Summary of Public Comments Presented
Land Use and Water Planning Task Force
State Planning Recommendations
A cross-acceptance process should be built into the development of the Florida Land Plan, Local government
Florida Water Plan and the Florida Transportation Plan to eliminate any representative
inconsistencies/incompatibilities early in the plan development. Miami
It should be clear what data sources are used by the agencies in the development of the state- Local govt. rep.
level plans. Miami
With the proposed repeal of the growth management portion of the state comprehensive plan Local Govt. Rep, Miami;
and the enhancement of the three state-level plans, will some of the balancing of the issues be Regional Govt. Rep,
lost in the individual plans? Miami, Tallahassee
The task force should provide more specificity as to the content of the plans. The language used Utility Representative,
for the Florida Water Plan (pg. 11, rec. #8) content does not provide any guidance. Maybe Tallahassee
those elements of the state comprehensive plan that address water policy could be included for
the Florida Water Plan. A good recommendation for plan content is on pg. 14, Recommendation
#10, item #4, which provides adequate direction for the content of the Florida Land Plan.
Recommendation #8, Item (1)(a), should be changed to reflect "water supply development, County representative,
protection and management". Much more emphasis needs to be placed on a Plan which written comments
specifies how much water is available and locations from which the water can be withdrawn. A
25 and a 50 year planning horizon should be used. In South Florida, it will take 15-20 years to
get a major water resources project involving canal and structural changes through
reconnaissance, feasibility, congressional approval, design and construction. Water and
wastewater projects will take seven years from inception to construction. Long term growth in
population is a very real problem for southeast Florida and it is expected that in 50 years the
population may triple. The water supply implications of this must be recognized as early as
possible. Long term planning must reflect the driving force of population demands. Under Item
(3), "Water areas" need to be defined as "water supply areas".
The Florida Water Plan should emphasize the priorities, strategies and schedules to meet the
water needs of people, including agriculture, while maintaining sustainable development in
harmony with natural systems. The Legislature needs to set a schedule for development of the
Florida Water Plan and subsidiary district water management plans. The Florida Water Plan
should comprise the sum and substance of the Water Resources and Facilities Reports of the
The task force should recommend that the State Water Policy (62-40, F.A.C.), be adopted by the Attorney, Tallahassee
Legislature. Currently, the Environmental Regulation Commission is adopting standards and
acting as a standard setting body.
The state-level plans should be adopted by the Legislature. The plans should go through an Attorney, Tallahassee
agency development process and through a review by the Governor's Office, then to the
Legislature for adoption. The proposed state-level plans will have an effect similar to the state
comprehensive plan and therefore should undergo a similar adoption process.
If the Florida Water Plan had the same elements and direction as Chapter 62-40, F.A.C., then Attorney, Tallahassee
the plan would be sufficient and the water policy could be abolished .
It is good that the task force is recommending the repeal of the growth management portion of County Representative,
the state comprehensive plan. Tallahassee
Those portions of the state-level plans that are binding to other agencies should be adopted by County Representative,
The recommendation requiring a single Florida Water Plan to address water issues is good, County Representative,
however, what will the role of the state water policy be with the enhanced Florida Water Plan? Tallahassee
Will they be duplicative?
Energy issues have not been discussed in the recommendations regarding the Florida Land Plan. County Representative,
How will these recommendations fit into the proposed revisions to the state comprehensive plan? County Representative,
The recommendation regarding the Florida Land Plan should mention those activities that fall Planning organization
under the special planning and siting acts. Representative,
Recommendations #1, 2, 3, and 9, appear reasonable to improve the State Land Development
Plan and to utilize the Land, Water, and Transportation Plans to provide Statewide growth
management policy direction, in lieu of creating a growth management portion of the state
comprehensive plan. The three plan approach, however, may pose a greater risk of, 1) policy
inconsistencies between the three plans than that which would occur within a single plan
prepared by one organization, and 2) the plan that contains the most specificity or which
contains specific project proposals would command greater legal or political weight than would
the plan that contains mostly policy language. If the three-plan approach is implemented, it is
recommended that Recommendation #3 be amended to provide, 1) policy language to ensure
that the three plans will be thoroughly evaluated, with full public review, to ensure policy
compatibility whenever they are prepared or amended, and 2) bottom-up representation by all
regional planning councils in this "cross-acceptance" process to ensure that implications of the
requirements for top-down consistency with the Land and Transportation Plans are fully
planning official, written
Recommendation #4 is good, however it could be improved by adding a requirement that State Local government
agencies preparing such plans for adoption publish and disseminate to the regional planning planning official, written
councils and counties the data, analyses and reasons for the policies and projects proposed in comment
these plans. If local governments will be required to use these plans as best available
information, they must understand the underpinnings.
