| Material Information
||Letter: An Alternative to the Immeiate Adoption of the AWUCA Rule, or Some Modification Thereof
||North America -- United States of America -- Florida
||Letter: An Alternative to the Immeiate Adoption of the AWUCA Rule, or Some Modification Thereof, Sept 26, 1994, To: SWFWMD Board From: J T Griffiths
||Box 10, Folder 14 ( SF-Water Use Caution Areas-SWFWMD - 1993-1994 ), Item 22
||Digitized by the Legal Technology Institute in the Levin College of Law at the University of Florida.
CITRUS GROWER ASSOCIATES, INC.
2930 WINTER LAKE ROAD
LAKELAND, FLORIDA 33803
September 26, 1994
To: SWFWMD Board
From: J. T. Griffiths
Subject: An alternative to the immediate adoption of the
SWUCA Rule, or some modification thereof.
The WUCA process has been progressing for more than three
years. In general, hydrologic conditions have improved on
the Ridge, been more or less static in eastern Tampa Bay,
and have apparently worsened in northern Tampa Bay.
Certainly, estimated ground water usage in the SWUCA has
been alleged to be reduced during the past two years in such
a manner that it exceeds the safe yields of 700 million
gallons per day by only a small margin.
This has been due to several factors which include, but are
probably not limited to, more accurate agricultural statis-
tics, reduced tomato acreage, successful conservation educa-
tion efforts, installation of more efficient water systems
and increased rainfall.
This reduced usage seems to remove the urgency for new rules
which appeared to be present some two years ago.
Therefore, is the Board not better served to delay immediate
adoption of the rule, to which there will'be major and very
substantial controversy, and agree to:
1. Have a rule adopted within one additional year.
2. Set up some specific committees composed of both
users and staff to negotiate, on an equal basis, as to how
the individual industry, or user group, should be re-
3. Then see if these divergent views can be reconciled
into a single, much less controversial, rule.
- 1 -
In addition, the rule needs to :
(1) provide a sure mechanism to reduce permitted
quantities to levels comparable to safe yield,
(2) encompass everything within the District south
of Brooksville in a single control district, but
recognize that the severity of restrictions must
vary according to local hydrologic conditions,
(I have received a letter from Chairman Davis
concerning hydrologic boundaries. I will answer it
in detail within a few days and you will all get
(3) make provisions for practically enhancing or main-
taining recharge capacity, and
(4) grant a recognition that land, whether permitted 2r
not, has an inherent right to the water which fals
upon and remains within or on the surface of the
land, just the same as people have an inherent
right to sufficient water for personal use.
(Perhaps 12 acre inches vs 80 gpd.)
Thank you for your consideration.
. T. Gtffiths
enc. Polk Co. Use as Compared with Safe Yield.
- 2 -
Polk Co. Use Compared with Safe Yield
Safe 1991 1992
Yield* Estimated Estimated
Use ** Use**
Agriculture 131.8 84.3 89.2
Industrial 9.3 61.0 59.5
Nursery 116.9 59.7 42.5
Public Supply 51.9 65.1 62.4
Recreation 8.8 7.7 6.5
Total 318.6 277.9 260.0
* Letter from David Moore, 8/26/94
** Fax SWFWMD, Conservation Projects, 9/26/94