Honorable Raubin O' D. Askew
November 16, 1978
implementation, need further explanation or definition, lac
clear authority, have interagency conflicts which require
resolution or have other problems. Some actions may exhibit '
a combination of problems. It is possible, as you will
notice when reviewing the list of policies, to have a
policy/recoinnded action which is listed as both currently
underway and not started. This is because the policy and
recommend actions contain several parts which are '
different stages of i le tion.
Hopefully, our cooperation with the DOA in this matter will
initiate executive agency actions aimed at. the revision
rec -ndd action statements now felt to be potentially &I .:
inhibiting to the eventual implementation of the goals,
objectives and policies of the plan. I strongly rece-
that the executive directions (_cde actions) be'
revisited in the very near future with appropriate input
from all affected implementing agencies..
Joseph W. Landers, Jr.
cc: John Bottcher
" 1 & : .
Honorable Reubin O' D. Askew
November 16, 1978
The recommended actions are, in some instances, much too
specific for this level of planning, and could preclude or
inhibit other equal, or more appropriate methods of policy
implementation. They also were developed without the input
and support of the water management districts, the very
agencies under whose general authorities most of the water
section's policies eventually will be implemented, and the
agencies whose cooperation the DER will need the most for
the development of a viable State Water Use Plan and even' .... ___
tually a State Water Plan.
In a memorandum of January 14, 1978 to Jim Tait, concerning
this issue, I noted that It was inappropriate for the
Division of State Planning (DSP) to specify mplementing
actions ( r nd--ed actions) without the active partici-
pation of the affected implementing agencies. I still feel
that these mMU actions were developed prematurely
and without the necessary consideration by all significantly
affected interests. The DER, with the assistance of the
water management districts, and in consultation with the
DSP, is prepared to systematically develop a set of realistic
implementing strategies for the policies in the water section
of the plan, within existing authority. But we are most
concerned about proceeding into premature rulemaking and
other actions suggested by the recommended actions in the
plan, given the extremely complex water issues which face
We have similar problems with other recommended actions in
other sections of the plan and will be discussing those with
the Division of State Planning of the Department of Adainis-
tration (DOA). On October 26, 1978, we transmitted to DOA
completed detailed questionnaires on the status of several
of the policies and recommended actions.
To conform with your executive order of August 28, 1978, we
have reviewed all the policies and recommended actions in
the plan that require an action on the part of this depart-
ment. Our report on the status of these actions is attached.
Various policy numbers are categorized as to whether or not
they were completed as of Uovember 1, 1978 Those not
completed are listed as currently underway or not started.
Those actions currently underway are either completed in
part, or underway and planned for future implementation.
Those actions not started are either not planned for future
Tall assee. Florida 32304
DeHonorable Rnoubin A kew A '
Tallahass ee," ". 32304 ;.' *;-' ..;> .t",
This is in response to your letter of transmittal for
E-incutive Order #78-48 regarding the implmentation of t--
State Co.prehensive Plan.
This department supports the goals, objectives and policies
contained in the plan. While we have noticed some oaiassions,
they are, for the most part, limitations which can be
addressed during the annual revisions of the plan.
However, in the same document that contains the goals,
objectives and policies (which constitute the plan by virtue
of Chapter 78-257, Laws of Florida, 1978), there are certain
recommended actions, which did not go through a rigorous
review by affected agencies and the public. Therefore, many
of the recommended actions either do not reflect other
alternatives and options to implement the policies, or do not
reflect the best and most cost-effective means of implementa-
In the water section of the plan, there are problems, spe-
cifically with the recommended actions which could negatively
impact the operations of the department and the implementa-
tion of the plan. Although this agency was involved in the
development of some of the recommended actions, there are
many others with which we were not involved which we feel
need substantial alterations or refinements.
TWIN TOWERS OFFICE BUILDING REUBIN O'D. ASKEW
2600 BLAIR STONE ROAD GOVERNOR
TALLAHASSEE. FLORIDA 32301 JOSEPH W. LANDERS, JR.
STATE OF FLORIDA
DEPARTMENT OF ENVIRONMENTAL REGULATIONt-
(i a W,,7
November 28, 1978 I,
Mr. Donald R. Feaster
Southwest Florida Water Management District
Post Office Box 457
Brooksville, Florida 33512 Flori
Enclosed for your information is a copy of Secretary Lander's response to
the Governor's executive order and letter of transmittal to this department
regarding the proposed implementation of the State Comprehensive Plan. This
response highlighted several of the significant concerns shared by both the
districts and the department in reference to the past development of the Water
Section's "recommended action" language.
Please contact me if you have any comments on this issue.
Garles B. Littlejohn
Bureau of Water Management
cc: Mr. Howard L. Rhodes