February 24, 1981
Change (9): The Department and Districts should assist "educational institu-
tions" (as opposed to State Universities) in the development of
educational curricula and "/or" research programs which meet
Florida's present and future water management needs.
Discussion: Assistance by the Department and Districts should not be limited
to only university level personnel nor university level research
programs. Valuable assistance can be given to schools which teach
kindergarten through high school levels as well.
February 24, 1981
Discussion: Waste treatment and management is an integral component of a
regional water resources policy and should be included.
17-40.07 Surface Water Management
Add to (I): The construction and operation of facilities designed to manage
or store surface waters, or of other facilities which drain,
divert, impound, discharge into, or otherwise impact waters in
the State, or improvements served thereby, shall not be harmful
to water "or land" resources or inconsistent with the objectives
of the Department or District.
Change (2)(d): The ability of the facilities and related improvements to
"reduce or" avoid increasing flood damage to offsite property
or the public "as a result of:" (as opposed to "through")
Change (2)(d)(i): floodplain "management" (as opposed to "development"),
encroachment or other alteration
Discussion: "Management" encompasses a wider variety of floodplain uses.
"Development" might be classified as a subset of management
17-40.08 Minimum Flows and Levels
Add to (2)(a): The "consideration," construction and operation of Water Re-
Discussion: Minimum flows must be considered prior to the construction and
operation of a Water Resource Project.
17-40.09 District Water management Plans
Add to (1): A water management plan shall be prepared by each district which
is consistent with the provisions of this chapter and which iden-
tifies specific geographical areas where water resource problems
"are fast approaching or" have reached critical levels.
Add to (2): A course of remedial action shall be specified for each "fast-
approaching or already" critical problem. Measures may include,
but are not limited to. ..
Discussion: Paragraph (3) has been combined with paragraph (2) since they are
so closely related. Paragraph (4) should be omitted as it has been
superceded by the inclusion of the words "fast approaching" in
paragraph (1) above. Its retention in this context is redundant.
February 24, 1981
Discussion: The inclusion of "land" resources is essential in that detri-
mental affects can be suffered by land as a result of draining,
diverting or altering the flow of both surface and ground water.
Considering only the effects on the water resource is not ade-
quate when evaluating a complex environmental system.
Add to (10): Minimum water flows and levels should be established "and main-
tained" to protect water resources and the environmental values
associated with coastal, estuarine, fresh water, and wetlands
Add to (11): Both structural and non-structural alternatives "must" be given
"equal" consideration in water resource project decisions. "This
must also include consideration of both supply augmentation and
demand management procedures."
Discussion: For example, if a structural alternative has been chosen to relieve
some water supply problem such as a water treatment facility, the
use of that facility should be evaluated for both its supply aug-
mentation potentials (for instance water reuse) and its possible
role in demand management (such as seasonal or peak time rates).
17-40.04 Water Use
Add to (4): "Beneficial" conservation of water shall be a requirement of each
17-40.05 Water Transport
Add to (2)(a) Comprehensive water conservation and reuse programs "have been
considered or" implemented and enforced in the area of need.
Discussion: There may be cases when water conservation and reuse programs
are impractical or inadequate for the needs of an area. There-
fore, evaluating the extent to which these programs have been
implemented may be inapplicable in this case. What is essential
in this case is that these alternatives have at least been
explored first before choosing to transport water.
Add to (2)(b) The major costs, benefits, environmental impacts "and intangibles"
are adequately determined for both the supplying, receiving "and
Change (2)(d) The present and projected water needs of the supplying area are
reasonably determined "and satisfied" (as opposed to "and can be
met") if the transport takes place;
Add to (2)(e) The transport plan incorporates a regional approach to water
supply, distribution "and waste management" including, where
appropriate, plans for eventual interconnection of water supply
Wafet el vanayemewr VVUwwize
Route No. I. Bov 31 00. Havana. Florida 32333 047
J. William McCartney (904
Executive Director M E M 0 R A N D U M
TO: Chuck Littlejohn, Office of Special Projects, DER
FROM: Bonnie Kranzer
DATE: February 24, 1981
SUBJECT: Comments on Chapter 17-40, State Water Policy
17-40.03 General Policy
Add to (3): Uses of water authorized by a permit should be limited to
reasonable-beneficial uses and "beneficial" water conservation
should be a condition of water use. The "economically effi-
cient" use and reuse of water of the lowest acceptable quality
for the purpose intended should be encouraged.
Discussion: Without the terms "beneficial" and "economically efficient,"
the above statement implies that water conservation must be
exercised at whatever the price. Water conservation, unfortu-
nately, is generally thought of as the practice of reducing
the amounts of water used. In a strict sense, conservation
should be defined as a "beneficial reduction" in water use.
This places the decision to conserve or not on a more quantita-
tive basis which can be evaluated in a specific time frame
either in the long or short run. The "beneficial" in the above
definition implies a benefit-cost ratio of greater than one.
Add to (8): Floodplains should be delineated and managed to "reduce and/or"
prevent flood damage.
Discussion: A sound water policy should also attempt to reduce, not just
prevent, flood damage. Current land and water management
practices often maintain flood damage potential. It is in the
best interest of the State to attempt to reduce future flood
damage in areas where this already occurs.
Add to (9): Facilities which drain, divert or otherwise alter the flow of
surface waters should be managed to "decrease or" prevent in-
creased flooding or drainage which is harmful to water "and land"
HENRY C. LANE TOM S. COLDEWEY DAN FARLEY
Chairman Pensacola Vice Chairman Port St. Joe Sec/Treas. Tallahassee
"HOWARD ODOM SAVAGE RUNNELS R. L. PRICE, JR. WILLIAM C. SMITH MARION TIDWELL W. FRED BOND
Marianna Destin Graceville Tallahassee Jay Pensacola