J. William McCartney
)r Management District
325 JOHN KNOX ROAD
TALLAHASSEE. FLORIDA 32303
October 18, 1977
Mr. Estus Whitfield
Mr. Curry Hutchinson
Department of Administration
Division of State Planning
660 Apalachee Parkway
Tallahassee, Florida 32301
Dear Estus and Curry:
Enclosed are the draft recommendations of the
Northwest District's board committee for Programs,
Planning and Development.
The comments represent the committee's reactions
to the general policy issues described in the Water
Element. However, the committee stressed that additional
comments may be forthcoming, particularly when the recom-
mendations are presented to the entire Governing Board
for their consideration.
If I can provide any other information, please
do not hesitate to contact me.
Rich G. McWilliams, Director
Division of Program Development
cc: Exebutive Directors, Water Management Districts
Torn S. Coldowey
Benson L. Skeiton, Jr
William H Williams
Henry C. Lare
i. n -, .
Draft Recommendation of the Program, Planning and Devel-
Northwest Florida Water Management District
S... October 11, 1977
The draft Water Element is a document of considerable merit
and obviously represents great effort on the part of the Division
of State Planning and other cooperating agencies. The comments
and suggestions enumerated below are submitted in an effort to
make the document somewhat more compatible with water management
practices, viewpoints, and particularly water management needs
in northwest Florida. Detailed word-by-word comments-were not
considered appropriate; emphasis was directed to general policy
issues of importance to northwest Florida.
1. The draft element is almost entirely a conservation/protection
oriented document. Although conservation of water resources
is doubtless one of the prime objectives of water management
in all areas of the state, the facilitation ofbeneficial
development of water resources is also of considerable im-
portance. For example, location of water supplies that could
be developed for industrial usage without conflict with other
existing or projected uses is a primary consideration in
determining the future growth of the northwest area of Florida.
Location and development of additional water supplies that
can be safely used to support economic development should
receive emphasis as a policy of the state.
2. (Re policy statement 1, page 6)...Maintenance of groundwater
levelskas near the pre-modification levels as possible is
stress d in a number of policies in the draft element. How-
ever, this policy statement does not describe the healthiest
I .... ... .. ...... .. ........._ .... .. 1
oI o 0 0 0 0 -
or most economical method of managing the groundwater system
in many areas. Northwest Florida's water quantity problems
are related, generally, to short term excesses .and short term
shortages. Removal of water from aquifers during periods of
shortage will make room for water in the system during periods
of excess. It is recognized that this practice could not
apply in some coastal areas with a potential for saltwater
encroachment. However, it can be an effective management
tool in many inland areas. We recommend that this statement
be changed to read..."Maintain groundwater within the safe
range of levels in the aquifer system..."
3. Policies related to maintenance of groundwater levels also
stress use of surface water in preference to groundwater for
many purposes, including municipal, industrial and agricultural
useS, where possible. It is important to recognize that the
cost of treating surface water, compared to groundwater, prior
to use may be prohibitive in many cases.
In further consideration of cost3 the Blement devotes
less than adequate emphasis to the economics of any water
use or management practice. If policies are to be effectively
implemented, they must be economically feasible.
4. Water management functions are being carried out at all
levels of government with many overlapping areas of authority
and responsibility. The Water Element should address, as
a policy issue, the optimum organizational structure for
accomplishing water management functions in Florida.
Of equal importance, state-policy should address the
optimum method of funding for the wide range of water management
C--- ----- ---
. = -L ...... I II I I I n U IIII I IIIII- "
activities in Florida. Funding sources and methods vary
considerably from one level of government to another and,
in fact, within the same governmental level in many cases.
Many funding sources re unsure fromaear o y ar, which
may preclude development of well planned, scheduled,
systematic, long-term management activities.
5. Although some inference is made concerning priority -water
uses in the draft element, state policy should provide
general guidelines to be used in establishing local or
regional water use priorities. However, the policy should
recognize differences in water resources and development
patterns in the various regions of the state and should
provide enough flexibility in establishing water use priorities
to accommodate these-differences.
6. State policy should address delegation of every possible
water Itanagement function to the lowest level of government
at which the information and expertise are available to
reach a soundly reasoned-solution to problems and that can
adequately function to carry out these responsibilities.
The legislative intent in delegation of all feasible portions
of Chapter 373, Florida Statutes would be an important
7. Although it is understandable that state level policies
cannot possibly address all levels of implementation, we
feel it would be quite appropriate for the policy state-
ments to provide some understanding of how and by whom they
would be carried out.
8. (Re policy statement 1, page 8)...Raising surface water levels
may involve "taking". Many modifications to surface water
courses have been in existence for many years. Changes which
would approximate the "original" hydroperiod may inundate
lands for which the landowner may justifiably demand compen-
sation. A second consideration must be given to areas such
as the conservation areas in south Florida where more water is
supplied to these areas than they would receive naturally.
This has been determined to increase the biological productivity
of the area. This policy statement could better include a
statement that, in all surface waters, levels should be main-
tained which are most advantageous to the area concerned.
9. (Re policy statement 6, page 15)...Water as a physical limiting
factor to growth is a questionable statement. Perhaps it
would be better to develop a policy which would provide for
information related to the available sources of water from
which individuals or industry could predict future costs of
water, water can be supplied to any area of- lorida in any
quantity or quality if the user is willing to pay the cost.
In other words, the overriding factor is cost.
10. Water-related mapping techniques, terminology, boundaries,
symbols, etc. are as varied as the agencies that use them.
As a prime example, there are at least three existing different
systems for delineation and cataloging of drainage basins
in the saarte. The existing discrepancies hamper the com-
Spatibility -of-technical-, information compiled- by various
agencies. The need for solution of these problems should
be indicated in the Element, possibly by inclusion in
objective (k), page 3.
11. The dependence of estuaries on fresh surface water supplies
(example: policy statement 2, page 9) is indicated in the
Element. An appropriate addition to the policy statement,
or its explanatory paragraph, would be an indication that
the actual volumes of water needed by estuaries are not
known and acquisition of this information should be of high
priority to the state.
12. Although the need for state-level water policies is certainly
apparent, the effect of simultaneous planning on local,
regional, state and federal levels will likely result in
conflicts that will be difficult to resolve. The alternative
of delaying state-level policy planning until local and
regional plans are complete should receive serious consideration.
13. The "beneficiary pays" concept (re page 3, objective m) is
of significant concern to all involved in water management.
It seems doubtful that all beneficiaries could be defined
or could effort to pay full costs for many water management
activities. We understand that this objective is currently
being revised and would like to express strong interest in
the outcome of that effort.