Title: Addendum and Errata for Economic Impact Statement dated Novemeber 15, 1994
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Title: Addendum and Errata for Economic Impact Statement dated Novemeber 15, 1994
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Spatial Coverage: North America -- United States of America -- Florida
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Abstract: Addendum and Errata for Economic Impact Statement dated Novemeber 15, 1994, SWFWMD Project No. P261, Dec 2, 1994
General Note: Box 10, Folder 14 ( SF-Water Use Caution Areas-SWFWMD - 1993-1994 ), Item 3
Funding: Digitized by the Legal Technology Institute in the Levin College of Law at the University of Florida.
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Bibliographic ID: WL00002288
Volume ID: VID00001
Source Institution: Levin College of Law, 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
I, I I


ITEM (1) AND (2)


Addendum and Errata for



Economic Impact Statement




dated November 15, 1994


For Revisions to Chapter 40D-2, F.A.C., Water Use
Permitting, and Chapter 40D-8, FA.C., Water Levels and
Rates of Flow, Including Rules Specific to the Southern
Water Use Caution Area


Southwest Florida Water Management District,
Project No. P261
December 2, 1994


IHZENAND SwER .
itn*suumr monoasn & Iosnsota m a socFniion
Reasure Economio Comuftutf .sH SWEngienerig


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ADDENDUM
To
Economic Impact Statement
For Revisions to Chapters 40D-2, Water Use Permitting
And 40D-8, Water Levels and Rates of Flow, F.A.C.

Dated
November 15, 1994

For
Southwest Florida Water Management District

By
Hazen and Sawyer, P.C.
in association with
Resource Economics Consultants and HSW Engineering


The following revisions to the Economic Impact Statement dated November 15,
1994 (EIS) should be made to reflect the final version of the rule revision which
was filed.


1. Page 1-16, line 27:


Replace "and what actions should be taken by the
Board" with The study will be based primarily on
water use data for the category of user studied
rather than on seasonal or localized changes in the
potentiometric surface. The study will be provided
to the Board for it to determine if rulemaking or
other actions should be taken."


This change is a requested clarification of the intent of the proposed rule revision.
The financial and economic impacts perceived by proponents of this clarification
in the revised rule are to reduce the uncertainty associated with the maintenance
of permitted water quantities held by existing users. No substantive conclusions
of the EIS are affected.


2. Page 1-18, after line 14:


Insert: "1.4.2.16


Board Reconsideration of
Permitted Water Quantities
or Other Permit Conditions


Page 1 of 3
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Addndum to Eamomic hpact Statement,
November 15, 1994


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Southwest Florida Water Management District

Within the SWUCA, if the District determines that
significant water quantity or quality changes, impacts
to existing legal uses, or adverse environmental
impacts are occurring, the Board, upon reasonable
notice to the permitted, including a statement of facts
upon which the District based its determination, may
reconsider the quantities permitted or other conditions
of the permit as appropriate to address the change or
impact, but only after an opportunity for the permitted
to resolve or mitigate the change or impact or to
request a hearing."

This change is a request to clarify existing policy and the intent of the proposed
rule. The financial and economic impacts perceived by proponents of this
addition to the revised rule are to reduce the uncertainty associated with the
maintenance of permitted water quantities held by existing users. No substantive
conclusions of the EIS are affected.

3. Corresponding changes in the standard permit conditions were made to
remove rule language in conflict with the intent of 1. and 2. above.


4. Page 1-21, after line 13:


Insert a new paragraph: "Wholesale Customers. A
wholesale public supply customer shall be required
to obtain a separate permit to effect the
conservation requirements set forth in this section
unless the quantity obtained by the wholesale
public supply customer is less than 100,000 gpd on
an annual average basis and, if applicable, per
capital daily water use of the wholesale public
supply customer is less than the applicable per
capital daily water use requirement outlined in
Section 3.6 of Chapter 3 of the revised rule."


See Section 3.2.1.6, Estimate of the Change in Cost or Economic Benefit to All Persons
Directly Affected by the Revised Rule Changes, Water Supply Utilities and Customers,
Cost to Reduce Per Capita Water Use Rate from 150 to 110 gpcd of the Economic
Impact Statement dated November 15, 1994. This subsection provides a
description of the financial and economic impacts of complying with the


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conservation requirements of the revised rule. In addition to the conservation
requirement costs mentioned above, the wholesale customer will incur permit
acquisition and administration costs. Currently, only wholesale public supply
customers in the existing WUCAs are required to obtain permits.


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( ERRATA
To
Economic Impact Statement
For Revisions to Chapters 40D-2, Water Use Permitting
And 40D-8, Water Levels and Rates of Flow, F.A.C.

Dated
November 15, 1994

For
Southwest Florida Water Management District

By
Hazen and Sawyer, P.C.
in association with
Resource Economics Consultants and HSW Engineering


,P This errata lists all typographic and editing errors which were found after
publication of the Economic Impact Statement (EIS) on November 15,1994. None
of these erratum result in a change in the conclusions regarding the financial and
economic impacts of the revised rdle.

