NORTHWEST FLORIDA WATER MANAGEMENT DISTRICT
FROHM: James A. Stidha Director, Water Resources Division
DATE: September 12, 1979
SUBJECT: SUmmary, Rule Writers' Meeting
Following is a summary of the discussions that were held at the meeting
of district rule writers. Attendees were: Robert Shultz, Jay Ahern, and
Barbara Vergara, Southwest Florida Water Management District; Bob Moresi
and Bud Harris, St. Johns River Water Management District; Al Csontos,
Suwannee River Water Management District; Steve Walker, South Florida Water
Management District; Jim Stidham, Marcia Penman, and Barbara Bies, North-
west Florida Management District; Sonny Vergara, Department of Environmental
Regulation, Buddy Blain and Fred McCormack, Blain and Cone, P.A.; and
Zane H. Leeper, Joint Administrative Procedures Committee.
JOINT ADMINISTRATIVE PROCEDURES COMMITTEE: Zane Leeper of the Joint Ad-
o* ministrative Procedures Committee gave a presentation on the organization
and purpose of the Joint Administrative Procedures Committee. He pointed
out that the Committee does not approve rules, but rather disapproves those
which it feels are not in compliance with the statutes. If the Committee
disapproves a rule, the Governor and the agency hold a conference to attempt
to resolve the argument; if an agreeable solution cannot be reached, the
Committee may then seek judicial resolution of the matter.
Mr. Leeper pointed out that the districts are required to adopt as
a rule all interagency agreements to which they are a party. This require-
ment is under 120.53 (method of operation of the agency) and has been
supported by the Committee on several occasions. This requirement to adopt
also applies to permit application forms.
Mr. Leeper stated that he felt standardization of format for all
water management district rules would be advantageous.
RULE STANDARDIZATION: It was generally agreed that standardization of the
format and numbering system for rules for all districts would be desirable.
A numbering system was proposed, and was found generally acceptable (Attach-
It was agreed that whatever system is finally adopted it should pro-
vide sufficient flexibility to allow for necessary changes. It was sug-
gested that rules concerning individual basins be given separate numbers
and that separate guidelines be established for the policies and procedures
It was felt that it would be helpful to establish an informal clearing-
F house of district rule writers to resolve problems individual districts may
have with the numbering system. A suggestion was made to hold quarterly
meetings of the district staff members involved in rule writing. This
meeting could be used as the clearinghouse.
An announcement was made that the Secretary of State's office has
reserved Chapter 40 of the Administrative Code for use by the districts.
The districts should be able to use this number by the end of the year.
RULES AND REGULATIONS GOVERNING WATER WELLS: An announcement was made
that the Department of Environmental Regulation would soon be revising
Chapter 17-20, 17-21, and 17-22, and would be soliciting suggestions for
revision of these rules. Discussion was held regarding district concerns
with 17-20 and 17-21. It was generally agreed that the delegation of authority
for 17-21 is unclear and that the authority for enforcement of the rule is
ambiguous. It was also generally agreed that, while the districts did not
want to undertake licensing of water well contractors, they (the districts)
regularly have problems with repeated rule offenders who remain licensed.
Northwest Florida Water Management District and St. John River Water Manage-
ment District were the only districts who appeared interested in assuming
responsibility for licensing.
Additional suggested changes to 17-21 were listed. These include:
a. expand the definition of "well to include elevator, shafts,
JV grounding shafts, exploratory boreholes, and sandpoint wells;
b. more clearly define who has responsibility for abandonment
of wells (i.e. it would presently appear to rest with the
property owner, whereas many consider this to be more appropriately
a responsibility of the state);
c. specifications for quality of boiler "make-up water" should be
d. language about temporary dewatering needs to be changed;
e. well completion reports should be filed 30 days after completion
of the well, and the time a well is completed should be established
in the rule;
f. more uniform interpretations of size and diameter should be given
(e.g. specify inside or outside diameter?);
g. the rule should include better specifications for PVC pipe;
h. wells should be cased to 10 feet below pumping level;
i. provisions should be made to require the well driller to properly
develop the well;
4 j. specifications should be made regarding the type of drilling mud
used (some degradable mud has been found to be a good medium for