THE ST. MARYS RIVER BASIN
Susanna Blair
Mackenzie Ezell
Hollie Hall
&
John November
In collaboration with the University of Florida Conservation Clinic and the University of
Georgia Environmental Law Practicum
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TABLE OF CONTENTS
Introduction ....................................................................................................................................................4
St. Marys Watershed Atlas.............................................................................................................................5
Area and Location ......................................................................................................................................5
Climate .......................................................................................................................................................5
Hydrology ..................................................................................................................................................6
Water Budget .........................................................................................................................................6
Flow .......................................................................................................................................................6
Tidal Influence .......................................................................................................................................7
Flooding .................................................................................................................................................7
Geology ......................................................................................................................................................8
Soils............................................................................................................................................................9
Blackwater River Chemistry ....................................................................................................................10
Ecology ....................................................................................................................................................11
Resource Use................................................................................................................................................12
Land Use ..................................................................................................................................................12
Silviculture ...............................................................................................................................................13
Commercial and Recreational Fishing .....................................................................................................13
Recreation and Tourism ...........................................................................................................................14
Inlet and Coastal Areas ............................................................................................................................15
Development ............................................................................................................................................15
Water Use.....................................................................................................................................................18
Water Quantity .........................................................................................................................................18
Consumption ........................................................................................................................................19
Water Quality ...............................................................................................................................................20
Point Sources of Pollution ...................................................................................................................20
Nonpoint Sources of Pollution.............................................................................................................21
Assessment of Nutrient Pollution ........................................................................................................21
Septic Systems .....................................................................................................................................21
Assessment of Septic Systems .............................................................................................................21
Institutional and Management Framework ..................................................................................................23
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Political Landscape ..................................................................................................................................23
Federal Environmental Institutional Framework .................................................................................23
Georgia Environmental Institutional Framework ................................................................................25
Florida Environmental Institutional Framework .................................................................................27
Local Environmental Institutional Framework ....................................................................................29
Regulatory Framework for Managing Water Quality..........................................................................30
Total Maximum Daily Loads...............................................................................................................32
Data Collection and Water Quality Assessment ..................................................................................33
Dissolved Oxygen ................................................................................................................................34
Silviculture ...........................................................................................................................................35
Septic System Pollution .......................................................................................................................36
Current Management....................................................................................................................................39
Wildlife Habitat........................................................................................................................................39
Water Quality Management .....................................................................................................................39
Water Quantity Management ...................................................................................................................40
Floodplain Management..........................................................................................................................41
Recommendations for an Adaptive Watershed Management Approach .....................................................42
Monitoring................................................................................................................................................42
Buffers......................................................................................................................................................42
Interstate Compact ...................................................................................................................................43
Conclusions ..................................................................................................................................................48
References ....................................................................................................................................................49
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Introduction
The St. Marys River is one of the best-preserved and most unique blackwater river systems in
America. The 125 mile long winding river forms the northeastern border between Florida and
Georgia and connects two nationally recognized ecological sites. The river’s headwaters
originate within the Okefenokee National Wildlife Refuge. The combination of rain and spring
water sources form the composition of the 1,300 square mile basin that drains into the
Cumberland Island National Seashore in the Atlantic Ocean. The waters of the St. Marys River
have long been known for its outstanding water quality. Old sailing vessels would come from
hundreds of miles off their course to fill the hulls of their ships with St. Marys River water to be
used as drinking water for their voyages. To this day, the river serves as an important
passageway for commercial, recreational, and naval vessels. It provides access to St. Marys
Harbor Georgia, Fernandina Harbor, and the U.S. Navy Submarine Support Base at Kings Bay.
The river system also supports extensive eco-tourism and silviculture industries.
The information contained within this report was produced by an interdisciplinary team and
summarizes the biophysical, social, economic, and legal landscape of the St. Marys watershed.
The first section of this report describes the watershed in its physical context. The interplay of
climate, geology, hydrology, and ecology are discussed to develop an understanding of the key
characteristics of this system. Overlaid on this framework are the key economic and social
features of the watershed. Following the explanation of the physical characters of the watershed
is a discussion of how the system is currently utilized by humans including the potential for these
uses to affect the value of ecosystem services provided by the system. The final section of the
report synthesizes the information presented to assess the current management efforts and make
recommendations for taking an Adaptive Management approach in the watershed. Current and
emerging management issues facing the watershed are explored with emphasis on the
characteristics of the watershed that constrain management.
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St. Marys Watershed Atlas
Biophysical Characteristics
Figure 1: St. Marys River Surface Basin
(SMRMC 2003).
Geographic Area
The St. Marys watershed is located on the eastern border between Florida and Georgia. The
basin occupies 1,300 square miles with approximately 765 square miles located in Georgia and
535 square miles located in Florida. The river itself is 130 miles long. Its headwaters originate
in the Okefenokee Swamp and the river eventually drains into the Atlantic Ocean at Cumberland
Sound. About 86% of the watershed is located in four different counties: Camden and Charlton
counties in Georgia and Nassau and Baker counties in Florida. Figure 1 is a map of the
watershed area and location. The watershed is represented by the Hydrologic Unit Code 0307024
by the U.S. Geologic Survey.
Climate
The St. Marys Watershed has a sub temperate climate characterized by mild winters and hot
summers. The average annual precipitation is between 40 and 52 inches per year. Summer is
the wet season with one-third to one-half of all precipitation in the basin falling during this time.
Fall is the driest season receiving only 20% of the annual precipitation. The average temperature
in the area is 69 degrees Fahrenheit.
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Hydrology
Water Budget.
The Okefenokee Swamp, as mentioned above, is the origination point of the St. Marys and
accounts for approximately 10% of the total river flow. The swamp’s water budget is
representative of the St. Marys watershed with approximately 82% of the water in the swamp
coming from rainfall, 15% from basin surface water runoff and 3% from groundwater discharge.
Around 80% of this inflow is released back into the atmosphere through evapotranspiration.
This is typical of water bodies in Florida and Georgia due to the warm climate and high summer
temperatures. Only around 2% of the swamp’s discharge flows into the St. Marys River.
Flow.
The St. Marys has 3 distinct
areas contributing flow: the
headwaters, the middle St.
Marys, and the lower St. Marys.
The headwaters are formed from
5 significant tributaries: North
Prong, Middle Prong, Cedar
Creek, South Prong, and Deep
Creek.
These headwaters
account for approximately 40%
of the flow seen at the mouth of
the river. The middle St. Marys
has two significant tributaries: Figure 2: Average Daily River Discharge 1965-1990 in cubic feet per second
the Suwannee Canal and Spanish
Creek. Cabbage Creek and the Little St. Marys contribute flow in the lower St. Marys. Figure 2
shows the increase in flow of the St. Marys along three points on the river- one near the
origination point at Moniac, GA, one just past where the headwaters converge near MacClenny,
FL, and one near the mouth of the river at Gross, Florida. The flow near the origin is only 250
cubic feet per second and increases to over 1500 cubic feet per second near the mouth of the
river. There is a drop in river flow during May, June, and July due to the high evapotranspiration
rates and an increase in flow during the hurricane season in September and October.
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Tidal Influence.
The lower third of the St.
Marys River is brackish water
due to tidal fluctuations in the
Atlantic Ocean. At low tide,
there is a maximum discharge
average of 6,000 cubic feet per
second. During high tide, there
is actually no discharge. Salt
water is pushed back into the
lower third of the river due to Figure 3: Daily Tidal Fluctuations at Gross, FL in cubic feet per second
minimal topographic changes
in the area. These tidal systems have undoubtedly shaped the ecosystem in the area. Figure 3
shows these daily tidal fluctuations at high tide, low tide, and an average daily flow of the
system.
Flooding.
The two causes of flooding in
the St. Marys Floodplain are
tidal surges or extensive
rainfall, which often cause the
river to overflow its banks.
Tidal surges would likely be
the result of a hurricane or
tropical storm affecting the
region.
A Hurricane Tidal
Surge Inundation Map for this
area shows possible flooding
nearly a third of the way up the
river. even if only a category 1
hurricane were to hit the east Figure 4: 100-Year Floodplains in the St. Marys River represented by the
coast at the Florida Georgia marigold color. (St. Marys River Management Plan p. 40)
border.
In the case of a
category 5 storm, large portions of northern Florida and southern Georgia would be covered to
Highway 1 (American Red Cross, 2008). Hurricane flooding hazards are managed under the
Federal Emergency Management Agency (FEMA), who supplies insurance as well as response
and recovery if there were be a disaster.
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Currently, a large portion of the river’s watershed is within the 100 year floodplain. Figure 4
shows the 100 year floodplains of the river highlighted in orange. The headwaters are largely
floodplain areas, in the middle St. Marys the floodplains are largely confined to the river margins
due to deeper banks, and the lower St. Marys, is approximately 50% floodplain areas. With
these significant floodplain areas, flooding is a major concern.
This river is subject to flooding events most years, primarily as a result of heavy rain events. In
the Florida portion of the watershed, 190,399 acres fall within the 100 year floodplain. Of these
total acres 3,000 acres are currently developed, with an additional 16,200 acres designated for
future development. (St. Marys River Management Committee Management Plan, 39). When
putting this into context for this area, increased development in the floodplain would result in
additional applications for National Flood Insurance Policies. At the very least, the issuance of
these additional policies would likely result in increased stringency for construction within the
floodplain. There is also a possibility that policy decisions at the federal level may lead to FEMA
limiting the amount of NFIP policies issued in at-risk floodplain areas, which certainly would
have an effect on development in the area. It may make sense for the St. Mary’s communities to
attempt to continue to strive to achieve higher classifications within the NFIP which could lead
to increased local control and lower premiums for its citizens.
Geology
The drainage basin of the
St. Marys can be separated
into two physiographic
regions that are delineated
by their geology. First, the
Atlantic Coastal Plan,
which extends from the
coast west to the Trail
Ridge, is a topographic
high that runs north to
south.
This plain is
distinctly different from
the Northern Highlands
that are to the west of the
Trail Ridge, in that the
elevation is no more than
Figure 5: Geological Map of northeastern Florida (Scott et. al.)
100 ft above sea level.
Unlike most of Florida, this region is not highly influenced by karstic hydrogeology. The
Floridan aquifer in this region is nearly 2000 ft below the surface and the surface geology is
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primarily composed of silicious or quartz sand and clay material. Figure 5 is a geological map of
northeastern Florida, which is representative of a majority of the geology in the watershed. To
the west, the dunes are composed of siliciclastics, organics, and freshwater carbonates. Just east
of these dune areas are the Trail Ridge Sands. This topographic high borders the eastern edge of
the Okefenokee Swamp and it is also what creates the large “U” turn in this river, as the river
chooses the path of least resistance as it flows around the relatively high topography. The Trail
Ridge Formation is an important lithologic unit in the southeast as it has a relatively high
concentration of heavy metals. The titanium minerals, rutile, ilmenite, and leucoxene, make up
about 45 percent of the heavy-mineral fraction. Staurolite, zircon, kyanite, sillimanite,
tourmaline, spinel, topaz, corundum, monazite and others make up the remainder of the heavymineral fraction (Scott et al.). This unit was once investigated for mining operations in this area.