Recommendation # 12 is a good recommendation with the suggested changes to Local government
Recommendation #3. planning official, written
Recommendation #7 should require that the Florida Water Plan provide regional and state-wide City representative,
priorities, implementation strategies, and reasonable schedules to meet the water needs. written comments
Alternate language for Paragraph #3 in the narrative under Recommendation #6 for Option A, State agency, written
B, C (pages 8-10 of the public workshop draft): comments
3. Each state agency submits its plan for review to the Governor and each of the
other two state agencies responsible for preparing state-level plans (FTP, FLP, or
FWP). The Governor shall determine consistency with the State Comprehensive
Plan and the agencies shall determine mutual compatibility with their respective
plans. In the even the agencies disagree on any revisions requested to achieve
mutual compatibility, the Governor shall resolve any issues in dispute. The
Governor may direct the agencies to make changes in the plans as necessary to
achieve consistency and mutual compatibility.
Recommendation #8 should be revised to require the Florida Water Plan to contain
(I) "Goals, benchmarks, policies, the identification of resource management issues,
implementation strategies, and reasonable schedules .
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(6) Other direction on the content of the Florida Water Plan as necessary or desirable,
including elements of the Florida Water Plan. outlined in the proposed State WIater Policy
Chapter 62 410, Florida Administrative; Code. (Note: It is not prudent to reference a
document that is merely proposed at this time, nor is it clear that a decision has been
made to authorize the State Water Policy to drive the Florida Water Plan.)
Regional Planning Recommendations
WATER MANAGEMENT DISTRICTS
Water management districts should take a more proactive approach to planning. Attorney, Miami
Water management districts continue to have taxing and regulatory authority without elected Citizen, Miami
Informal coordination between the water management districts and the regional planning Regional Govt. Rep.,
councils works well. An example of this is the ex-officio membership of the water management Miami
district members on the regional planning council staff.
As local governments have adopted their local comp plans, they relied upon the permitted levels Local Government
and water supply regulations of the water management districts as the authority of water Representative, Orlando
availability. The WMD really had no concept of the role that their rules had in the
comprehensive planning process. The districts did not understand that their rules could cause
concurrency problems for local governments.
The proposed linkage between the SRPP and the DWMPs is appropriate. The district water Utility Representative,
management plans should not be merely a compilation of historical facts, and current activities Tallahassee
of the district.
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A mechanism must be provided to involve local governments early in the development of the County Representative,
district water management plans. Tallahassee
The recognition of the cost that the district water management plans will have on local County Representative,
governments should be included somewhere in the task force report. Tallahassee
Those portions of the district water management plans that will be binding on other entities County Representative,
should be adopted by rule. Tallahassee
Why is Recommendation #13 needed? Citizen, written
Recommendation #14 why is it necessary to mandate the contents of the district water Citizen, written
management plans in statutes? comments
Recommendation #13 would be supported if significant emphasis is placed on local government County representative,
participation and participation by the public. However, if the Department of Environmental written comment
Protection (DEP) finds the district plans to be inconsistent with the Florida Water Plan, the local
governments and the public should again be given the opportunity to provide input on changes
provided or requested by DEP and made by the districts. After input by the public and local
governments, the governing board's action would then constitute final agency action.
The district water management plans should be based on 25 50 year planning horizons (for County representative,
the same reasons identified in the Florida Water Plan comments above). The district water written comments
management plans should identify water availability areas for both surface and groundwater
where water is both available and permittable. The district plans should contain information on
the potential quantities of water available for consumptive use as described under Chapter
373.0395, Florida Statutes. The district water management plans should reflect the sum total of
the Water Resources and Facilities Reports as described under Recommendation #21. In
particular, the district plans should contain both a ground water basin resource availability
inventory and a surface water basin resource availability inventory.
In reference to Recommendation #15, each district should prepare updates to the plan as County representative,
needed, and consequently adopt rule amendments, revisions, or updates as required. The district written comments
should not be required to stick by a plan or parts of a plan that subsequently are shown to be
erroneous or unworkable. Plans should be "living" documents subject to change when the need
arises rather than subject to revision every five years. The districts should also be required to
provide the means by which the public can petition changes to the Plan when the Plan is found
to be in need of revision.
Interdistrict transfers of water should require more than just Governing Board approval due to Local Government
the importance of the resource. Representative,
STRATEGIC REGIONAL POLICY PLANS
The strategic regional policy plans should remain the nexus of the planning process due to the Regional Govt. Rep.,
necessity of the SRPPs to balance the many issues facing the region. Miami
Since the SRPPs must be adopted by a 2/3 vote, they will be very difficult to adopt. By making Regional Agency Rep.,
the SRPP be compatible with the DWMP and not have the DWMP be compatible with the SRPP, Orlando, written
the councils will have to incorporate what the WMD dictates. The relationship should be comments
mutually compatible. If the DWMPs are adopted by rule, the councils will have to comply with
The strategic regional policy plans are prohibited from being regulatory. Given the proposed County Representative,
relationship between the strategic regional policy plans and the district water management Tallahassee
plans, which are regulatory in nature, will the regional plans then become regulatory in nature?
