| Material Information
||Memo: Water Element of the State Comprehensive Plan
||North America -- United States of America -- Florida
||Memo: Water Element of the State Comprehensive Plan, To: Governing Board Members, From: Donald Feaster, Feb 27, 1978
||Box 10, Folder 21 ( SF Water Use Plan, State-Water Element - 1977-78 and 1985 ), Item 12
||Digitized by the Legal Technology Institute in the Levin College of Law at the University of Florida.
.iL i .. "
February 27, 1978
TO: GOVERNING BOARD MEMBERS
FROM: DONALD R. FEASTER, Executive Director
SUBJECT: Water Element of the State Comprehensive Plan
The staff and I have reviewed the latest draft of the Water Element of the
State Comprehensive Plan. Overall, we believe this is a good statement and
we have no serious problems. We do find a number of areas where improvement
is possible: (1) there is an imbalance on emphasis of groundwater as opposed
to surface water in fact, the plan seems to systematically discount surface
water as a source of high quality water; (2) we find several instances of
redundant policy statements; (3) we have a few cases of ambiguous terminology;
and (4) we find that some of the recommended action statements following.
selected policies are ambiguous or uncomplete while others appear to be too
detailed or restricted. Specific comments follow.
1. Objective B Water Levels, Objective C Pollution, and Objective D--
Conservation all appear to only address groundwater. They should be
reworded or expanded to cover both surface and groundwater. We also
note that all the policies formerly listed under "GROUNDWATER" are:
now listed under Objective D Conservation.
2. Policy #9 Executive Direction, (2) should include statement "with
due consideration to flood control".
3. While Policy #14 addresses both quantity and quality aspects of both
groundwater and surface water, the recommended action which follows
addresses only adverse effects for groundwater withdrawals. Further--
more, the recommended action could increase the incidence of injection
or connector wells as a means of alleviating adverse effects of ground4-
4. The recommended action on Policies #15 and #16 are also not broad enough
to cover the policy statements themselves.
5. Policy #19 second sentence Since all structures have some undesirable-
effects, we suggest this sentence be changed to read "where structures
exist and are shown to be undesirable, consider the replacement of'structures:
with non-structural methods where practical".
6. Policy #20 Since any drainage of wetlands will produce some adverse:
affects, the degree of adversity prohibited should be included in this?
statement. It is unclear what is meant by the term "public values".
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February 27, 1978
Governing Board Members
7. The 1 in 100 year storm specified in the
is far too limiting. We need to include
of lesser magnitude.
8. Policy #22 The word "caused" should be
program section of Policy #21
contingency plans for storms
added between "degradation" and
9. Policy #23 What are the "water resource restoration programs" mentioned
in the first line?
10. Objective G should reference groundwater management programs and plans
rather than just water storage and conservation programs.
11. Policies #32 and #33 appear to be duplications of Policy #9 and Objec-
tive E, respectively.
12. Policy #35 The recommended action statement should be terminated with
the phrase "delegation of authority".
13. Policy #38 Drop off the end phrase "before using groundwater" in the
policy and in the recommended action. This policy implies that surface-
water (runoff) is low quality and groundwater is high quality.
14. Objective N indicates that one agency will take the responsibility for
both quantity and quality.
15. Policy #41 Recommended action (E) can be eliminated since it is part
of water resources protection in (D).
16. Policy #42 appears to repeat ObjectiveAI..
17. Policy #45 appears to repeat Objective M. There
over the various methods for determining who the
any particular project.
is also some concern
beneficiaries are for
Overall, this draft is a significant improvement over previous drafts.. I.
have no problems with the current philosophy expressed.