Title: Letter: Oct 18, 1977 with attachment
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Title: Letter: Oct 18, 1977 with attachment
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Language: English
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Spatial Coverage: North America -- United States of America -- Florida
 Notes
Abstract: Letter: Oct 18, 1977 with attachment, To: R G Whittle Jr. From: John Maloy
General Note: Box 10, Folder 21 ( SF Water Use Plan, State-Water Element - 1977-78 and 1985 ), Item 20
Funding: Digitized by the Legal Technology Institute in the Levin College of Law at the University of Florida.
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Full Text


A JOHN R. MALOY. Executive DOrertor
South Florida /o

SWater Management District

POST OFFICE BOX V, WEST PALM BEACH, FLORIDA, 33402
TELEPHONE 305-6868800

IN REPLY REFER T09205/6-104J ober 18, 1977

Mr. R. G. Whittle, Jr.
State Planning Director
Department of Administration ,
Division of State Planning

Tallahassee, Florida 32304
Dear Mr. Whittle:

Please accept this as an update of our July 29, 1977 comments to
Division of State Planning on the Water Element. Through this trans-
mittal letter and the accompanying attachment we will attempt to
explain our objections to the Element.

We have been working with the Policy Advisory Committee to develop the
Water Element. However, from the beginning and throughout our involvement,
we have had technical and philosophical differences with DSP. These
differences were made public not long ago when we were informed that
our planning effort and management practices in south Florida were not
consistent with the "State's Water Element".

It is important to point out that with many of the policies, we do not
object to the letter of the document, however, as a state policy guide,
we feel we must question its broad application and net impact on water
resource management, particularly in south Florida. Our main concern in
reviewing the Water Element is that in emphasizing certain goals, it limits
or restricts other Important objectives presently contained in Florida
Statutes and called for in other Elements of the State Comprehensive Plan.
As the regional water managers we cannot endorse a plan which either fore-
closes or redirects objectives which the Legislature created.

Our specific comments are attached for your review.
enerel


R. ALOY
Secutive Director
JRM:et
Attachments
nobert L. Clark. Jr. Dr. John M. UHGrove C. A. Th a Robert W. Padrick W. J. Scarborough
Chairman Fort Lauderdale Vice Chairman Boca Raton Lake Harbor Fort Pierce Lake Placid
J. R. Sratt R. Hardy Matheson Ben Shepard Stanley Hole Maurice L. Plummer
I a. H -Il Mlauin Is ,.lh..l NalIsta Ft. MyVvs
Formerly Central and Southern Florida Flood Control District


C%





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ATTACHMENT #1
PREFACE TO SFWMD COMMENTS ON THE WATER ELEMENT

Specific comments on the Water Element (DSP-BCP-26-77) dated 10-11-77
are included in this attachment. These comments which constitute the District's
current formal position, are related to the District's statement made at the
West Palm Beach Public Meeting on the Plan on September 21, 1977, as follows:
1. Comments on the soundness of hydrological principles and the realities
of water management in South Florida:
a) Stating objectives based on "prior to modification" conditions
(Comment #3)
b) Watershed Management (Comments #6, 10)
c) Ground Water Management (Comnent #12)
d) Surface Water and Floodplain Management (Comment #13)
e) Water Supply, Use and Conservattan (Comnents 15a, 15e, lSf and 15h)
2. Commnts on broad statements and inferred conclusions:
a) "Prior to modification" (Comment 3a, b, c, e and 7)
b) Surface Water Management (Comment 4)
c) Required Definitions (Comment 8)
d) Watershed Management (Comment 9)
e) Value of Nature's Services (Comment 10)
f) Ground Water Management (Comment 12)
g) Surface Water Management (Comment 13)
h) Water Supply., Use and Conservation (Comnent 15b, 15c, 15d, 151)
I) Water Resources Project Evaluation (Cament 17)
Other substantive comments are also provided in the part of the attachment
which follows. The bibliography referenced In the comments is provided
at the end of this attachment.