1.0 Errata Related to Rule Revision for Row Crops without Mulch

During the rule revision process, the proposed rainfall basis for row crops without
mulch was changed from seasonal 2-in-10 effective for permitted supplemental
quantities and zero effective for the initial credit calculation to seasonal 5-in-10
effective for permitted supplemental quantities and seasonal 2-in-10 effective for
theinitial credit calculation. The efficiency parameter was changed from 80
percent to a phase in of 75 percent through 2~O and 80 percent beginning in 2004
for both permitted supplemental quantities and the initial credit calculation.
These changes in rainfall basis and theefficiency phase in are not reflected in the
Economic Impact Statement (EIS) dated November 15, 1994. For all crops
modeled in the EIS, only the highest efficiency was modeled to address the final
impacts of the rule revision.

In the EIS, unmulched watermelon and potato water use, production and residual
returns to land and risk were modeled. This errata contains the changes to the


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indicated pages of the EIS concerning the financial and economic impacts as the
revised rule affects melon and potato production in the SWUCA under the revised
rainfall basis. Overall, watermelon and potato production is expected to remain
economically viable under the revised rle. No significant economic impacts are
expected as the revised rule affects watermelon and potato production in the
SWUCA although the costs of managing water may increase and net revenue may
decrease to some extent.

The following lists errata to the EIS dated November 15, 1994 regarding the
financial and economic impacts as the revised rule affects melon and potato
production.

11 Replace Paragraphs 2 and 3 on page 93-63 and paragraph 1 on page 93-64
(the paragraphs under Melon Production) with the following paragraphs
concerning melon production.

Melon Production Currny Usin SenKClosed Seepae, Irrigation :

Melons grown without mulch using semi-dosed seepage are allocated permitted
supplemental water quantities based on seasonal 5-in-lO effective rainfall and 75
percent efficiency through 2003 and 80 percent efficiency beginning in 2004 under
the revised rule. The initial credit calculation is based on the same efficiencies
and phase-in as the supplemental water quantity and the rainfall basis is seasonal
2-in-10 effective. Under the baseline regulations, melons using semi-closed
seepage are allocated water based on 60 and 70,percent effi i anianual 2-
in-10 drought rainfall. Permitted water quantities are expected to be lower than
the baseline permitted quantities.

Probability simulations of water cutbacks and yield reductions found that melons
using semi-cosed seepage and Who remain.at the baseline efficiency of 60 percent
will experience water cutbacks averaging 23 percent, higher when permitted
supplemental efficiency is 80 percent than under baseline regulations. Avy~age
yield reduction is estimated to be 33 hundredweight (cwt) per acre or 10 percent
of baseline yields of 320 cwt per acr (which ar also unresticted yields), if the
80 percent efficiency used to permit supplemental and initial credit allocations
under the revised rule are not achieved. If the percent efficiency is achieved,
the average water cutback is 0.7 percent and the average yield loss is 1.1 cwt per
acre.




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SThe grower has the option of improving water management techniques and/or
converting from semi-dosed seepage to a fully-enclosed seepage system or adding
a drip irrigation system. Alternatively the grower could maintain the existing
irrigation efficiency and accept acreage and yield reductions. This economic
analysis evaluates the economic impact of converting the semi-closed seepage
system to a fully-enclosed seepage system.

Appendix 9.3-B presents a watermelon crop budget published by the University
of Florida for watermelon irrigated with semi-dosed seepage. Residual return to
land and risk is estimated to be $371 per acre per year. The cost of converting the
semi-closed seepage system to fully enclosed is $111 per acre per year. This cost
increase was taken from Table 93.20 and is the difference between the annual cost
per harvested acre of the fully enclosed system, $445, and the annualized cost per
harvested ar.e of the semi-enclosed system, $334. Residual return to land and risk
for watermelons would be expected to fall by $111 per acre per year plus $6
revenue loss from the potential yield reduction at 80 percent efficiency (1.1 cwt
$5 per cwt) to $254 per acre per year. Watermelon production is still
economically viale when the semi-endosed seepage system is converted to a fully
enclosed seepage system although the costs of production and the costs of
managing water will increase.

Note that revenue would drop by about $165 per acre (33 cwt ($8 per cwt price -
$3 per cwt harvest, hauling and selling)) at 60 percent efficiency so it may be less
expensive to increase efficiency than to take the yield reductions. Because
estimated residual return to land and risk is greater than zero, no significant
economic impacts are expected from the revised rule as it affects watermelon
production currently using semi-dosed seepage. However, the cost to increase
efficiency and the potential revenue loss from potential yield reductions will
reduce residual returns to land and risk by as much as $165 per acre.

