St.

Johns River
Water Management District
Hans G. Tanzler III, Executive Director David Dewey, MaiUand Service Center Director

601 South Lake Destiny Road, Suite 200 Maitland, FL 32751 (407) 659-4800 On the Internet at floridaswater.com.

January 11 . 2013 Andreyev Engineering Inc Attn: Nicolas Andreyev 4055 St Johns Pkwy Sanford FL 32771 RE: Consumptive Use Permit Application 2-083-129419-1 Adena Springs Ranch, Marion County, Florida

Dear Mr. Andreyev: Thank you for the electronic submission of your response to the District's Request for Additional information letter dated December 29,2011. We have reviewed the response and have determined that additional information is needed in order to complete the application .. The information requested below is required by District Rule Sections 40C-2.101 and 40C-2.301, Florida Administrative Code (F.A.C.). Specifically, the following information is needed: 1. The Supplemental Application for Commercial/Industrial Type Uses requires applicants to provide a flow chart (schematic diagram) depicting the flow of all sources of water, their use and eventual discharge (see page CI-1, #4,). In your response, you reference Attachment F in response to this requirement. While Attachment F describes use of the source of water (Upper Floridan Aquifer) it does not contain a flow chart or schematic diagram depicting the flow of water through the Meat Processing Plant. Please provide the required diagram. Please note that the diagram must show the flow of water starting from the source (well) through all the processes and the ultimate discharge. [40C2.301(4)(a),(b),(e), F.A.C.; Sections 4.2,9.0, 10.3(a),(b),(e), A.H.] 2. Please describe in detail how the proposed maximum monthly use was determined for all proposed uses of water. [40C-2.301(4)(a)(b)(d)(e), F.A.C.; Sections 4.2,9.2,9.4, 10.3(a),(b),(d),(e), A.H.] 3. In various places within your submittal, you reference several proposed maximum day and maximum month usage. For example, on the Supplemental Application Form for Commercial/Industrial Types Uses, you propose a maximum
- - - - - - - - - - - -GOVERNING BOARD VERO BEACH

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lad Daniels, CHAIRMAN

JACKSONVILLE

John A. Miklos, VICE CHAIRMAN

ORLANDO

Douglas C. Boumique, SECRETARV

JACKSONVIUE OCALA

Maryam H. Ghyabi, TREASURER

ORMOND BEACH

Chuck Drake
ORLANDO

Richard G. Hamann
GAINESVlUE

George W. Robbins

Fred N. Roberts, Jr.

W Leonard Wood .
FERNANDINA BEACH

Adena Springs Ranch January 11, 2013 Page 2 Application No. 2-083-129419-1

day use for the Meat Processing Plant of 0.120 mgd (see page CI-1). On the Supplemental Application Form for Agricultural Or Aquacultural Type Uses, you propose a maximum day use for pasture irrigation of 21.57 mgd (see page AG-4) and a maximum day use for livestock watering of 0.414 mgd. It is unclear as to whether there is any other anticipated maximum day usage for the project. To clarify all maximum day needs for the project, please provide a single table showing all anticipated average day and maximum day usage for the project by use type. In addition, please modify Table 1 to include a column that shows anticipated maximum day withdrawal by well. [40C-2.301(4)(a),(b).(e), F.A.C.; Sections 4.2. 9.0, 10.3(a),(b),(e), A.H.] 4. Please specify whether you plan to operate all 34 center pivot systems at the same time for a 24-hour period. If not, please indicate the maximum number of systems that will be operated at the same time and indicate the maximum number of hours that the maximum number of systems will be simultaneously operated. Please note that, if all the systems are operated concurrently for a 24hour period, the maximum potential withdrawal based on the rated capacity of the wells equals 64.54 mgd. [40C-2.301 (2)(b), (4){a)(b)(d)(e), F.A.C.; Sections 4.2,9.2, 9.4, 10.3(a),(b),(d),(e), A.H.] 5. Please demonstrate that the proposed maximum daily use will not cause an unmitigated adverse impact on an existing adjacent land use. [40C-2.301(5)(a)2., F.A.C.; Sections 4.2, 9.4, A.H.] 6. Please demonstrate that the proposed maximum daily use will not cause interference with existing legal uses of water. [40C-2.301(2){b), F.A.C.; Sections 4.2, 9.2, A.H.] 7. The requested irrigation allocation appears to be based on irrigating 3852.6 acres. However, the irrigated acreage is not consistent between all submitted documents. For example, Table 5 of Attachment M indicates the irrigated area is 3869.7 acres, the proposed pasture irrigated area in the application form (page AG-4) is 3868.65 acres, and Table 1 of the Nutrient Management Plan (Attachment K) indicates the irrigated pasture area is 3732 acres. Please clarify the proposed number of irrigated acres and revise your submittal accordingly. [40C-2.301(4)(a),(b),(e), F.A.C.; Sections 4.2, 9.0, 10.3(a),(b),(e), A.H.] 8. In Appendix E - Irrigation Management Plan of the Nutrient Management Plan (Attachment K), it is stated that the SJRWMD is developing an irrigation management plan for Adena Springs Ranch. Please be advised that SJRWMD is not developing such a plan for this project. Therefore, as part of your water conservation plan required by section 12.5.7, A.H., please submit an irrigation management plan for the proposed project and revise Appendix E accordingly.