In fact, Dupont has a Titanium mine in Starke, Florida although this doesn’t affect our
watershed, This mine is in the same Trail ridge formation, and could forecast future mining
operations within the watershed in the future.
To the east of the Trail Ridge Sands is the Cyprus Head formation that is composed of shallow
marine siliciclastics. There is a small outcropping of the Hawthorne group in this watershed.
This is a clay formation with high concentrations of phosphorous. The undifferentiated
sediments to the east of this are sands that were deposited in a freshwater system, and it has some
organic content. The Holocene sediments are quartz and carbonate sands and muds, while the
Beach Ridge and Dunes are more modern deposits of marine quartz sand (Scott et al.).
Knowing the geology of a watershed has many important implications. The geology is one of
the major controls of topography, aquifer topology, infiltration rates, soil types, as well as
possible contaminants. For example, the Hawthorn formation is rich in phosphorous, and may
cause naturally occurring high phosphorous concentrations in ground or surface water. This
same reasoning can be applied to some of the relatively high concentrations of iron that have
been found in some groundwater wells in the watershed, as this mineral is present in some of the
clay formations (Gihring et al, 2007).
Soils
There are four main types of soils in the St. Marys River basin. Histosols, comprised of mostly
peat in this region, are commonly found in the upper reaches of the River in lower topographic
features. This type of soil is identified by a thick surface layer that is very high in organic
carbon. In the higher topographic regions of the watershed, Ultisols can be found. These soils
have a sandy surface horizon and a clayey subsurface. Spodisols are primarily found along the
main stem of the river. These soils are commonly poorly drained and have a shallow hardpan or
spodic horizon. Finally, Entisols are found in the floodplain regions of the watershed. These are
mineral and quartz sand dominated with little organic content. The ability of soils to drain water
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has implications for the ability of the watershed system to filter contaminants before they reach
the river. The soils in this watershed tend to have an upper depth of between two and nine feet
of sand that overlays a dense clay layer. Water entering the basin rapidly infiltrates the sand
layer; however infiltration is impeded when the water contacts the impermeable clay layer which
concentrates and directs water flow to the river (SJRWMD, Watershed facts). The existence of
this impermeable clay layer should increase the emphasis on ensuring that sources of pollution
are controlled and functional buffers are required.
Blackwater River Chemistry
The inherently low nutrient and dissolved oxygen levels of the St. Marys River make it
particularly vulnerable to contamination. The sandy materials comprising much of the geology
and soils in the area do not retain organic materials well and nutrient pollutants move through
them easily. The result is a rapid movement of nutrients from their source to nearby ground or
river waters. Nutrients entering the river can drive a proliferation of algal growth increasing the
biological oxygen demand, resulting in a decrease of the already low dissolved oxygen levels.
Currently, there is a lack of knowledge as to what extent the native ecosystem can tolerate
nutrient and dissolved oxygen fluctuations. The hypothesis that low dissolved oxygen levels are
a natural occurrence in the river should not slow down research geared at determining whether
there are also anthropogenic factors that have contributed to this level. Managers must have the
foresight to understand that although past human action may not have lead to the low dissolved
oxygen levels, the sensitive nature of this blackwater river will require stringent monitoring of
even minor future activities that could impact the dissolved oxygen levels.
Ecology
The St. Marys Basin is a natural hot spot for ecological activity as it creates a wildlife corridor
between the Okefenokee Swamp at its origination point and the estuaries at the mouth of the
river. The watershed contains 34,223 hectares of undisturbed natural communities,
approximately 8.7% of the catchment area. The St. Marys river and floodplain provides
important ecological corridors for the Florida Black Bear, dry sandhill habitat for the Sherman’s
fox squirrel, open habitat for the Southeastern American Kerstel, red cockaded woodpecker, and
gopher tortoises, as well as pristine blackwater river habitat for several endangered species of
fish.
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The natural tidal system salt marsh, swamp and
maritime forest communities in the St. Marys
contributes to the existence of the large number
of species in the estuary. The estuary and
beaches provide foraging and nesting grounds
for the West Indian Manatee, and the coastal
waters are utilized as calving grounds for the
critically endangered Northern Right Whale.
Collectively, the basin’s ecosystems and waters
are home to many federally threatened or
endangered species including mammals,
reptiles, birds, and fish. A partial list can be
found in Table 1.
Common Name
Fish
Atlanic Sturgeon
Endangered/Threatened
Threatened
Reptiles
Table 1: Federally threatened or endangered species
American Alligator
Threatened
Atlantic Loggerhead
Threatened
Turtle
Atlantic Green Turtle
Endangered
Leatherback Turtle
Endangered
Eastern Indigo Snake
Threatened
Atlantic Hawksbill
Endangered
Kemp’s ridley
Endangered
Flatwoods Salamander
Endangered
Mammals
Northern Right Whale
Humpback Whale
Florida Manatee
Endangered
In 1996, Florida wisely identified critical areas
Endangered
Endangered
that are home to endangered or threatened
species and/or flora. In Georgia, however, there
Birds
has been no marking of the critical species Red Knot
Under Review
habitats in the area. Since Georgia has failed to Arctic Peregrine Falcon
Endangered
Wood
Stork
Endangered
identify these critical habitats, future
development in this area could encroach on these significant areas, reducing their value and their
ability to support the species that depend on these corridors in order to survive. Identification of
these natural areas is only the first step, The communities of the St. Marys watershed must also
support the public funding of land acquisition programs that can ensure that these significant
areas are protected.
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Resource Use
Land Use
Land use in the St. Marys is
divided
between
many
different groups of uses
including:
wetlands,
agriculture,
grasslands,
forestry, urban development,
and open water. Currently,
there is not a significant
amount
of
urban
development in most of the
St. Marys River watershed,
with development limited
mainly to the banks of the
Figure 6: Land Use by percent for the St. Marys RIver Watershed. The green
river and the coastal inlet. bars represent the land use in 1992 and the orange are those from 2001 (data
Currently, the main human from USGS, 2009).
use in the watershed is
silviculture.
Figure 6 is a graph
showing the percentage of land cover
for
each
land
use
category
within the watershed. The uses from
1992 to 2001 change slightly, however
there are more dramatic increases in
grasslands and urban land cover. There
are decreases in wetlands, forests and
open water. The change in the amount
of forest land could be a result of
increased timber harvesting or the
conversion of timberland to urban land
cover. In merely this 9 year span there
was an increase in urban development in
the watershed of approximately 7%.
Figure 7 is a map of the St. Marys River
Watershed. In this figure, the estuary is
the light yellow region to the east, the
river is the light yellow line moving
through the watershed, making the large
Figure 7. Map of St. Marys River Watershed, showing both
the Areal Empower Intensity (AEI) and the forecasted land
use change in Florida for 2020, 2040, and 2060 as indicated
by the red colors (data from USGS, 2009 and FGDL, 2009).
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“U” and ending in the Okefenokee Swamp, the light yellow region in the west. The yellow and
orange colors that make the backdrop of this map represent the Areal Empower Intensity (AEI).
This is a method of determining what land is susceptible to human influence. Areas with a value
of 0, such as the river or the swamp are least susceptible, while the more orange colors are areas
that are more susceptible to impacts. Superimposed on this AEI is the forecasted land use
change for the Florida side of the river for the years of 2020, 2040, and 2060. The, light to dark
red, colored regions show the projected increase in urban sprawl along most of the south side of
the river. The most significant regions of development are directly along the river as well as in
the southwestern portion of the watershed. This figure indicates that there is a strong chance that
some of the silviculture industry’s land along the river will be converted into development and
that the town of Macclenny, Fl will drastically increase in size. This figure acknowledges that
the coastal areas will see little change, because it is already quite developed.
Silviculture
The timber industry dominates the physical, political, and economic spheres surrounding the St.
Marys. In Nassau County, for example, in terms of physical dominance 323,400 acres out of
417,000 total land acres are timberland. The economic importance of the timber is demonstrated
by the fact that in Nassau county alone, timber is valued at about $292,510,000. (Florida
Department of Agriculture and Consumer Services 2009). When it comes to political
significance, the dominant silviculture companies in the watershed have the reputation of
oftentimes having enough political pull to sway government officials when they are making
important policy decisions in the region. The silviculture industry has been the most powerful
private stakeholder group in the St. Marys River watershed.
Commercial and Recreational Fishing
Over 65 species of fish have been identified in the River (St. Marys River Guide). At the St
Marys Rivers’ mouth, redfish, flounder, and spotted sea trout are abundant, while largemouth
bass, panfish, and catfish are popular species in the middle and upper portions of the River (St.
Marys River Guide). Florida and Georgia agree on fishing and boating regulations in the form of
a Reciprocal Agreement, which mainly assigns each state’s regulations to that side of the River
(St. Marys River Management Plan). These regulations are supported through sufficient
enforcement of activities on the River (St. Marys River Management Plan). Nevertheless, in
recent years commercial fishing has nearly disappeared. Historically, the St. Marys River was a
popular fishing location for sturgeon, largemouth bass, sunfish, and other fish. The mercury in
fish tissues is causing the fishing of some species to be limited. This mercury is believed to be
atmospheric in origin and deposited from industrial sources. It is converted into methylmercury
through biological processes in the soil and water. Unfortunately, there are currently
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consumptive guidelines in this river due because the hign mercury levels present in fish tissue is
causing the river to not support its current designation as a Class III fishing river. In the Upper
St. Marys, recommendations limit largemouth bass to 1 meal/month and redbreast sunfish to 1
meal/week. In the lower portion, recommendations limit largemouth bass to 1 meal/week.
There are a number of unknowns associated with the mercury problem in the St. Marys
including: how to reduce atmospheric mercury levels, the rate at which mercury levels in the fish
tissue is rising, and if mercury levels in the river are actually significant enough to classify it as
impaired.
The Atlantic sturgeons are a threatened species that was supported in the river until the mid1980’s. Recent surveys have shown that the Atlantic and shortnose sturgeon have been extirpated
from the river. No sturgeon was reported in the river in a study conducted over a 5.5 year span.
