personally appeared ...... k C ,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
My Commission expires: ';-<7-79
The spirit anu intent of the SWFMD rules nd regulations will
be totally thwarted.
9. Further, the proposed Application violates the
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) () ; 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 i
reflected and said Application does not truly
reflect project size, dimensions, capacity, et
10. That based upon the Applicant's ownership of some
1200 acres, the proposed withdrawal is an unreasonable diversion o
water and is some 8.33 times the water crop limitations pro-
mulgated by Southwest Florida Water Management District.
WHEREFORE, COVINGTON DEVELOPMENT CO., makes this
demand for Intervention and files this Verified Complaint
pursuant to Ch. 403.412 Florida Statutes.
COVINGTON DEVELOPMENT COMPANY,
A Florida Corporation,
Its Vice President 1
Dated: October #, 1975
STATE OF FLORIDA )
COUNTY OF PASCO )
On this 1 day of c L ,1 1975, before
me, a Notary Public within and for the County of Pasco,
5. Ihe Application filed fail., Lo 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
6. That such a high withdrawal rate without benefit of
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
burden of proof of environmental viability. Applicant makes no
such showing and indeed, adequate data is not available for any
7. The Environmental Assessment conducted and published
by Southwest Florida Water Management District (April, 1975)
clearly points out the dangers to surrounding properties and the
Land O'Lakes area from the proposed wellfield including, drying
up of surface water bodies, depletion of the shallow and deep
aquifers, sinkholes, alteration of wildlife and vegetation,
effect upon the City of Tampa water supply, and others. This
Study is incorporated herewith by reference. The clear conclusion
> 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
as part of the St. Petersburg water supply. Should harm occur
to the Land O'Lakes area, it will become difficult if not
impossible for Pasco County to halt the flow of this water to
St. 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
and Petition to Intervene in the above-referenced proceedings,
pursuant to Ch. 403.412 Florida Statutes, and in support
1. There is presently pending before the Southwest
Florida Water Management District ("SWFMD") an Application by the
City of St. Petersburg for permission to initiate withdrawal of
water from wells located at the Cypress Creek Wellfield.
2. This Application is made pursuant to the rules of
SWFMD governing works of the District, Consurr.ptive Use permit
requirement, as well as the rules and requirements of the Florida
Department of Natural Resources and the Water Management acts.
3. The Application seeks a permit for an initial
consumptive withdrawal at the rate of 10 million gallons per day.
4. Although ostensibly a "pumping test", this request
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.
NI C HA E I 1 E 1 L ., P. C.
ATTORNEY AND) COUNSELOR AT LAW'
1051 B1 l. B 1 U1 I..1)I-N C
DETRO I, IX ICHIGCA 482A 0
October 8, 1975
Southwest Florida Watet Management District
P.O. Box 457
Re: Pending Application of City of
St. Petersburg for ConumpYtive
Us-e Permit form Cypress Creek
The City of St. Petersburg and/or Pinellas County
have recently filed an Application for Consumptive Use
Permit to withdraw ground water from Cypress Creek Wellfield
in Pasco County.
Enclosed please find a Petition to Intervene on
behalf of my clients. The basis,of our intervention is
that we oppose the grant of this permit for the reasons
set forth in the annexed petition.
As Intervenors we request copies of all notices,
hearing dates or other actions taken with regard to this
Thank you in advance for your cooper io
You e y 1 ,
cc: Fletcher DychesEsq.
Courtesy copies: Jacob D, Varn, Esq.
Carl Linn, Esq,
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