personally appeared --IO A *4C ,aeu on
behalf of Covington Development Company, to me known to be
the person who signed the foregoing Verified Complaint and
Petition to Intervene Pursuant to Ch. 403.412 (s) Florida
Statutes for and on behalf of said Company, and stated that he
has full authority to act on behalf of said company and that
the contents hereof are true to the best of his information
S, Notary Public
My Commission expires: <-cd-79
The spirit and intent of the SWFMD rules and regulations will
be totally thwarted,
9. Further, the proposed Application violates the
i following provisions of the Pasco County Water Ordinance, among
others; notwithstanding the grant of a "testing" permit by Pasco
a. Statements of policies and objectives.
b. Paragraphs 3(2) (d) ;3 (2) (e) ;3 (2) (f); 3(2)(j);
6(1); 6(3) (b); 6(3) (c); 7(4); 21; and 30.
c, In addition, based upon the lack of available '
data, compliance with section 12 is impossible.
d. In addition, it is maintained that the Applica-
tion as presently drawn is tantamount a
fraud upon the County Commissioners since
only a "foot-in-the-door" arbitrary quantity is
i reflected and said Application does not truly
reflect project size, dimensions, capacity, etc.
ij 10. That based upon the Applicant's ownership of some
1200 acres, the proposed withdrawal is an unreasonable diversion of
water and is some 8.33 times the water crop limitations pro-
i mulgated by Southwest Florida Water Management District,
WHEREFORE, COVINGTON DEVELOPMENT CO., makes this
demand for Intervention and files this Verified Complaint
Spursuant to Ch. 403.412 Florida Statutes.
|i COVINGTON DEVELOPMENT COMPANY,
I A Florida Corporation,
;i Its Vice President
i Dated: October 1, 1975
STATE OF FLORIDA )
ki ) SS.
| COUNTY OF PASCO )
i\ On this _J^ day of ..Q... 1975, before
i me, a Notary Public within and for the County of Pasco,
__________ ______________________ !j
5. The Application filed fails to reflect the fact
that this initial withdrawal is only the first phase of the
wellfield project; the plans for this project include a pipeline
(already built) with a capacity of 130 million gallons per day,
a pumping-treatment plant with an initial capacity of 65 mgd to
130 mgd, and an ultimate project withdrawal of from 50 mgd to
ji 6, That such a high withdrawal rate without benefit of
i prior testing and a full environmental assessment is plainly
contrary to the spirit and intent of SWFMD, DNR and the Water
! Management acts which clearly place upon the applicant the
i burden of proof of environmental viability. Applicant makes no
such showing and indeed, adequate data is not available for any
j1 such showing.
7. The Environmental Assessment conducted and published
it by Southwest Florida Water Management District (April, 1975)
i clearly points out the dangers to surrounding properties and the
Land O'Lakes area from the proposed wellfield including, drying
'i up of surface water bodies, depletion of the shallow and deep
!; aquifers, sinkholes, alteration of wildlife and vegetation,
i; effect upon the City of Tampa water supply, and others. This
. Study is incorporated herewith by reference. The clear conclusion
i of this Study is that adequate data has not yet been developed.
,I 8. The proposed Application cannot be justified as
| a "test" since the water will be actually consumed and used
h as part of the St. Petersburg water supply. Should harm occur
j to the Land O'Lakes area, it will become difficult if not
i impossible for Pasco County to halt the flow of this water to
SSt. Petersburg residents who will have come to depend upon it.
STATE OF FLORIDA
BEFORE THE SOUTHWEST FLORIDA WATER MANAGEMENT DISTRICT
IN THE MATTER OF PERMIT APPLICATION
OF ST. PETERSBURG FOR CONSUMPTIVE
USE PERMIT FOR CYPRESS CREEK WELLFIELD.,
VERIFIED COMPLAINT AND
PETITION TO INTERVENE PURSUANT
TO CH, 403,412 (s) FLORIDA STATUTES
COVINGTON DEVELOPMENT COMPANY, a Florida Corporation,
for itself and as managing partner of Lake Padgett Pines, a
Florida co-partnership, herewith files this Verified Complaint
iand Petition to Intervene in the above-referenced proceedings,
pursuant to Ch. 403.412 Florida Statutes, and in support
j whereof shows:
1; 1. There is presently pending before the Southwest
Florida Water Management District ("SWFMD") an Application by the
SCity of St. Petersburg for permission to initiate withdrawal of
; water from wells located at the Cypress Creek Wellfield.
I 2. This Application is made pursuant to the rules of
! SWFMD governing works of the District, Consumptive Use permit
i requirement, as well as the rules and requirements of the Florida
i Department of Natural Resources and the Water Management acts.
( 3. The Application seeks a permit for an initial
Sconsumptive withdrawal at the rate of 10 million gallons per day. r
4. Although ostensibly a "pumping test", this requested
withdrawal is for production and consumptive purposes and will
actually be pumped through the 84 inch pipeline to consumer
customers in the City of St. Petersburg.