District Plan Would Further Reduce Silver Springs Flow

The flow of Silver Springs, a major source of fresh water for the St. Johns, has declined by over 32% since the 1930's. Yet, the St. Johns River Water Management District (SJRWMD) recently announced a plan, called a minimum flows and levels (MFL), that will allow another 10 million gallons of water a day (mgd) to be withdrawn from the aquifer that feeds the springs, paving the way for more water for Sleepy Creek Ranch. This would result in an additional 2.5% decline in the flow of the Silver Springs, despite flows that have already been below the proposed MFL for 15 of the past 16 years. 

The SJRWMD estimates that the historical decline in flow is mostly due to suppression from submersed aquatic vegetation (SAV) and long-term rainfall deficit.  The agency claims that groundwater pumping is only responsible for about 3.5% of this decline.  At a recent public workshop in Ocala, Dr. Robert Knight, director of the Howard T. Odum Florida Springs Institute in Gainesville and president of the Silver Springs Alliance, described the SJRWMD's explanations for the decline as "ludicrous" and said the proposed MFL is "an embarrassment to the water district."

Since they project that the withdrawal of an additional 10 mgd would reduce flows below the MFL by 2025, the District plans to artificially recharge the aquifer with treated wastewater and captured stormwater.  Nitrate-Nitrogen concentrations in Silver Springs are 25 times higher than historic levels. This "prevention strategy" would potentially add to the nutrient pollution that has already degraded the springs and aquifer.

The bottom line is that this MFL will not protect Silver Springs and the Silver River and prevent further degradation. 

Recent news coverage of this issue:

Robert Knight: The true price of green grass, The Gainesville Sun 3.23.17

Crowd pushes back against water agency, Ocala Star-Banner 3.16.17

Water agency OKs reduced flow for Silver Springs, Ocala Star-Banner 3.13.17

You can find the proposed MFL on the District's website.  To comment on the proposed MFL, send an email to SilverSpringsMFL@sjrwmd.com

The SRJWMD Governing Board will decide upon the proposed MFL at its April 11 meeting. 

You can also send individual emails to the Board members:

John Miklos, Chairman                     jmiklos@sjrwmd.com
Fred Roberts Jr., Vice Chairman       froberts@sjrwmd.com
Chuck Drake, Secretary                    froberts@sjrwmd.com
Ron Howse, Treasurer                      froberts@sjrwmd.com
Doug Bournique                               dbournique@sjrwmd.com
John P. Browning Jr.                         John.Browning@sjrwmd.com
Douglas Burnett                                dburnett@sjrwmd.com
Maryam Ghyabi                                mghyabi@sjrwmd.com
Carla Yetter                                       cyetter@sjrwmd.com

Anne Shortelle, Executive Director ashortelle@sjrwmd.com

Does Dredging Make Economic Sense?

photo credit: NOAA

St. Johns RIVERKEEPER continues to have the following concerns, regarding the proposal to dredge the last 13 miles of the St. Johns River channel from 40-feet to 47-feet deep:

  • The environmental impacts to the river have been significantly underestimated.
  • The proposed mitigation plan does nothing to offset the damage from dredging.
  • The economic and environmental risks have been ignored or downplayed.
  • The projected economic benefits have been dramatically overstated.
  • Relevant information and facts have been excluded from the analysis and/or public debate.  

To learn more about the proposed dredging issue click here

While St. Johns RIVERKEEPER is primarily focused on the potential environmental impacts, the economics of the project are obviously extremely important to the decision-making process and the degree to which the community is willing to accept adverse impacts to the St. Johns.

Recently, new information was released by Dale Lewis, a retired logisitics expert, who has been conducting an independent analysis of the economics of the proposed dredging of the St. Johns.  The results of this extensive work support our position that the economic benefits have been significantly overstated by Jaxport and their consultants.

While Dale served on the Riverkeeper Board from 2000 - 2004, he has not conducted this analysis on our behalf. Dale has put in hundreds of hours of his own accord due to his interest and expertise in logistics, concerns as a taxpayer, and of course, his concern for the St. Johns River.  Here are some of his key points.


  1. We will still be a prosperous port.
  2. Jacksonville is successful today, in the Automotive, Breakbulk, Chemical, Dry Bulk, Steel, Lumber, Poultry, RoRo and Puerto Rico container trades.
  3. None of these trades requires water over 40 ft deep. The Corps of Engineers has said that these trades do not benefit at all from deeper water.
  4. The port’s planning documents show that these trades are expected to grow jobs by over 20% from 2020 to 2035.
  5. Jaxport’s documents show that these “no-dredging” trades are worth $100 to $150 Million per year in tax revenues, for more than 25 years, with no deep-dredging required.
  6. And there are additional potential container opportunities, as ship designs change...


