Title: Memorandum on the Economic Impact of State Water Policy
Full Citation
Permanent Link: http://ufdc.ufl.edu/UF00051096/00001
 Material Information
Title: Memorandum on the Economic Impact of State Water Policy
Physical Description: 1p.
Language: English
Publication Date: March 16, 1981
Spatial Coverage: North America -- United States of America -- Florida
General Note: Box 2, Folder 3B ( STATE WATER POLICY ), Item 86
Funding: Digitized by the Legal Technology Institute in the Levin College of Law at the University of Florida.
 Record Information
Bibliographic ID: UF00051096
Volume ID: VID00001
Source Institution: University of Florida
Holding Location: Levin College of Law, University of Florida
Rights Management: All rights reserved by the source institution and holding location.

Full Text
March 16, 1981


TO: JOHN WEHLE, Interagency Coordinator

FROM: 44Uk S- J. EDWARD CURREN, Attorney, Legal Department

RE: Economic Impact of State Water Policy

I have just today reviewed a copy of the Department of Environ-
mental Regulation's Notice of Rulemaking that it published on
March 6, 1981 in the Florida Administrative Weekly regarding
rule adoption of the State Water Policy as Sections 17-40.01 to
17-40.10, F.A.C.

The review caused me to realize that in all of our efforts in
reviewing the many drafts of the policy, we may have overlooked
and not reviewed the economic impact statement developed by the
DER as a part of rulemaking.

The language in the notice seems to indicate that the economic
impact associated with the water policy has been discounted as
insignificant. The notice language in effect defers considera-
tion of specific economic impact until water management district
implementation by rulemaking.

The notice language states that, "It is anticipated that the more
specific sections may eventually have an economic impact on the
private sector, but this will not occur until they are proposed
as rules. When this occurs, each of these will require an eco-
nomic impact statement on their specific content under the
provisions of Section 120.54, Florida Administrative Code."

The further statement in the notice that certain of the policies
may result in some increased costs to certain water management
districts is, if anything, an understatement. It appears that
the water management districts will not only have to address the
economic impact of proposed rules, but will be required to assess
the economic impact of the State policy on the same subject. I
wonder if the water management districts will be prepared to
defend both.


cc: L. M. Blain, Esquire
J. T. Ahern
G. W. Kuhl

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