Melon Production Currenv Using Taveling Gun Irrgation

Melons grown without mulch using traveling gun irrigation are allocated
permitted supplemental water quantities based on seasonal 5-in10 effective
rainfall and 75 percent efficiency through 2003 and 80 percent efficiency beginning
in 2004 under the revised rule. Theinitial credit calcwationlis based on the same
efficiences and phase-in as the permitted supplemental water quantity and
seasonal 2-in-10 effective rainfall. Under the baseline regulations, melons using
traveling gun are allocated water based on 75 percent efficiencies and annual 2-in-
10 drought rainfall. Permitted water quantities under the revised rule are
S expected to be lower than the baseline permitted quantities.

Page 3 of 12 Errat for Eanomic hnpact Statemed,
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Probability simulations of water cutbacks and yield reductions found that melons
using traveling gun and who remain at the baseline efficiency of 75 percent will
experience water cutbacks averaging 4.4 percent higher when permitted
supplemental efficiency is 80 percent than under baseline regulations. Average
yield reduction is estimated to be about 8 hundredweight (cwt) per acre or 2.5
percent of baseline yields of 320 cwt per acre (which are also unrestricted yields),
if the 80 percent efficiency used to permit supplemental and initial credit
allocations under the revised rule are not achieved. If the 80 percent efficiency is
achieved, the average water cutback is 0.7 percent and the average yield loss is
1.1 cwt per acre.

The grower has the option of improving water management techniques and/or
maintaining the existing irrigation efficiency and accepting acreage and yield
reductions.

Appendix 9.3-B presents a watermelon crop budget published by the University
of Florida for watermelon irrigated with traveling gun. Residual return to land
and risk is estimated to be $237 per acre per year. If actual efficiency remains at
the baseline level of 75 percent, revenue would drop by about $45 per acre per
year (8 cwt/acre ($8 price $3 harvest, haul and selling cost). Residual return
to land and risk would fall to $192 per acre per year under the revised rule.
Because residual returns to land and risk are greater than zero, no significant
economic impacts are expected from the revised rule as it affects watermelon
production currently using traveling gun. However, the cost to increase efficiency
and the potential revenue loss from potential yield reductions will reduce residual
returns to land and risk by as much as $45 per acre per year.


1.2 Replace Paragraphs 2, 3 and the beginning of paragraph 4 on page 93-64
and the remainder of the partial paragraph at the top of page 93-65 (the
paragraphs under 93.83 Potato Production) with the following
paragraphs concerning potato production.

93.83 Potato Production

Potatoes grown without mulch using semi-closed seepage are allocated permitted
supplemental water quantities based on seasonal 5-in-10 effective rainfall and 75
percent efficiency through 2003 and 80 percent efficiency beginning in 2004 under
the revised rule. The initial credit calculation is based on the same efficiencies
and phase-in as the supplemental and the rainfall basis is seasonal 2-in-1O
effective. Under the baseline regulations, potatoes using semi-dosed seepage are

Page 4 of 12 Erraa for Eanmic Impa Statement,
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allocated water based on 70 percent efficiency (potatoes are grown in the ETB-
WUCA) and annual 2-in-1O drought rainfall. Permitted water quantities under
the revised rule are expected to be lower than the baseline permitted quantities.

Probability simulations of water cutbacks and yield reductions found that potatoes
using semi-dosed seepage and who remain at the baselirefficiency of 70 percent
will experience water cutbacks averaging 65 percent higher when permitted
supplemental efficiency is 80 percent than under baseline regulations. Average
yield reduction is estimated to be 20 hundredweight (cwt) per acre or 10 percent
of baseline yields of 210 cwt per acre (which are also unrestricted yields), if the
80 percent efficiency used to permit supplemental and initial credit allocations
under the revised rule are not achieved. If the 80 percent effidency is achieved,
the average water cutback is 0.9 percent and the average yield loss is 1.2 cwt per
acre.

Appendix 9.3-B presents a potato crop budget published by the University of
Florida for potatoes irrigated with semi-closed sepage. Residual return to land
and risk is estimated to be $464 per acre per year. Simulated yield loss under the
revised rule when actual efficiency is at the baselinelevel of 70 percent is 20 cwt
per acre resulting in an estimated net revenue loss of $180 per acre (20 cwt per
Sacre yield loss times ($10 rice loss $1 dig and haul cost)). Residual return to land
and risk becomes $283 per acre per year.

Growers with low irrigation efficiencies have the option of improving water
management techniques and/or converting from semi-dosed seepage to a fully-
enclosed seepage system or adding a drip irrigation system. According to Phyllis
Gilreath at IFAS, experiments have found that fully-endosed seepage irrigation
is a viable irrigation alternative for potatoes as long as the pipes are buried from
16 to 18 inches below the soil surface. Alteratively the grower could maintain
the existing irrigation efficiency and accept acreage and yield reductions. This
economic analysis evaluates the economic impact of converting the semi-enclosed
seepage system to a fully-enclosed seepage system.