The SRPP should have a prominent role in the ICE process, particularly in the identification of Regional Agency
natural resources of regional significance. Representative,
REGIONAL WATER SUPPLY AUTHORITY MASTER PLANS
There should be some link between the regional water supply master plans and the local Local Government
comprehensive plans, although unclear as to what this relationship should be. Also, the regional Representative, Orlando
water supply authority master plans and the district water management plans should be
compatible with one another, not consistent. Regional water supply master plans should not be
adopted by rule due to the fact that they are created by and consist of member local
What interaction will transpire between the regional water supply authorities and the 298 State agency, written
Before creating additional planning requirements by recommending that regional water supply County Representative,
authorities develop master plans, what is the task force trying to fix? The task force should Tallahassee
make recommendations as to the contents of these plans.
The report should include incentives for the water management districts to cooperate with the Local Government
local governments in the development of the district water management plans. By requiring Representative, Orlando
cross-acceptance of the district water management plans with other relevant local and regional
plans, an incentive is provided for the districts to involve those government entities and the
public in plan development.
The cross-acceptance process should occur at the beginning of the planning process, not once Local Government
the plans are almost completed. The task force should not recommend that a formal cross- Representative, Orlando
acceptance process be established for the agencies to follow, but that the required governments
and effected parties be brought together early in the plan development process to discovery any
incompatibilities or inconsistencies.
METROPOLITAN PLANNING ORGANIZATIONS
The task force report should at least mention the Metropolitan Planning Organizations, although Planning organization
no recommendations have been made. Representative,
Local Government Planning Recommendations
To perform water supply planning, all user classes must be considered. Local comprehensive Utility Representative,
plans do not address agriculture, water source, or investor owned utilities, etc. The local plans Tallahassee
have focused on infrastructure for publicly owned utilities. A planning vehicle is needed to
incorporate all water users into the local plans.
The task force report does not make any recommendations to the ICE element. Citizen, written comment
Recommendations 21 and 24 refer to five-year EAR reports, when in fact, 166 cities are on a 12 State agency, written
year, followed by a 10 year EAR schedule, with the remaining governments in a 7 year report comments
schedule at this time.
'Timely Reports" by the water management districts in Recommendation #22: Since a single State agency, written
water source may serve coastal and inland counties in addition to cities over and under 2,500, comments
timely reporting by the water management districts would probably mean annual reports, since
the EAR schedule spans from November 1995 until February 2004.
Stormwater management should not be addressed as simply disposal of excess water but as a
resource that is, in fact, a source of water capable of meeting environmental, agricultural, and
urban demands. The integrated relationship between stormwater management and water supply
availability must be addressed. In order to do this, the district must provide regional guidance
for opportunities to store, treat and retain stormwater.
Why is the task force elevating the issue of stormwater (Recommendation #24) when it is County Representative,
already addressed through 9J-5, F.A.C.7 This recommendation should be deleted. Tallahassee
Data and Information
The use of best available data should not be mandated to all levels of government, rather the County Representative,
data must be made available to the governments for possible use. The task force should not Tallahassee
recommend that the water management district data is presumed to be the best available.
Increased exchange of data and information is strongly supported. County Representative,
Water management districts should supply local governments with the data and information Local government
needed for local planning efforts. The district data should be considered the best available, representative
Local governments, in turn should, have the option to use the district's data or develop/prove Miami
that their data is more accurate.
There should be two-way communication of data between the local governments and the water Local Government
management districts. Local governments should be involved in the development of district data. Representative, Orlando
Is there duplication with the Water Resources and Facilities Report having to be submitted to the Local Government
regional planning councils and the local governments? Could the report be given to the Representative,
councils for inclusion into the strategic regional policy plans. The strategic regional policy plans Tallahassee
consistency link to the local government would then tie the data to the local governments.
Recommendation #21 is a good recommendation, but item #4 should be expanded to include Local government
data required of local governments by Chapter 9J-5, F.A.C. planning official, written
Recommendation #23 could have been made stronger. Citizen, written comment
Somewhere in all of the plans at the various levels, there should be a requirement that all the Citizen, written
plans use a common set of population projections. Maybe mandate the RPCs to develop the comments
projections with help from BEBR. The Metropolitan Planning Organizations, in particular, seem
to do whatever they want in developing population projections.
Why is it necessary to legislate the use of water management district data? Citizen, written comment
The Water Resources and Facilities Report should be done in time to be used in the Citizen, written comment
Intergovernmental Coordination Elements.