Adena Springs Ranch January 11,2013 Page 3 Application No. 2-083-129419-1

[40C-2.301(4)(a),(b),(e),(k), F.AC.; Sections 4.2,9.0, 10.3(a),(b),(e),(k), 12.5.7 A.H.] 9. Please submit a well table for the project. The table must include the information required on Table 1 of the Permit Application for Consumptive Uses of Water for all existing and proposed wells. [40C-2.301(4)(a),(b),(e), F.A.C.; Sections 4.2, 9.0, 10.3(a),(b),(e), AH.] 10. Please provide a detailed description of the source of power for the proposed wells. [40C-2.301 (4)(a),(b),(d) F.AC.; Sections 4.2,9.0, 1O.3(a),(b),(d) AH.] 11.ln Attachment P, you indicate that the implementation of a lower quality water source is economically infeasible. Please provide documentation demonstrating that the use of a lower quality water source in place of groundwater will make the proposed cattle operation economically infeasible (e.g., will cause the operation to be uncompetitive with similar operations). As part of this analysis, please provide the following information: a. Projected annual cash flows and rate of return on investment b. Projections of annual operating revenues, by source/type of revenue c. Projections of annual operating expenses by category/type of expense, including the delineation of expenses associated with water supply d. Projections of annual capital costs in project level detail with funding sources and useful life estimates, including the delineation of water supply costs e. Projections of annual volumes by type of product to be supplied/produced f. Analysis of historical, current, and projected market pricing for each type of product to be supplied/produced g. Identification of key assumptions, including annual operating cost escalation factors, capital funding assumptions, product assumptions (Le. pounds of product per head of cattle), etc. h. Identification of all historical/current capital costs in project level detail with funding sources and useful life estimates not included in the projected future annual capital costs, including the delineation of water supply costs. [40C-2.301(4)(f),(g), F.A.C.; Sections 4.2, 10.3(f),(g) AH., as to all subparts] 12. The following requests pertain to the "Alternative Water Source Feasibility Analysis" contained in Attachment P: a. It is stated that the cost for the 34-well UFA supply system is $1. 7M ($50,000 per 12" well). This seems low and not all-inclusive. As this

