Jay Landers, Esq.
September 9, 1987
Water Management Districts are terrible ways to administer
the complex environmental regulatory statutes that exist in
Florida. They are simply government by amateurs, who can
only make decisions once a month. Because of the Sunshine
Law members of the Boards as a collegial body cannot even
discuss pending matters except at officially noticed meetings.
As with any form of government by collegial agency head, the
staff only gives the governing board the information the staff
wishes the governing board members to possess. Therefore,
those who make the decisions are often greatly uninformed
as to the nature of the questions before them.
My suggestion to achieve environmental efficiency is
to get Water Management Districts out of environmental permitting.
Let them regulate the storage of water, the transport of water
and the withdrawal of water from ground water sources. Let
DER and DNR administer areas within regulatory and sovereign
jurisdiction. Eliminate overlap between DER and DNR where
it is a problem. Let general revenue pay for statewide governmental
Kenneth G. Oertel
OERTEL & HOFFMAN
A PROFESSIONAL ASSOCIATION
KENNETH G. OERTEL SUiTE
KENNETH F HOFFMAN 2700 BLAIR STONE ROAD
SEGUNDO J. FERANOEZ TALLAHASSEE, r-ORIOA 32309
HAROLD F X PURNELL TELEPHONE 904" 877-0099
M. CHRISTOPHER BRYANT
W AVID WATKINS MAILING ADDRESS.
MARTHA J. EENFIELO POST OFFICE BOX 6507
ELEANOR A JOSEPH
OOUGLAS S MANSON TALLAHASSEE, e ORID, A 32314-650
R. L. CALEEN, Sepemer 1987
WILLIAM E. POWERS, JR.
Jay Landers, Esq.
Barnett Bank Building
Tallahassee, FL 32301
Re: Environmental Efficiency Study Commission
It is with genuine dismay that I have reviewed the progress
of the Environmental Efficiency Study Commission and I feel
the need to express my concern about the directions I see
the Commission taking. One cannot argue against "efficiency"
in the review of environmental, matters. That is a proposition
too closely akin to worshiping motherhood and "good government."
Expediency may be the most efficient way to run government,
but not necessarily the best way. Those of us who deal with
.government agencies are instinctively wary of improvements
done under the name of efficiency.
I have strong feelings that delegating present environmental
permitting functions to Water Management Districts would be
not only inefficient, but a very unwise change to make in
Florida's present environmental regulatory responsibilities.
I believe the Water Management Districts are the cause
of the criticisms for why environmental permitting may be
too cumbersome and repetitive. Water Management Districts
were originally set up with the idea that they would regulate
withdrawals of ground water and the management of quantities
of surface water. I believe that the time is here to bring
them back to those original functions and get Water Management
Districts out of all environmental permitting. This would
achieve great simplicity. It would insure that environmental
policy questions are conducted under the control and supervision
of agencies that have statewide review powers, not regional
responsibilities. Policies should be uniform and guidance
should come from central locations.