Written Testimony on Ordinance No. 2011-072111-02 Aquifer Protection
Jefferson County Board of County Commissioners July 21, 2011 Jefferson County, Florida
Chairman Fulford and members of the Jefferson County Board of County Commissioners, the International Bottled Water Association (IBWA) and the Southeastern Bottled Water Association (SEBWA) appreciate the opportunity to provide written testimony on Ordinance Number 2011- 072111-02. This ordinance proposes amendments to the Jefferson County Land Development Code in an attempt to provide additional protection for land and groundwater resources within the Aucilla/Wacissa River Ecosystem.
IBWA and SEBWA understand and support the need for Jefferson County to preserve and protect its land and water resources, and we support sound land and groundwater management policies, laws and regulations that are comprehensive, science-based, multi-jurisdictional, treat all users equitably, and balance the rights of current users against future needs in order to provide and protect sustainable resources.
However, we respectfully oppose Ordinance No. 2011-072111-02 sitting before the Board of County Commissioners. The proposed changes to the Jefferson County Land Development Code specifically and unfairly single out bottled water and establish a very stringent set of requirements for land use approvals. These requirements are obviously not based on either the potential impact of a withdrawal on the land or the resource, both of which should be standards for approval. There is no evident hydrogeological, scientific, or resource sustainability basis for these provisions. In contrast, these provisions base the sustainability of the land and water resources solely on the type of user versus actual withdrawal or environmental impacts. From the perspective of land and water development and management programs, the bottled water industry should be treated no differently than other users. Ordinance 2011-072111-02 clearly does not meet this test. To single out the bottled water industry from other land and water users will not further the sustainability of Jefferson County’s land and water resources, and is not in the best interest of the County’s residents and visitors.
The bottled water industry uses a de minimus amount of groundwater to produce an important consumer product, and does so with great efficiency. According to a 2005 study by the Drinking Water Research Foundation (DWRF), annual bottled water production accounts for less than 2/100 of one percent (0.02%) of the total groundwater withdrawn in the United States each year. This is the equivalent of a half-gallon bottle filled with water from a 20,000 gallon Olympic-size swimming pool. Based on additional information gathered in the DWRF study, 87% of the water withdrawn by bottled water companies in 2001 was, on average, actually bottled for consumption by humans. The bottling
1700 Diagonal Road, Suite 650 Alexandria, VA 22314 Ph: 703-683-5213 Fax 703-683-4074 Web: www.bottledwater.orgIBWA/SEBWA Written Testimony on Ordinance No. 2011-072111-02 July 21, 2011 Page 2 of 4
process is therefore a very efficient one. When comparing the amount of groundwater used by other industries with the 0.02% that is used by bottled water companies on an annual basis, it becomes very clear that any attempt to manage groundwater resources must focus on all users and not target any one industry. The sustainability of aquifers and other water resources is not determined by who uses the water, but by how much is being withdrawn.
Because a long-term sustainable supply of high-quality water is quite literally the foundation and “lifeblood” of our industry, we fully recognize the critical importance of environmental conservation and stewardship of all land and water resources. Be assured that IBWA and SEBWA members employ environmental conservation and stewardship practices when using and managing Florida land and groundwater resources. This is achieved, in part, through the use of monitoring wells and environmental assessments of sources to help ensure both the quantity and quality of the source. IBWA and SEBWA members are particularly active in groundwater protection programs, and are also often participants in local/regional water stewardship partnerships on aquifer protection. Criticism of the bottled water industry in water management debates is not based on the science or hydrology of water withdrawals by our industry, and is a misguided and misinformed attempt to block water use while setting the stage for a wider attack on other commercial, industrial, and agricultural users.
States ultimately have primary jurisdiction over their land and water resources, and must effectively manage those important resources to ensure that they will be sustainable. IBWA and SEBWA believe that in order to ensure sustainable land and water resources, a comprehensive management approach must be taken. IBWA and SEBWA support the reporting of withdrawals for all groundwater users, and establishment of regulatory frameworks to evaluate the impact of all commercial/industrial water users. To this end, the bottled water industry has been a strong and vocal supporter of comprehensive groundwater management legislation and regulations enacted in recent years in Maine, Michigan, New Hampshire, Pennsylvania, Vermont, and Wisconsin. In these states, the bottled water industry actively supported programs requiring permitting of large quantity groundwater withdrawals that ensures a science-based approach to evaluating potential impacts of all water withdrawals.
