E s T P. 0. BOX 457 BROOKSVILLE, FLORIDA 33512
DERRILL McATEER, Chairman, Brooksville JOHN A. ANDEKSON. Treasurer. St. Petersburg DAVID HIPP, Williston
," ... A. M. PICKARD, Vice Chairman, Lakeland HERMNAN B't1IZL', .5nA" .. -, UL F. HUBBARD, Oklawaha
"E" SG' T.- P BEDIWARD MEDARD, Secretary, Tampa S. C. BEXREO ,V d -'L ,Cs F I YCE A. WILLIAM, Leesburg
i'I Ile Twachtmann, Executive Director
I O 1969 |j
November 24, 1969 .'
Mr. John W. Kriska
FlI Aida Well Drillers Association
Post Office Box 547 -/
Seffner, Florida 33584 :
Thank you for your letter of November 19, 1969 transmitting a copy of
Mr. Dunham's letter to you. Dale has sent it on to me for reply.
Mr. Dunham has a legitimate complaint about the 2-inch-only well
drillers. But he is wrong in implying that we purposely misled the
drillers. At our District hearings we publicly stated that every person
who constructs any well in the District must be registered and be the
holder of a valid, current registration certificate. The same informa-
tion has been published in 357R-1. 02 (1) "Registration of Well Drillers"
and has until a couple of weeks ago been our practice.
However, our attorney, Mr. Myron Gibbons, recently informed us that
357R-1. 02 is not consonant with 357R-1. 01 (a) which defines a well as
"a hole .... having a diameter of more than two (2) inches. ..." It is
his interpretation that this wording invalidates our intent and thus, until
the Rules and Regulations are revised to correct this error, we cannot
require the 2-inch driller to register.
There are other errors inadverten l1 crePt into the Rules and Regu-
lations as approved by the Boar o Governors an- s pa led" Spie-
ment #70, Water Resources, Chapter 357R-1, copy of which is attached.
It is our intent and purpose to try to live with these Rules and Regulations
a while longer so that all the "bugs" will be clearly apparent and after
recognized can be taken out by subsequent appropriate action of the Board
Needless to say, we regret very much that our first attempt at writing
a usable and reliable set of Rules and Regulations was not perfect. Mr.
Building a modern Ark The "Four River Basins, Florida" project -. -
Mr. John W. Kriska
November 24, 1969
Dunham is assured, by copy of this letter, that our intent is honorable and
only this unfortunate clash of section wording prevents us now from carry-
ing out the intent as clearly stated in 357R-1. 02 (1).
Garald G. Parker
cc: Mr. R. B. Dunham
M%. Myron G. Gibbons
Ir. Lester M. Blain