Title: Legal and Administrative
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Permanent Link: http://ufdc.ufl.edu/WL00002527/00001
 Material Information
Title: Legal and Administrative
Physical Description: Book
Language: English
 Subjects
Spatial Coverage: North America -- United States of America -- Florida
 Notes
Abstract: Legal and Administrative 8/17/1977
General Note: Box 10, Folder 21 ( SF Water Use Plan, State-Water Element - 1977-78 and 1985 ), Item 28
Funding: Digitized by the Legal Technology Institute in the Levin College of Law at the University of Florida.
 Record Information
Bibliographic ID: WL00002527
Volume ID: VID00001
Source Institution: Levin College of Law, University of Florida
Holding Location: Levin College of Law, University of Florida
Rights Management: All rights reserved by the source institution and holding location.

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The District's formal position has been presented at prior Water Element

Policy Advisory Committee meetings and we will continue to work through that

-vehicle, despite the fact that our involvement has not been effective in making

this a realistic workable document. In light of Mr. Hutchinson's prior comments,

however, it appears necessary to summarize our position on the water element for

the record.

1. The District can not support the current water element document. It

is not consistently grounded in sound hydrologic principles and does

not recognize the realities of water management in south Florida. In

addition much of the report contains broad sweeping statements or

inferred conclusions which are based on unknown or unspecified docu-

mentation. This is particularly true in the latter textual portion

of the document, which has not been reviewed by the Policy Advisory

Committee.

As an example, two of the basic directions of the document and many of the

policies are to 1) bring water levels back to redevelopmentt levels" and 2)

employ water retention/detention areas in "upland areas" to increase percolation.

First, redevelopmentn" water levels are virtually unknown in a scientific sense

since drainage activities were initiated prior to the turn of the century, long

prior to adequate data collection programs. Second, there are very few areas

where water levels could be raised higher than they are currently without flooding

and property damage. Moreover, while the concept of "upland detention" can be

practiced in some areas of the District, most of south Florida is indeed lowlands

with already high groundwater levels. The simplistic principles of raising

groundwater levels and using upland retention are not adequate concepts on which

to base water resources policy. Optimizing water levels has and will continue to

be an objective of the District's water.management program.


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There are numerous other areas of substantive problems including the
water element's position on environmental versus economic balance, the practice

of deepwell injection, interbasin transport of water to name but a few.

Unless and until the document is substantially revised, the Water Element
can not warrant this agency's support or approval.


Statement presented at the
Public Meeting on the State
Comprehensive Plan
September 21, 1977
West Palm Beach, Florida

. MD


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