, the margin of error was necessarily large.  Also, figures for water availability that represent averages over time can mask the severity of short-term fluctuations in available water.  Lack of information about registered diversions introduces uncertainty.  For example, the basin summaries show the natural flow of a river, and how much of that flow is usually in the channel or diverted for human use.  But in many basin summaries, the number of registered diversions on a river exceeds the total flow of the river.  The obvious conclusion is that the registered diversions are not all in use, or there would be far more dry riverbeds than at present.  But which registrations are in use?  Which are obsolete?  Which might be re-activated and cause a problem later on?  Added to that, how might climate change amplify future flow variation? Those questions need answers in order to craft a reasonable plan for any given river.

Another cautionary note relates to the geographic scale of the basin summaries.  In the Farmington River basin, there is often a disparity between flow in small tributaries and flow in the mainstem, especially since the latter is artificially maintained by releases from impoundments.  We might be lulled by the fact that the basin as a whole looks robust.  But to evaluate possible impacts of our actions on smaller streams within the watershed we should check more localized data, and do location-specific modeling.  This warning applies to other river basins as well.

The draft plan and its executive summary already contain these caveats.  We repeat them here to emphasize that the Draft State Water Plan is the starting point for much more work.

  1. Needs, and options, for balancing in-stream water requirements with human consumption demands.

The draft plan repeatedly states the intent to balance in-stream water needs with human consumptive needs.  However, we agree with comments by Rivers Alliance of Connecticut and others, that “balance” needs clearer definition.  One obstacle to defining balance is that there’s a wealth of quantitative data about how to meet human consumptive needs for water, and a large number of people who are familiar with that information; but biological needs for water in aquatic habitats, and the value of meeting those needs, are less well documented and understood by fewer people.  Lack of knowledge is easily interpreted as lack of importance; despite intent to be even-handed, the better documented side carries more emphasis.   That said, the basin summary sheets do graphically present ecological use and human consumptive use side by side for each of the 44 sub-basins studied.  This is a step in the right direction.  Going forward, our understanding of “balance” should be finer-tuned as more information emerges about the ecosystem services and economic values of our streams and rivers.

The available options for balancing in-stream requirements with water supply demands are presented in the draft plan as information only, without expressed preference, which is a necessary first step.  How we decide to choose among options is deferred to some later stage.

  1. Fair mechanisms for deciding how water can be extracted, sold, and moved by water utilities vs. allocated for other essential purposes.

It’s fair to say that this issue generated the political impetus in 2012-13 for developing a State Water Plan (and for organizing the Water Utility Coordinating Committees). But in actuality, it covers a broader area of concerns, and involves more regulations, plans, and policies, than this State Water Plan can encompass.  The draft plan provides no formulas or criteria for allocating water to this or that purpose.  Rather than prescribing a resolution for the conflict that spurred the legislature to authorize this State Water Plan in the first place, the draft plan organizes information and options that will be relevant to resolution later on.  Again, it’s a platform for future decisions rather than a set of decisions in itself.

  1. Fully recognizing the value of maintaining aquatic ecosystems such as rivers, streams, and wetlands.

This point was discussed above, but two more points can be added that we recommend as additions to the draft plan.  The value of aquatic ecosystems would be better recognized if:

  1. An estimated dollar value was put on their “ecosystem services” such as water filtration, pollution detoxification, the transport and cycling of nutrients, etc., as well as other public goods such as recreation, wastewater reception, etc.; and
  2. The water plan explicitly points out that it should not be legal to pump a river dry. Right now, a waterway can be legally pumped dry if it is over-allocated to registered diversions; or due to the fact that groundwater pumping is not currently included in state streamflow regulations.
  3. Transparent process with mechanisms for input from a broad range of stakeholders and the general public.

The development of the draft state water plan was an open public process, and inclusive of many stakeholders.  There was one glaring lack of transparency, however, arising from the exemption of water supply plans from Freedom of Information requests.  Despite the best efforts of advocacy groups and the Department of Public Health, this problem was never satisfactorily resolved.  It is still virtually impossible for a citizen of Connecticut to obtain a water utility’s water supply plan without unreasonable delay (if it can be obtained at all) and without a degree of redaction that goes well beyond what’s necessary for security purposes.

Fortunately, the consultants who prepared the Draft Water Plan were granted access to the information, so we can be reasonably sure that the aggregated data are credible.  But going forward, more people must have access to more information, if stakeholders and citizens are to have any meaningful role in all the policy decisions that still lie ahead.   On this point, and on many others, we concur with the comments provided by Rivers Alliance of Connecticut.

As emphasized repeatedly in the Draft State Water Plan itself, the document is a starting point.  It identifies gaps in scientific knowledge, procedures that need to be established but are as yet undeveloped, and unresolved policy decisions that remain to be addressed.


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