Adena Springs Ranch January 11, 2013 Page 4 Application No. 2-083-129419-1

selected option is the basis for comparison to the other options, additional detail is needed. Please provide the basis for, and an itemized breakdown of, the estimated construction costs, including proposed diameter, depth, and capacity of wells; pumps; power (e.g., electrical) supply system; instrumentation and control components; emergency power supplies if applicable; and piping connections to the pivot system. b. Reference is made to capital costs, e.g. for the proposed 34-well ground water supply system and for the alternative water source options. Capital costs should include construction costs and non-construction costs such as design, permitting, operations labor, energy consumption, maintenance, parts replacement, and repair costs. The cost estimates provided do not include non-construction cost components, which can be significant when comparing options. Please provide either a life-cycle based cost comparison, or a separate construction-only cost with an estimate of an annual O&M cost, for the 34-well system and for each of the options. c. With reference to routing of a water transmission main, the Option A route for the transmission line from the Ocklawaha River is approximately 7 miles from the SR 40 bridge to the southern property boundary of Adena Springs Ranch. Please provide details on whether an alternative route was considered from the CR316 bridge location, which is apprOXimately 5 % miles from the eastern, and more central, boundary of the ranch property. d. A pivot operation plan is needed to define the hydraulic requirements of the irrigation supply system. For Options A and B, a transmission line is proposed from the river to the storage pond and a trunk line is proposed from the pond to serve the pivot systems. Please provide details on the criteria used for sizing these pipeline segments, including how the pivot systems are proposed to be operated and an estimate of average day and max day flows. In describing the pivot operational plan, please address whether the trunk line needs to meet full demand flows as it reaches the northern pivots at the end of the system. If it is determined that pipe sizes should be revised based on how pivots are to be operated, please provide a revised cost estimate. e. Sizing of storage ponds is related to the number of acres of irrigable area. The cost estimates for Options A, B, and C indicate a 2,100 acre irrigable area. In other project documents, the irrigated area is described as 3,853 acres. Based on the information provided, the storage pond appears to be sized for 88 million gallons. Please clarify the discrepancy for irrigated area and provide detail on the criteria used for sizing the storage pond,

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e.g. one possible criterion to define would be the number of days supply for a specified average or max day demand. f. For Options C, D, and E, please provide details on the pivot operation plan related to flow capacities and watering schedule for the acreage to be irrigated, and the associated criteria used for sizing pipelines, pump stations, and storage ponds.

g. On the aerial maps for the various options, please check the scale shown and if correction is needed, please resubmit revised aerial maps. [40C-2.301 (4)(f),(g), F.AC.; Sections 4.2, 10.3(f),(g) A.H., as to all subparts] 13. The groundwater modeling outputs and other related information from the sensitivity analysis indicate that the proposed withdrawals from the project alone will cause a projected drawdown of up to 1.8 feet in the Surficial Aquifer System within the property boundaries and up to 0.8 feet in off-site areas. The cumulative impact conditions within the Surficial Aquifer System indicate a potential drawdown of up to 2.4 feet within the property boundaries and up to 1.3 feet of potential drawdown outside the project limits. Please provide documentation and analyses demonstrating that potential environmental harm will be reduced to an acceptable amount. The analysis must identify and quantify those specific wetlands and other surface waters (both on and off-site) affected by the potential consumptive use and demonstrate how harm has been reduced to an acceptable amount. It must also include a discussion of the types of wetlands, surface waters, and ecological communities that are present and the extent to which the ecological functions of these systems will be affected by the proposed consumptive use because of any predicted water level reductions.. In addition, please provide graphics at a scale sufficient to identify individual ecological communities overlaid with the groundwater modeling drawdown contours. [40C-2.301(4)(e), F.AC.; Sections 4.2,9.4, 10.3(e), AH.] 14. Please submit a proposed environmental monitoring plan. The monitoring plan must include proposed monitoring adequate to verify potential impacts both on and off the project site. [40C-2.301(4)(e), F.AC.; Sections 4.2,9.4, 10.3(e), AH.] 15.ln your submittal, you conclude that there are minimal and/or no changes in flow predicted to occur at any springs other than Silver Springs as a result of the proposed project. However, the sensitivity analysis you provided indicates changes in spring flow to nearby springs of nearly 19%. Furthermore, evaluation of monitoring well data has provided a local scale indication of measurable drawdown from groundwater pumping in the vicinity of other nearby springs (Le., Orange, Camp Seminole, and Magnesia). Please demonstrate that any potential environmental harm to the springs listed in your submittal (see your Attachment

