Groundwater Supply Assessment and Section 404 Permitting for Water Supply Reservoirs
Renner, James R.
Crawford, Thomas J.
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Upon review of permit applications submitted to the Savannah District of the U.S. Anny Corps of Engineers for construction of water supply reservoirs, it appears that groundwater supply has been assessed inadequately. The Environmental Protection Agency is directed to recommend denial of a Section 404 permit application if the proposed activity is not the least environmentally damaging practicable alternative. In consideration of a water supply reservoir permit application, the typical water supply alternatives include: 1) no action; 2) conservation; 3) groundwater; 4) increased withdrawal from streams; 5) various alternative reservoir sites; 6) upland storage lagoons; and 7) various redistribution schemes. Generally, installation of groundwater wells is a non-water dependent activity with minimal direct impact to the aquatic environment Therefore, unless the applicant shows that groundwater is not a practicable water supply alternative, a reservoir permit application may be denied on the basis that groundwater wells are less environmentally damaging. There are two steps involved in assessing the practicability of any water supply alternative (and they must be performed in order): 1) Determining the potential availability; and 2) Identifying economic and logistical factors pertinent to utilization of the resource. This paper describes errors in methodology and interpretation in the groundwater availability assessments prepared for eight reservoir permit applications. Steps necessary for adequately evaluating groundwater availability are then discussed.