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COMMENTS ON "WATER ELEMENT OF THE STATE COMPREHENSIVE PLAN" (DSP-BCP-26-77)
10-11-77


The following comments are based on the overall statement made in the
Introduction (Page 3, para. 3) which Identifies the element uses as:
(1) guidance for public and private water-resource development.
2 a basis for executive and legislative decision-making at all
levels of government.
(3) a broad framework to assist local, state and federal agencies
in land use and water planning and management.
4) the policy basis for the Florida Water Plan .
5a basis for the drafting of needed legislation.
6a basis for the systematic continuation of research, analysis
and problem solving of water management problems in Florida.
The revised version of the element (as of October 11, 1977) was then re-
viewed to determine if the uses defined above could be met primarily at the
District level (in some cases where there are interfaces with other levels
of government, comments were also provided).
It was assumed that the Water Element, as part of the State Comprehensive
Plan, would be consistent with the many water-oriented statements, objectives
and policies in the other elements of this plan. Several comments are made
with respect to this consistency where they were identified as affecting the
ability to carry out the uses described above.
Each section of the element is individually reviewed below.
1. Introduction (pages 1 through 4)
Generally a plan that deals with wide-ranging issues such as those in this
element contains a set of assumptions and definitions. These are very
effectively used in the Energy, Utilities and Land Development Elements,
but are not provided in this element. A number of comments provided later
in this review could possibly be resolved if the above were documented
(and referenced where new or unique parts are added).
Without assumptions and definitions the remaining text in the element is
subject to Interpretation by the many levels of organizations that are
listed as being potential users.
2. Overall Goal Statement (page 5)
The text indicates that optimum water management goals are water quality,
water conservation and wise use. This is an incomplete, and possibly
misleading interpretation of goals as stated in Ch. 373 (.016) and (.036),
which provides more balanced coverage in terns of beneficial use, eco-
nomic development, etc.


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3. Objectives for Grrounwater Management (section B, page 6)
Introduced for the first time in this section Is the term "prior to
modification". The concept is that ground and surface water stages
(levels) and periods of inundation (hydroperiods) should be managed
to approximate those which occurred pript to modification (which for
the lack IU definition. I assumed to be synonymous with historical
or pre-development conditions).
This concept appears to be modified laby the clapse "to the maximum
extent practical .", however the "prior to modification" phrase
appears numerous times in this element without restricting clauses.
Discussion of the concept that historical conditions (prior to
modification) represent the best imns of optimizing ecological,
hydrol~pgial and other objectives is required so that the many
potental users of this eTlment can apply it as an "objective" towards
which progress is to be made. In addition, these users must be aware
of the limitations this concept will impose or require when being
applied as a water-management objective. This is discussed below.
a). The ground and surface water stages and their seasonal
fluctuations which existed under pre-development con-
S editions t be defined adequately to serve as design
criteria or water resource management.
Data available prior to modification are mostly descriptive
and qualitative, and even when evaluated by the most
qualified and experienced professionals (such as Parker,
1974), add up to judgements of these conditions.
Inferences can be drawn from soil type information and the
petrology of certain sediments, but these techniques can-
not provide adequate quantitative data on the seasonal and
annual fluctuations of stages.
.The need for accurate quantitative data must be emphasized
since recent scientific investigations on wetland systems in
south Florida (Kushlan, et'at T 75; Goodrick, 1974; Pesnell
and Brown 1977 to cite only a few) have shown that plant
and animal comqmuities are sensitive to variations in the
seasonal and adMual ydrologic regimen, which cannot be
developed from the methods discussed above.
b). It cannot be assumed that conditions "prior to modification"
were by any means contant. Citing the largest wetland in
the state as an exaampe Parker (1974) and others have noted
that historically the Everglades~ must have undergone severe
drought (as evidenced by ash deposits at depth in the peat
profiles) although the extent, severity and duration of these
events is unknown.