A similar fate has been observed for shad in the river. The exact cause of the sturgeon extirpation
is unknown, but potential causes include groundwater removal from paper mills, over-fishing,
river-flow alterations, water quality declines, human population growth, human induced salinity
level alteration, and nutrient-laden runoff from dairy farming and silviculture. Unfortunately, the
St. Marys, has seen a reduction of 82% in the amount of fishing conducted on the river from
1986 to 1999. Nevertheless, recent actions may cause an improvement in fishing conditions on
the river. The St. Mary’s Fisheries restoration Committee (SMFRC) is currently developing a
plan to reestablish native fisheries in the river through effective partnerships and consensus
adaptive management. The SMRMC has hypothesized that the improved water quality that is a
result of the closing of the paper mill located at the headwaters of the river in 2002, along with
the decrease in water withdrawals from the aquifer below, has provided the potential for sturgeon
populations to be re-established in the river. This re-establishment of a sustainable fish
population could eventually stimulate the economy and could provide the centerpiece for
establishing hunting, tourism, and other related industries in the region.
Recreation and Tourism
Recreational uses of the St. Marys River include boating, fishing, and hiking in the state parks.
The St. Marys River Canoe Trail is officially designated as part of Florida’s Statewide System of
Greenways and Trails. In 2000, 17 public access sites on the main River were identified, with 7
located on the Florida side. A variety of publicly accessible recreational sites are located on the
River, including two national sites (Okefenokee Swamp National Wildlife Refuge and
Cumberland Island National Seashore) and three state sites in Florida (Ralph E. Simmons
Memorial State Forest, John M. Bethea State Forest, and Fort Clinch State Park).
The St Marys River Management Committee (SMRMC) also continues to support and encourage
public knowledge about the River and the recreational activities it has to offer. In conjunction
with the St. Johns River Management District, the SMRMC published the St. Marys River Guide
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in order to further this objective. The Guide lists opportunities to see the basin’s wildlife and
notable sites for environmental education along with providing camping and visitor information.
Inlet and Coastal Areas
The St. Marys’ inlet and coastal area is comprised of both estuarine and marine waters with
exceptional biological, aesthetic, and economic value. Human use of this land dates back to
3500 B.C. and today, the inlet has been significantly modified by humans to provide access to
the Kings Bay Naval Submarine Base and the Port of Fernandina. Fernandina Beach and Amelia
Island to the south of the inlet are significantly developed while Cumberland Island and the Fort
Clinch State Park are both protected areas around the inlet with minimal development and
significant ecological value.
The St. Marys River, Amelia River, and Cumberland Sound all empty into the Atlantic Ocean at
this inlet. The St. Marys inlet is an altered natural inlet maintained by the Army Corps of
Engineers. The actual inlet has been significantly modified to achieve its current depth and
width by two federal navigation projects. The first project began in 1881 with the construction
of parallel jetties to maintain the navigation channel. These jetties have been modified over the
years and currently the north jetty is 19,500 feet long and the south jetty is 11,200 feet. The
channel extends out approximately 12.5 miles into the Atlantic. The inlet influences beaches
four miles north of the inlet and 13 miles south of the inlet.
Sand is accumulating in excessive amounts on the north side and inside the inlet while it is not
able to nourish the southerly beaches. Amelia Island, directly south of the inlet, has 9.1 miles of
beach that are currently experiencing critical erosion. The channel is also slowly migrating
south, eroding away land in the process. The Kings Bay Naval Submarine Station in the inlet
area uses a constructed access channel initially constructed in 1955 to allow the movement of
submarines in and out of the Atlantic. This project has extended the entrance of the channel to
125 miles offshore. This inlet channel and Cumberland Sound require massive annual
maintenance dredging to maintain a depth of 46 feet and a width of 500 feet.
The inlet and sound construction has brought about serious concerns regarding the beaches,
wildlife, and development. Suitable material must be acquired to help nourish beaches down
drift from the inlet to help mitigate the impacts of erosion. Dredging of excess material north of
the inlet must also occur to prevent marine life such as whales and dolphins from becoming
beached. Several species of endangered turtles use these beaches as nesting grounds making
protection of them vital. With the inlet migrating southward, there is the real possibility of the
highly populated areas of Fernandina Beach and Amelia Island to become eroded over time (St.
Marys River Entrance Inlet Management Study Implementation Plan 1997).
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Development
Developments of Regional Impact, also known as DRI’s, are projects in either Florida or Georgia
that will affect an area well beyond the local government jurisdiction where the project may be
located. These projects require the developer to submit an Impact Statement to the local
governments of the area. These governments coordinate with regional planning councils to
determine if the project is in the best interest of the region and therefore the state. The DRIs go
through a process that includes this step, as well as public notices and hearings. Figure 8 shows
the process of DRI permitting that must be done in order to be approved in the State of Florida.
In Florida, only after the DRI has gone through these steps, will the project be either approved or
denied by the local government. In Georgia, the DRI process is not binding, and instead simply
provides recommendations for the developers to improve the project from ecological, social, and
economical standpoints.
In Georgia, there are currently over 40 DRIs in the process of being reviewed in our watershed.
Many of these DRIs propose massive development in the watershed. One prime example of
these projects is the Villages at Kingsland. This 15,000 acre project will not only double the
city’s area and take over 20 years to build, but will require significant capacity increases. In
order to serve this DRI alone, 5 new groundwater wells must be drilled to provide an extra 16
million gallons per day (MGD) of water to the area, a new treatment plant will be built for the 12
MGD of wastewater, and the problem of 180,000 tons of solid waste produced annually by the
development has not yet been able to be solved. This presents significant concern that these
projects are not only being approved as in the best interest of the region, but also how these
projects will affect the water supply in the area. Without further regulation of these
developments, it is probable that they will significantly alter the face of the watershed.
On the Federal level, the National Environmental Policy Act attempts to regulate the federal
development through Environmental Impact Statements (EIS). While there is only one such EIS
in our watershed, it has been consistently updated and supplemented with ongoing expansion.
The EIS was first applied for in 1976 by the Navy for the construction of the Kings Bay Naval
Submarine Station. The study attempted to forecast the social, economic, fiscal, and
environmental impacts of this project on the area, particularly the estuary and inlet at the mouth
of the St. Marys River. This project was approved as well as the supplemental EIS despite the
fact that all these EIS’s have acknowledged that the project has significant impacts through
dredging, marine mammals,
resources,
sanctuaries
for
threatened and endangered
species, and water resources.
The St. Marys watershed has a
high potential to continue
providing ecosystem services
St.
Marys
River
Watershed
Figure 8: Florida Developments of Regional Impact Permitting Process
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Blair, Ezell, Hall, & November
including provision of habitat for a great diversity of wildlife like the black bear and sea turtles.
As you can see, with the expanding local and federal projects, there is concern over the
protection of wildlife and their habitat. In our watershed, there are rare, threatened, and
endangered species that need or will soon need protection. Two species are particularly
representative in this area, the turtles and black bear. There are six endangered turtles in estuary,
inlet, and surrounding ocean waters. These turtles use the coastal beaches at Cumberland Sound
and the inlet beaches as nesting grounds. The Florida Black Bear uses the large forested areas
and surrounding rivers as its habitat. The conservation of valuable wildlife corridors within the
St. Marys watershed will assist in the connection of an ecological greenway between the Ocala
and Osceola National Forests.
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Marys
River
Watershed
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Water Use
Water Quantity
Both Florida and Georgia have state regulations concerning water withdrawals from both surface
and groundwater. Although both states utilize “regulated riparian” systems based on reasonable
use, there water regulations often differ. Currently, all water withdrawals in the state of Georgia
are handled through the Georgia Environmental Protection Department. When EPD is making
permitting decisions related to surface water consumption they must balance a number of public
interest factors such as the nature and size of the water body, the extent, importance, and nature
of the planned consumption, how the consumption would affect flows in accompanying water
bodies, the nature of impairments of the water body which could have adverse effects on
competing water uses, and the injury that would result to the public health, safety, and welfare if
such impairment are not prevented. (Ga Code § 12-5-31(e)) For surface water or groundwater
use, an applicant who plans on using more than 100,000 gallons per day must apply for a water
use permit from the Georgia EPD (rule 391-3-2-.03). Under this rule the applicant must prove
that this water use will not cause material injury or detriment to other water users of the same
area and is not contrary to the public interest. Most of these permits are issued for 10 years and
may be renewed (Georgia Department of Natural Resources, 2002). A positive addition to
Georgia’s water law regulations is that when applying for a permit for increased water
consumption the applicant must include a water conservation plan. (Ga Code § 12-5-96
(a)(2)2007) A permit is required for all public drinking water sources. As of 1998, all applicants
who apply for a new permit for groundwater withdrawals must also provide an approved back-up
water supply source that is capable of providing adequate water service, if the groundwater
source becomes nonfunctional. This has strong implications for withdrawals directly from the
relatively pristine St. Marys River, especially if development increases as expected within the
region. Permits must also be applied for agricultural water use if the amount exceeds 100,000
gallons per day. Unfortunately, in the state of Georgia agricultural water use permits do not
expire and are exempted from most regulatory oversight. Additionally, agricultural water users
are not required to record or report their water usage, and there is little to no enforcement
requiring them to stay within the permitted amount. There is evidence that agricultural water use
in Georgia has been increasing. In 1970 only 175,000 acres were irrigated and by 2004 there
were nearly 1.49 million irrigated acres in Georgia (Haire, 2005).
In Florida, the St. Johns River Water Management District (SJRWMD) has governance over
water usage in the St. Marys Watershed. Consumptive Use Permits (CUPs) are required for
users who plan to use 100,000 gallons or more per day. These permits are not for water use
intended for in home domestic use (Chapters 40C-2, 40C-20, or 40C-22, F.A.C.) In the CUP
ruling there are very strict instructions about water uses for irrigation, reclaimed water, even
fountains, and a strong focus on reclaimed water usage especially for golf course irrigation. The
applicant must show that the water use will be reasonable and beneficial, that it will not interfere
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River
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Blair, Ezell, Hall, & November
with any presently existing legal use of water, and it must be consistent with the public interest.
(Chapter 40C-2, F.A.C.) (GaDNR, 2002 and SJWMD, 2009).
Current water withdrawals from the St. Marys River watershed are shown in Table 2. This table
represents both surface water and groundwater
Public Agriculture Industry Golf
withdrawals and is split up by specific permitted
Courses
use. The agricultural water use in Georgia is an
estimate, due to the lack of an accurate Georgia 2.13
0.52
31.32
-reporting mechanism. The total water use in
this basin is approximately 100 MGD. By Florida 11.85
1.53
33
20
comparison, Gainesville, Florida main well
2.05
64.32
20
field, Murphree Well Field operated by TOTAL 13.98
Gainesville Regional Utility, has a projected
withdrawal amounts for 2010 at 29.5 MGD.
Table 2. Water use (MGD) by permitted type in
Georgia and Florida. St. Marys River Water
Management Plan from the Committee and Fisher and
Thompson (2003).
