Title: Letter Re: Draft Consolidated Public Water Supply System Permit From the Office of the County Attorney, Dated Jan 2, 1998
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Permanent Link: http://ufdc.ufl.edu/WL00003936/00001
 Material Information
Title: Letter Re: Draft Consolidated Public Water Supply System Permit From the Office of the County Attorney, Dated Jan 2, 1998
Physical Description: Book
Language: English
 Subjects
Spatial Coverage: North America -- United States of America -- Florida
 Notes
Abstract: Jake Varn Collection - Letter Re: Draft Consolidated Public Water Supply System Permit From the Office of the County Attorney, Dated Jan 2, 1998
General Note: Box 16, Folder 3 ( Letters, Drafts, Permits - 1995 -1998 ), Item 1
Funding: Digitized by the Legal Technology Institute in the Levin College of Law at the University of Florida.
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Bibliographic ID: WL00003936
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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I BOARD OF COUNTY COMMISSIONERS
I

Office of the County Attorney

Emeline C. Acton, Couny Auomny County Center
S Cor At 601 E. Kennedy Blvd. -- 27th Floo
Ronald 0. McCord, ChiefAssisr
Donald R. Odom i a P.O. Box 1110
DaMR o CnA rm Tampa, Florida 33601
James J. Porter, ChiefAssis (813) 272-5670
Fax (813) 272-5231
Jennie Granahan Tarr, ChlufAsssm Fax ( )
Guhile F. Theodore, Chuf Assist Hillsborough County
.Florida
Joaeph Egoacue, Admnnisraor




Via Telefax & U.S. Mail


January 2, 1998

Jake Varn, Esq.
Steel, Hector & Davis
215 South Monroe
Suite 601
Tallahassee, FL 32301

Re: Draft Consolidated Public Water Supply System Permit

Dear Jake:

As requested in Ed Helvenston's December 19, 1997 Memorandum,
below are Hillsborough County's initial comments to the draft
consolidated public water supply system permit. Due to the short
time available to review and provide comments, the County is unable
to provide you with all of its technical and legal comments by
today's deadline. Therefore, please be advised that Hillsborough
County reserves the right to submit additional comments to the
District in the future.

1. Introduction, Page 2:

a. In addition to limiting the combined production from the
Central System by December 31, 2002 and December 31,
2007, there should also be a limit on the Central
System's combined production from the date of the
issuance of the system permit to December 31, 2002;

b. The ability to increase the withdrawal of water in excess
of the quantity specified in the Facilities Quantities
table should also be based upon reasonable assurances
that such an increase will not result in adverse
environmental impacts in and around the area of the
proposed increased withdrawal; and

c. Table 1 and Table 2 are not attached.


An Affirmative Action/Equal Opportunity Employer










2. Sections 6A & 6B, Page 4: Both sections use the phrase "new
water supply capacity". As Hillsborough has commented at
previous Partnership Plan meetings, use of the word "capacity"
in this manner should be discontinued because it may be
misinterpreted. As had been explained at previous meetings,
the District's intent is to require the development of 85 MGD
of new permitted water supply. Hillsborough believes that
this intent should be clearly stated in both sections.

3. Section 8B, Page 5: This section requires impacts to surface
waters and wetlands to be avoided or minimized, "when
practicable", through reduction of groundwater withdrawals.
First, impacts to surface waters and wetlands should always be
avoided or minimized. Notwithstanding Hillsborough's first
point, the use of the phrase "when practical" is too vague.
If this standard remains in the permit, criteria should be
incorporated to determine whether or not it is "practicable"
to avoid or minimize impacts to surface waters and wetlands.

4. Section 9A(1) (c), Page 7: Exhibit C is not attached.
Therefore, Hillsborough cannot be determined whether revisions
are necessary.

5. Section 9C, Page 8: This section requires the Permittee to
monitor, investigate, and catalogue the development of
sinkholes and incidences of land subsidence on and "around"
Public Water Supply System property. Use of the word "around"
is too vague. Specific distances, hydrologic criteria based
upon a modeled drawdown contour, or some other specific
criteria should be incorporated to determine the boundaries of
the Permittee's obligation.

6. Section 10B, Page 9: This section needs to be re-worked since
one member government cannot ensure that another member
government will maintain a water-conservation oriented rate
structure.

7. Section 11B(1) & (2), Page 11: Table 3 which is not attached.
Therefore, Hillsborough cannot determine the appropriateness
of the number and distribution of rain gauges and evaporation
pans that will be required by the District.

8. Section 11C(1), Page 11: Table 4 is not attached. Therefore,
Hillsborough cannot determine the appropriateness of the
number, parameters, or frequency of the water quality sampling
that will be required by the District.

9. Section 11D(1), Page 12: Table 5.a. is not attached.
Therefore, Hillsborough cannot determine the appropriateness
of the number or location of the staff gauges and piezometers
that will be required by the District.










10. Section 10E, Page 12: Table 6 is not attached. Therefore,
Hillsborough cannot determine the appropriateness of the
number and location of the surficial, intermediate, and
Floridan aquifer monitor wells that will be required by the
District.

11. Section 12, Page 13: Table 7 is not attached. Therefore,
Hillsborough cannot determine the appropriateness of the
number and location of the regulatory wells that will be
required by the District.

12. Section 13A(1), Page 15: Exhibit D is not attached.
Therefore, Hillsborough cannot determine the appropriateness
of the mitigation areas. In any event, what criteria are used
to determine a mitigation area?

13. Section 13B(2)(a), Page 16: Same as comment number 12.

14. Section 15B, Page 23: Table 8 is not attached.

If you have any questions regarding Hillsborough's comments,
please don't hesitate to contact me. Otherwise, I look forward to
meeting with you on January 7, 1998.

Sincerely,


ave Forziano
Assistant County Attorney


cc: Mike McWeeny
Jim Jeffers
Scott Emery
Ray Allen


<** r




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