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March 12, 2008


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Mayor Asks EPD Director To Remove City From Level 4
Commerce has made an official request to be exempted from water restrictions forced upon 61 drought-stricken counties in Georgia.
In a letter to Dr. Carol Couch, director of the Environmental Protection Division, Mayor Charles L. Hardy Jr. presented the city’s argument that since its water supply was never imperiled by the drought last fall that it should be exempted from the state level 4 requirement.
“A Drought Contingency Plan was approved in November 1998 that established procedures to be followed when the reservoir reached certain pool elevations,” Hardy wrote. “This was based on the expected yield of the reservoir during low flow conditions. The drought plan was modified in November 2007 to more closely follow the EPD Level 2 and Level 4 outdoor water use guidelines. The plan activates with restrictions (Level 2) when the reservoir drops 1.0 foot from full pool, then a drop of 2.0 feet will activate mandatory restrictions (Level 4). As previously stated, during this drought period the reservoir only dropped 0.8 feet.”
Hardy also pointed out that the city reservoir was able to help Jefferson and Jackson County at the worst of the drought.
“The city’s ability to provide water to the surrounding communities was very evident when the City of Jefferson’s reservoir dropped critically low as well as the Bear Creek Reservoir which serves the JCWSA (Jackson County Water and Sewerage Authority). The provision of water to these systems averaged 0.9 mgd. The production at the treatment plant still only reached 50 percent capacity.”
Then, the mayor explained why the city wants out of the restrictions, noting that expansions of the water treatment plant and the wastewater plant since 1996 have left the city with a debt service of $13 million.
“The ability to pay this obligation is very dependent on the water sales for the system,” he wrote. “Any reductions in water sales will greatly affect the financial status of the city.”
Hardy also reported that officials met in late January with water officials from Toccoa, Lavonia, Royston, Carnesville, Comer, Banks County, Madison County, Franklin County, the Broad River Soil and Water Conservation District and the State Soil and Water Conservation agency.
“All parties represented were located within the Savannah-Upper Ogeechee River Basin,” he told Couch. “No jurisdiction represented had any difficulty in supplying water to their respective customers during the 2007 peak drought.”
Hardy asked that the city be allowed to manage its reservoir under its drought contingency plan “in lieu of the mandated state restrictions.”
“We will be glad to host another meeting with other Savannah-Upper Ogeechee River Basin water providers and invite you or our representative to attend and hear first hand our concerns about a ‘one size fits all’ solution to the state’s contingency plan,” he concluded.
The mayor also sent a copy of the letter to Rep. Tommy Benton.



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