Consumption
Figure 9 is a map of central and north Florida
showing the projected drawdown of the
potentiometric surface of the Florida aquifer
to year 2030. Most of this drawdown is
associated with the city of Jacksonville, but
the cone of the depression associated with this
water usage does extend well into our
watershed. From just these projections the
aquifer below the St. Marys could see
decreases from 0.5 to 10 feet. It is important to
remember that this figure only illustrates the
impact to groundwater sources in Florida and
gives no indication as to the amount of
drawdown associated with groundwater use in
Georgia.
The over use of groundwater will undoubtedly
lead to an increased use in surface water, as
this has already happened with the withdrawal
of water from the St. Johns River to supply
Seminole County in Florida. Besides the St.
Johns, the St. Marys River is the closest
supply of freshwater for the Jacksonville area,
St.
Marys
River
Watershed
Figure 9: Projected changes in the elevation of the
potentiometric surface of the Floridan aquifer system in
response to projected increases in groundwater withdrawals,
1995-2030 (from SJRWMD, January 2009)
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Blair, Ezell, Hall, & November
and with increased urban development in the watershed proper, this river could definitely
become a source for area water withdrawals.
There is little doubt that there will be increased development in and surrounding the St. Marys
River Watershed. This increased development will require increased water use, which begs the
question, what is the holding capacity of the water in this watershed?
Water Quality
Designated Use
In Florida water quality standards use water quality criteria to define designated uses of the
States water bodies (FDEP, 2007). The St. Marys River is designated a Class III which means
that the River must be “suitable for recreation, propagation & maintenance of a healthy, wellbalanced population of fish and wildlife” to meet its designated use. In Georgia the designated
use of the St. Marys River is a Fishing River. Florida and Georgia agree on fishing and boating
regulations in the form of a Reciprocal Agreement, which mainly assigns each state’s regulations
to that side of the River.
Point Sources of Pollution
Both the states of both Florida and Georgia permit point source discharge into the St. Marys
Basin. Permission to discharge domestic or industrial wastewater or storm water to surface
water bodies is provided through the National Pollutant Discharge Elimination System (NPDES)
permit (FDEP 2007). In addition to NPDES permitted point discharges, Florida & Georgia also
regulate the land application of domestic and industrial wastewater. Permitted point sources of
contamination in the St. Marys include treated wastewater from sewage treatment, concrete and
other industrial plants. The 200 or more permitted wastewater discharges are known sources of
metals, nutrients, and coliforms. Point source discharges of wastewater have a high probability of
reducing water quality. While this fact is known, the activities continue to be allowed as long as
the water quality standards governing the rivers designated use are not violated. Generally
permitted discharge loads are not reduced unless a Basin Management Action Plan has been
implemented for the receiving water body.
The receiving waters of point source discharges are not adequately monitored for water quality.
Without monitoring of the waters receiving point-source discharge it is impossible to determine
to what extent these activities may have altered the River. The associated management
implications are that extensive monitoring of the system must occur to allow for the
identification of a loss of water quality and ecological function.
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Nonpoint Sources of Pollution
Nonpoint sources of pollution generally enter surface waters with rainwater as it flows from the
landscape carrying with it naturally occurring and anthropogenic materials. Agricultural
activities are known sources of nonpoint pollutants such as sediment, fertilizers, animal wastes,
pesticides, and pathogens. Rainwater leaving urban, industrial and residential landscapes is
referred to as ‘urban runoff’. Urban runoff carries with it sediments, nutrients, oil, grease,
metals, bacterial, pesticides, herbicides and other toxic wastes into the St. Marys River. The
potential future conversion of timberlands in the basin to urban sprawl will increase the amount
of nonpoint pollutants entering the river. Florida and Georgia both utilize Best Management
Practices for their silviculture industries. Utilizing the proper Best Management Practices during
silvicultural activities may lead to a reduction in the contribution of nutrients, sediment, organic
debris, pesticides and herbicides to the St. Marys River. It is essential that further studies are
conducted to establish whether these BMP’s are effectively protecting water quality, including
within the tributary areas. Also of great concern in the St. Marys Basin is the potential for near
river septic tanks to act as nonpoint sources of nutrients and coliforms (Georgia Department of
Natural Resources 2002). The collective contribution of nonpoint source contaminants to the St.
Marys River has the potential to negatively impact water quality unless Best Management
Practices are effectively utilized and updated to ensure that their purpose of improving water
quality is achieved.
Assessment of Nutrient Pollution
Currently in the state of Florida the definition of nutrient loads that exceed acceptable limits are
based on a narrative definition rather than a numeric value. The narrative states, “In no case
shall nutrient concentrations of a body of water be altered so as to cause an imbalance in natural
populations of aquatic flora or fauna (Florida’s Division of Water Resource Management,
2007).” This rule considers other information that might “indicate an imbalance in flora or fauna
due to nutrient enrichment, such as algal blooms, excessive macrophyte growth, a decrease in the
distribution (density or aerial coverage) of sea grasses or other submerged aquatic vegetation,
changes in algal species richness, and excessive dissolved oxygen swings (Florida’s Division of
Water Resource Management, 2007).” This definition is useless without adequate monitoring of
water quality to allow the identification of system changes. To gain the States support in
remediating excessive nutrient loads that may emerge in the future it is imperative that extensive
and coordinated monitoring of the above-mentioned ecological parameter begins and continues
indefinitely. It also may make sense to measure excessive loads through the use of a numeric
value system.
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Septic Systems
Nutrients and coliforms originating from septic systems are considered a non-point source of
pollution. Degradation of water quality due to septic systems is a major stakeholder concern in
the St. Marys. Septic systems provide small-scale sewage treatment in rural areas that are not
connected to municipal sewer systems. Septic systems consist of a tank and a drainage field as
show in Figure 10. Household wastewater flows into the septic tank where the solids sink, the
scum floats and anaerobic bacteria begin the decomposition process. When the volume of the
septic system reaches capacity the liquid waste flows out of the tank and into the drainage field
via porous piping. Complete treatment of wastewater depends on in-tank processing and
dispersal of effluent to the leach field. If not properly maintained septic systems can become a
source of organic matter, nutrients, oxygen demanding bacteria and pathogens to the
environment. Proper functioning of the septic tank depends on the maintenance of sufficient
tank volume and drain field capacity to allow for sufficient decomposition of waste.
Maintenance requires the removal of accumulated partially decomposed solid waste from the
septic tank every 3 to 5 years. If sufficient septic tank volume is not maintained sufficient
decomposition of waste is not achieved, the leach field will become clogged and fail releasing
organic matter, nutrients, oxygen demanding bacteria and pathogens into the environment
(Cogger, 2009).
Figure 10: Septic System Diagram
The St. Marys River is particularly vulnerable to septic contamination. Until 2005 there were no
regulations associated with septic tank installation location along the river, resulting in the
presence of aging septic systems within 100 feet of the river. The sandy materials comprising
much of the geology and soils in the area do not retain organic materials well and liquids move
through them easily. The result is a rapid movement of wastewater through the septic systems
leach field to near by ground or river waters. Additionally, the St. Marys River frequently
floods. Floodwaters increase the already shallow water table potentially inundating septic tanks,
flushing waste materials into the river. Collectively, these conditions lead to a high probability
of septic tank contamination of ground and river waters in the St. Marys System.
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Political Framework
Political Landscape
As with any region in the United States, The St. Marys River Basin is under the jurisdiction of a
myriad of federal and state legislations and is under the watchful eye of many stakeholders from
the federal, state, regional, and local levels. As it is, the management of the St. Marys is shaped
by stakeholder concerns. Below is a discussion of the framework of the political landscape that
structures management of the St. Marys Watershed. The complex layering of authorities across
agencies and state boundaries often cause disjointed management efforts within the watershed
and also provides the dynamic foundation for the potential to adaptively manage this watershed.
Federal Environmental Institutional Framework
Figure 11: Overview of Federal Legal Framework in St. Marys River Watershed
Figure 11 above depicts the general federal agencies and acts that have impacted the St. Marys
River watershed. The major federal stakeholders listed above include the Environmental
Protection Agency, Department of Defense, Department of Agriculture, Department of Interior,
and the United States Army Corps of Engineers (USACE). These stakeholders oversee the
implementation of several acts described below. The Environmental Protection Agency oversees
the implementation of the Clean Water Act (CWA), which intends “to restore and maintain the
chemical, physical, and biological integrity of the nation's waters” (United States Environmental
Protection Agency 2009). The CWA establishes requirements for recognizing and improving
impaired surface waters. This includes the development of the Total Maximum Daily Loads
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Marys
River
Watershed
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Blair, Ezell, Hall, & November
(TMDLs) and the National Pollution Discharge Elimination (NPDES) programs. In 1987
Congress amended the Clean Water Act to establish a “non-point source management program”,
recognizing the need for greater federal leadership in guiding state and local non-point source
water protection efforts (United States Environmental Protection Agency 2009).
Other influential federal legislation includes Federal Emergency Management Agency and the
National Oceanic and Atmospheric Administration’s Coastal Zone Management Act (CZMA).
The CZMA was enacted in to effectively manage, protect, and develop the coastal zones of the
United States. The St. Marys River watershed’s coastal region is oftentimes subject to stringent
regulation and rules that are aresult of programs initiated because of this act. Current and future
policy decisions related to FEMA’s National Flood Insurance Program may have considerable
impacts on the watershed. Fernandina Beach is located on the barrier island just south of the St.
Marys outlet and is a major population center within the river’s watershed. Policy changes within
the National Flood Insurance Program in the future could have a large effect on development
trends on Fernandina and the other barrier islands along the coast.
The National Environmental Policy Act is managed by the Environmental Protection Agency
under the Council on Environmental Quality. This policy requires federal agencies to apply for
and be granted permits before developing an area. These applications are called Environmental
Impact Statements, and currently the King’s Bay Naval Submarine Base located at Cumberland
Sound is the only EIS permit in our watershed.
The Department of Forestry, in collaboration with the Environmental Protection Agency, have
coordinated with both Florida and Georgia to develop similar Silviculture Best Management
Practices (BMPs). In Florida, it is suggested that silviculture operators utilize the “Silvicultural
Best Management Practices Manual”. These BMPs are developed specifically for silviculture
and are intended to be applied on all such operations in the state regardless of whether or not the
operation is subject to other regulatory standards or permits. Silviculture operations in Florida
are presumed to comply with state water quality standards as long as they voluntarily provide a
notice of intent to implement BMPs on their property and follow the other requirements
established under the Florida Administrative Code [F.A.C.] 5i-6 (DACS‐11305
2009). These
requirements include the maintenance of documentation that verifies the implementation and
maintenance of BMPs on the subject property.