The cost of converting the semi-dosed seepage system to fully enclosed is $111
per acre per year. This cost increase was taken from Table 93.20 and is the
difference between the annualized cost per harvested acre of the fully enclosed
system, $445, and the annualized cost per harvested acre of the semi-enclosed
system, $334. Residual return to land and risk for potatoes would be expected to
fall by $111 per acre per year plus the estimated revenue loss from reduced yield
at 80 percent effidency of $11 (1.2 cwt per acre yield loss times ($10 price loss $1
Q( dig and haul cost)) to $342 per acre per year. Potato production is still

u [ ""* *W--
Page 5 of 12 Errata for Economic hmpdt StaIumnt,
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economically viable when the semi-enclosed seepage system is converted to a fully
enclosed seepage system although the costs of production and the costs of
managing water will increase.

Because residual return to land and risk is greater than zero when actual
efficiency is at the baseline level of 70 percent under the revised rule, no
significant economic impacts are expected as the revised rule affects potato
production.

13 Replace Paragraphs 2 and 3 on page 33-37 (the second paragraph under
Unmulched Potato Production) with the following paragraphs concerning
potato production.

Unmulched Potato Production

Potatoes grown without mulch using semi-closed seepage are allocated permitted
supplemental water quantities based on seasonal 5-in-10 effective rainfall and 75
percent efficiency through 2003 and 80 percent efficiency beginning in 2004 under
the revised, rue. The initial credit calculation is based on the same efficiencies
and phase-in as the permitted supplemental water quantity and the rainfall basis
is seasonal 2-in-10 effective. Under the baseline regulations, potatoes using semi-
cosed seepage are allocated water based on 70 percent efficiency (potatoes are
grown in the ETB-WUCA) and annual 2-in-10 drought rainfall. Permitted water
quantities under the revised rule are expected to be lower than the baseline
permitted quantities.

Probability simulations of water cutbacks and yield reductions found that potatoes
using semi-closed seepage and who remain at the baseline efficiency of 70 percent
will experience water cutbacks' averaging 65 percent higher when permitted
supplemental efficiency is 80 percent than under baseline regulations. Average
yield reduction is estimated to be 20 hundredweight (cwt) per acre or 10 percent
of baseline yields of 210 cwt per acre (which are also unrestricted yields), if the
80 percent efficiency used to permit supplemental and initial credit allocations
under the revised rule are not achieved. If the 80 percent efficiency is achieved,
the average water cutback is 0.9 percent and the average yield loss is 1.2 cwt per
acre.

Growers with low irrigation efficiencies have the option of improving water
management techniques and/or converting from semi-dosed seepage to a fully-
enclosed seepage system or adding a drip irrigation system. According to Phyllis
Gilreath at IFAS, experiments have found that fully-endosed seepage irrigation

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is a viable irrigation alternative for potatoes as long as the pipes are buried from
16 to 18 inches below the soil surface. Alternatively the grower could maintain
the existing irrigation efficiency and accept acreage and yield reductions.

1.4 Replace Paragraphs 4 and 5 on page 33-39 (paragraph 4 begins with
"Implementing a fully enclosed -'7 with the following paragraphs
concerning potato production.

Renovating a semi-closed seepage system into a fully enclosed seepage system
would reduce residual returns from $464 per acre per year to $353 per acre per
year. In addition, the estimated yield loss when actual efficiency is 80 percent
under the revised nule is 12 cwt for an estimated revenue loss of $11 per acre per
year. Residual return to land and risk under the revised rule would fall to $342
per acre per year when actual efficiency is increased to 80 percent by converting
to a well-managed fully enclosed seepage system.

Adding tailwater recovery, water table monitoring, tensiometers, automated
pump/valve controllers and field flow metering would result in-estimated cost
increases of $67, $3, $7, $6 and $7 per acre per year, respectively. The grower
would implement one or more of these measures as necessary.

Potato production is still economically viable when the semi-enclosed seepage
system is converted to a fully enclosed seepage system although the costs of
production and the costs of managing water will increase. Because yield per acre
is expected to fall by 12 cwt per acre or one half of one percent even when
efficiency is increased to 80 percent, average yield per acre for the are is expected
to fall from 210 cwt per acre to 209 cwt per acre. No significant economic impacts
are expected from the revised rule as it affects potato production in the SWUCA.

15 Replace Paragraphs 4, 5 and 6 on page 33-40 (paragraph 4 begins with
"MAlons grown without mulch '9 and paragraphs 1, 2, 3 and 4 on page
33-42 with the following paragraphs concerning melon production.

Melon Production Currently Using Sem*Closed Seepagearrigation

Melons grown without mulch using semi-dosed seepage are allocated permitted
supplemental water quantities based on seasonal 5-in-0 effective rainfall and 75
percent efficiency through 2003 and 80 percent efficiency beginning in 2004 under
the revised rule. The initial credit calculation is based on the same efficiencies
and phase-in as the permitted supplemental water quantity and the rainfall basis
t( (C is seasonal 2-in-10 effective. Under the baseline regulations, melons using semi-

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dosed seepage are allocated water based on 60 and 70 percent efficiencies and
annual 2-in-10 drought rainfall. Permitted water quantities are expected to be
lower than the baseline permitted quantities.