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F) will be reduced to an acceptable amount. [40C-2.301 (4)(d), F.AC.; Sections 4.2, 10.3(d), A.H.] 16. Please provide documentation demonstrating that the proposed water use will not cause the level of a water table aquifer, the potentiometric surface level of an aquifer, or the water level of a surface water to be lowered below a minimum level which has been established in Chapter 40C-8, F.AC., or cause the rate of flow of a surface water course to be lowered below any minimum flow which has been established in Chapter40C-8, F.AC. [40C-2.301(5)(a),5.,6., F.A.C.; Sections 9.4.6,9.4.7.] 17. The following questions pertain to the DSV Consulting report which was included with your submittal as Attachment O. Please note that District staff may not agree with all of the conclusions contained within the report. However, it was determined that the following additional information regarding the report is needed. a. On page 32 and in Table 1, you state that "beginning with the rating curve number 2, (February 27, 1947), spring pool elevation, along with UFA elevation, were used as independent variables in the German (2010) discharge rating curves." Please note that spring pool elevation was not used by the USGS as an independent variable in computing spring discharge for publication prior to Water Year 2003 (September 2002). The German 2010 report was developed by the District to provide a consistent discharge data set for Silver River MFL analyses, but does not invalidate the use of Sharpes Ferry well head data alone as a variable prior to 2003 as a rating method. Consequently, the conclusion on page 35 that the "rating curve comparison suggests that the hydraulic capacity of the spring vent (sic) system has decreased in recent years" may not be warranted without a review of the original USGS ratings. Please address this issue and revise your conclusions as appropriate. [40C-2.301(4)(d), F.AC.; Sections 4.2, 10.3(d), AH.] b. Please clarify throughout Attachment 0 what discharge datasets, USGS or German, have been used. For the analysis of the rating curve changes, the German rating curves are used; however, this is not consistent throughout the report. The double mass curve analysis uses the USGS data while the rating curve analysis uses the German data. [40C2.301(4)(d), F.A.C.; Sections 4.2, 10.3(d), A.H.] 18. District staff has reviewed the information, data and results from the two Aquifer Performance Tests (APTs) performed on the property. Based on this review, we conclude that the information, data and results of the APTs are insufficient to provide reasonable assurances that District consumptive use permitting criteria

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will be met. Re-analysis of the data from the existing APTs using a numerical groundwater model may provide insight and yield additional information; however, intensive review of the data collected to date indicates that additional APTs are warranted. Therefore, please perform additional APT(s) that will provide information, data and results adequate for use as a basis of evaluation for providing reasonable assurances in demonstrating that District consumptive use permitting criteria will be met. An APT plan must be submitted for review and approval by the District prior to performance of the tests. Specifically, staff has concluded that the existing APTs contain the following errors or omissions that must be addressed. APT Report Well #21 Attachment G (Also Appendix A of Attachment F) a. Please provide the field data for this APT. The three "background" wells shown on Figure 2 all experienced drawdown from the APT. Please provide an evaluation of the suitability of these wells as background wells. If the wells are not suitable, please designate them as additional monitoring sites and identify and provide the data for an appropriate background well. b. Drilling information discussed in Sections 2.0 and 3.0 indicated that the shallow monitoring wells SW-1 , SW-2, and SW-3 were drilled before any of the deeper wells. These wells are screened within a clay layer and, therefore, would show limited or no response during the APT. The driller's log for Well #21 indicates a sand layer exits immediately below the clay horizon that wells SW-1, SW-2 and SW-3 were screened into. The reported groundwater table at the time of the APT was below the top of the clay layer. Please address the effects that the construction of these wells had on the interpretation of the APT. c. The RAI narrative indicates that Attachment G addresses ponding that was observed by SJRWMD staff during the APT, and the subsequent response in the shallow monitoring wells, particulaily SW-1 ; however, these issues were not addressed in Attachment G. Please revise Attachment G to address these issues accordingly. In addition, please review the hydrograph for all of the shallow monitoring wells and address the potential effects of the ponding that was observed. d. On page 5, it is reported that the Avon Park formation was not penetrated because Scott (1988) indicated it was of "low permeability". Assuming you are referencing to Scott's publication on the Hawthorn Formation, Mr. Scott does not discuss the Avon Park formation in that document. Such an observation is also inconsistent with the NCF groundwater model you used and relied upon in Attachment F, and also with the USGS Mega-

Adena Springs Ranch January 11, 2013 Page 8 Application No. 2-083-129419-1

Model that includes this area. Please provide support for this conclusion.
-1

e. The reported leakance value of 3.12 E-9 day is not considered plausible, indicating significant issues with the interpretation of the APT results. As a point of reference, the head differential between wells SW-1 and MW-1 at the start of the monitoring program on March 18,2012, is approximately 17.8 feet. Using the reported leakance and head differential of 17.8 feet, recharge to the UFAS would be estimated to be 0.0002 inches/yr. SJRWMD estimated recharge for 2005 for this same region is estimated to be between 8 - 12 inches/yr. Please review all input parameters used in the calculation, and if the results remain the same, please provide a rationale for the apparently low rate of recharge. As part of any reassessment, please provide appropriate leakance values for this area. f. Please provide supporting information for the selection of aquifer thickness (restrictive layer thickness (70 tt in the analytical solutions used in evaluation of the APT data.