The Department of Interior’s National Park Service manages a significant number of sites within
the watershed, the Cumberland Island National Seashore and the Okefenokee Swamp. Also
under the Department of the Interior, the Fish and Wildlife Service has become an influential
agency within the watershed through the passage of the Endangered Species Act and the Fish &
Wildlife Coordination Act. The Endangered Species Act can in some cases prohibit certain
activities that would cause harm to the endangered and/or threatened species and their habitats.
The addition of the Fish and Wildlife Coordination Act to the federal regulatory framework
requires the USACE to coordinate permit applications with federal and state fish and wildlife
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Marys
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Blair, Ezell, Hall, & November
agencies. This additional level of environmental protection has lead to increased assurances that
protection of wildlife will be taken into consideration when analyzing permit applications under
Section 404 of the Clean Water Act. This section regulates the filling in of wetlands and other
navigable waterbodies with dredged or fill material. This act has also been used as the primary
authority for federal wetlands protection.
Georgia Environmental Institutional Framework.
In Georgia, the state is currently in the process of developing a statewide comprehensive water
management plan (Georgia Department of Natural Resources 2002) through the Environmental
Protection Department. The process for developing this plan is diagramed in Figure 12.
Figure 12: Georgia Environmental Institutional Framework
This plan calls for the creation of Regional Water Planning Councils. The operation of each
council is defined in a Memorandum of Agreement between the council, EPD, and the Georgia
Department of Community Affairs Various state agencies and officials, including the Governor,
the DOA, and the DCA take part in nominating members for the water planning councils. These
councils have been formed in each of the 11 districts. The state has been divided the state into 11
districts, although there are 14 major river systems in Georgia, as shown in Figure 13. Many
believe that these districts have been drawn primarily for political concerns instead of being
formed in response to natural watershed boundaries. The political nature of the division related
to water transfers policy and also an emphasis on planning for future growth is demonstrated in
the plan’s executive summary- “Water resources and water needs vary widely by region, and
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Blair, Ezell, Hall, & November
future growth and development will occur differently in each region. The plan allows for these
regional differences while also providing statewide policies and management practices to support
regional planning.” (Georgia Department of Natural Resources 2002).
This division of the state into 11 districts could
have a significant effect on the future
management of Georgia rivers and the St. Marys
River watershed in particular. The St. Marys
Watershed has been split between the
Suwannee/Satilla and the Coastal Georgia
planning districts. This split causes concerns
over whether the interests of the St. Marys
watershed will be given proper consideration
when developing future water policy. For
example, the EPD is called on to develop a
Water Conservation and Implementation Plan
(WCIP).
These long-term regional water
resource management plans will include a report
from each of the regional planning councils that
will include resource assessments, estimates of
current and future water needs, and an
evaluation of management practices that will be
essential to meet the region’s needs within the
capabilities of the resources. This type of
planning based on the regional level may lead to Figure 13: Georgia Water Planning Regions
the splitting-up of the constituents of the St. Marys River watershed. This could lead to the
watershed not being properly represented in regional water management and planning.The plan
does however recognize that “all of the water planning regions border other regions or share
surface or groundwater resources with other regions; therefore, each regional planning council
will communicate and coordinate with adjacent, upstream and/or downstream councils as well as
EPD to ensure the appropriateness of the recommended management practices” (Georgia
Department of Natural Resources 2002). This acknowledgement hopefully will influence the
Suwannee/Satilla and the Coastal Georgia planning districts to communicate effectively when
developing policy that will affect the St. Marys watershed.
It is also valuable to point out that the Department of Human Resources (DHR) Public Health
Department (DPH) regulates Septic Tanks in Georgia. Septic tanks are quite prevalent along the
river banks and are a major concern as a possible source of nutrient loading as well as harmful
bacteria into the river.
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Florida Environmental Institutional Framework
In Florida, the Department of Environmental Protection (DEP) is the lead agency in state
government for environmental management and is one of the more diverse agencies in state
government, protecting our air, water, and land (Florida Department of Environmental
Protection, 2009). FDEP’s authority is diagramed in Figure 14. A few significant agencies
within the DEP are the Office of Greenways & Trails (OGT), Division of State Lands, and the
Division of Recreation and Parks. The OGT has officially designated a paddling trail along the
river, the St. Mary’s River Canoe Trail. The Division of State Lands (DSL) has acquired
numerous tracts of land within the watershed that serve as valuable wildlife corridors through
programs such as Florida Forever, the state’s acquisition program which is credited with
acquiring over 600,000 acres of land since (Florida Department of Environmental Protection,
2009). The Division of Recreation and Parks manages numerous public parks within the
watershed, including Ft. Clinch state park.
Figure 14: Florida Environmental Institutional Framework
Many of Florida DEP’s most significant responsibilities in terms of water quality are performed
within the Watershed Management Program. This program is charged with the coordination of
monitoring, data management, assessment, the state TMDL program, non-point source
management, and protecting our ground water resources (Florida Department of Environmental
Protection, 2009). The Office of Water Policy plays a key role in ensuring the effective
implementation of DEP’s responsibilities under the Florida Water Resources Act (Chapter 373,
Florida Statutes). The office addresses statewide water management issues in coordination with
the water management districts and other agencies. Examples of their work includes water plans
for the DEP and water management districts, minimum flows and levels for the state’s water
resources, and regional water supply planning and conservation. The Office of Water Policy’s
function includes working in close coordination with each of Florida’s five regional water
management districts (WMDs) and other agencies to resolve statewide water planning and
management issues. The office is also responsible for the production of the Florida Water Plan
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Blair, Ezell, Hall, & November
Annual Progress Report, updating
the
Water
Resource
Implementation Rule (Chapter
62-40, F.A.C.), preparing the
Annual Status Report on Regional
Water Supply Planning and also
with developing the Five-Year
Water Resource Development
Work Programs. Florida is
currently in the process of
adopting quantitative nutrient
water quality standards. The
process includes recognizing that
the different water bodies of the
state
contain
hydrologic
variability that naturally cause
Figure 15: Florida Water Management Districts
nutrient levels to vary. This
process,
which
is
being
developed and administered by the FDEP, has been spurred by the EPA formally ordering that “a
numeric nutrient criteria should be established on an expedited schedule.” The plan took a
positive step towards reaching this goal in March of 2009 when the FDEP submitted its “Current
Numeric Nutrient Criteria Development Plan” to the EPA. (FDEP- Development of Numeric
Nutrient Criteria for Florida’s Waters, 2009)
The DEP is also involved in managing the quality and quantity of water in Florida through its
relationship with the state's five water management districts. The districts are Northwest Florida
Water Management District, Suwannee River Water Management District, St. Johns River Water
Management District, South Florida Water Management District and Southwest Florida Water
Management District, shown in Figure 15. Chapter 373, Florida Statutes, gives the DEP
"general supervisory authority" over the districts and directs the Department to delegate water
resources programs to them where possible. These districts are authorized to administer flood
protection programs and to perform technical investigations into water resources. They are also
authorized to develop water management plans for water shortages in times of drought.
Regulatory programs delegated to the districts include programs to manage water consumption,
aquifer recharge, well construction, and also surface water management. The St. Marys River
watershed falls within the jurisdiction of the St. Johns River Water Management District
(SJRWMD).
Florida Fish & Wildlife Service’s Division of Habitat & Species Conservation and also its
Division of Fish & Wildlife Research have worked hard to accomplish many important tasks
such as Ecosystem Assessment & Restoration, and also Freshwater Fisheries & Wildlife
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Research. Their science-based approach has put additional checks on development in order to
protect species in the region. FF&WS has been quite influential in assisting local efforts,
including its current efforts in assisting the St. Marys Fisheries Restoration Committee in the
development of a plan which incorporates adaptive management approaches to habitat and
species restoration.
Local Environmental Institutional Framework
The St. Marys River Management Committee was established in 1993 as an intergovernmental
entity of appointed and elected members that meet monthly to implement plans and programs
related to the management of the St. Marys River. In 2003 with the assistance of the SJRWMD,
the SMRMC developed a management plan to guide the river’s future. This management plan
was adopted by area governments in a four-county resolution. It is important to point out that the
SMRMC has little independent power, without the support and agreement of the local county
governments. See Figure 16 for an explanation of the groups working with the SMRMC to
manage the St. Marys River.
The committee’s goal is “to
promote and protect the long
term viability of both the
environmental and economic
resources in the St. Marys in a
way that retains local control,
protects property rights, and
fosters cooperation among
individuals, governments, and
agencies at all levels.” (St.
Marys River Management
Plan, 2003) The members of
Figure 16: Groups working with the St. Marys River Management Committee to
the
SMRMC
have produce a watershed wide management plan. The dotted line represents
demonstrated their strong collaboratively produced watershed management instrumentation. To date the
dedication
to
the Committee has produced the Septic Think Tank which provided the networking
critical for the successful implementation of Watershed wide septic tank
environmental protection of setbacks.
the river through past efforts
such as the establishment of consistent setbacks for septic drainfields along the river and annual
river “clean ups”. Nevertheless, the statement of their goals also illustrates that the management
committee is responsive to economic interests, property rights issues, and the retention of local
control within the watershed. This retention of local control could turn out very positively for the
watershed, as long as local management is responsive to identified impairments.
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A positive example of how local control is working positively is the emergence of the “Septic
Think Tank”. This committee of government and private individuals dedicated to improving
septic tank regulation in the watershed is presently making positive strides towards uniform
regulation amongst the counties that will hopefully lead to a reduction in impairments caused by
septic tank failures.
On the other hand, this retention of local control could be problematic if this preference for local
control leads to a general policy leaning towards anti-regulation. This concern is why it is so
important that the SMRMC continues to take the lead in the development of progressive policies
and programs that will protect the health of the river and fill the vacuum that could have been
filled by additional state and federal regulation. The current management plan does an admirable
job of addressing most of the important issues within the watershed. In the future, it will be
essential that the SMRMC continues to update the management plan when it becomes
appropriate.
Regulatory Framework for Managing
Water Quality
The regulatory framework for water
quality management in Florida is
depicted in Figure 17. The Regulatory
framework
for
water
quality
management in Georgia is depicted in
Figure 18. Rules set by the Clean Water
Act hold the State responsible for
managing water quality.
The state
acknowledges the Clean Water Act
through the establishment of a
partnering state law.
In Florida, the
Florida Watershed Restoration Act (Fla.
Stat 403.067) is the law that supports the
Clean Water Act.
In Georgia the
Georgia Comprehensive Statewide
Water Management Plan supports the
Clean Water Act and empowers the
Georgia
Environmental
Protection
Department to enforce the Identification
of Impaired Surface Waters Rule.
Collectively the Clean Water Act and
the supporting State Law hold the State
Figure 17: Florida Water Quality Management Framework.