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A, i 1


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The discussion so far indicates that while a general idea
of hydrologic conditions "prior to modification" can possibly
be obtained, quantitative data of the type needed for use as
design criteria in meeting a specific objective cannot. It is
not adequate to approximate historical conditions, or to define
historical conditions in terms of high water marks or "average"
water levels, since much of the response of biological
communities is to other characteristics of the hydrologic
regimen.
It is stated that the reestablishment of natural water levels
would store as much water as possible and would provide for
the maximum feasible amount of water for economic development
(page 2). This inferred conclusion does not indicate a
recognition of the realities of groundwater management. The
reestablishment and maintenance of redevelopment groundwater
levels could reduce the quantities of water available for
municipal, agricultural and industrial use and minimize
available groonidater storage. A clearer understanding of
this dichotomy can be gained by considering a general, hypo-
thetical example, as follows:
As the wet season ends and the dry season begins, the water
table to the zone of influence of a municipal or agricultural
wellfteld begins to decline as the rate of withdrawal and
groundwater evapo-transpiration begin to exceed recharge.
When the water table is lowered beyond, say for the purpose
of discussion, seven feet, groundwater ET becomes a negligible
factor. As the dry season and withdrmals continue, the water
table continues to recede with the most pronounced drawdown
occurring at the points) of withdrawal. At this point in the
discussion, it is readily apparent that any attempt to maintain
historical water table elevations during this period would be
acting directly counter.to maximizing the quantity of water
available for use. It should further be noted that the degree
of such drawdowns are restricted by the factors used in
determining the maximum. og. term, safe sustained yield.
As the dry season terminates and the wet season begins, recharge
exceeds the rate of withdrawal and groundwater ET, and water
table rise to begin the cycle again. It is important to note
that during the dry season drawdown, groundwater storage "space"
was created, which is refilled during the subsequent wet season.
Were this "space" not created, and the groundwater table were
at or near the surface, wet season rainfall could not be stored
in the groundwater and would constitute rejected recharge. Since
wellfields are most often located near or at the source of
demand, i.e., urban or agricultural areas which have flood con-
trol and water control imiats on stages, this rejected recharge
would be reflected in increased surplus runoff.


_









It is apparent from this example that an objective which
calls for reestablishment and maintenance of historical
water levels would, from the viewpoint of municipal,
agricultural or industrial use- of groundater, neither pro-
vide for the "maximum feasible amount of water for economic
use" nor the storage of- as much water as possible.
c). It may not be optimal to re-establish or even pursue pre-
development conditions from even an environmental perspective.
This can be shown through several examples:
1. It has been noted from early historical accounts (Pesnell
and Brow.i 1977) that the currently extensive and productive
95.000 acre marsh of Lake Okeehobee did not exist as an
enargent littoral zone prior to the early 1900's.
Historically, lake stage conditions were apparently not
supportive to such vegetation, and if such conditions
were re-established, the emergent~ marsh would most likely
be lost.
2. Here "prior to modification" conditions to be established
In the Conservation Areas not only would the current
.diversity noted by Dineen, 1972 be reduced, but the de-
sirable characteristics of wet pratrle likely be. Tost.
3. A anagmeent approach .of re-establishing historical con-
ditions does not, as shown above, apply to the largest
wetlands areas of south Florida.
d), Predevelope nt surface and groundwater stages could not be
practicably attained in most of the -Si1a:T n urbanized areas,
redevelopment stages-are for practical purposes completely pre-
cludd by flood control ard drainage extgencies and legal rights.
In insy agricultural areas, farming. practices and flood control
requirements eliminate the practicality of attaining pre-
development stages, and since the problems of overdrainage are
recognized by the agricultural community in general, stages are
usually maintained as high as practical at the current time. The
evaluation of raising surface and groundwte stages is being
carried out as a part of the District's multoibjective water use
planing. Howevr, the proposedpolicy-d oabdective statements
at the subject document do not recognize the. onstraining realities
of increasing stages and are, therefore, untenable.
e), It can be shown from the above discussion that the broad range of
public "values: atre nt optiiazed by uaaging water resources to
approximate the patterns which existed "prior to modification".
Even if such conditions could be accurately defined in "objective"
terms of something that should be reached or attained, these
objectives would not lead to the optimization of public values.