g. Analysis of the step-drawdown test in Section 11.2 indicates that drawdown in the pumping well due to aquifer losses was 0.82 tt at a pumping rate of 2,400 gallons per minute at the end of the step-drawdown test (six hours). This result conflicts with the reported drawdown shown on Figure 4 for monitor well MW-2, which is located 49 feet from the pumped well. At the end of the step-drawdown test, there is shown to be approximately 2.2 feet of drawdown. Because the water level in a monitoring well is not influenced by well losses, it is not plausible to have greater drawdown in a distant monitoring well than experienced in the pumped well. Without having the field data to review and analyze (requested above), the APT results as presented are unacceptable and are considered unreliable. Please review the input parameters and assumptions utilized in the well loss analysis, and if warranted, revise them. If the results remain unchanged, please provide an alternative explanation that would allow for less drawdown at the pumping well than at the observation well(s).

APT Report Well #83 Attachment H (Also Appendix A of Attachment F)

h. The APT appears to lack acceptable background monitoring wells. The 4inch "background" well mentioned in Section 1.0 was not used as a background well. The data provided indicates this well experienced drawdown during the APT. There were also water level data for Well #21 during the APT for Well #83, but there was no discussion of this well, or depiction on the Figures. That well also experienced drawdown during the APT. Please provide an evaluation of the suitablility of these wells as

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background wells and/or designate them as additional monitoring sites. Please also identify the location of these wells and indicate why these wells were not used as part of the APT analysis. i. The drilling and logging programs discussed in Section 2.0, 3.0 and 4.0 do not discuss the 11-ft voids encountered in the drilling of the UFAS monitoring wells MW-1b and MW-2b from 173 to 184 bls, although there was no void found in the test production well. Please address the effect of the observed field condition on the execution and analysis of the APT. The same reference to Scott (1988) appears on page 5 of Attachment H. Please provide support for this conclusion (see request d. above).

j.

k. Section 5.1 references flow data collected during the tests, but such data were not provided. Please provide this data. Figure 4 indicates more drawdown during the first failed APT than the final test. Please provide an explanation for this. There are also appears to be a data and/or plotting error on Figure 4 for monitoring well MW1 b for the first failed test. The data indicates a decline in water levels at this well of 1.39 feet between 10:15 and 10:30. As a comparison, well MW-2b, which is reported to be 49 feet closer to the production well, experienced a decline of 0.01 feet. Please review the water level data and provide an explanation for the abnormal decline that was observed. I. In Section 10.1, the observed drawdown in the two shallow monitoring wells was discussed, and is shown on Figure 5. The two wells respond differently at the start of the failed test, but react almost exactly the same at the end of the data collection period. Please discuss why the character of the water level plots for the two shallow monitoring wells changes at the start of the first failed test, relative to pretest conditions and during the test.

m. A review of the monitoring data provided indicates the water level record for the 4-inch UFAS well experienced a short (27 minute) pumping influence approximately 37 minutes prior to the end of the pumping period of the APT. The available data for those wells suggests that the length of the APT was insufficient to utilize these wells as part of the analysis. Please explain why the data for the 4-inch well and Well #21 were not discussed or analyzed as part of the APT. n. In Section 11.1, you indicate that the calculated leakance rate (1.05 E-2) is not plausible, and a value of 3.8 E-5 would be more plausible based on the modeled recharge rate in the NCF model. Please demonstrate that the analytical solution used to derive the leakance is appropriate. Please