  1. No. Maersk has recently built 16 new “shallow draft” ships of 8,600 TEU capacity, drawing just 39 feet of water.(Jaxport is 40 ft)
  2. These ships have shallower draft and 10% better fuel economy than previous ship designs.
  3. Maersk built these 16 new vessels, investing $2.2 Billion, so they could more-efficiently serve the Europe / Brazil market.
  4. As an ocean carrier, Maersk also invested over $1 Billion into Brazilian port improvements and has established a training school for Brazilian dock workers and ship’s officers.
  5. Why would Maersk do this? Because producers and shippers have created a market for goods, and have looked to Maersk to move the goods.
  6. Ocean carriers will build the vessel capacity needed to support shippers who want to serve valuable markets. If investment is also needed on shore, they’ll do that, too.
  7. Don’t give up on fully-loaded 8,600 TEU ships coming to Jacksonville, without dredging.
  8. Don’t assume that the ship designs of tomorrow will look like the designs of today; we could benefit greatly from changes in new, more-efficient container ship designs.


  1. First, we invest a total of about a billion dollars. (Dredging is just one part of the overall cost.)
  2. This creates a huge cash-flow requirement.
  3. To reach its cash-flow goals, Jaxport’s plan requires 100% container growth in the first 9 years after dredging.
  4. This would be a huge, rapid change; over the last 3 to 5 years, Jaxport’s container business has grown 1% per year.
  5. Jaxport’s growth plan is 1 Million TEU’s per year (55%) higher than the Army Corps of Engineers’ demand estimate.
  6. This additional 55% growth would have to come from taking 1 Million annual TEUs of market share away from ports in other states, on top of delivering a 3% base growth rate.
  7. The Florida Ports have predicted this level of growth in a long succession of 5-year plans since 1998, yet no Florida port has ever done half this well. To emphasize, Florida’s container ports have not yet reached the annual container volume forecasted in the 1998 Five-Year plan.
  8. From 2003 to 2015, a time when cargo was leaving West Coast ports and actively looking for a home in the East, Florida ports actually lost container market share. Savannah captured 100% of the southeastern market share gains.
  9. Miami, Savannah and Charleston have a path forward in which they can each protect all of their market share for Far Eastern cargo.
  10. Miami’s deep dredge is completed; Savannah and Charleston are moving ahead.
  11. Savannah and Charleston can see a day when they are out of capacity; they have committed to jointly building a new container port on the Savannah River, with state money, on dredge spoil land, exempt from the Corps’ economic analysis process.
  12. The environmental permit process for the new Savannah port has officially begun, 10 years before the need becomes critical, positioning Savannah for continued success.
  13. To the West, Mobile is growing stronger, and is in the process of capturing WalMart’s newest Import Distribution center, bringing WalMart to a total of 6 Import DCs in the USA.
  14. Jaxport proposes a very ambitious plan, one never accomplished by a Florida port.
  15. The markets to the North, South and West of us are protected by strong competitors. Their advantages include much more than water depth.
  16. To succeed, Jaxport would have to capture a much larger share from these ports than it does today, capture it quickly, make sure that it grows and then hold on to it for more than 25 years.
  17. This level of competitive performance would be more than triple anything ever accomplished by any Florida container port.
  18. It takes a billion dollars to make the attempt.
  19. Do you really believe that Jaxport’s most aggressive sales projection ever, 100% growth in 9 years, will come true? That’s what it would take.  It’s hard for me to believe.


  • Long-term, excess regional container capacity, with 3 strong East Coast competitors, making it difficult for Jaxport to capture market share at the aggressive pace shown in the plan.
  • Overstated local benefits for container jobs, payrolls, and tax revenues. 
  • Cost overruns, which tend to be underestimated in large projects.  Read this Florida Times-Union article about how the Army Corps has routinely underestimated the costs of dredging over the last 50 years. 
  • Decision-making without a published economic valuation forecast for the port’s other trades if they were pushed aggressively, including: Automotive, Breakbulk, Chemicals, Petroleum, RoRo and Puerto Rico containers. None of these trades requires water over 40 ft deep. 

In order to help facilitate a more informed decision on the proposed dredging, Dale has been meeting with elected officials, local business leaders and members of the media to share his findings.  We are hopeful that Dale's efforts will lead to a robust community dialogue and more honest assessment of the pros and cons of this project. 