Figure 18: Georgia Water Quality Management Framework
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Blair, Ezell, Hall, & November
department of environmental protection responsible for enforcing management of clean water in
the State.
To identify impaired waters in each of the state’s river basins, both states departments of
environmental protection evaluates existing water quality data using the Identification of
Impaired Surface Waters Rule (IWR). The rule establishes specific criteria for defining
impairment. The IWR states that for each river basin in the state the Department will establish a
Planning List of potentially impaired waters. The IWR states that “the methodology for
developing the Planning List includes an evaluation of aquatic life use support, primary contact
and recreational use support, fish and shellfish consumption use support, drinking water use
support, and protection of human health. Data older than 10 years cannot be used to evaluate
water quality criteria for the Planning List (FDEP, 2009).” If the waters on the Planning List are
determined to be due to anthropogenic causes the waters are placed on the Verified List. The
Florida DEP must develop TMDLs for waters placed on the Verified (Water Quality Assessment
Report). If an assessed water body meets its designated use then it does not require additional
management. However, if the assessed water body contains contaminants that exceed the
standards, then the managing agency has three options: first, it can prove that management for
this contaminant is already under way, second prove that this contaminant is naturally occurring.
If the contaminant is naturally occurring or already under management then no additional
management needs to occur. However, the third option is to establish TMDLs and associated
management plans for restoring water quality.
Total Maximum Daily Loads
The Total Maximum Daily
Load (TMDL) development
process is utilized by both
states to restore water quality.
While
researching
the
regulatory framework for
water quality management it
was realized that the TMDL
process provides an excellent
basis
for
the
Adaptive
Management of Water Quality.
The TMDL process for
Georgia is presented in Figure
19 (Georgia Department of
Natural Resources, 2009). The
red boxes in this diagram
St.
Marys
River
Watershed
Figure 19: Georgia TMDL Development Process
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31
Blair, Ezell, Hall, & November
contain the common elements of
standard management protocols.
The blue boxes in this diagram
contain elements of the TMDL
process that reflect an Adaptive
Management Approach. Georgia
relies on it’s Basin Planning
Councils to synthesize management
recommendations from 4 state
agencies into a TMDL Plan. Once
this plan is implemented Georgia
relies on Watershed Protection
Measures such as permitting of
wastewater, storm water, and water
withdrawals to reduce point source
pollution.
Control of non-point
sources of pollution is left to the
stakeholders and their willingness to
voluntarily
implement
Best Figure 20: TMDL Development Process in Florida
Management Practice’s. Once these
Watershed Protection Measures are implemented continuous monitoring of their effectiveness
allows for the evaluation of management strategies. Results from monitoring and water quality
assessment feedback into TMDL development and implementation of Watershed Protection
Measures. The inclusion of monitoring, evaluation and management plan adjustment are critical
components of an Adaptive Management approach to watershed management.
Florida’s process for developing TMDL’s are presented in Figure 20 (FDEP, 2009). Once again
the elements of this management plan that reflect an Adaptive Management Approach are in
blue. Florida depends on its Water Management Districts to develop Basin Management Action
Plans. These BMAPS are developed with extensive stakeholder input. Once implemented the
effectiveness of the BMAP is monitored, evaluated, and adjustments are made if management is
not working. The inclusion of stakeholder input and the monitoring and evaluation of BMAP
effectiveness stake this is a truly Adaptive Management Approach to Watershed management.
Data Collection & Water Quality Assessment
The information presented in Figure 21 was derived from Florida’s Division of Water Resource
Management’s Water Quality Assessment Report for the St. Marys River that was conducted in
2007. Of the 364 water body segments making up the St. Marys Basin, 242 lack sufficient data
for making a water quality assessment. Of the 112 water body segments with enough data to
make an assessment, 76 are Not Impaired, 18 are Impaired and 28 are on the Planning List
St.
Marys
River
Watershed
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Blair, Ezell, Hall, & November
awaiting confirmation of
impairment. Of those 46
water body segments that
are potentially impaired
17 are due to high
mercury levels in fish and
10 are due to low
dissolved oxygen levels.
The other impairments
found are for silver,
cadmium,
BOD,
coliforms, copper, DO and
iron. In total the water
quality has been assessed
for 30% of the water body
segments in the St. Marys
Watershed.
Due to Figure 21: Proportion & Agencies collecting data in the St. Marys Watershed
insufficient data we do not
know the status of 66% of the water body
segment making up the St. Marys River
watershed. In all, 40% of water bodies with
sufficient data are impaired. The most common
causes of impairment are mercury and dissolved
oxygen levels as shown in Figure 22.
Examination of this information shows that 60%
of water bodies with sufficient data for
assessment are impaired. If this trend holds true
for the water body segments without data there
are 145 unidentified impaired water body
segments in the St. Marys Basin. Assessment of
these water bodies is of great importance for the
establishment of baseline data from which
management decisions can be made.
Figure 22: A. Water Quality Assessment status for
water bodies in the St. Marys basin. streamB.
Reasons for impairment of waterbodies on the
Verified and Planning Lists.
St.
Marys
River
Watershed
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Blair, Ezell, Hall, & November
Dissolved Oxygen
Low dissolved oxygen levels have been identified as the reason for impairment in 10 of the
verified impaired rivers. In Florida, the St. Marys River is classified as a Class III River and the
standard for dissolved oxygen under this classification any measurement of 5 mg/l or lower of
dissolved oxygen is considered impaired. Below, are two graphs taken from the Water Quality
Analysis Report prepared by the Florida Department of Environmental Protection illustrating the
dissolved oxygen trends overtime for the upper stretch of the river (Upper) and the lower stretch
(Lower) (Figure 23). There are number of sampling locations, but these are typical values seen
along the river. A number of measurements are below 5 mg/l, especially in the lower stretch of
the river. This decrease in dissolved oxygen could be interpreted as a possible spatial trend,
however in close examination of the data sets, there are some sampling inconsistencies.
Figure 23: Dissolved oxygen measurements overtime for an upper and lower section of the St. Marys River. The red
line is the 5 mg/l Class III River standard for Florida rivers. (adapted from Gehring et al. 2007).
For dissolved oxygen measurements the depth at which a sample is taken, the temperature of the
water, the air temperature, the cloud cover, as well as the time of day can all influence the
dissolved oxygen measurement. The samples for dissolved oxygen were taken by a number of
different state and federal agencies, at countless sampling locations, at various depths, and with
little to no consistencies. So, although there is a great deal of data supplied by the FDEP Water
Quality Analysis Report as well as the STORET database, one must be careful in the
interpretation. However, these data do show that this river does innately have low dissolved
oxygen concentrations, and should be managed accordingly.
St.
Marys
River
Watershed
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Blair, Ezell, Hall, & November
Impacts of Silviculture
Nearly 70% of the land in the St. Marys River Watershed is utilized by the silviculture industry.
This being known, it is important to consider the potential negative environmental effects that
this could have on the watershed. After tree removal, or cultivation, there could be increased
stream flow due to more surface water run-off as well as less subsurface water interference. This
increase flow off the land surface could bring with it excess nutrients into the stream system as
well as increased sedimentation and woody debris. A decrease in river pH has been identified
after cultivation in other river systems. River temperature may also increase due to decreased
forest cover. Roads, culverts, and trenches can lead to excess sediment being delivered to the
river, as well as intercept subsurface water flow. Excess fertilization can cause nutrient
enrichment in river systems, which cause ecosystem change. All of these possible effects of
silviculture have the potential for causing ecosystem change. This change maybe quite localized,
as much of the increased sedimentation may be a point source, and a number of these effects
only occur during cultivation. This is an important consideration during river quality
monitoring. A stretch of the river may be experiencing local effects do to activity on the
surrounding lands. This change in river characteristics may be short lived, but only necessitates
consistent monitoring along the river course.
While the negative effects listed above are just “worst case scenarios” it is important that they be
measured, especially when they are considered with the natural chemistry of the river. The St.
Marys River is a blackwater river due to the location of its headwaters in the Okefenokee Swamp
as well as the soils on the banks of
the river having high levels of
organic carbon. The river also
innately has low dissolved oxygen
levels, low pH, low nutrient
concentrations,
and
low
conductivity values.
Silviculture is the most prominent
land-use in this watershed and
must
be
considered
when
evaluating
ecosystem
health.
Contamination from septic tanks is
the largest stakeholder concern,
and point source discharge has the
potential
to
deliver
high
concentrations of nutrients and
other contaminants directly into the
river flow. These three represent
St.
Marys
River
Watershed
Figure 24 : Schematic of compounding effects of silviculture, point
source discharge, and septic tank contamination on the innate
chemical characteristics of the St. Marys River.
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35
Blair, Ezell, Hall, & November
the three most probable sources of river contamination and it is important to consider these in the
context of the fragile chemistry of this black water river. Figure 24 is a visual representation of
the compounding affects of these possible sources of contamination (in the yellow boxes) on the
river (red box). Silviculture can decrease the pH of an already low pH system. An increase
water temperature and the addition of organic debris can decrease the dissolved oxygen in the
water in already low dissolved oxygen conditions. Silviculture as well as point source discharge
can increase sedimentation into a river, which has the possibility of changing species habitat.
Point source discharge as well as septic tank contamination can lead to nutrient enrichment,
which can directly increase primary productivity, leading to a decrease in dissolved oxygen. All
of these activities can have the combined effect of exacerbating an already fragile river
chemistry.
Septic System Pollution
Septic systems are known
sources of bacteria and nutrients.
As assessments of nutrients have
already been discussed above,
here the focus is on the various
types of bacteria measured to
indicate
septic
tank
contamination of water bodies in
the St. Marys Watershed.
Fecal bacteria are a broadly
defined group of bacteria that are
commonly found in human and
animal feces.
Fecal bacteria
themselves
are
generally Table 3: Agencies sampling, characters quantified, and analytical
harmless. However, they often methods utilized for quantification of coliforms in the St. Marys River
co-occur
with
pathogenic
bacteria, viruses and protozoa that are harmful to people swimming in or eating shellfish from
contaminated waters (U.S.E.P.A. 2009). Elevated levels of fecal bacteria often result in the
degradation of water quality by causing cloudiness, smell, and increase oxygen demand. The
sub-group of fecal streptococcus, enterococcus is the most valuable bacterial indicator of fecal
contamination of recreational surface waters. Enterococcus originates only in the fecal matter of
mammals and is tolerant of both fresh and salt-water environments.
The EPA approved
Standard Method 9230C membrane filter technique may be used for fresh and saline water
St.
Marys
River
Watershed
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Blair, Ezell, Hall, & November
samples, but is unsuitable for
highly turbid waters (APHA,
AWWA & WEF 2006).
