Title: Letter to St. Johns River WMD Governing Board
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Permanent Link: http://ufdc.ufl.edu/UF00051098/00001
 Material Information
Title: Letter to St. Johns River WMD Governing Board
Alternate Title: Letter to St. Johns River WMD Governing Board suggesting changes to the proposed Chapter 17-40, Florida Administrative Code.
Physical Description: 2p.
Language: English
Publication Date: March 11, 1981
 Subjects
Spatial Coverage: North America -- United States of America -- Florida
 Notes
General Note: Box 2, Folder 3B ( STATE WATER POLICY ), Item 88
Funding: Digitized by the Legal Technology Institute in the Levin College of Law at the University of Florida.
 Record Information
Bibliographic ID: UF00051098
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





"Letter to The Honorable Victoria J. Tschinkel
from A. Ray Beville, Chairman, SJRWMD
March 11, 1981
Page -2-


acC 7. Page 7, Line 14. -- (b) whether the facilities meet-yn design
\ ^c or performance standards adopted by the Department or Districts;

In addition to these specific suggestions, the Governing Board wishes to express
the following comments:

1. We are concerned that the proposed rule goes far beyond the proposed
purpose of providing general policy guidance to water management
districts in that the Department is placed in a position that exceeds
the intent of Chapter 373, Florida Statutes with regard to the
Department's relationship with the Districts.

In this regard, we believe that paragraphs (2) through (6) of Section
17-40.10 should be deleted because, if the Department of Environmental
.:i Regulation does not already have this authority, the adoption of such
c language is illegal and, if the Department does already have this
authority, the language is unnecessary.

2. We are further concerned that the proposed rule does not adequately
cover the breadth of water management policy as provided in Chapter
S373, Florida Statutes. For example, policy considerations concerning
Q. saltwater encroachment, protection of groundwater, groundwater manage-
ment, and declarations of water shortages are not explicitly addressed.

3. We also believe that the Department should insure the greatest possible
public participation in the adoption process in order to achieve a
general public acceptance.

In closing, the Governing Board commends the Department on its efforts toward
the development of this rule. However, we urge that the Department give
careful consideration to our suggested changes and comments as we work to-
gether to better our system of water management.

If I or any of the staff can help you in any way, please do not hesitate to
ask.

Sincerely,
/ /

A. RAY BEVILLE, Chairman
Boad of Governors

ARB/DH:djr
cc: Governing Board Members, SJRWMD
Govern oarC WMD's








ST JOMNS Rvea PcE Mo or


NtlANAG IENT POST OFFICE 30X 1429 PALATKA. FLORIDA 32077
SST7 C 904/328-8321


March 11, 1981



The Honorable Victoria J. Tschinkel om s secretaryry
Secretary .-
Department of Environmental Regulation
Twin Towers Office Building
2600 Blair Stone Road
Tallahassee, Florida 32301

Dear Vickie:

The Governing Board of the St. Johns River Water Management District wishes
to suggest the following changes in the language of the Draft Regulation of
proposed Chapter 17-40, Florida Administrative Code:

1. Page 2, Line 11. -- -I-addi*$eR-te-meFe-Ppee-fie-prevy*ses-eemtaRed
ep. hefre$R The following is intended as a general statement of policy
\ stated and implermntiditn athe specific provision -ontaH-and-
,, shall provide a basis for Department review of District programs, rules
and plans:

2. Page 2, Line 16. -- Water necessary to support essential non-withdrawal
,4c demands, including navigation, recreation, and the protection of fish
Sand wildlife, should be reserved from allocation by permit.

3. Page 2, Line 19. -- Uses of water authorized by a permit should be
limited to reasonable-beneficial uses wheme-water-eemseyvatien-metheds
c ae-a-ee9sidepaeR -ef-sueh-uses. (A minority of the Governing Board
wanted to leave the language as stated.)

4. Page 2, Line 26. -- High priority should be given to the regulation,
c, conservation or acquisition of wetlands ad4 floodplains, and seher-
recharge areas. (A minority of the Governing Board wanted to leave
the language as stated.)

5. Page 3, Line 19. -- Both structural and non-structural alternatives
should be given fyll adequate consideration in water resource project
decisions.

6. Page 5, Line 6. -- (4) Conservation of water shall be a requirement
of each permit unless shown not to be economically or environmentally
^ feasible. (A minority of the Governing Board did not desire this
lyc addition.)


A. RAY BEVILLE FRANCES PRGNONE CLAUDE 0. GODWIN JOHN V. D'ALBORA. JR.
Chairman Fernandina Beacn Vice Chairman Orlando Secretary Titusvile Treasurer Cocoa
LYNNE CAPEHART M'CHAEL BRADDOCK FRANK X. FRIEDMANN, ,JR. IDWAL OWEN
Gainesville Pierson JacKsonvtile JacKsonvtlie
ED. 'SONNY" VERGARA
Executive Director





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