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note that a comparison of the observed and simulated head differences between the water table and the Upper Floridan aquifer indicates that local recalibration of the NCF model is necessary to properly assess impacts. o. Please provide supporting information for the selection of aquifer thickness (restrictive layer thickness (70 ft in the analytical solutions used in evaluation of the APT data. p. The report states that the unexpectedly low transmissivity at Well #83 is due to a nearby zone of much higher transmissivity, which was determined to be a distance of approximately 500 ft from Well #83. The method utilized by AEI assumes one linear aquifer boundary and one "image injection" well. However, AEI assumed the block of low transmissivity might be represented on the surface by the 75-ft topography contour. Given this "theorized" aquifer conceptual model for the Well #83 site, please explain why AEI believes an analytical solution, with its limiting assumptions, could be used to provide reasonable assurance in providing a plausible and correct interpretation of the Well #83 APT? [40C-2.301(4)(a),(b),(d),(k) F.A.C.; Sections 4.2,9.0, 10.3(a),(b),(d),(k) A.H., as to all subparts] 19. The narrative discussed the use of the steady state NCF model to address a shorter duration (30 day) pumping event using a transient version of the NCF model. Conversion of the steady-state version of the NCF model to a transient model requires assumptions to be made regarding aquifer storage properties and would be a fundamental change to the model. No documentation was provided regarding the changes made to the model. Proposed changes made to the model for the sensitivity analysis should also be included. Please provide a narrative describing the changes made to convert the NCF model for transient simulations and incorporate the transmissivity changes that are incorporated in the sensitivity analysis in the new/transient simulation. [40C2.301 (4)(a),(b),(d),(k) F.A.C.; Sections 4.2,9.0, 10.3(a),(b),(d),(k) A.H.] 20. The MODFLOW files provided include an output file containing resultant heads from the "C"/"Current End of Permit simulation. No other files were provided. Please provide the input files that were used to generate the "C" simulation head file. [40C-2.301(4)(a),(b),(d),(k) F.A.C.; Sections 4.2,9.0, 10.3(a),(b),(d),(k) A.H.] 21. Comparison of the cell by cell flow files (cbc) and well fluxes for the simulations that were provided indicate that two of the wells are in locations different than stated in the reference table, as follows: Well 28 is located in Row 87, Col 62, table indicates Row 87, Col 61

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Well 55 is located in Row 91 , Col 60, table indicates Row 90, Col 60 Please review the modeled well locations and provide either revise modeling results and files, or revise the noted table accordingly. [40C-2.301(4)(a),(b),(d),(k) F.A.C.; Sections 4.2,9.0. 10.3(a).(b).(d).(k) A.H.] 22. Review of the proposed sensitivity analysis input parameters indicates that it is likely that the revised NCF model will result in greater drawdowns in the immediately vicinity of the wells than predicted by the current version of the NCF model. Please update the saline groundwater upconing evaluation to address the greater drawdowns that are anticipated to occur in the sensitivity analysis scenarios. [40C-2.301(4)(a),(b).(d),(k) F.A.C.; Sections 4.2, 9.0, 10.3(a),(b),(d),(k) AH.] 23. The 58 well locations. as specified by row and column in the table titled "Maximum Monthly Withdrawal Rates for All Wells," do not match those provided in the model files or the Table provided in Section 2.2 of the report. Please review the modeled well locations and provide either revised modeling results and files, or update the noted table. [40C-2.301(4)(a),(b),(d),(k) F.AC.; Sections 4.2.9.0, 10.3(a),(b),(d),(k) A.H.] 24. Well 56, which has a specified flux of -601.5641 cfd, is not active in the second stress period (flux:: 0). Please re-run the transient model with the well active, and submit updated supporting documentation and/or summary report. [40C2.301 (4)(a),(b),(d),(k) F.AC.; Sections 4.2,9.0, 10.3(a),(b),(d),(k) AH.]

25. The location of Well 83/33 depicted on Figures 1, 2, and 8 conflicts with the position information (lat/long) provided on Figure 3, as well as Attachment E of the CUP submittal (Updated Site Map with Wells). It also conflicts with GPS data collected by SJRWMD staff at the time the geophysical surveys were performed. Please confirm the well location. and if necessary, revise the report to reflect accurate position information. [40C-2.301(4)(a),(b).(d),(k) F.A.C.; Sections 4.2, 9.0, 10.3(a).(b),(d),(k) AH.] 26. The location of the site boundary appears to be shifted approximately 1300 ft west of its actual location and/or is out of registration with the underlying topographic information depicted on Figures 1, 2 and 8. Please confirm the site boundary location, and if necessary. revise the report to reflect accurate position information. [40C-2.301 (4)(a),(b),(d),(k) F.AC.; Sections 4.2.9.0, 10.3(a),(b),(d),(k) AH.] 27. After reviewing the results of the sensitivity analysis, District staff has determined

