STATEMENT THAT THE PROPOSED RULE
IS NO MORE RESTRICTIVE THAN FEDERAL STANDARDS
There are no applicable federal rules or federal agencies admini-
stering similar rules for comparison of the proposed rule amendments to
federal standards. Therefore, it is concluded that the proposed rule
is no more restrictive than federal standards.
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estimate at this time; however, the largest time responsibility
will come from the initial review of water management district
plans, policies and revisions for consistency.
Another possible cost is that involved with the rule devel-
opment that may result from the adoption of this: rule. The
Department may suggest rule development proceedings in order to
insure consistency among the districts. Again, it is expected
that any costs incurred by such actions will be absorbed by
existing departmental and district personnel and respective
funding. It is remotely possible that situations may arise
where this is not the.case but it is not-within the scope of
this impact statement to substantively address this possibility
II Estimate of Costs and Benefits
As discussed above, future actions related to the general
policies will vary on a case-by-case basis within districts a:.d
may result in increased costs to certain water management dis-
tricts and in select cases to potential private applicants.
These costs will be identified at the appropriate times accor.:in.
to the provisions of Chapter 120.54, F.A.C. The benefits
resulting from implementation of this rule are expected to
clearly outweigh any potential costs which may result. The
general continuity between water-related rules will minimize
bureaucratic confusion, and may eventually alleviate permitting
time delays, a permit applicant's cost in both cost of application
preparation and need for dealing with widely differing water
policy conditions under changing circumstances in different
regions. These benefits in and of themselves again cannot be
quantified because they must be assessed on a case-by-case basis.
The number of complaints filed with the Department based on
unnecessary delay due to inconsistency in rule policy implemen-
tation in various parts of the State attest to the timeliness :f
this rule development and its probable beneficial impact.
III Estimate of Impact on Employment and Competition
This rule is not expected to have any effect on competition
or employment in the State of Florida. As suggested above, the
workload of the Department of Environmental Regulation and th.-
water management districts may be increased; however, it is
expected that existing staff reorganization of priorities wil_
absorb the increased workload and increased efficiency elsewhere,
and be more cost-effective across the State.
IV Data and Methodolcgy Used
The methodology employed for development of this EIS is
largely drawn from the professional expertise of Department
staff, public testimony and comment from affected interest
groups at public workshops and hearings.
Economic Impact Statement
Proposed Amendment to Chapter 17-40,. F.A.C.
Docket Number 81-4R
The proposed Water Policy rule is intended to provide
general guidance for the Department of Environmental Regulation
and the five water management districts for "the development
or modification of Department and district programs, rules and
plans." In addition to general guidance, the rule lists more
specific criteria to be considered in all decisions concerning :
water use, water transport, water quality, surface and grcund
water management, establishing minimum water flow levels and
district water management plans. It is evident from the general
nature of the language in the rule and the decLaration of intent
that no specific action other than the possible initiation of
rule development is expected by the water management districts.
There will also be some possible costs to DER for review of
district plans and rules; however, the major intent and direction
of the proposed rule, and hence the economic impacts, are of
secondary nature. It may be that the more specific sections 'il1
eventually have an economic impact on the private sector but
this is not likely to occur unless they are proposed as rules.
When this occurs, each of these will require an economic impact
statement on their specific content under the provisions of
Chapter 120.54, F.A.C. At that time, the economic analyses wil1
have to be on a case-by-case basis and it is therefore premat.ire
and unnecessary at this time to attempt to identify and quantify
any of these potential costs.
I Estimated Costs of Implementation
The content of this rule is to be used as a policy guide .'..
future water-related state and water management district plans.
Many of these policy directives are taken from existing law ar.(r
do not constitute incremental changes in and of themselves.
However, under the provisions of Section 17-40.10, F.A.C.,
entitled "Implementation", the rule does direct staff of the
Department of Environmental Regulation to review the provisions
of this rule periodically but in no case less frequently than
every four years. Additionally, the Department will review
existing rules of all the districts for consistency with the
provisions of this chapter within twelve months after adoption.
Further corrective action is specified for those district rul.s
and policies which are judged to be inconsistent with this
chapter. This specific charge suggests a cost to the Departmcr.
of Environmental Regulation of as much as one man-year during
Fiscal Year 1981-82 with less effort (approximately 1/2 man-
year) required annually thereafter. The actual increase in
paperwork will be on a case-by-case basis and impossible to
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