Title: Letter: Adoption of SWUCA Rules
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Permanent Link: http://ufdc.ufl.edu/WL00002300/00001
 Material Information
Title: Letter: Adoption of SWUCA Rules
Physical Description: Book
Language: English
 Subjects
Spatial Coverage: North America -- United States of America -- Florida
 Notes
Abstract: Letter: Adoption of SWUCA Rules, Oct 20, 1994, To: SWFEMD Board Members, From: Jim Cox
General Note: Box 10, Folder 14 ( SF-Water Use Caution Areas-SWFWMD - 1993-1994 ), Item 15
Funding: Digitized by the Legal Technology Institute in the Levin College of Law at the University of Florida.
 Record Information
Bibliographic ID: WL00002300
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
JOE L DAVIS INC. 81t373ee11 P.92




JAMES L. COX
1014 LAKE HOLUINGSWORTH DRIVE
LAKELAND, FLORIDA 33803




OCTOBER 20,1994


TO: SWFEMD BOARD MEMBERS
FROM: JIM COX

COPY TO: PETE HUBBELL
MARK FARRELL

SUBJECT: ADOPTION OF SWUCA RULES.


THE URGENCY WHICH I HAVE ESPOUSED SO FREQUENTLY HAS
BEEN OVERCOME BY A SERIES OF CONCERNS AS TO THE PROPOSED
SWUCA RULES.

SOME OF THESE CONCERNS ARE:

1) SEVERAL OF THE BOARD MEMBERS ARE NOT "COMFORTABLE"
WITH WHAT WE ARE DOING.

2) THE SWUCA RULES DO NOT ADDRESS THE PROBLEMS IN THE
MOST IMPACTED AREA OF THE DISTRICT -THE NORTHERN TAMPA BAY
AREA. THE GENERAL PUBLIC DOES NOT UNDERSTAND THRE SIGNIFICANCE
OF THE FACT THAT THE SWUCA AREA AND THE NORTHERN TAMPA 3Sy
AREA ARE DIFFERENT HYDROLOGIC BASINS. HOW DO WE ANSWER THE
QUESTION ASKED BY A PERSON IN AN INLAND COUNTY "WHY ARE YOU
ISSUING STRICT RULES FOR US BUT NOT ISSUING RULES TO GOVERN
PINELLAS AND PASCO COUNTY?".

3) THE BOUNDARIES OF THE SWUCA, EVEN IF TECHNICALLY
CORRECT, ARE CAUSING NEEDLESS CONFUSION AND ANTAGONISM. WE
MUST, OF COURSE, B~ PREPARED TO DEFEND THE BOUNDARIES ON A
TECHNICAL BASIS (EVEN IF THE TECHNOLOGY IS MURKY) BUT WITH
PROPER EXPLANATION:SLIGHT VARIATIONS WILL PROBABLY BE
ACCEPTABLE.

4) IN THE ..ABSENCE OF AGGRESSIVE AND COOPERATIVE
MANAGEMENT OF THE WATER RESOURCE BY PERMITTEES, THE PHOBIA
AGAINST "MICRO-MANAGEMENT" IS DIFFICULT TO JUSTIFY. THE
REFUSAL OF SOME WATER SUPPLIERS TO FACE THE FACT THAT THE
PRICE OF WATER MUST GO UP IS ILLUSTRATIVE OF THIS ATTITUDE.
PERHAPS WE HAVE TO ACCEPT THE BURDEN OF FORCING WATER PRICES
TO RISE, AS A CONSERVATION MEASURE, TO EASE THE POLITICAL
PROBLEMS OF LOCAL GOVERNMENTS AND WATER SUPPLIERS.


i




JOE L DAVIS INC. 8137738011 P.83
0 0

-2-




5) IN THE CASE OF PUBLIC SUPPLY THE RULE RELIES HEAVILY
UPON PER CAPITAL CONSUMPTION. THIS CONCEPT IS DIFFICULT TO
DESCRIBE AND ENFORCE. THERE SHOULD BE A BETTER WAY TO ACHIEVE
THE SAME OBJECTIVE.

6) IN DEVELOPING THE SWUCA RULES A MAJOR EFFORT TO
OBTAIN PUBLIC INPUT WAS USED. UNFORTUNATELY, MOST OF THE
INPUT CAME FROM PAID REPRESENTATIVES OF SPECIAL INTERESTS.
THE GENERAL PUBLIC IS JUST NOW BECOMING AWARE OF THE IMPACT
OF THE RULES. WITNESS THE CORRESPONDENCE FROM THE BANKING
COMMUNITY AS TO COLLATERAL VALUES. A SEMINAk 4PONSRED BY
A BUSINESS GROUP AND NOT DOMINATED BY SWFMD MIGHT BE AN
EFFECTIVE COMMUNICATIONS MEASURE.

7) THE POLITICAL ENVIRONMENT WITH IN THE STATE IS NOT
CONDUCIVE TO DISPASSIONATE DECISION MAKING AT THIS TIME.

8) THE TAMPA BAY WATER COORDINATING COUNCIL HAS.SADPTPED
A FOUR MONTH PERIOD FOR THEIR DELIBERATIONS. THE RESULTS OF
THIS EFFORT WILL BE HELPFUL IN OUR APPROACH TO !RULE MAKING.

9) AS WE REVIEW THE "PLAIN SPEAKING" VERSION OF THE
PROPOSED SWUCA RULES AND THE APPROACH WE PLAN TO TAKE IN THE
NORTHERN TAMPA -BAY AREA WE SHOULD GET A BETTER UNDERSTANDING
OF THE NEED TO BE AGGRESSIVE IN DEALING WITH THE WATER PROBLEMS
THROUGHOUT THE DISTRICT.



IN VIEW OF THE ABOVE, I INTEND TO PROPOSE A DELAY
IN ADOPTING THE SWUCA RULES AT THE OCTOBER BOARD MEETING.
THE ISSUANCE OF PERMITS WITHIN THE SWUCA AREA CAN BE
STOPPED BY THE ADOPTION OF A SPECIFIC RULE.
A BROAD LEVEL OF SUPPORT FROM THE GENERAL PUBLIC,
ESPECIALLY THE BUSINESS COMMUNITY, WILL.BE COMFORTING AS
WE FACE THE INEVITABLE RULE CHALLENGES AND LITIGATION.

THIS LETTER IS POORLY ORGANIZED (AND TYPED), BUT
PERHAPS YOU WILL REGARD IT AS FOOD FOR THOUGHT.


BEST REGARDS,

7,

/y^ ^6


II




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