'~-~~~~~ -;-- ---- ----










Appearing under this "objective" is the term "to the maximum extent
practical". Throughout the remainder of the element this term, or similar
ones like "to the greatest degree practical" and "to thi extent practical"
constitute non-obective language that defeats the purpose of stating
the objechti e first place. In other words an "objective" is usually
stated in a plan as something to be attained or reached for in as
quantitative a manner as possible. Nowhere in this element are there
any quantitative objectives (or goals) such as those that appear in typical
federal planning documents (e.g., the goals originally stated in P/L 92-500
for 1983 and 1985 wastewater treatment and disposal, etc.).
4. Objectives for Surface Water Management (section C, page 6)
There is no question that wetlands are important from a number of ecological,
social and aesthetic viewpoints however the fifth part of this objective
must be clarified in terms of:
a). Are all wetlands included, or only those of ecological significance?
b). What criteria must be used to determine where reestablishment would
be required?
c). What specific documentation exists to support the statement that
"the values and functions .. .vital to the public in-
terest ." are those given?
This objective bri gs up a general comment that applies throughout the
element as reviewed. There are no references given in the text at any point.
There is a bibliography provided towards the end of the element, but there
are no references to this bibliography in any part of the text.A This negates
the bibliography as well as the indirect references made to it throughout
the element as conclusions, examples, requirements, scientific facts and
historical conditions.
5. Objectives E and G (page 7)
The same comment as made under #2 above applies in both these objectives.
6. Watershed Management Objective and Policies (page 8. 3rd sentence)
". runoff should flow along gentle gradients without ever reaching a
velocity which strips soil or nutrients from the land". Erosion of soil
and nutrients is a natural process which has occurred since the first formation
of land and water. The statement in quotes is therefore not sound hydro-
logically or realistically.
7. The following Objective and Policy statements include the concept of "prior
to modification", and based on the comments given in #3 above should be
defined and referenced and/or deleted:


I. A* I






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a). Policy statement muier 1 and 2, page 9.
b). Policy statement number 1 and WZ page 11.
c). Objective and Policy statemiet -umber I, page 13
Sd). Policy statement number 2, page 14.
e). Policy statement number 9* page TS.
f). Objective and Policy statement number 2, page 18 and 19.
8. Numerous terms used in the element do not lend themselves to objective or
policy Statements, for example:
a). Policy 3(3), page 9: What is the meaning of "appropriate", cost-
effective?
b). Policy 7, page 10: "free energy" needs to be defined.
c). Groundwater Management Objectives and Polities, page 10: "optimum
levels".
d). Policy number 3, page 17r comnprehensive management".
e). Policy number 5, page 9: ". within the constraints of historical
biological ccm ilttOs And existing lend use', ritlie clarification
Sand defftitton.
9. It was assumed that the sanr basic uses (as given on page 1 of these
com ents) are to be made of the other elemits comprtsing the-State Com-
prlehAstc e Plan (SCP). ..,Te other water-QNit4ed elaents were reviewed with
respect to the Watershed Management and other objectives and-policies of
the water element. For the SCP to be totally usable by various levels
of government and other organizations it must IJntegrat.1 thet r-related
statements, policies, guidance, etc., in such a manner as to be consistent
and capable of being followed without contradition, polarity or crossing
purposes.
In the Watershed Management section (pages 8 to 10) most of the policies
are in-direct conflict ltth the' resillts of a statewide poll (as reported
in page 14 of the AseQltural Eimenat), where over' 50 of the persons
polled answered th ti iaIi should be dratned for agriculturel purposes.
This problem is also iWpent with respect to the policies Inder Ground-
water Management (pages 10 to 13) and SdUfacewaterManagement (pages 13 to
15).
10. The text under Policy 7 of Watershed Management (page 10) closes with the
phrase "the free management services of -natural systems". TO use this
guidance as part of an objective at the regional or local level of water


