and obviously represents great effort on the part of the Division
of State Planning and other cooperating agencies. The conmets
and suggestions enumerated below are submitted in an effort to
make the document somewhat more compatible with water sana--1S
practices, viewpoints, and particularly water iaqm-t se
in northwest Florida. Detailed word-by-word comments were ot
considered appropriate; emphasis was directed to general policy
issues of importance to northwest Florida.
1. The draft element is almost entirely a conservation/protectioe
oriented document. Although conservation of water resources
is doubtless one of the prime objectives of water msaaeme-t
in all areas of the state, the facilitation of beneficial
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)...Mlaintenance of groundwater
Levels as near the pre-andification levels as possible is
stressed in a number of policies in the draft element. How-
ever, this policy statement does not describe the healthiest
er mo economical method of managing the groundwater system
ia mey areas. Northwest Florida's water quantity problem
ae related, generally, to short term excesses and short term
mrtages. smval of water from aquifers during periods of
bortage will make room for water in the system during periods
ef eames. It is recognized that this practice could not
oaly oa some coastal areas with a potential for saltwater
ecrl~ acl nat. however, it can be an effective management
toi in many inland areas. We recommend that this statement
S e changed to read..."Naintain groundwater within the safe
raye 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
maay 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 oe may be prohibitive in many cases.
Is further consideration of cost, the Element devotes
less thea adequate emphasis to the economics of any water
ve or inya-est practice. If policies are to be effectively
iJlemeted, they must be economically feasible.
4. water mnagemeat 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
aecoplishing water management functions in Florida.
Of equal importance, state policy should address the
optimum method of funding for the wide range of water management
activities in Florida. Funding sources and methods vary
Considerably from one level of government to another and,
in fact, within the sam governmental level in many case.
Many funding sources are unsure from year to year, 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 elenst, state policy should provide
general guidelines to be used in establishing local or
regional water use priorities. However, the policy IsheLd
recognize differences in water reesurces and devlelmpet
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 management function to the lowest level of governeat
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 portiome
of Chapter 373, Florida Statutes would be an important
7. Although it is understandable that state level policies
cannot possibly address all levels of isplemntation, gw
feel it would be quite appropriate for the policy state-
ments to provide some understanding of how and by whos tben
. would be carried out.
'I I ITR' A-" 1 --*L;-- U_ :-- : r--^- -. -" -
8. (Bl policy statement 1, page i)...Raising surface water levels
-ay iWolve "taking". Many modifications to surface water
aruger have bee in existence for may years. Changes which
wed appreciate the "original" hydroperiod may inundate
and feIo which the landowner may justifiably demand compen-
seial, A second consideration must be given to areas such
e the conservation areas in south Florida where more water is
el"pliod 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-
taiied which are most advantageous to the area concerned.
9. (- policy statement 6, page 15)...Water as a physical limiting
factor to growth is a questionable statement. Perhaps it
w9W4 be better to develop a policy which would provide for
infoemtion related to the available sources of water from
whicIk idividuals or industry could predict future costs of
waer. Water can be supplied to any area of Florida in any
guestity or quality if the user is. willing to pay the cost.
n other words, the overriding factor is cost.
0. Mlter-related mapping techniques, terminology, boundaries,
symiols, 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 state. The existing discrepancies hamper the com-
patibility 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.
* -I -- -1L L -- ----_
11. The dependence of estuaries on fresh surface water supplies
example : policy tatemeat 2, page 9) is indicated in the
Element. An appr private addition to the policy statement,
or its explanator paragraph, would be an indication that
the actual volume of water needed by estuaries are not
known and acquisi ion of this information should be of high
priority to the 4tate.
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 coneideratio
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.