Glades: “no longer reasonable…viable”
Given the state of Georgia’s recent statements about the project, it’s hard to see how this project moves forward. Then again, if Hall County agrees with the state that Glades could function as a flow augmentation project, then the project would be teed-up to receive state direct investment and construction grants. And the project would be a card in Georgia’s ‘water wars’ hand.
At any rate, the project as currently proposed is a sinking ship because the Georgia’s Environmental Protection Division says so explicitly.
Here’s how GRN commented:
“Because everyone makes history, these comments contribute to a critical moment: this is the first major reservoir project in the state of Georgia to undergo a full environmental impact and assessment review. Reservoirs are major projects with significant impacts on communities and the environment. GRN advocates for the EIS process and asks the Corps to consider additional reviews for all major reservoir projects in Georgia because of their individual and cumulative impacts.
Regarding the Glades Reservoir proposal, we ask the Corps to deny Hall County’s Section 404 permit application in light of recent actions by the State of Georgia and because of outdated and flawed population and water demand data.
The project plan has changed five times since 2007—from a small community amenity lake to a massive pump storage project specifically to serve Hall County. Most recently, in November, 2015, the Georgia Environmental Protection Division (EPD) intimated that the Glades Reservoir proposal may yet again transform into a ‘multiple purpose‘ project of state significance, and thus serve a need beyond Hall County.
EPD has also declared, in official comments submitted regarding the Apalachicola-Chattahoochee-Flint Water Control Manual (dated January 29, 2016): ‘given the revised 2050 needs projections…it is clear that Glades reservoir is no longer part of any strategy to meet the water supply needs of the State through 2050.’ EPD further stated, if Hall County’s ‘population projection through 2050 [had] not decreased as drastically as contained in the new Office of Planning and Budget’s projections, there may have remained some additional water supply need for Hall County from Glades Reservoir.’ But because of the population projection decline, ‘the State can say unequivocally that Glades no longer remains part of the region’s 2050 water supply strategy.’ Additionally, the state asserts: ‘as contemplated in the Glades DEIS’ and the Apalachicola-Chattahoochee-Flint Water Control Manual DEIS, Glades ‘is no longer reasonable or even viable.’
The Governor’s office has likewise publically questioned the validity of population projections utilized by consultants and applicants all over the state. And as the Savannah District is no doubt aware, EPD has explained that while the ‘State will be working with Hall County on a revised certification of need, the old certification of need provided by EPD Director Jud Turner on April 9, 2013 is outdated’ and was ‘rescinded’ on January 22, 2016.
The Governor’s Office of Planning and Budget’s 2002 population projections lined up remarkably well with actual US Census counts until 2009 when the projections and actual population diverged dramatically. (View graph) OPB’s 2010 projections were off by a wide margin, but OPB’s 2015 projections and US Census estimates appear more closely aligned. Hall County and Gainesville building permit data reveals relatively steady development between 2000 (1,619 permits issued) and 2005 (1,489). But after 2007, the number of issued permits plunged from 1,229 to a 2012 total of 261 permits issued. Water consumption declined in Hall County from a high in 2000 of 139 gallons per capita per day (gpcd) to around 100 gpcd in the depth of the 2007 drought before bottoming out at 93 gpcd in 2009, according to Metro North Georgia Water Planning District data.
Despite anemic growth and reduced water consumption, Hall County continues to pursue the Glades reservoir. Estimates of total cost—which are historically inaccurate—for the 850 acre lake top out at $300,000,000 with a projected 36 to 72 million gallons per day yield.
Because Hall County has changed Glades’ purpose so many times and in the face of a mounting tab, Hall County needs a bailout. To finance this project, Hall County has turned to the Governor’s Water Supply Program (GWSP).
In 2013, the Georgia Environmental Finance Authority (GEFA) re-wrote the scoring criteria for the second round of the GWSP. The biggest change eliminated the first and key threshold question that was asked of all projects in 2012: ‘Does the applicant(s) demonstrate a need for new water supply through 2050?’ According to directions in the 2012 scoring criteria, ‘if the applicant does not demonstrate such a need, the applicant earns a zero for’ the ‘Proposed Approach’ criterion. In other words, the 2013 criteria stripped a key qualifying question that was responsible for a number of projects rating a zero for need in 2012. In 2013, applicants did not have to identify the need; they only had to indicate ‘the need is significant.’
In 2013, GEFA also allowed GWSP applicants seeking state direct investment (SDI) to revise and resubmit their applications based on new criteria that identified a project’s significance to the state. Hall County’s SDI application requested $14,599,000 and suggested the county might pay off some of the reservoir’s debt with a flat annual fresh water fee of $70 per tax parcel—regardless of size or value—levied on each of county’s approximately 75,000 tax parcels for at least fifteen years.
In 2014, GEFA worked with a consultant to determine what asset the state could acquire with SDI in Glades. GEFA originally anticipated a one-year process in 2014 whereby the consultant would provide “consulting services for evaluating the state’s interest in three reservoirs.” The selected consultant was to be tasked with validating reservoir impacts, hydrologic analyses on a watershed scale, and costs. Plus, the consultant was going to ‘provide assistance in evaluating options for the state’s entitlement share through utilization of modeling results and other information.’
GEFA has placed this validation and evaluation exercise on hold, and GEFA continues to evaluate Hall County’s $14,599,000 SDI request as the project navigates the federal environmental impact statement process.
Special Permit Conditions
Finally, the Corps has included very limited information regarding special permit conditions that could be included and required of the applicant. The DEIS does not specify how many years a conditional permit will be valid. We cannot support the proposed special permit conditions. Section 404 permits are valid for five years and extensions are possible.
We ask the Corps to deny Hall County’s Section 404 permit application in light of recent actions by the State of Georgia, and because of outdated and flawed population and water demand data.”