`` ~ ` '










management will require considerable additional definition. Unfortunately
the most recent findings on the worth of nature's services are less than
clear and conclusive (See SCIENCE, Vol. 197, Sept. 2. 1977, page 963, a
part of the article on "How Much Are Nature s Services Worth?" by Walter
Cestman).
The conclusions of the above reference are that our understanding of eco-
system functioning is limited and that much analysis remains to be done
before the worth of the services can be Integrated into meaningful
objectives for water management. As noted in the last paragraph of
comment #3, objectives need to be defined based on knowledge of what is to
be attained or attempted.
11. Policy 5, page 9-10 of Watershed Management implies a set of priorities as
does Policy i, page 11 of Ground water Mana nt (second para., 1st
sentence). Guidance is needed at various levels of government on water
resource priorities, but in a form that is not at cross-purposes with other
priorities given in the other elements of the SCP.
For example, Objective W-1 of the Agriculture Element (page 8) priorities
agricultural water supply as second highest (after damstic supply), while
page 9 of this element has a total water use prioritization, Including that
for natural systems.
12. Ground after Management Objectives (page 11 to 13)
Policy 3 (page 12) deals with saltater intrusion, which in redevelopment
situations had saltwater migrating upstream through uncontrolled channels,
This conflicts with the sound water management-by returning to historical
conditions.
Policy 4 (page 12 text) attempts to establish a cause and effect relationship
that is true only under specific sets of conditions, and certainly not
generally applicable in terms of overall and systematic water resource
management.
13. Surfaae Water and Floodplain Mangement (pages 13 to 16)
The statement under the introductory paragraph (page 13) is disposed in
one direction which does not represent the true relationship of public and
private values. In reality each is part of the other and could not exist
without the other. The projects in south Florida clearly have water con-
servation and water supply among their major purposes.
Policy 1 (page 13) takes the position that the pattern of seasonal water-
level fluctuations must approximate that which prevailed before modification
took place. Comment #3 should be referred to for the problems in this area.
In addition the proposal to protect floodplain storage capacity up to
ordinary high water mark, and where practical up to the 100-year flood
level is unrealistic non-objective reasoning, and inconsistent with accepted
floodplain management practices. (American Society of Planning Officials,
1972).


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Policy 3 (page 14) is in direct cross-purpose with the substantial aquatic
weed control efforts being carried out in Florida. the "stage area
curves" statement should be deleted since it represents a misunderstanding
of the characteristics of the hydrologic regime which influences littoral
zone vegetation. The statement that "littoral vegetation is essential
to the enhancement of water quality" needs to be clarified and referenced.
Policy 5 (page 14) will not preclude all damages as the result of using
floodplain zoning and elevated structures. The last sentence of the text
does not allow for the fact that there can be instances where channel
enlargement could be a cost-effective and environmentally acceptable
means for providing flood protection for future residential development.
Policy 6 (page 15) indicates that wetlands are suitable for golf course use,
which is inconsistent with the previously stated "vital" uses of these areas.
Policy 7 (page 15) states that first floor elevations of all structures
should be one foot above.the level of a 100-year flood. This is in-
consistent with local and regional criteria ti much of south Florida and
does not have any rationale provided as to this position's reasonableness.
14. Wastewater Management (pages 16 to 18)
Policy 2 (page 16) provides a priority for the allocation of wastewater
treatment funding that would be at cross-purposes with the objectives of
the Economic Development Elematt as found in:
a). Objective I(S), new policy on page 12.
b). Objective 11(2), page 24.
c). Objective 11(4), page 29.
Policy 5 (page 17) suggests that "deepwell injection appears to offer, at
best, an interim solution". Existing data indicate that this method is
indeed a viable wastewater disposal technique in suitable areas of the state
and has been approved by EPA for application in Florida.