With a pricetag of nearly $1 billion (once cranes and required infrastructure improvements are included) and the future health of the St. Johns River on the line, we can't afford to get this decision wrong. 

Recent articles:

Ron Littlepage: We need deeper dive on the numbers for the dredging, Florida Times-Union 3.7.17

Analyst: Jaxport may not see the economic impact projected with deepening the St. Johns River, Jacksonville Business Journal 3.6.17

In August 2014, St. Johns RIVERKEEPER released a paper, "Does the Deep Dredge Make Economic Sense for Jacksonville?", to help the community make a more informed decision regarding the proposed dredging. "Based on the assessments of industry experts, key performance data, and a comparison of the infrastructure and competitive attributes of other East Coast ports, Jacksonville does not appear to be a viable contender as a first-in, last-out port of call. When the irreversible damage that is likely to occur to the St. Johns River is taken into consideration, it makes it even more difficult for Jacksonville to justify such a massive expenditure of public resources."

Also, read UNF Professor Dr. David Jaffee's assessment of the economic realities of this controversial project - JAXPORT AS AN URBAN GROWTH STRATEGY: COMMUNITY IMPLICATIONS AND PROSPECTS.  

Activate the St. Johns River

Activate the St. Johns River

From March 18 to April 2, 2017, paddling trips, eco-tours, and other opportunities to experience and explore the St. Johns River and its tributaries will be available throughout the river’s watershed.

Join one of the scheduled events or plan your own outing with your friends, family, or organization.

By getting out on the water, we will:

  • Raise awareness of the wonders of the St. Johns and the pollution problems that threaten our river’s future.
  • Provide opportunities for the public to experience the wildlife, beauty, and special places of the river.
  • Showcase the tremendous recreational and economic opportunities provided by the St. Johns.
  • Highlight businesses that depend on the St. Johns and the economic benefits of a clean and healthy river.
  • Demonstrate strong public support for protecting and restoring our river.
  • Send a powerful message to our elected leaders that we must Save the St. Johns.
  • Have fun exploring one of our state’s most important waterways!

 By activating the St. Johns, we can make a powerful statement about the river’s importance, while introducing new audiences to the wonders of this magical waterway.

Click here for a flyer that you share with your friends, family, and colleagues.   Read this letter to our partners, if you are interested in organizing or hosting an event as part of the Save the St. Johns - Activate the River campaign. 

Visit www.savethestjohns.org for more information about scheduled outings and trips throughout the watershed. 

Petition Filed to Challenge Sleepy Creek Lands Permit

JANUARY 9, 2017




Palatka, FL – St. Johns Riverkeeper, Florida Defenders of the Environment, Silver Springs Alliance, and Ocala resident Alice Gardiner jointly filed a petition today for a formal administrative hearing to contest the issuance of the Sleepy Creek Ranch Consumptive Use Permit (CUP) for an 84% increase in its water allocation.  Click here to read the petition. 

Two years ago, the St. Johns River Water Management District (SJRWMD) staff recommended denial of the permit request based on anticipated adverse effects on spring flows and a determination that an "increase in allocation of 1.12 mgd of groundwater is not consistent with the public interest...."

On December 12, 2016, the SJRWMD reversed its decision and now recommends issuing the permit based on a new version of the Northern District Model, a large-scale scientific model used to establish minimum flows and levels for waterways. A recent peer-review of the new version of the model indicated that the model is proprietary and uses non-peer reviewed code, preventing members of the public from being able to verify the results and validate its use.

The petitioners are seeking an administrative hearing to challenge the appropriateness of the model, along with the assertion that Sleepy Creek Lands provided reasonable assurances that the proposed withdrawals would not cause harmful impacts to Silver Springs and the Silver River and that the project is in the public interest.

A rally to demonstrate opposition to proposed permit will still take place at the St. Johns River Water Management headquarters in Palatka on Tuesday, January 10. While the SJRWMD Governing Board will not take a vote on this harmful permit on Tuesday due to the petition, citizens are encouraged to attend to voice support for our springs and rivers at the rally and during the public comment period at the meeting.

Tuesday, January 10, 2017 10:00 AM
SJRWMD Headquarters
4049 Reid Street, Palatka 32177

Sleepy Creek Lands Back For More

Sleepy Creek Lands Back For More Save Silver!

Sleepy Creek Lands (formerly known as Adena Springs Ranch) and its the Canadian billionaire owner, Frank Stronach, continue to seek consumptive use permits (CUPs) from the St. Johns River Water Management District for a massive 3-phase cattle operation located in the springshed to Silver Springs.

