AMERIJAN WATER WORKS ASSO, NATION /
\t D .s REPLY TO
S3 X C;'ll cnInnIuI /
rry W. Knepper, P.E. "-
/ epper & Willard, Inc.
ri ,,. i 01 N. Westshore Blvd., Suite 27
Spa, FL 33607
Ovi "Kf I K June 4, 1981
PALM L .ir:-; xr iTin 44
O LD K ,l'fk ."S; F&OAD
( ti FiMArN [. .;r
'" sMs. Victoria Tschinkel
TAMPA WA1ErI ." 'T .- .
1C.TYArLiI tAzA Secretary, Florida Department
"rI-fA !": of Environmental Regulation
PAsi-IHAiiMAN. Blair Stone Road
rrou. POPE.. Tallahassee, Florida
ORLANDu ur it II1IS COMMISSION
okLAt.u uu.. Re: Water Polic Chapter 17-40
trtic1 fzF7 40.03 General Policy
: C H: IGCU
AMRi- oAN C. ,N o Dear Ms. Tschinkel:
P L ->0kL A :;'
The following comments are provided for your in-
SECR.,, r L Lt:;:L.LEC) formation and consideration as input for the
EVEREL [ KINLO(.,tC
R c.IR oUTow rule-making process for the subject proposed
,,N.cLNmArELAVl policy. These comments consist of those made
by members of the Water Resources Committee,
UH7(,, which serves the Florida Section, American
DAVID L CH,,,"
nTIAtr i.:, Water Works Association and the Florida Pollution
Control Association. Membership in these two
OH(i ANDO. :-2til-A;
associations consist of professionals in the
,u fields of water resources in general and water
,i, supply and wastewater treatment and disposal
tY VC i"i in particular, as well as other interested and
,Zii t1-iH B.'; LVD concerned people. Total membership approximates
lit ~ 2500 people and represents a cross section from
T government, consultants, utilities, education,
..., industry and many other fields.
w..,HA.N ... Comments were made on the January 16, 1981, draft
A,, of the entire water policy by committee members
Fr: U JOF LU;:s and directed to you through our Joint Associations
o..u Legislative Committee. Those comments essentially
n LAn'i:h" n": indicated that most if not all of what was addressed
S,-,. was already covered by existing laws and regulations.
^.M., However, specific comments were made and some of
cNt:,L.LE 3?b2 those comments are repeated herein where applicable
m,,,e to Article 17-40.03. Those statements not speci-
snO I o-uN fically mentioned herein are considered desirable
COCOA Ufit IlflES "'rt.ULIC W-ORKS
U' r 1 riii bNt- ic ui( KS-
2.11 rUt i,.E
.A-nA : .,2 continued .
JAMI IA Or'i_
UNIVcRSITY Oi (' Nr IAL ORlDA
Q Jk 'c 'AWWA PONI fRN^tCE. ST LOUIS MO JUNE 7 12. 1981/AWWA-FPCA-FW & PCOA JOINT CONFERENCE. MIAMI BEACH FL, NOVEMBER 10 14. 1981
SOUTHWEST FLORIDA WATER MANAGEMENT DISTRICT / i? *
Crespondence Action and Routingo, *
XEROX SENDER <" ORIGINAL TO
INFORMATION (COORDINATE WITH )
Executive Director 1
Asst. Ex. Director Asst. Ex. Dir.
Dir. Data Proc. Dir. D. Proc.
Dir. Employee Rel. Dir. Emp. R.
Dir. Field Services____ Dir. Fd. Ser.
Dir. Finance Dir. Finance_
Dir. Gen. Ser.______ Dir. Gen. S.
Dir. Regulatory Dir. Reg.
Dir. Res. Dev. Dir. Res. D.
Dir. Tech. Sup. Dir. Tech. S.
I. A. Coord. I. A. Coord. IA...
Prog. Coord. ____ Pg. Coord.
Ed Hoyt Hoyt
Public Information Public I.
L. M. Blain
Chairman, Gov. Bd. --- SUSPENSE:
Vice Chairman, G. B. REMARKS:
Ms. Victoria Tschinkel
June 4, 1981
goals, which we support. We do urge caution in how such
goals are interpreted or who does the interpreting so
that decisions about Florida's water resources are not
unjustly biased or unfairly restrictive.
Section 17-40.03(3) There is some concern that
various users will be required to use lower
quality water than may be available or plentiful.
As an example, it would be hoped that a community
would not be required to cut back on its use of high
quality Floridan Aquifer water (which is more than
sufficient to serve the community's needs) so that
other water, such as a surface water of some distance,
or installation of a costly secondary distribution
system would be required so as to use "lower quality"
water for irrigation and other nonpotable uses.
Such a decision should be based on a plan which has
assessed the resources available, amount needed, and
the facilities/management alternatives to meet needs
with the resources available.
Section 17-40.03(5) It is hoped that protection is
achieved primarily through regulation rather than
acquisition. Wetlands and flood plains do not provide the
primary natural recharge to the aquifer when one con-
siders their relatively small area when compared to
other land areas of the State. Consequently, the
benefits gained when compared to the expenses must
be carefully evaluated before purchase is made so
funds are spent wisely and not just for the sake
of buying "wetlands."
Section 17-40.03(7) Use of the word "protect" as
used in this section could be interpreted as meaning
no allowable changes could occur. In order to be
more consistent with Chapter 373, it would seem that
terminology such as "that would prevent significant
detrimental impact to the" or "that would not result
in significant harm to the" would be more appropriate.
Section 17-40.03(10) It is suggested that the word
"oil" be deleted and a broader term "pollution" be
inserted. As such, careless aquatic weed control
should then be reduced or eliminated so dead and de-
caying vegetation is not allowed to accumulate upstream
Ms. Victoria Tschinkel
June 4, 1981
from a control structure and result in depleted
oxygen levels, nutrient enrichment and sludge buildup.
Section 17-40.03(11) Generally, water supplies are
developed locally and later expanded to outlying
areas as the needs arise. It's a matter of simple
economics the further one must go for water, the
more expensive it becomes because of the facilities
necessary to get it to where the needs are. Other
factors enter into the decision as well including
water quality and source reliability, but it appears
this section is intended because of a political problem
between the areas who have or do not have water.
As long as the use is reasonable, beneficial and
does not adversely affect existing water users,
water "transfer" should be acceptable. In order to
address the potential problem, it is suggested that
the basic questions of how much resource is available,
where are the needs, and how can the needs be met with
the available resource be answered for the State
as a whole and within each of the water management
districts. Then, and only then, will we get a
true picture of whether or not transfers of water
will even be necessary and if so, where and how can
they be accomplished without adverse affects on the
Hopefully, the comments will provide you some "food for thought"
as you deliberate the adoption of Article 17-40,03 at
the June 8 hearing. If we can be of any further assistance
in the matter or in other matters related to Florida's
water resources, please feel free to call on us.
Very 1ruly yours,
Terry W. Knepfpr, P.E.
Chairman, Water Resources Committee
cc: Roy Likins, Chairman FS/AWWA
Garrett Sloan, President FPCA
Tim Brodeur, President FW & PCOA