Title: Letter of Dec. 24, 1997 - Review of Don Conn's Comments on the Consolidated Permit
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Permanent Link: http://ufdc.ufl.edu/WL00003939/00001
 Material Information
Title: Letter of Dec. 24, 1997 - Review of Don Conn's Comments on the Consolidated Permit
Physical Description: Book
Language: English
 Subjects
Spatial Coverage: North America -- United States of America -- Florida
 Notes
Abstract: Jake Varn Collection - Letter of Dec. 24, 1997 - Review of Don Conn's Comments on the Consolidated Permit
General Note: Box 16, Folder 3 ( Letters, Drafts, Permits - 1995 -1998 ), Item 4
Funding: Digitized by the Legal Technology Institute in the Levin College of Law at the University of Florida.
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Bibliographic ID: WL00003939
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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12/24/97 14:40


e904 754 6878 SWFWMD LEGAL


Southwest Florida

Water Management District
2379 Broad Street Brooksvllle, Florida 34609-6899 e 1-800-423-1476 (Florida Only)
or (352) 796-7211 SUNCOM 628-4150 T.D.D. Number Only (Florida Only): 1-800-231-6103
Internet address: http://www.dep.state.fl.us/swfwmd


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Roy G. Harrell. Jr.
Choirmon, St. Petersburg
Joe L Davis, Jr.
Vice Chairman. Wauchula
Curtis L Law
Secretary. Land O Lakes
Sally Thompson
Treasurer. Tampa
James L Allen
Bushnell
Ramon F. Campo
Brandon
Rebecca M. Eger
Sarosoto
John P. Harliee. IV
Bradenton
Ronald C. Johnon
Lake Woles
James L. Marlin
St. Petersburg
Brenda Menendez
Tampa
E. D. "Sonny" Vergara
Executive Director
Gene A. Heath
Assistant Executive Director
Edward B. Helvenston
General Counsel




























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12/24/97 14:41 0904 754 6878


December 24,1997

MEMORANDUM

TO: John Heuer, Interim Deputy Executive Director

FROM: Ken Weber, Chief Regulation Geologist, Technical Services

SUBJECT: Review of Don Conn's Comments on the Consolidated Permit


Here are my comments on the letter from Don Conn dated December 24, referenced to
his item numbers:

1. The individual facilities should have quantities assigned because there is a
continuing need to limit each facility to prevent adverse impacts. Without such
limitations, a facility could be pumped at a quantity above that at which impacts were
assessed resulting in adverse environmental or existing user impacts.

2. The individual withdrawal points should have quantity limitations for the same
reasons as stated above.

3. We should not impose requirements upon the District through our permits, this
permit is intended to limit the permitted. There is no reason to believe that the District
will not provide a timely response in an emergency situation.

4. This language does closely conform to the Partnership Plan, although I believe
some improvements were made that were going to be considered as changes to the
Plan.

5. The condition language only says they have to consider pumpage reduction first;
They would not necessarily have to implement that measure if another was found to be
more effective. Our position has always been that reductions in withdrawals is the
primary mechanism for mitigation, and that other measures are secondary and of
limited applicability.

6. I believe the intent was to give the District control over mitigation, and
considering that this permit would be issued under the "cooperative scenario", there
shouldn't be substantive disagreements on such issues.

7. This is an area for discussion, but the chances of getting expeditious agreement
on such a weighty issue is unlikely. I suggest we leave it as worded but agree to
continue to meet with them to resolve this issue.

8. I don't believe there are sites that WCRWSA and/or their consultants aren't


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aware of, but Clark should be able to give you more information on this one.

9. This condition merely says that the EMP will be used for all sites unless and until
40D-8 levels and criteria are established, at which point for any sites where there is a
conflict 40D-8 would control. It is not anticipated that 40D-8 levels will be set for all of
the sites in the EMP, therefore this dual-coverage is necessary.

10. See answer to 6, above, except that this relates to monitoring. Again, Clark may
be able to help on this one.

11-15. The tables are still being constructed, but you can let WCRWSA know that
pretty much all we are doing is combining the tables from the existing permits. There
may be a few exceptions, but on the whole they are substantively the same sites as
currently monitored. If necessary, we could have Mario, John Parker, Len, and John
Emery point out any sites that are not listed on the existing permits.

16. This one would best be discussed with Jim Robinson and Frank Hearne.

Jim Robinson and I are "tag-teaming" the consolidated permit, and he will be in the
office next week. I will be out from tomorrow through the 6th of January, but will be
calling in and available via phone, fax and E-mail. I can participate in conference calls
and fax or E-mail-in work products if necessary. Let me know if there is anything more
to be done.


KAW


cc: Jim Robinson


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SWFWMD LEGAL




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