Recently, the Jacksonville District of the U.S. Army Corps of Engineers (Corps) issued a notice soliciting public comments regarding the St. Johns River Water Management District’s (SJRWMD) permit application to withdraw an average of 10 million gallons of water a day (MGD) from the South Fork of Black Creek. The water would be pumped a distance of about 17 miles and discharged into Alligator Creek, which flows into Lake Brooklyn.

The Black Creek Water Resource Development (WRD) Project is being sold to the public as a restoration project for the Keystone Heights Lakes. However, the SJRWMD website describes it as a  North Florida Regional Water Supply Plan project “to help meet future water supply demands…” that offers no guarantees that it will improve water levels in the lakes.  With no limits on future withdrawals, this project lacks a true water conservation component to protect our aquifer and lakes and will likely be used to justify additional groundwater pumping down the road.

Black Creek, a major tributary to the St. Johns, is one of the healthiest waterways in the Lower St. Johns River. Removing an average of 10 MGD threatens not only the health of the South Fork, but also Black Creek and the St. Johns. Unfortunately, there are many potential unintended consequences that may result in negative impacts to these important waterways.

In addition, the $41 million project is being funded through Amendment 1, the Florida Land and Conservation Initiative that was intended primarily for the purchase of conservation lands, not for water supply projects.

We are highly concerned about the following potential impacts to Black Creek and the St. Johns River.

  • Loss of Critical Habitat and Negative Impacts to Endangered Species and Local Fisheries
  • Water Quality Degradation – loss of natural water pollution filters including wetlands and submerged aquatic vegetation
  • Loss of Natural Forested Floodplain and Flood Protection

The Army Corps of Engineers underscores our concerns, concluding as part of their initial review that “the flow of South Fork of Black Creek, and, hence, downstream waters would be impacted. Therefore, our initial determination is that the proposed action might have an adverse impact on EFH (Essential Fish Habitat) or federally managed fisheries in Black Creek, the St. Johns River, and/or the Atlantic Ocean.”

In addition, transfer of black, tannin water from the South Fork to the aquifer and Keystone Heights Lakes may present water chemistry challenges that have not been fully vetted. 

Thank you to the people that submitted comments regarding this project to the Army Corps by the November 2018 deadline

To view the comment letter submitted by St. Johns Riverkeeper, click here. We are still waiting to hear from the SJRWMD if a public meeting will be held. 

Comments and Questions regarding this project? Please contact your St. Johns Riverkeeper, Lisa Rinaman, at