Despite widespread public opposition, Sleepy Creek Lands received approval in 2015 for 1.46 million gallons of water a day (MGD) for Phase I of the project. Now, the applicant is seeking an 84% increase. They want an annual average of 2.68 MGD of water and daily maximum of 9.57 MGD.

In response, St. Johns Riverkeeper, Florida Defenders of the Environment, Silver Springs Alliance, and Ocala resident Alice Gardiner jointly filed a petition on Monday, January 9 for a formal administrative hearing to contest the issuance of the Sleepy Creek Ranch CUP.   Click here to read the press release and learn more about this legal action. 

The SJRWMD Governing Board was scheduled to vote on the CUP request at its upcoming meeting on Tuesday, January 10.  Due to the petition, the permit has been removed from the agenda.  

However, a demonstration and press event is still being organized by St. Johns RIVERKEEPER, Florida Springs Council, Silver Springs Alliance, Sierra Club Suwannee-St. Johns Group, Putnam County Environmental Council, and Florida Defenders of the Environment at the SJRWMD offices in Palatka to show support for Silver Springs and opposition to the Sleepy Creek Lands permit request. 

Tuesday, January 10, 2017 10:00 AM
SJRWMD Headquarters
4049 Reid Street, Palatka 32177


  • Average flows at Silver Springs over the past decade are already reduced more than 35% compared to historic levels.
  • • The SJRWMD previously determined that groundwater pumping has been over-allocated in this area. Models predicted that existing permit uses combined with the Sleepy Creek Lands allocation would reduce the flow of Silver Springs by approximately 80 cfs or 50 million gallons of water a day.
  • Silver Springs currently suffers from nitrate-nitrogen concentrations more than 25 times higher than historic levels.
  • The state developed a pollution reduction goal (TMDL) that calls for a 79% reduction of nutrients going into Silver Springs and the Silver River from existing sources. 


  • The requested groundwater withdrawals of 978 million gallons per year will further reduce the flow of Marion County’s springs, according to the SJRWMD Technical Staff Report (TSR).
  • The 9,500 head of cattle planned for Phase I would produce an estimated 158 million gallons of manure and 11 million gallons of urine per year. The irrigated grass would require about 700,000 pounds of nitrogen from fertilizer annually.
  • Nutrient-rich waste created from the cattle manure and fertilizers is likely to reach nearby surface waters and the groundwater that ultimately discharges from Silver Springs. This would only exacerbate existing nutrient pollution problems in Silver Springs and the Silver River.
  • While this CUP for an additional 1.22 MGD will be for a shorter duration (2017-2023), it is the camel’s nose under the tent and elevates the applicant’s rights to water as an existing user. This will make it easier for Sleepy Creek to renew groundwater withdrawal permits in the future and opens the door to potential surface water withdrawals from the Ocklawaha River.


  • The Technical Staff Report (TSR) for the permit originally recommended a Substantive Denial due to a projected reduction in the flow of Silver Springs by approximately 80 cubic feet per second, adverse impacts to riparian floodplains and the in-stream channel, potential for land collapse, and reduction in aquatic fauna and habitat.
  • On December 12, 2016, the District staff revised the TSR and now recommends issuing the permit. 

 Contact the St. Johns River Water Management District Governing Board members and Executive Director and ask them to deny the Sleepy Creek CUP request (Application #91926-4).   The Board will vote on Tuesday, January 10 on the permit. 

John Miklos, Chairman                    jmiklos@sjrwmd.com
Fred Roberts Jr., Vice Chairman      froberts@sjrwmd.com
Chuck Drake, Secretary                   cdrake@sjrwmd.com
Ron Howse, Treasurer                      rhowse@sjrwmd.com
Doug Bournique                               dbournique@sjrwmd.com
John P. Browning Jr.                         John.Browning@sjrwmd.com
Douglas Burnett                               dburnett@sjrwmd.com
Maryam Ghyabi                               mghyabi@sjrwmd.com
Carla Yetter                                      cyetter@sjrwmd.com

Anne Shortelle, Executive Director ashortelle@sjrwmd.com

Click here for the factsheet. 

Check out more coverage, St. Johns staff urges approval of Sleepy Creek water request, Gainesville Sun, December 29, 2016.

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District Plan Would Further Reduce Silver Springs Flow
Does Dredging Make Economic Sense?
Activate the St. Johns River
Activate the St. Johns River
Petition Filed to Challenge Sleepy Creek Lands Permit

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