l I 1..- I

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15. Water Supply. water Use and Water Conservation Objectives and Policies,
(pages )
a) The assumd cause and effect relationship O eet storater discharge
by drainage facilities, and reduced grouAwrr ditwharge is not
sound from a hydrological basis. The operating stag at which
drainage canals anrsettUliaed has a uch nerl fect on the
potential groundwater storage than does th r e P oval.
bt) The emphasis placed upon comnervatio In .n pai as "continued
economic vitality and environmental health ire absolutely dependent
upon the conservation...of water... resources" s greatly misplaced
when the annual -wter conditions in south Florida are considered.
c) The conclusionan the first Asetence of the third par, as to misused
water contributing significantly to solvig waterr Sftage problems
must be supported with rfrer ices that we k I'A U ln atilyzing this
problem. Including those that considered per capta water usage,
dreght freaqwi y effects, existing. system capblities, climatic
conditions, etc.
d) The last sentence states a conclusion or establipbes criteria con-
cerning economic efficiency and water conservation that cannot be
suppioted with urrent wperplsf tha amrecwcurring in California
and the mid-West. Referencesshould be provided that show how the
Swt a tlateh mud spesflcally k their Impacts on the total water
cycle are (from the water source to athe wter tretent plant to
the t back to water smure 4nd MLt~l t treatment facility).
If these references prove that inhibiting proliferation of water use
and nafinite civsfervatl at wfel 4 ulwea hti y beneficial
~thgthis might be ne object thae t ha4 a ioS lotn in fact.
e) Policy number 2. page 19 states, "discourage draddWiti which exceed
the average recharge" is an inaccurate hydroTogic concept and needs to
be defined and clarified.
f) Policy number 3. page 19: "amintain surface waters at or above average
seasonal levels" ust consider the relationships .iWeen such practices
and flood control before Its viability as a objective can be determined.
g) Policy number 5, page 19: No specific coemat cn beomade until the
phrase "importation of water" Is fined.
h) Policy 7, page 21 must clearly recognize the distinction between time
and rate of runoff:andthe agagmt-of runoff. They a net synonymous.
It alsa.mst be recogOeed that -i conditions,
a much greater quantity, rof t r a orrocndwater
storage by evaporation. This wathr wtt v7eet hot available for
consumptive use. The statement that inre runoff to the sea and
increased consumptive uses have resulted in chronic water shortages
does not mea that reduced runoff can be 5trMla*3dl directly to
increased water availability. Wile preservation 4Iunoff water is
Important it must be noted that there will be some Tdsses due to
evaporation and transpiration.





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i) Policy 8, page 21 does not recognize the most essential elment of
water conservation programs. That is their relationship with the
total economic system. Of particular importance is the interaction
between reduced water consumption and the bonded indebtedness of the
utility involved.
Experiences in northern California have shown that significant care
must be taken in the implementation of conservation programs to
prevent unnecessary increases ih water rates. This is a major part
of the conferiation program policy that should be defined in this
element.
Water conservation progrms/peolcies are provided in other elements
of the SCP that may be at cross-purposes, or be misinterpreted with
respect fo those given in the Witer Element (See Policy 3, page 17,
OUtlities Element: Policy 6, page 27, 7Land Development Element:
Objective H11, page 10, Agricultural Element).
J) This section needs to recognize the possibility of advancing techno-
logical progress making available new and more effective means for
supplying, treating and reusing water. These possibilities are
recognized in many of the other SCP Elements as follow:
1) Utilities Element: Policies 6, 9 and 10 (pages 19, 32, 21)
2) Land Development Elemet: Policies 3 and 6 (pages 29 and 30).
3) Agriculture Element: Policy 11 (page 11).
All levels of government need toabe advised as to the state's posture
on developing and using these advancing technologies. the criteria
and constraints if any, and their relationship to water resources
of the future.
16. Legal and Administrative (pages 22 to 25)
a) In general throughout this Element, statements of new and old policies
are integrated in the texti so that the ability to support 'ae use of
*a basis for the drafting of needed legislation" is not provided.
New policies are separated from old policies in the Economic Develop-
ment and Growth Elements and this makes it much easier to evaluate
the new from the old in terms of legislative action requirements.
b) Policy 1, page 22 suggests developing clearer tests of what constitutes
a reasonable-beneficial use. This would obviously narrow the scope
of term as originally'defined by the legislature and would reduce
the flexibility in applying it to water resource ,mnagment.
c) Policy 2, page 22 Is at cross-purposes with Ch. 373, which recognizes
that differences may arise from area to area, among different sources,
and uses, which may affect allocations policy.
d) Policy 7a and 7d, page 24 will make it difficult, if not impossible
to comply with objective 11 (page 8) of the Utilities Element (Funding
sources for utility restoration will be very limited).








