Title: Standardization of Rules
Full Citation
Permanent Link: http://ufdc.ufl.edu/UF00052782/00001
 Material Information
Title: Standardization of Rules
Alternate Title: Excerpts from Memo of June 15, 1977 from Littlejohn to Joseph M. Landers re Standardization of Rules, and changing the rule numbers from 16 to 17 with arguments for and agains
Physical Description: 3p.
Language: English
Publication Date: June 15, 1977
Spatial Coverage: North America -- United States of America -- Florida
General Note: Box 5, Folder 18 ( SF Rules, Standardization of Numbering ), Item 48
Funding: Digitized by the Legal Technology Institute in the Levin College of Law at the University of Florida.
 Record Information
Bibliographic ID: UF00052782
Volume ID: VID00001
Source Institution: University of Florida
Holding Location: Levin College of Law, University of Florida
Rights Management: All rights reserved by the source institution and holding location.

Full Text

' Page Four
Joseph W. Landers .. ^Waf / OF ^/^^//

June 15, 1977 4d 7rr

I later found that Cressee had ignored the Department
request to greatly increase operations funding. I then wrote a
letter for you to send to Cressee which recommended increased
operations funding and sent a cony to all HIMD's. This letter apparently
had no impact.
During the session, we continually sought to obtain a com-
promise between UMD's and the Governor's office, arranged for a
meetinn with thi wovro n vr.r, an, na- a noint+ of rmam ininnr neutral
during Legislative Budget hearings. One result of our efforts was
a softening of the Governor's position on land acquisition.
There was no effort made by Buddy or other Wi3ID lobbyists
(except Morgan) to communicate during the session. I personally
lobbied in behalf of the 3 newer districts in an effort to obtain
adequate funding for operations. Several points should be made:
1. Our original budget request was supportive of both the
older districts for '!RDA and the newer districts for operations.

P 2. Although time was short, we should have given the WMD's
a chance to review our rocomnndations prior to submission to the
3. Our efforts on the task force were primarily those of
correcting mistakes and refining arguments rather than developifgq
4. Although the Governor's office wanted secrecy, I should
have alerted you to the potential impact of excluding W1oD's. Had
I done so, you would have likely insisted that they be included.
5. Our recommendations to Cressee were for an equivalent
amount of funding to U'D's as last year, only for different purposes.
6. Had we actively lobbied in the Governor's behalf during
the session, we may have made a substantial difference in the amount
of !RDA allocated. We chose not to. (For details, refer to attachment

Standardization of Pules

The program proceed without incident until iuddy raised
the technicality of whether the Secretary of State's office would
F^ object to new- rules boina adopted with the same number. !e suggested
(over the phone) changing the letters 1l01 to 1IR.01, etc. \.e in
turn suggested changing the rule numbers to 17. He said this sounded


Joseph W. Landers
Paqe Five
June 15, 1977

At the next standardization meeting, I suggested this change
and all agreed. Buddy attended this meeting but may have Been out
of the room when I brought it up. In either case, it was not con-
During the next quarterly meeting, all HMD's raised hell
about Chapter 17 and requested that they remain in Chapter 16.
'Buddy denied having agreed to Chapter 17.
Rip Caleen attended the next standarization meeting at
which Buddy and John Iheeier argued for a separate Chapter designation
for tiMD's. The arguments were not strong (see below).
Rip decided to go directly to Secretary of State's office
and.you stated that you had simply made the decision and "low-keyed"
it at the next quarterly meeting.

Buddy orchestrated a series of phone calls to Liz Cloud,
she kicked it up to Shrieve and things are on hold for the time being.

SA summary of arguments for and against changes to Chapter 17
is as follows:
Arguments For:

a. Go to one Chapter Quantity and Quality.

b. Department association with WMD's under 373.

c. Logical way to go since they have to change anyway.

d. Not sure can get separate number.

e. Delegation if delegate provisions of 17 rule to
another rule, then would have one rule reference
another Chapter.

f. Confusing to public if all water permitting isn't
in one Chapter.

Arguments Against:

a. MMD 16-X rules sometimes referenced as DNR rules
in Administrative weekly.

^ b. Tired of changing, want own numbers.
c. RPC's Loxahatahee have own rule numbers.

-1t E N* 0

Joseph W. Landers
Page Six
June 15, 1977

d. Really want different rules for each WI1D some
numbers for all IMD's a compromise.

A few points can be made:

1. I think Buddy has been inconsistent in his position
but has denied this to McAteer.

2. This issue has been blown way out of proportion,
mostly by Buddy.

3. I think Rip should be present when we discuss this.

Oklawaha Basin Controversy

Buddy requested an Attorney General's opinion as to whether
District funds collected within the Oklawaha Basin should be trans-
ferred to the SJRWMD (about $200,000). The AG's response was that
such transfer was not authorized under Chapter 373 and that further-
more no transfers of district funds was permissible.

This ruling caused the SJRWMD a lot of trouble while the
SIFMM!MD Board was apparently willing to transfer the $200,000. The
question is "Why did Buddy request the oninlon and did he have any
input into the final opinion?" Herb Webb in particular thinks Buddy
was playing games here. ,'

Hooker's Prairie/ W.C. Grace
Terry Cole had some problems with a permit granted to
U. C. Grace phosphate in Hooker's Prairie by S'FWMMD. I casually
mentioned this to Buddy at the !NPFHWID meeting in Wakulla Springs
so he could anticipate controversy and alert SIUF1MD staff and
Board members. .

The next thing I knew McAteer had said that I was "bad
mouthing" S!UFFMID. I called Buddy and McAteer to clear the air.
No specifics were given.
The point here is that in attempting to help SFUIFMD
things got distorted and I was accused of subverting their pro-
C\ gram.

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