| Material Information
||commentary on the General Water Policy Proposed Hearing Draft
||Letter to Victoria Tschinkel, Secretary, Department of Environmental Regulation (DER) from Gerald Grow, Editor, ENFO, with commentary on the General Water Policy Proposed Hearing Draft dated May 7, 1981
||May 14, 1981
||North America -- United States of America -- Florida
||Box 5, Folder 25 ( SF STATE WATER POLICY - VOL. III ), Item 7
||Digitized by the Legal Technology Institute in the Levin College of Law at the University of Florida.
809 Teague Drive C i [
Tallahassee Fl 32303, ""
May 14, 1981
MAY 20 1981
Victoria Tschinkel, Secretary
Department of Environmental Relgulation Office o the Secretry
Twin Towers Office Building
Tallahassee FL 32301
I would like to register my responses to the General Water Policy
Proposed Hearing Draft dated May 7, 1981.
1. In general, I think this is a much better, clearer document than
the last one, and I like it. More specifically,
2. In line 2 of section (5), should that be "aquifer recharge?" It
now reads "aquifer discharge." I don't recall hearing about aquifer
discharge areas, whereas aquifer recharge areas are very important to
water quality and quantity.
3. I am confused about the meaning of section (9). First of all,
the phrase "flood damage consistent with" reads like a related group
of words, whereas I think they contain two referents. Second, the term
"desirable" leaves much to be desired. Desirable by whom? How determined?
Third, section (9) implies but does not name the inevitable conflict
between "flood control" and "natural water management systems" referred
to in section (4). Natural water management systems, such as the Kissimmee
River, include flood activity and wide fluctuations in water level,
especially in South Florida.
If mechanisms already exist for settling conflicts such as this one
(between flood control and natural management systems), it would be good
to footnote them in the final annotated draft of the Water Policy, so
citizens can more fully grasp the governmental structures established to
determine water policy.
If mechanisms do not exist to settle such conflict, they need to
4. I am in strong agreement and support of:
Item 2: reserving water for recreation and wildlife;
Item 3: require conservation in water management programs;
Item 3: use water of lowest acceptable quality;
Item 4: preserve and restore natural water management systems;
Item 5: protect wetlands etc.
Item 6: mitigate impacts of prior alterations of hydroperiod;
Item 7: establish minimum flows;
Item 8: encourage non-structural solutions (Strong support of this
one). Query: who determines what "adequate consideration" of
-T -TT non-structural alternatives is?
Item 11: local and regional supplies;
S.: Item 13: interstate agreements.
MAY 26 1981
ept. of Environmental Regulation
Office of General Counsel
I want to commend you and your staff on your excellent work in
re-drafting the General Water Policy. Except for item 9 as noted, which
I do not really understand the wording of, I very much prefer the May 7
draft to the draft withdrawn at the last hearing.
Thank you all for your patient hard work.