e) From an administrative point of view, the philosophies, goals,
obJetives and policies of the Water El t, which are at cross-
purposes .i th os of other elements o ti SCPE ll.i lead to
misinterpretation, and the inability to apply the SCP at any level
of government.
The following Water Element Policies:
Watershed Management Policies 1, 2 and 4 (pages 8 and 9)
Ground Water Management Policies 1, 4 and 5 (pages 11 and 12)
Surface Water Policies 1, 3, 4, 6 and 7 (pages 13to 15)
Water Supply Policies.2, 3, 5, 6 and 7 (pages 19 to 21)
Legal and Administrative Policies 4 and 7 (pages 23 and 24)
are clearly at cross-purposes with the following policies in other
elements'of the SCP with respect to the ability to support growth,
economic development and utilities development in Florida. These
other Element Policies are:
Objective I (5), new policy on page 12, April 1976 version of
the Economic Development Element, starting "Encourage state,
county and municipal governments to provide utilities etc.*
Objective II (2), page 24, Economic Devel. Element, starting
"encourage non-seasonal..industries to locate etc."
Objective II (4), page 29, Economic Devel. Element, starting
"improve public facilities in counties that have etc."
Policy 3, page 43, Energy Element
Policy 4, page 13, Growth Element
17. Water Resources Project Evaluation (page 25)
Recognition needs to be given in this section, or elsewhere in this
Element, to the fact that much remains to be learned about the water
resources and natures services throughout Florida. Numerous co usions
are drawn In the Water Element in areas where other elements of the
are encouraging research to provide basic scie-TnTc and technical answers
upon which conclusions can be made.
This recognition is made in numerous other SCP elements, related to water
resources as follows:
Utilities Element: Policies 17 (page 10), 6 (page 19), 10 (page 21),
and 13 (page 35).
Energy Element: Policy 3 (page 49).
Land Development Element: Policies 3 (page 27), 4 (pge 30), 11 (page 29),
1 (page 24) and 5 (page 25).
Agriculture Element: Policies WII (page 10), WIll (page 13).
Growth Element: Policies 2 (page 11). 3 (page 12) and 2 (page 31).





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18. It is recommended that the "supporting appendices" be deleted from the
Water Eleenmt since this section was not discussed by the PAC and does
not add relevant planning information in terms of objectives and policies.












BIBLIOGRAPHY

American Society of Planning Officials, 1972. Regulations for Flood
Plains. Planning Advisory Service, Report No. 277, Chicago,
Illinois 60637.
Dineen, J. W. 1972. Life in the Tenacious Everglades. Central and
Southern Florida Flood Control District, West Palm Beach, Florida.
In Depth Report, Vol. 1, No. 5.
Goodrick, R. L. 1974. The Wet Prairies of the Northern Everglades.
In. Environment of South Florida: Present and Past, edited by
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