Probability simulations of water cutbacks and yield reductions found that melons
using semi-dosed seepage and who remain at the baseline efficiency of 60 percent
will experience water cutbacks averaging 23, percent higher when permitted
supplemental efficiency is 80 percent than under baseline regulations. Average
yield reduction is estimated to be 33 hundredweight (cwt) per acre or 10 percent
of baseline yields of 320 cwt per acre (which are also unrestricted yields), if the
80 percent efficiency used to permit supplemental and initial credit allocations
under the revised rule are not achieved. If the 80 percent efficiency is achieved,
the average water cutback is 0.7 percent and the average yield loss&is 1.1 cwtper
acre.

Net revenue would drop by about $165 per acre under the revised rule which will
reduce residual returns to land and risk to $206 per acre per year when effiency
remains at the baseline level of 60 percent. It may be less expensive to increase
efficiency than to take the yield reductions. The grower has the option of
improving water management techniques and/or converting from semi-closoed
seepage to a fully-enclosed seepage system or adding a drip irrigation system. 9
Alternatively the grower could maintain the existing irrigation efficiency and
accept acreage and yield reductions.

Table 33.16 provides estimates of costs and returns associated with implementing
fully enclosed seepage, drip, tailwater recovery, water table i~onitofrig
tensiometers and automated pump/valve controllers.

Residual return to land and- risk for unmulched watermelon production using
semi-cosed seepage is estimated to be $371 per acre per year. The cost of
converting the semi-dosed seepage system to fully endosed is expected to reduce
residual returns by $111 per acre per year. Residual return to land and risk for
watermelons would be expected to fall by $111 per acre per year plus a $6 annual
revenue loss from the potential yield reduction at 80 percent efficiency to $24 per
acre per year.

Adding a tailwater recovery system to a semi enclosed seepage system is
estimated to increase costs by $66 per acre per year. Water table monitoring,
tensiometes and automated pump/valve controllers increase costs of watermelon
production only slightly ($7 per acre per year or less).


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S Watermelon production is still economically viable when the semi-enclosed
seepage system is converted to a fully enclosed seepage system although the costs
of production and the costs of managing water will increase.

Because estimated residual .return to land and risk is greater than zero when
actual efficiencies are at the baseline level of 60 percent, no significant economic
impactsare expected from the revised rule as it affects watermelon production
currently using semi-closed seepage. However, the cost to increase efficiency and
the potential revenue loss from potential yield reductions will reduce residual
returns to land and risk by as much as $165 per acre.

Melon Production Currently Using Travelin Gun Irrigation

Melons grown without mulch using traveling gun irrigation are allocated
permitted supplemental water quantities based on seasonal 5-in-10 effective
rainfall and 75 penrent efficiency through 203 and 80 percent efficiency begging
in 2004 under the revised rule. The initial credit calculation is based on the same
efficiencies and phase-in as the permitted supplemental water quantity and
seasonal 2-in-lO effective rainfall Under the baseline regulations, melons using
traveling gun are allocated water based on 75 percent efficiencies and annual 2-in-
, ( 10 drought rainfall. Permitted water quantities Ader the re~vied rule are
expected to be lower than the baseline permitted quantities.

Probability simulations of water cutbacks and yield reductions found that melons
using traveling gun and who remain at the baseline efficiency of 75 percent will
experience water cutbacks averaging 4.4 percent higher when permitted
supplemental efficiency is 80 percent than under baseline regulations. Average
yield reduction is estimated to be about 8 hundredweight (cwt) per acre or 25
percent of baseline yields of 320 cwt per acre (which are also unretricted yields),
if the 80 percent efficiency used to permit supplemental and Initial credit
allocations under the revised rule are not achieved. If the 80 pecnt efficiency is
achieved, the average water cutback is 0.7 percent and the average yield loss is
1.1 cwt per acre.

Residual return to land and risk for melon production using traveling gun
(overhead gun) is estimated to be $237 per acre per year. f actual efficiency
remains at the baseline level of 75 percent, revenue would drop by about $45 per
acre per year. Residual return to land and risk would fall to $192 per acre per
year under the revised rule. Because residual returns to land and risk ae greater
than zero, nosignificant econeic impacts are expected from the revised rule as
Q f it affects watermelon production currently using traveling gun. However, the cost

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to increase efficiency and/or the potential revenue loss from potential yield
reductions will reduce residual returns to land and risk by as much as $45 per
acre per year.

The grower has the option of improving water management techniques and/or
maintaining the existing irrigation efficiency and accepting acreage and yield
reductions. Tabl 33.16 provides estimates of costs and returns associated with
implementing fully enclosed seepage, drip, tailwater recovery, water table
monitoring, tensiometers and automated pump/valve controllers. Converting to
a fully enclosed seepage or drip irrigation system does not appear to be the most
economically or practically sound method to increase efficiency. Instead, other
less expensive methods would be used such that the cost per acre per year does
not exceed $39 ($45 net revenue loss at 75 percent efficiency minus $6 net revenue
loss at 80 percent efficiency .

