Title: Letter from Container Corporation of America
Full Citation
Permanent Link: http://ufdc.ufl.edu/UF00051103/00001
 Material Information
Title: Letter from Container Corporation of America
Alternate Title: Letter from Container Corporation of America with an attached statement of suggested changes in the proposed Water Policy.
Physical Description: 4p.
Language: English
Publication Date: Feb. 26, 1981
Spatial Coverage: North America -- United States of America -- Florida
General Note: Box 2, Folder 3B ( STATE WATER POLICY ), Item 93
Funding: Digitized by the Legal Technology Institute in the Levin College of Law at the University of Florida.
 Record Information
Bibliographic ID: UF00051103
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

Si*rra Club (c inued)

page 8 17-40.10 (2)

...shall review existing policies and rules for consistency
with the provisions herein. Prior to final a enay action
the Departments proposed findings sall be the subject
of a public hearing heldI pursuant to Chapter 0*

page 8 17-40.10 (3)
...with the provisions contained herein. The Department
shall review such rules within twelve months from the date
of their adoption for consistency with the provisions
contained herein. The Department' s proposed findings
shalll be adopted after public notice and opportunity
for public hearing held pursuant to Chapter 120.

The fallowing are changes proposed by the Florida Chapter
of the Sierra Club to the 2/12/81, workshop draft of 17-40.
page 2 17-40.03(8)
...to prevent flood damage and enhance water quality.
page 3 17-40.03 (11)
delete the existing paragraph and add as follows:
(11) The costs and benefits of structural and non-
structural alternatives should be compared in making
water resource decisions.
page 4 17-40.05 (1)
...of each involved District and the Department.

page 5 17-40.07 (2)(b)
(b) The abtlty of necessity for the facilities to
meet established standards and criteria.
page 6 17-40.08 (1)
(1) When minimum flows and levels are established
pursuant to 373.043, seasonal variations shall be
considered where they are relevant for protection of
the water resources or ecology of the area. In establishing
minimum 7ews and levels, consideration shall- e given
to .

page 7 17-40.08 (3)
add a now paragraph as follows,
(3) The provisions of this subparagraph shall be completed
as soon as practicable and shall be substantially
completed within eighteen months from the effective date
of this rule.
page 8 17-40.09 (4)
*..shall also be identified and a schedule for completion
of the necessary activities Tshal be defined.
page 8 17-40.09 (5)
add a new paragraph identical to that proposed for 17-40.08(3).


Fernandina Beach Mill Division

Suggested changes in State Water Policy:

1. Sec. 17-40.03

(14) "Those who use water resources prior to the adoption of this policy
shall be allowed to maintain such use as established by past practice and
shall be given preference when considering new user requests or diversion
of water from one area to another."

2. Sec. 17-40.04

(2)(P) "Use of water prior to the adoption of this policy shall be considered
when issuing permits."

3. Sec. 17-40.03

(7) Should delete "maximum".

4. Sec. 17-40.07

(1) Delete "harmful to water resources or" and change that line to "shall
be consistent with the objectives of the Department or District".

5. Sec. 17-40.07

(2)(A)(X) "Existing water users".

6. Sec. 17-40.08

(1)(L) "Users of water resources prior to adoption of this policy."

7. Sec. 17-40.08

(2)(A) Change to read "The construction and operation of new Water
Resource Projects".

8. Sec. 17-40.08

(2)(B) Should read "The issuance of permits for new users, persuant ....".

Paper Mill Division North Eighth Street Phone: 904 261-5551
Fernandina Beach, Florida 32034

February 26, 198

18 D. it9

Mr. Charles Littlejohnf the Sece
Florida Dept. of Environmental Regulation thSecretry
2600 Blair Stone Road
Twin Towers Building
Tallahassee, Florida 32301

Mr. Littlejohn:

The attached statement is made on behalf of Container Corporation of

The current users of water or water resources of the State of Florida
should be given consideration under all sections of the proposed water
policy. We suggest the changes labeled one thru eight, which appear below.
Suggestions 1,2,5,6,7. and 8 are concerned with existing user assurance of
availability for continued use of water resources. Suggestions 3 and 4
are concerned with environmental protection laws. As for suggestion 3,
the law requires control of pollution to the degree which is environmentally
and economically feasible; the word maximum implies a possible change in
state regulation. There is also the same concern in suggestion 4. At the
present time,factors which are environmentally harmful to water resources
are regulated by the Department. In section 17-40.07(1), the objectives of
the Department and District are stated twice. The suggested change states
this in one statement and leaves out the word harmful, which added ambiguity
to the original statement.


Fernandina Beach Mill Division

Walter M. Kendrick,
Technical Superintendent


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