Enterococci bacteria serve as
the best indicator of health risk
associated with septic system
pollution in the recreational
waters throughout the stretch of
the St. Marys River (U.S.E.P.A.
2009). There are four agencies
reporting
quantified
fecal
associated bacteria from the St.
Marys River watershed to the
EPA’s STORET database.
Between the four agencies there
are 10 identified and 1
unidentified method utilized for
quantifying
fecal
bacteria
characters. Table 3 shows the
agency sampling, the character
sampled for and method used
for fecal bacteria in the St.
Marys River watershed.
To assess the extent of septic
tank contamination of the St.
Marys River was being
quantified those methods
utilized in the St. Marys were
compared
with
those
approved by the USEPA.
This
research
and
a
comparison of these methods
with those approved by the
EPA revealed a major
finding.
None of the
agencies collecting coliform
data in the St. Marys
Watershed are quantifying E.
coli bacteria. Furthermore,
both the Georgia and Florida
St.
Marys
River
Watershed
Character
Measured
U.S.E.P.A.
Standard
Method
Coliform
(total)
1.
APHA‐9221‐B
2.
APHA‐9222‐B
3.
APHA‐9222‐B+B.5c
Coliform
(fecal)
1.
APHA‐9221‐C
or
E
2.
APHA‐9222‐D
Fecal
streptococci
3.
APHA‐9230‐B
4.
APHA‐9230‐C
5.
APHA‐9230‐B
6.
APHA‐9230‐C
7.
APHA‐9221‐B.1
/‐F‐12‐14
8.
APHA‐9223‐B‐13
9.
APHA‐9222‐B/9222‐G‐19
/
9213‐D
Enterococci
Escherichia
coli
Table
4:
U.S.
EPA
approved
methods
for
quantifying
coliforms
in
freshwaters
Table 5: Summary of Water Quality Concerns in the St. Marys Basin.
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Blair, Ezell, Hall, & November
Environmental Protection Departments measure broader coliform groups and report them as E.
coli. Without the monitoring of E. coli bacteria septic tank contamination of the St. Marys River
cannot be confirmed, nor can the effects of septic tank setbacks be evaluated.
Assessment of the methods used for data collection showed that a major management weakness
is the lack of cooperation between agencies. A major first step in taking an Adaptive
Management approach in this watershed is for all of the agencies to agree on what they are going
to measure and use the same methods to do so. To take this a step further we recommend that
only USEPA approved methods be utilized to allow for nationwide comprehension and
comparison of data. The methods approved by the USEPA for quantification of coliforms are
presented in Table 4.
St.
Marys
River
Watershed
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Blair, Ezell, Hall, & November
Current Management
The St. Marys watershed has a high potential for providing ecosystem services including
provision of habitat for a great diversity of wildlife like the black bear and sea turtles. In our
watershed, there are rare, threatened, and endangered species that need or will soon need
protection. Two species are particularly representative in this area, the turtles and black bear.
There are six endangered turtles in estuary, inlet, and surrounding ocean waters. These turtles
use the coastal beaches at Cumberland Sound and the inlet beaches as nesting grounds. The
Florida Black Bear uses the large forested areas and surrounding rivers as it habitat. The St.
Marys watershed holds a critical portion of the greenbelt providing this habitat.
Wildlife Habitat
Currently, in the St. Marys watershed there is not a true wildlife habitat protection management
plan in place. Nassau County recently took a positive step when it hired the Nature Conservancy
to study the county’s ecology and make recommendations related to protecting the natural spaces
in the county. This type of study needs to be emulated by the other counties in the region, and
then each of them should cooperate to develop a regional plan for conservation. The fact that the
region is currently relatively undeveloped has fortunately caused less impacts to many of the
species’ habitats in the area. However, in order to protect the wildlife in this area from becoming
listed on the federally endangered wildlife list, preemptive action needs to be taken. The
watershed should be managed as a whole, functioning system.
Strategy should be developed to manage and protect the ecology of the St. Marys watershed by
integrating management of the entire system through cross-boundary cooperation. Ecosystem
management theory is one approach to accomplishing this goal. This management is basically
adaptive management applied to ecosystem where management decisions are made based on the
best available science and revised as new science is gathered. This management approach also
involves looking beyond the boundaries of the St. Marys watershed to find ecological
connections with neighboring areas. The St. Marys River corridor provides a riparian connection
to the Okefenokee Swamp as well as ecological connections between areas outside of the basin
due to the relatively undeveloped land that provide ecological connections. This is particularly
important for species (St. Marys River Management Committee 2003).
Some of these actions include: maintaining natural river flows, identifying and marking notable
intact ecosystems for important species, acquiring conservation easements, and establishing
buffers to protect wildlife.
St.
Marys
River
Watershed
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Blair, Ezell, Hall, & November
Water Quality
Both Florida and Georgia are currently in the process of assessing and restoring water quality in
their states’ water bodies. Georgia completed a State Water Plan in 2008. The emphasis of this
plan is to promote sustainable use, re-use and conservation of the water as well as to protect
against water shortages. The plan is based upon modeled projections of future water quality and
demand. Water quality improvement and management projects are funded by the Georgia EPA
and Environmental Facilities Authority. TMDL’s were completed for 20% of the St. Marys
River Basin on the Georgia side in 2008 and full restoration of water quality is projected for
2012. In comparison, the Florida Water Management Districts are charged with administering
flood protection programs, gathering research in support of water management, and developing
plans for periods of water scarcity, acquiring land to support water resource management, and
regulating water use. So their job is much broader than the water planning councils in Georgia.
Water quality has been assessed for about 30% of the St. Marys Basin as of 2007. The DEP’s
TMDL completion is planned for 2011.
Water Quantity
In Florida, water management districts assign minimum flows and levels (MFLs) to rivers.
These are the minimum water levels and/or flows assigned to a particular water body as
necessary to prevent significant harm to water resources or ecology. Three to five MFLs are
defined for each water body and may reflect the minimum infrequent high, minimum frequent
high, minimum average, minimum frequent low and minimum infrequent low (SJRWMD,
2001). The management equivalent in Georgia is 7q10 levels. This solitary level is assigned to a
particular water body and reflects the measure of minimum river flow required to protect the
ecological integrity. Technically, the 7q10 level is the historical minimum stream flow that
occurs over 7 consecutive days during a period of 10 years.
Neither Florida nor Georgia have established minimum flows for the St. Marys River. There is
little long-term gauge readings over the length of the river. Currently, the USGS monitors water
level gauges at Moniac, Georgia and Macclenny, Florida near the origination and headwaters
convergence areas of the St. Marys River. However, the USGS stopped monitoring the river
gauges downstream from Macclenny. This makes it difficult to determine the minimum flow
levels to be required from Macclenny to the mouth of the river. This area is where the greatest
potential for urban sprawl and/or withdrawals from Jacksonville may occur. Secondly, it is
difficult to develop minimum levels because these generally require an understanding of natural
fluctuations and consistent long term monitoring is essential. Thirdly, a number of TMDLs are
set based on flow rates so designating this type of TMDL may not be possible. It may make
sense to set minimum flow levels for the St. Mary under either Georgia’s or Florida’s system and
then develop uniform management based on these measurement guidelines.
St.
Marys
River
Watershed
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Blair, Ezell, Hall, & November
Floodplain Management
Floodplain management in Florida is governed by local planning ordinances and by storm water
regulations under the SJRWMD. The management district requires that there is no let loss of
storage in the 10-year floodplain. This essentially requires that there be no structures built in the
floodplain or if there are structures built in the floodplain they must be elevated on pilings. The
100-year floodplain construction is required to be above the elevation of the 100-year flood.
This is commonly accomplished through the use of clean fill mounds on which homes are built.
However, this technology compromises the function of the floodplain, because it limits the
amount of water storage on the land and forces water on to other areas. The SJRWMD is
currently working on a plain that requires all further construction in the 100-year floodplain to be
on pilings (Committee Management Plan). There are no specific floodplain management
strategies in Georgia. The 100-foot buffer under the River Corridor Protection Act does
contribute to some floodplain regulation. However, the regulation in this act is quite limited
when compared to what is required in Florida. Both states participate in the National Flood
Insurance Program (NFIP), which requires some construction limitation. This is primarily done
through the use of rate map, which delineate specific at risk areas. However, these maps are
quite outdated and may not reflect current and especially future high-risk areas (Committee
Management Plan). There is further protection under NFIP known as the Community Rating
Service program. This is an incentive program, which can lower the flood insurance premiums,
in some cases up to 45%. This program does have required floodplain regulation to which the
counties have to comply. Neither Georgia nor Florida currently participates in this program.
St.
Marys
River
Watershed
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Blair, Ezell, Hall, & November
Recommendations for an Adaptive Management Approach
Under the current management scheme the future of the St. Marys Watershed in its current state
is uncertain. The major hindrances to the success of the current management process are the lack
of coordination between management groups and the lack of an organized effort for data
collection and analysis. Without these two key changes it is impossible to determine how the
increase in development will affect water wildlife habitat and quality and quantity. Nor can we
properly estimate the impact of global warming and rising sea levels have on the estuarine
systems. Due to this shortfall we are unprepared to identify the causes of ecosystem degradation.
Following are some recommendations for improving the current management efforts in the St.
Marys. The recommendations are in part based upon the core aspects of the Adaptive
Management process.
Monitoring
Both of the states have agencies that are collecting water quality data. The lack of coordination
between these agencies in the St. Marys Basin results in spatial and temporal data gaps and
inconsistencies in analytical methodologies. These agencies are commonly measuring the same
constituents and the sampling locations can overlap. Money and time is being wasted with these
uncoordinated efforts. We recommend that an effective monitoring program be established to
coordinate the two states’ efforts. Such a program would include harmonizing TMDL’s as well
as the coordination of water sampling methods, location, and timing. We suggest the adoption of
EPA approved laboratory procedures for the quantification of contaminants to allow consistent
interpretation of data. Implementation of a coordinated monitoring program will allow for the
establishment of baseline water quality data and provide needed information for model
development and management decision-making. We find that a base line for both water quality
as well as quantity is essential for the future of this watershed. With the potential for growth in
development of this area, it is very important to evaluate the impact and without a starting point,
this is nearly impossible. Proper collection of baseline data and monitoring of management
effects will allow the identification of sources of degradation to the river system.
Buffers
In order to sustain the wildlife habitat and scenic beauty in the St. Marys, minimum buffer
widths should be implemented along the river and its tributaries throughout the watershed to
prevent degradation due to increased development and land and water use changes. The Center
for Watershed Protection has indicated that a minimum of a 100 ft buffer is essential to provide a
water body with the protection it needs to maintain water quality. (Shueler, T.R., and Holland,
H.K. (editors), 2002). The St. Marys watershed should follow the example of jurisdictions that
have established plans for wildlife habitat corridors. (Hillsborough County, 2006). For example,
in Hillsborough County they have established wildlife habitat corridors by utilizing the
St.