Watermelon production is expected to remain economically viable under the
revised rule. No significant economic impacts are expected as the revised rule
affects watermelon production in the SWUCA although the cdts of managing
water may increase and net revenue may decrease to some extent

2.0 Errata Which May Clarify the Meaning of the Text

The following are errata which may clarify the meaning of the text.

2.1 On Page 1-14, delete "and Intermediate" from the Section 1.42.11 heading.

22 Delete the following paragraphs: page 9.1-14 the last paragraph beginning with
"Under the proposed SWUCA rule revisions..." and page 9.1-15, the top partial
paragraph and the firs two full paragraphs beginning with "Water quality from
confined aquifers... an ending with "water becomes scarce relative to demand."
These paragraphs are ielicafrom the Prelimnary Economic Anaysis Report of the
Proposed SWUCA Wa ter Management Plan, January 1994. They serve no
purpose in this part of the EIS.

23 Replace the title of the table after page 9.2-74, "Table 92-24: Calculation of
Water Supply Costs" aithe tihe ee "Table 9.2-25: ralculatim of Water Supply
Castsfor0.67, 334 and 667 mgd Facilitiesi on all six pages of table.

2.4 In Section 93 replace all references to the "proposed management plan",
"Management Plan" and "S WCA Management Plan' with "revised rule".


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2.5 On pages 93-45 and 93-46, make the following replacements. The water use
efficiency parameters for citrus were changed from the SW CA water
management plan parameters during rule revision. Citrus was modeled using
these new parameters reflected in the revised rule and the Tables in the EIS,
Sections 33 and 93, reflect these changes. Iswever, the text on this page was
not edited to reflect the results of this latest model run.


PAGE NO. LINE NO. ERRATA
9.3-45 19 replace "70" with "85.4"
9.3-45 20 replace "three" with "1.5"
9.3-45 22 replace "four" withi three"
9.3-45 23 replace "17.6" with "62"
93-45 24 replace "12" with "8"
9.3-45 26 replace "2.1" with "13"
93-45 31 replace "1.9" with "13"
93-46 1 replace "35" with "3.1"
9.3-46 2 replace "3.0" with "23"

2.6 On page 93-18, beginning with line 19, remove the last two sentences of this
paragraph because it was decided not to try to assume acreage projections for
potatoes: "While formal projections ..... within the ETB-WUCA."

2.7 Make the following word and section reference replacements.

PAGE NO. LINE NO. ERRATA
93-68 19 replace "confined" with "loridan"
Section 9.4 all pages replace "confined" with "Floridan"
9.4-1 22 replace "is" with "can be used to calculate"
9.4-6 26 replace "7.1" with "9.4.1"


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Pae I1 of 12
Hwd4.3MW4


Erata for EcMomkic hIqpd SiU St,
Novwur 15, 1994


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Southwest Florida Water Management Distrct

3.0 Changes Made Directly to the Economic Impact Statement dated
November 15, 1994

Some changes were made directly to the EIS dated November 15, 1994. These
changes do not change the financial or economic conclusions. They were made
to clarify the meaning of a paragraph, to improve the interpretation of a Section
or to improve the formatting. They were made directly to the document for the
ease of the reader.

31 On page 9.1-1, the top paragraph was added to summarize the purpose of Section
9.1.

32 On page 93-6, note that the second paragraph has been rewritten for clarity.
This rewrite better reflects how nurseries were evaluated in this ES.

33 In Section 33, the tables were renumbered on the tables and in the text.
Originally, Table 331 did not exist. Now the tables are numbered such that the
first table which appears' in this section fs Table 33.1.

3.4 The page numbering in the Table of Contents was changed to conform to the
actual page on which each section begins.


Page 12 of 12
Ha~4463AM42


Errata for Ecaonmic hpct SWat 9t,
November 15,1994


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ITEM (3)


r\ January 9, 1995

MEMORANDUM

TO: Governing Board

FROM: Jay Yingling, Senior Economist, Planning Department

SUBJECT: Analysis of Revisions to Chapters 40P-2 and 40D-8,, F.A.C.,
and Basis of Review Approved December 20, 1994

I have been asked by the Office of General Counsel to review the
revisions to the SWUCA rules which were proposed and approved as
Exhibits I through 4 (attached) at the December 20, 1994 Governing
Board meeting to see if they would alter the conclusions of the
Economic Impact Statement (EIS). Most revisions appear to be
editorial changes or clarifications and have no significance in terms
of economic or financial impacts. However, there are two exceptions.
In Exhibit 1, the addition of "based on. an average of the previous"
changes the literal meaning of the sentence. Permitting from the
Floridan aquifer could likely resume earlier under the revised
language than under the previous. This could also make a larger
quantity of relatively less costly Floridan water available to
permittees in the future (assuming that levels in the aquifer
rebound). The previous language would have required that levels
remain above the adopted levels for five consecutive years.'