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that reasonable assurance has not been provided that potential harm to wetlands and other surface water resources has been red uced to an acceptable amount. The sensitivity analysis results do not reflect the observation data that has been collected at this site to date. The sensitivity analysis model results, compared to the site-specific observed data, include significant deviations from observed water levels between aquifers and flux/discharge from surface water features portrayed in the revised model (when compared to the original NCF model). In order to provide reasonable assurance, the District requires the applicant to conduct site/local-scale analysis that incorporates improved hydrogeologic information that better replicates the observed conditions. This can potentially be achieved with a refined, calibrated site-specific model, using the NCF model as a starting point, and incorporating additional aquifer parameters/data. [40C-2.301(4)(a),(b),(d),(k) F.A.C.; Sections 4.2,9.0, 10.3(a),(b),(d),(k) A.H.] 28. Please provide construction plans for the CLA water management area (NMP, Cattle Unloading/Corral Facilities; page 10). Please be advised that depending on the type of system proposed, an environmental resource permit may also be required. [40C-2.301(4)(k), F.A.C.; Sections 4.2,9.0, 10.3(k) A.H.] 29.Your proposed Nutrient Management Plan (NMP) does not demonstrate that the consumptive use will not cause or contribute to a violation of state water quality standards in receiving waters of the state, as required by rule 40C-2.301 (4)(k), F.A.C., and section 10.3(k), A.H. The project will discharge to Daisy Creek, which is verified impaired for low dissolved oxygen (DO), and flow into the Lower Ocklawaha River. Daisy Creek and the lower Ocklawaha River downstream of Daisy Creek are both Outstanding Florida Waters (OFW). Thus, the applicant must demonstrate that the proposed use will not contribute to a decrease in DO or an increase in N or P in an impaired water. Notably, the NMP states on page 3 that the NMP "minimizes the transport of Nand P to surface and groundwater." However, that is not sufficient to demonstrate that there will not be a lowering of DO or an increase in N or P to an impaired water. To demonstrate that there will not be a violation of a state water quality standard, you may demonstrate that the proposed use will result in a net improvement (net decrease) for the discharge of Nand P to Daisy Creek and the lower Ocklawaha River. One way to make such a demonstration would be to obtain an environmental resource permit (ERP) for areas that will be irrigated and where proposed activities will impede or divert surface water flows (such as the proposed retention ponds for the CLAs). District staff are willing to meet to discuss possible approaches for the applicant to obtain an ERP that will address water quality issues.

Adena Springs Ranch January 11, 2013 Page 13 Application No. 2-083-129419-1

Please address the following questions about your NMP: a. Overall, the NMP appears to assume that all forage crops will uptake 100% of all phosphorus that is applied (Le., 100%, efficiency in plant uptake of P). District staff do not concur with this assumption. For each crop type, please submit information on the expected phosphorus and nitrogen uptake efficiency rate based on scientific literature, cite the literature source, and revise any calculations and tables predicated on 100% uptake efficiency to reflect the expected phosphorus and nitrogen uptake efficiency rate. b. Please provide a detailed expected crop schedule: crop type, location, rotation rates and growing periods for each center pivot. If a detailed crop schedule is not provided, District staff will use a conservative (high nutrient level) crop production schedule in its analysis of nutrient loading. c. Please provide ration quantities, composition, and timing. d. Please indicate the annual amount of animal waste within center pivots and confined livestock areas (CLAs) that will be disposed of offsite under NRCS code 633 (P. 3, para. 6) and provide a plan demonstrating that such offsite disposal will occur. Otherwise, District staff will assume that all animal waste within the center pivots and CLAs will remain on site. e. Please indicate in the NMP the location, quantity, and frequency that inorganic N will be applied in the center pivot areas. f. In the submittal, there is a statement that groundwater seepage "will not be a problem." (P. 11, para. 3). Please provide detailed information demonstrating either that no groundwater seepage will occur in the center pivot areas and CLAs or the extent of groundwater seepage in those areas. To ensure that groundwater seepage will not cause a water quality problem, you may want to consider performing a ground penetrating radar analysis and/or a ground coring analysis of the center pivot areas and CLAs that will adequately characterize those areas.

g. Please indicate whether cattle will have access to the proposed retention ponds adjacent to the corrals, as suggested in the NMP (P. 10, para. 5). h. Please submit the P index worksheet (P. 17, para. 4).

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i.

