DNR Comments on draft Surface Water Regs of 2011
The flawed definition of "Safe Yield" within the State Surface Water Withdrawal Act is described by the South Carolina DNR in their comments to DHEC dated Sep 26, 2011.
The DNR comments speak to draft Surface Water Withdrawal Regulations under review in 2011 following passage of the Act in 2010. Click link below for a PDF copy of DNR's comments... The critique of "Safe Yield" begins at the 3rd page and related streamflow graphs are provided on the last two pages; and DNR points include: 1) "safe yield" will not be available in most streams more than half the time, 2) "safe yield" presents unrealistic, high values, which are not available during dry periods, and 3) "safe yield" will not adequately protect natural resources .
Also, addressed (on the 2nd page) are DNR's concerns with the "Minimum Instream Flow" definition, to include: 1) the definition does not adequately take into account additional water needed for downstream withdrawals; and 2) the defined standard (20-30-40 MADF) may not always be appropriate, so flexibility is needed to set minimum flow standards.