The second exception is item 11 in Exhibit 2 regarding wholesale
public water suppliers. The revisions indicate that wholesale public
water suppliers in the rSWUCA may be required to obtain permits. -The
previous language indicated that this was a District-wide requirement.
The wholesale public water supplier permit requirement was addressed
in the Addendum to the EIS (p. 2 of 3). The Addendum is attached for
your information. The revised language will relieve wholesale public
water suppliers outside the SWUCA and the NTB WUCA from having to
incur the permitting and permit condition compliance costs addressed
in the Addendum.

In summary, the two exceptions tend to lessen potential economic and
financial impacts of the proposed rules. Therefore, the revisions do
not significantly affect the overall conclusions of the EIS. If you
should have any questions, please feel free to call me at extension
4406.

JWY
Attachments
cc: Mark Farrell
Richard Owen
Karen Lloyd
Ken Weber
Grace Johns (Hazen and Sawyer)


I





e I

Governing Board Meeting
December 20. 1994


Rulemaking
Public Heaing Approal
Revisions to Chapters 40D-2 and 40D-8.628. Florida Administrative Code.
Including Rules to Implement the Southern Water Use Caution Area

It has come to staffs attention that there is a correction required in the language regarding
the minimum level in the Basis of Review Section 4.3 as approved by, eit aron
November 15, 1994. Thea language should be corrected as shown in Exhibit No. 1. The
correction reflects the manner in which staff intends to use the minimum level and reflects the
explanation that has been given by staff at public meetings as to howthetminimumlevel will
be used.

All counsel and representatives for the groups that previously petitioned for a headrig on the
rules have been advised of this proposed correction.
Staff also requests that the Board ratify the typographical and scrivenerserrors that were
corrected with the publication draft. Exhibit No. 2 contains a i'ting of those matters.

Staff Recommendation: See Exhibits to this Item

Approve the changes reflected in the Exhibits to this item.

Presenters: Kenneth A. Weber, Chief Regulation Geologist, Technical Servibes,
Resource Regulation
Karen A. Uoyd, Senior Attomey, Office of General Counsel:






;+














The following change is proposed to be made to Section 4.3 MINIMUM

FLOWS AND LEVELS:



Within the Southern Water Use Caution Area (SWUCA). new groundwater

quantities will be permitted to be withdrawn from the Floridan

aquifer when the potentiometric surface has. Mem based on an

average of the previous five consecutive years. been above the

minimum level established in 40D-8.628. F.A.C.. and depicted in

Figure 4-1. and the potentiometric surface resulting from the

C proposed withdrawals together with the annual average withdrawal

for the previous five years as determined by the District will

remain above the minimum level established in 40D-8.628. F.A.C..

and depicted in Figure 4-1. Withdrawals from the Floridan aquifer

associated with an aquifer storage and recovery project are

excepted and may be permitted so long as. on a cumulative basis, no

more is withdrawn than has been previously stored. Further.

withdrawals may be permitted for crop protection. which is limited

to irrigation for frost/freeze protection and wind storm

protection. Permitted withdrawals from the Floridan aquifer will

j- not be considered to be in violation of this paragraph because of


, I





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a seasonal or localized lowering of the Floridan aquifer
potentiometric surface.









EXHIBIT NO. 2

Errata Sheet

1. 40D-2.031(3): Change effective date of SWUCA rules from "
S1994" to 199_."

2. 40D-2.321(4): Correct reference to "40D-2.301(2) and (3)" to
be "40D-2.321(2) and (3)."

3. 40D-2.331: Correct reference to "40D-2.331(3)(a) and (b) to
40D-2.331(3) and (4)."

4. 40D-2.801(3): Correct so that no change is proposed rather
than inadvertently striking the part of the sentence that
reads "...reaffirms the declaration of Water Use Caution Areas
and.... "

5. 40D-2.801(3) (b)7. (a), (b) and (c) : Add note that all
references to Townships are to Townships "South" and all
references to Ranges are to Ranges "East."

6. 40D-2.801(3) (b)8.: Add "" around words 'three prong test.'

7. Basis of Review, Within Section 3.1, the Section titled
"STANDBY QUANTITIES WITHIN THE SWUCA", the paragraph titled
"Standby Permits When Using Alternative Sources Within The
SWUCA" and the Section titled "REACTIVATION OF STANDBY
QUANTITIES WITHIN THE SWUCA": correct references to paragraph
titled "Alternative Source Standby Permit" to be
"5. Alternative Source Standby Permit."

8. Basis of Review, Within Section 3.1, the Section titled
"ALTERNATIVE SOURCES WITHIN THE SWUCA": correct reference to
paragraph tilted "Alternative Source Suppliers" to be
"Alternative Source Suppliers Within The SWUCA."

