October 6, 1980
RE: SFWMD--Rules Matrix--Telephone Conversation With Steve Walker
At your request, I called Steve Walker in response to his August 26,
1980, letter to you. Steve and I discussed the rules matrix as it
has been tentatively planned by South Florida. His comments are
summarized as follows:
1. General and procedural rules: Steve said he was under the
impression that the general and procedural rules would be
divided into Chapters 0 and 1, as SWFWMD did, but then he
saw that some of the other districts were including all
general and procedural rules in Chapter 1. He does not know
what South Florida is going to do on this.
2. Consumptive use rules: Steve said that South Florida has chosen
to use the designation "water use" rather than "consumptive use
of water" because of its difficulties with the use of the word
"consumptive." Apparently some people felt the word "consumptive"
was too narrow, so arguments have been avoided by deleting that
word. There is also the problem of the bifurcation between
"consumptive use permits" and "general permits."
3. Artificial recharge: Steve has included artificial recharge
in Chapter 40E-5, saying that Chapter 5 is the chapter designated
in his version of the matrix for rules on artificial recharge.
I told him that we would consider designating Chapter 5 for that
purpose in the matrix.
4. Real property acquisition and disposal: Steve said that his
matrix shows this topic belonging in Chapter 9 and said that
he would move these rules from Chapter 40E-7 to 40E-9.
5. Miscellaneous rules: These are shown on Steve's chart to go in
40E-8. He said that he will rename 40E-8 as "water levels and
rates of flow," as we have named it, and put miscellaneous rules
in 40E-7, since land acquisition rules are being switched to
6. Chapters designated for general permits (40E-12, 40E-14): These
rules were separated from the more general provisions to go into
the low number chapters so as to provide a place for the reci-
tation of the general permits themselves. Steve said he is in
the process of rewriting the general permits.
Memorandum to LMP
October 6, 1980
7. Water shortage plans: These are plans that are basin-specific
for use in particular areas. Steve said he is considering
moving all of these into one chapter. The same would apply to
surface water management basin rules, which are listed in his
chart as going in 40E-40-49.
Steve said that 7(#Y 1t&A4k has been done by his district on
the recodification, in part because they are waiting for receipt
of a word processor. As they recodify their rules, they will call
us for rule numbers and titles.
Steve expressed surprise that our rules were adopted with three
digit decimal places, since his copy of the matrix shows two digit
decimal places. I told him that he must have an old matrix, as the
matrix we are working from has three digit decimals.
Steve asked me for a copy of our latest matrix. I am sending him
copies of both our alphabetical listing and our numerical listing.
A copy of my letter to him is' attached.