Some of the comprehensive groundwater management statutes and regulations the bottled water industry has supported have required a higher standard of approval for the bottled water industry than for other users of the same resource. The bottled water industry has accepted these standards in order to provide a foundation for a predictable future for the industry. For proof of this close to home, we strongly encourage the Board of County Commissioners to review the bottled water industry’s active and cooperative involvement with the Suwannee River Water Management District for nearly a year beginning in late 2008 as the District worked to develop and implement updated regulations for the permitting of water use and a new water use permitting guide. The District’s balanced consideration of all stakeholders’ views and opinions, including the bottled water industry, resulted in the adoption of a new rule set that is both equitable and judicious, while not restricting commerce. We encourage the Board of County Commissioners to pursue similar approaches to manage land and water use. In all instances the bottled water industry, not only in Jefferson County but throughout the state of Florida, will abide by the parameters of all respective Water Management Districts with regard to water usage.
Bottled water is not a luxury item, but rather a safe, healthy, convenient food product that consumers choose because of its refreshing taste, and because it is an excellent way to stay hydrated. Reports on America’s declining health are in the headlines almost daily, and many consumers choose bottled
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water as a healthy beverage alternative or mainstay. For these reasons, any actions that discourage the production and use of this product are not in the public’s best interest. And the bottled water industry is always at the forefront of relief efforts during natural disasters and other catastrophic events such as hurricanes, wildfires or terrorist attacks. Florida has, of course, not been immune to such disasters. Targeting the bottled water industry with an ordinance such as this would be an ironic disservice to and poor public policy for an industry that is called upon every year to provide crucial drinking water to the citizens of Jefferson County.
Over the last few years, Florida and the nation have felt the devastating toll of a weakened economy, plummeting home sales and a stagnant job market. Jefferson County has also experienced the same and while signs of recovery are imminent, it is likely to take several years before they are fully realized. Any proposal that would have a negative impact on jobs will only prolong this economic malaise. This ordinance will directly influence existing and potential jobs for Jefferson County and the state of Florida which has a strong commitment to the bottled water industry. While it is vital that businesses, communities and government do all they can to protect natural resources and the environment that we co-exist with; they also must support a vibrant and growing economy to ensure the necessary resources are there to provide the finances, manpower and ideas to make preservation a reality.
If Jefferson County finds the need to implement systemic and long-term changes to improve the environmental impact of goods production, as well as management of the county’s natural resources, be assured that IBWA, SEBWA and our members stand ready to work with you. But we ask that any related efforts not specifically target the bottled water industry. To that end, we ask the Board of Commissioners to soundly reject Ordinance 2011-072111-02.
Thank you very much for your consideration of our testimony, and please feel free to contact IBWA or SEBWA if you have any questions or would like to discuss this issue further.
James P. Toner, Jr. Director of Government Relations IBWA
Allen Wankat President SEBWA
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The International Bottled Water Association (IBWA) is the trade association representing all segments of the bottled water industry, including spring, artesian, mineral, sparkling, well, groundwater and purified bottled waters. IBWA represents bottled water bottlers, distributors and suppliers throughout the United States, including several small, medium and large size companies doing business in Florida.
The purpose of the Southeastern Bottled Water Association (SEBWA) is to provide its members with information to enhance industry knowledge, category growth, and operating efficiencies. The Association should be viewed as a resource in promoting greater levels of awareness for government relations, quality control, technical advancements, and public relations.
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Companies in Florida that manufacture, distribute and sell bottled water products employ as many as 8,800 people in the state, and generate an additional 26,640 jobs in supplier and ancillary industries. These include jobs in companies supplying goods and services to bottled water manufacturers, distributors and retailers, as well as those that depend on sales to workers in the bottled water industry. These are good jobs, paying an average of $40,710 in wages and benefits. Not only does the manufacture and sale of bottled water create good jobs in Florida, but the industry also contributes to the state’s economy as a whole. In fact, in 2009 the bottled water industry was responsible for over $5.44 billion in total economic activity in Florida. Furthermore, the bottled water industry generates sizable tax revenues in the state, with the industry and its employees paying over $214.7 million in property, income and sales taxes.