9. Basis of Review, Within Section 3.1, the Section titled "USE
OF RECLAIMED WATER AND STORMWATER WITHIN THE SWUCA" :
a. after the words "Section 3.1" and before the word
"titled" insert the words "the subsection";
b. delete "Part IV permit, as that term is defined in
Chapter, Section 2.2 of this Basis of Review," and insert


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1,1 LI






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"a permit issued pursuant to 40D-4 F.A.C." since "Part IV
permit" is no longer defined in the rules or Basis; and
c. in the paragraph titled "3. Surface Water Utilities":
after the words "Chapter 3" and before the words "titled
"Per Capita Daily Water Use Within the SWUCA" insert the
words "the subsection"; capitalize the title "Per Capita
Daily Water Use Within the SWUCA"; and after the words
"Chapter 3" delete "which paragraph is" and insert the
words "the subsection."
10. Basis of Review, Within Section 3.3, the paragraph titled
"Irrigation Water Use Allotments Within The SWUCA" correct the
reference to "Section 3., Basis of Review" to be "Chapter 3,
Basis of Review."

11. Basis of Review, Within Section 3.6 the subsection titled
"WHOLESALE CUSTOMERS":
a. the subsection titled "WHOLESALE CUSTOMERS" is clarified
to be "WHOLESALE CUSTOMERS WITHIN THE SWUCA";
b. after the words "annual average basis and", delete the
words "if applicable";
c. clarify the reference to "Section 3.6 of this chapter 3"
to be "Section 3.6 of the subsection titled "PERMIT
QUANTITIES AND COMPLIANCE WITH PER CAPITAL WATER USE
WITHIN THE SWUCA."

12. Basis of Review, Within Section 3.6, the subsection titled
"SERVICE AREA POPULATION ESTIMATES AND PROJECTIONS WITHIN THE
SWUCA", the subparagraph titled "(1) Public Lodging Data":
a. correct reference to "WUCA" to be "SWUCA";
b. after the words "Section 3.6" insert "under the
subsection titled "PER CAPITAL DAILY WATER USE WITHIN THE
SWUCA, under";
c. correct reference to the paragraph titled "Significant
Use" to be "Significant Use Within The SWUCA."

13. Basis of Review, Within Section 3.6, the subsection titled
"PERMIT QUANTITIES AND COMPLIANCE WITHIN PER CAPITAL DAILY
WATER USE WITHIN THE SWUCA":
a. correct title to read "PERMIT QUANTITIES AND COMPLIANCE
WITH PER CAPITAL DAILY WATER USE WITHIN THE SWUCA";
b. in the subparagraph titled "Permitted Quantities Within
The SWUCA-Existing Permits": capitalize titled reference
to "SERVICE AREA POPULATION ESTIMATES AND PROJECTIONS

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WITHIN THE SWUCA";
Sc. in the subparagraph titled "Permitted Quantities Within
The SWUCA-Renewals, Modification Or New Permits To
Increase Quantities": clarify by adding after the words
"shall be based on" the words "those subsections and
paragraphs in" and deleting the words "the paragraphs"
following the words "Section 3.6."

14. Basis of Review, Within Section 5.2, the paragraph titled
"Metering Of Alternative Sources Within The SWUCA": insert the
word unnumberedd" after the words "the first" and insert the
word unnumberedd" after the words "the fifth."


































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EXHIBIT NO. 3



The following change is proposed to be made to Rule 40D-2.301(2)

CONDITIONS FOR ISSUANCE OF PERMITS:


(2) Applications for modifications of permits, renewal permits.

Reallocation Permits and Ground Water Withdrawal Credit Permits

within the Southern Water Use Caution Area (SWUCA) are presumed to

meet 40D-2.301(1) (a)-(n) so lona as the withdrawals meet or do not

exceed the criteria set forth in the Basis of Review described in

40D-2.091. This presumption is necessary to facilitate movement


(reallocation) of existing permitted around water auantiti n within


the Southern Water Use Caution Area (SWUCA)


Since the Digtrir1-


has already determined that on a regional cumulative basis existing

withdrawals are causing uneaeepae-a adverse impacts, without this

presumption any permit application, including those for

reallocation could be determined not to meet the Conditions for

Issuance in 40D-2.301(1)(a)- (n) even though there may be no net


increase in withdrawals from within the SWTrIA


- -


.










EXHIBIT NO. 4



The following change is proposed to be made to Rule 40D-8.628(2):



(2) The 1991 annual average potentiometric surface for the upper

Floridan within the SWUCA is depicted in Figure 8-1. This

potentiometric surface is derived by averaging the upper Floridan

aquifer potentiometric surface maps for May and September 1991 as

published by the U.S. Geological Survey. The averaging process

consists of interpolatina the potentiometric values from each map

to a common grid with each arid cell one mile by one mile 4 ft

> tr- h-b I. -me batear. The two potentiometric values at each

point on the grid are averaged and the grid of average values is

contoured to produce the 1991 annual average potentiometric

surface. The data. maps. computer procedures and documentation

upon which the 1991 annual average potentiometric surface is based

are contained at the District's Resource Data Department. MaDpina

and Geographic Information System Section and in central records

file AL-00085 Southern Water Use Caution Area/Rules.




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