Marys
River
Watershed
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Blair, Ezell, Hall, & November
methodology established by UF’s center for wetlands “Wekiva River Basin Buffer Study.”
(Brown, 1989). This study suggested a science-based methodology focused on targeting
significant species of animals and plants and then evaluating their buffer requirements to ensure
their protection. (Brown, 1989) For wetlands, it is recommended by some experts that the buffers
be a minimum of 322 feet and can increase to over 550 feet with no development. In the estuary
areas, some studies of similar areas have recommended that the buffers be at least 322 feet with
no maximum width established. Buffers of these widths would provide more than adequate
protection for the wildlife in these areas (Brown 1990).
The SMRMC has already made positive steps by implementing 100 foot buffers along the river’s
edge for septic drainage fields. These buffers do not actually prohibit the building/development
in this area, but only these drainage fields; therefore, they do not provide adequate protection for
ecology in the area. If these buffers were increased to 100 feet for both Florida and Georgia and
prohibited all development in these zones, they would begin to provide more adequate ecological
protection.
Silviculture buffers based on Best Management Practices are currently in place and range from
35 feet in the tributaries to 200 feet along the main stem of the river. However, these buffers do
not completely prohibit the harvesting of trees within these areas. After additional scientific
analysis is completed regarding the adequacy of the silvicultural buffers included in each state’s
BMPs, consideration should be given to adjusting the width of these buffers to reflect all
ecological considerations, including wildlife habitat. In addition, increasing the buffers
throughout the entire stream to 100 feet would moderate stream temperatures and prevent woody
debris from entering the river. 200 foot buffers provide effective sediment removal, and 350 foot
buffers will provide protection for habitats and nutrient retention.
Administration through Interstate Cooperation
Throughout the history of the United States there have been many legal battles fought over
watersheds that cross state boundaries. Although the St. Marys presents no imminent threat of a
conflict between Georgia and Florida, the watershed will benefit from proactive management
decisions that will provide a unified “vision” for this unique transboundary watershed. As part of
this “vision”, management efforts in the St. Marys River Watershed could greatly benefit from
increased interstate coordination to induce consistent management from one riverbank to the
next. While the Supreme Court or Congress are often forced to intervene in decisions related to
shared water bodies, in this type of adversarial setting at least one party will become unsatisfied
with the results. By acting while the river remains relatively healthy, both states may be able to
develop an agreement that will dictate future management policy in a manner acceptable to both
parties.
The complexity of the mechanisms for this type of agreement can range. On one end of the
continuum, a simple “memorandum of understanding” between the EPD and DEP could result in
St.
Marys
River
Watershed
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Blair, Ezell, Hall, & November
increased cooperation amongst the two states at the state level, in the same way that the SMRMC
operates on the county level. On the other end of the continuum, an “interstate compact” could
provide a durable and responsive framework for management issues within the watershed
through a unique regulatory program with federal oversight. Any agreement could also fall
somewhere in between these poles. What is most important is that any arrangement fits the
unique attributes of the watershed and represents a collective vision among stakeholders.
It would be essential that an initial “advisory group”, composed of key stakeholders and state and
local government officials, reexamine the substantive issues in the watershed based on this
adaptive management assessment and propose a structure that could effectively implement
management solutions. (National Center for Interstate Compacts (NCIC), 2009) Fortunately, the
formalization of an interstate agreement has already gained momentum through the efforts of the
SMRMC, supported by the University of Georgia and University of Florida. Stakeholders who
expressed concern over the proposed strategy of designating the St. Marys as an Outstanding
Florida Water under Florida law expressed interest in instead pursuing an interstate agreement,
including a compact. Since “interstate compacts” represent a common form of interstate
agreement, it may be beneficial to examine what a compact between Georgia and Florida for the
St. Marys might look like, how interstate compacts are created, and the different ways that they
can be structured.
An interstate compact between Florida and Georgia would be a contractual agreement that would
create uniform policy to protect the St. Marys River watershed. (NCIC, 2009). It would allow
both states to develop a management structure for interstate cooperation that fits the particular
attributes of the St. Marys watershed. This sort of compact would be considered a “regulatory or
administrative compact” (NCIC, 2009), under one taxonomy. Regulatory or administrative
compacts often require the consent of congress to become effective because the regulations may
impact one of congress’ enumerated powers. (NCIC, 2009). However, congressional approval is
not required of all compacts, only those that increase a state’s political power and encroach on
federal authority. The process of forming the interstate compact requires that one state adopt the
terms of the compact into law through enacting legislation. If the terms of the compact are
deemed acceptable to the other party state, it can then choose to adopt the same terms into its
own law (NCIC, 2009). Once the states have “adopted identical compact language” the
agreement becomes effective (NCIC, 2009).
While the process of developing an interstate compact can be arduous and sometimes takes
decades, in many cases it can be the most effective answer to current and anticipated water
conflicts. (NCIC, 2009). A St. Marys interstate compact need not be complex. It could begin
simply and then be amended or modified as necessary to meet newly arising demands and
pressures within the watershed. (NCIC, 2009). A positive characteristic of a potential compact
would be that both Florida and Georgia would be able to develop harmonized rules and
regulations for the watershed that could be adapted as necessary without the need to go back to
St.
Marys
River
Watershed
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Blair, Ezell, Hall, & November
the legislature each time for approval, subject to the authority legislatively delegated by the
terms of the compact (NCIC,2009). However, the interstate compact would have disadvantages
as well. For example, the requirement that any regulatory language be substantially similar may
affect current law in one state or the other. (NCIC, 2009). Using a compact as an adaptive
framework, each state’s rules and regulations could continuously be adjusted to reflect a adaptive
watershed approach to the management of the river in two states.
There are three different possibilities as at to how the institutional framework for this compact
could be structured:
(1)The compact could create a brand-new multi-state governmental authority/
“commission” to administer the compact.
(2 ) The states could utilize an existing local institution, such as the St. Mary River
Management Committee, to administer the agreement.
(3) The states could choose to forgo the establishment of any type of “commission” and
instead could develop uniform standards, which both Florida and Georgia would
implement individually within their current regulatory framework. The additional
administrative duties that would emerge as a result of this compact could be taken on by
existing agencies within Florida and Georgia that would be charged with coordinating the
effective management of the compact.
If the states chose to develop a brand-new multi-state governmental authority/ “commission” to
administer the compact, the process would certainly be expensive and complicated. It would be
necessary to clearly establish:
- How the commission would be funded, since a commission would most require at least
some staff;
- Strict financial monitoring procedures for the commission;
-The commission’s scope of authority and the type of enforcement mechanisms/power
they would possess;
- The rulemaking procedures of the commission;
- Whether the commission would be subject to the Administrative Procedures Act (APA);
- How the commission would ensure that each state complied with the terms of the
compact;
- Clear guidelines that would control whom would serve on the Commission and how the
composition of the commission would be properly balanced between each state.
Even if a new “commission” were not formed, it would still be essential to determine:
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- How each state would administer the compact and provide resources to coordinate
management;
- What agencies would be involved in the compact;
- If Florida and Georgia could develop a uniform management regime amidst constantly
evolving statewide management plans;
- Who would be responsible for developing lobbying, educational, and training materials
to ensure public awareness and compliance.
Due to the expense and arduous process connected with forming a new commission it may make
sense to utilize an existing local institution, such as the St. Mary River Management Committee,
to administer the agreement. By utilizing this established local institution as the management
entity, the difficulties and costs associated with forming a new “commission” could be avoided
while taking advantage of the procedures/structure that have already been developed by the
SMRMC. This type of structure for the compact may also make sense because it would continue
the tradition of retaining local participation in management of the St. Marys watershed by
continuing to emphasize each of the four county’s role in management. Nevertheless, because
the SMRMC is a voluntary organization, it would still be worthwhile to establish at least one full
time person to serve as staff to the SMRMC for purposes of implementing the agreement.
Issues that may be Included within Interstate Compact
- Septic Tank Regulations and Setback Requirements- The “Septic Think Tank” is
currently developing recommendations. These recommendations could be in the compact.
- Common Protocols for Water Monitoring/ Sampling- This part of the compact would
provide the framework for an agreement between the two states to effectively exchange
information and technical support. The collaboration that would result from an interstate
compact on the St. Marys could reduce the costs associated with managing the watershed
by creating economies of scale that can more effectively address problems than efforts by
either state on its own (NCIC, 2009). Please see this paper’s section on monitoring for
further suggestions.
- Uniform Water Quality Standards- In order to effectively utilize the common protocols
for monitoring/sampling, it is essential that both states establish uniform water quality
standards. The two states should collaborate to establish uniform numeric criteria,
including nutrients, that reflect the unique characteristics of this watershed. A vital step
in accomplishing this goal would be to make sure that officials from the EPD, DEP, both
the Suwannee/Satilla & Coastal Georgia water planning councils, and the SJRWMD are
taking part in the process from the beginning. Please see this paper’s section on water
quality for further details.
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Conclusions
The St. Marys Watershed system, including managing agencies and stakeholder groups, are on
the path to taking an Adaptive Watershed Management Approach. Stakeholder groups are
engaged and are willing to explore management alternatives. The Total Maximum Daily Load
development process in place for both Florida and Georgia includes emphasis on stakeholder
involvement, data collection, and evaluation of management effectiveness. Collectively, these
situations form a strong foundation from which an Adaptive Watershed Management approach
can be built. However, for the St. Marys River, to be successfully managed into the future there
must be greater coordination between both governance and data collection agencies. Both States
must work together to harmonize TMDL’s and other regulations, based on the specific needs of
the river along both banks. Data collection agencies must work together to develop a rivermonitoring plan that includes timing and location of sampling as well and utilization of EPA
approved analytical methods. While these recommendations may seem daunting, it is our
opinion that coordination of agency efforts and the installation of an effective monitoring regime
will be more cost effective than the current strategy and provide better protection than the current
management strategies.
The implementation of Adaptive Management requires a clear set of goals to be set for the future
state of the river. These goals must be decided on by federal, state, and local authorities, as well,
and arguably most importantly, by the local stakeholders and users of this ecosystem. With
constant, effective, and coordinated monitoring the path towards these goals can be followed or
changed if that is required. To accomplish this most effectively an interstate agreement, which
could be a compact, that guides future use of water and land use in the watershed, is
recommended. We believe that the St. Marys has nearly all the tools in place to accomplish this.
The St. Marys River Management Committee, composed of representatives from the four main
counties, stakeholders, and landowners in the watershed, all volunteer their time to make
decisions in the best interest of this watershed. They would undoubtedly be one of the most
important and effect means for facilitating the formation of an interstate agreement or compact.
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