Please provide the application rate and frequency of supplemental fertilizers P and N for paddocks within center pivots. Will fertilizers be applied at the IFAS recommended rate, the measured deficiency from the tissue test or soil test results, or will it be based on the NMP budget (Table 9)? (P. 23, para. 4). Please provide complete literature references for crop descriptions and nutrient (P and N) uptake rates within the proposed center pivot areas (Table 6).

j.

k. Please specify how you will adjust the time animals are in an irrigated pasture based on amount of nutrients applied.

I.

Please provide a literature reference for 50% N volatilization (P. 30, para. 3).

m. Please describe what tillage practices will be employed for redistribution or incorporation of manure within center pivots. Include practices to be employed during planting or reseeding of forage crops. n. Are the nutrient values listed in Table 2 based on both manure and urine or just manure alone? If they are based only on manure, then please revise the nutrient values in Table 2 to include nutrients from urine as well. o. Please provide the application rates for P and N and include them in the nutrient balance. (P. 40, para. 3) p. Please indicate on the site map where areas of concrete and other impervious or semi-impervious surfaces will be located, as well as any areas where proposed activities will impede or divert surface water flows (such as swales and the proposed retention ponds for the CLAs). (P. 41, para. 2) q. The NMP refers to soil nutrient testing as recommended in Table 15, but that Table is not included in the NMP. Please include this Table in the NMP. (P. 42, last sentence) r. In appendix 0, BMP checklist, explain why 2.2 and 7.3 are not applicable.

s. Please describe how manure will be collected from heavy use areas (HUAs) like "concrete feedfaces" or "cooling pond paddocks." Please

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describe how this manure will be applied to mechanically harvested pastures and indicate whether this is included in the nutrient balance calculations. (P. 27, para 2) t. Please describe in detail how you will maintain adequate ground cover in HUAs. While the NMP generally indicates that the applicant will make use of portable feeders, portable shades, electric fence and twine, and portable water troughs, no specific plan was provided.

u. Please provide a water quality monitoring plan for both groundwater and surface water, including proposed background and compliance groundwater monitoring wells and proposed background and compliance surface water monitoring locations, a map showing each such monitoring location, and a monitoring schedule. [40C-2.301(4)(k) F.A.C.; Sections 4.2,9.0, 10.3(k) A.H., as to all subparts] Please use either of the following electronic options for responding to this letter and all future permit application submittals: 1. Using the District's website at - www.floridaswater.com/permitting. go to the "Apply for a permit or submit compliance data" section, click to sign-in to your existing account or to create a new account. Under Account Services select RAI response and enter your permit application number. Attach the documents that you are using to respond to the RAI letter. This site also allows you to attach and submit both application and compliance documents. 2. Email - attach and submit any pending application correspondence to applicationsupport@sjrwmd.com. The subject line of your email must include your CUP application number. If you cannot submit information electronically, you may submit the information by mail or hand delivery to the following address, with all documents having the CUP application number shown above: Dwight T. Jenkins, Esq., P.G., Hydrologist IV St. Johns River Water Management District Maitland Service Center 601 South Lake Destiny Road Maitland, FL 32751-7262 Please submit the requested information in a timely manner to help expedite the review of your application. District procedural rules require applications to be technically and administratively complete within 120 days from the date of receipt of a Request for Additional Information. Applications that are not complete within this timeframe must be

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forwarded to the Governing Board with a recommendation for denial based upon an incomplete application. If you need more than 120 days to provide the additional information, please send a written request to me stating the reason you need more time and we will advise you if an extension may be granted. If you have any questions regarding this letter or the application in general, please contact Dwight Jenkins at (407) 659-4868 or djenkins@sjrwmd.com . We look forward to receiving your additional information so that we may proceed as quickly as possible to take action on your permit application.

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Cc: DRS - RAIL

Sincerely,

Director, Division of Regulatory Services

Ocala Meadows Farms, LTD 14875 Bayview Avenue Aurora, ON, L4G 3G8 Plum Creek, LLC 14875 Bayview Avenue Aurora, ON, L4G OK8 Sleepy Creek Lands, LLC 2650 N. Military Trail, Suit 240 Boca Raton, FL 33431 Edward P. de la Parte De la Parte & Gilbert, P.A. 101 E. Kennedy Blvd., Suite 2000 Tampa, FL 33602 District staff: Dwight Jenkins Tim Wetzel Carl Larrabee