The term "timely fashion" in Recommendation #22, needs more specificity. Citizen, written comment
Does the term "best available data" include population projections? Citizen, written comment
Recommendation #21 should accurately reflect the preceding narrative providing background to City representative,
the recommendation. As currently worded, the recommendation implies that the Water written comments
Resources and Facilities Report would contain mandates to local governments, not technical data
and complete information as needed to develop evaluation and appraisal reports and to update
local comprehensive plans.
Recommendation #19 appears overly restrictive in that it may preclude the use of "best available City representative,
data" that is "regional" rather than "local" in scope or context. The treatment of "best available written comments
data" in Recommendation #19 should be consistent with Recommendation 23.
Recommendation #18. The water supply elements need special emphasis in this County representative,
recommendation. In (7), "water supply availability determinations" should be replaced with written comments
"estimates of water available and permittable in various geographic areas of the District and
delineation of water source areas where groundwater and surface water withdrawals are not
possible or are not recommended." If local government has this information then they can begin
to plan their future development and detail capital improvement plans. Without specific
information on water supply availability, it will not be known whether restoration goals, and
agricultural or urban water supply demands can be met. Item (8), needs to be added which
requires that the district workshop each report and gather public input. The report needs to be
accepted by the district governing board only after public input.
Recommendation #18 should accurately reflect the preceding narrative providing background to City representative
Do not support Recommendation #19. This recommendation should emphasize reliance on ALL County representative,
information that is available and should be taken into consideration for development of regional written comments
Recommendation #20 is supported, however, deadlines must be set for development of the
Water Resources and Facilities Report. Chapter 373.0395, Florida Statutes, which requires a
groundwater basin resource inventory by each district and a report submitted to each affected
municipality, county, and regional planning agency has not been met because it lacks a
deadline. In addition, a surface water basin resource inventory should be prepared by the
district somewhat in parallel with the groundwater basin resource inventory. The South Florida
Water Management District discharges approximately 4 billion gallons of freshwater per day on
the average to tidewater. The quantities discharged and the potential methods of storage in each
basin of this water should be addressed by the District. These discharges represent a
tremendous waste of our water resources.
Recommendation #23 is good, unless more accurate information is available. Additionally, the County representative,
regional planning councils pursuant to section 186.505(22), F.S., should conduct cross- written comments
acceptance reviews to identify inconsistencies between local plans, and between local plans and
regional plans, particularly as to the availability and source of water supply to meet the future
growth demands of the region.
The water management district data and information should be used as best available data. The Regional Agency
local government would still have the opportunity to develop and use their own information, Representative,
however the burden would be on the local governments to prove that their information is better. Tallahassee
Clarify how the integration and coordination will be carried out among all of the planning Multi-agency
documents. Commission, Miami
Do not forget the importance of land in the planning process. Land is a finite resource. Multi-agency
The report does not address the needs of agriculture. Citizen, Miami
Public awareness and education is important for the planning process and should therefore be Citizen, Miami
addressed in more detail in the report _
Agrees in particular with recognizing the SCP as the cornerstone of the planning process, Planning organization
adopting the SCP as the state planning document, consistency/compatibility of the state-level member, Tallahassee
plans, the need for a greater level of guidance, performance monitoring and accountability is
important. Intergovernmental coordination and public participation is vital to the planning
process. How will all of this come together as far as timing?
There should be cooperation during the development of all of the plans to identify and resolve Local Government
any inconsistencies/incompatibilities. Representative,
There needs to be clear recognition of the local government's ability to control development Local government,
density and intensity within floodplains. written comment
The Intergovernmental Coordination Element deadlines should be used instead of the EAR Citizen, written comment
deadlines. Many of the report's recommendations involve intergovernmental coordination. In
addition, the ICE's are due approximately one year before the EARs are due.
The problem of competing demands for water among ecosystem restoration, agriculture, and County representative,
urban growth must be resolved. Water supply issues must be addressed through a balanced and written comments
cooperative water supply planning framework which considers the needs of the environment,
agriculture, and people. To the extent that ecosystem restoration requires water quantities
which exceed presently available quantities, the rate of restoration should parallel long-range
plans for redirection of excessive stormwater discharges. Water supply plans must be developed
which are environmentally, technically, and economically feasible. Restoration objectives should
not require urban users to develop the most expensive sources of water (e.g., saline Floridan
aquifer water or water from the ocean) when alternative sources of fresh water are wasted to
tide. In addition, water supply alternatives should be flexible to provide for all reasonable water
needs environmental, agricultural, and urban.
The task force should address the funding commitments that will be needed for the Local Government
implementation of the recommendations. Representative and
The DRAFT Report seems to place the SRPP subordinate to the district water management plans Regional Agency Rep.,
and the Florida Transportation Plan, particularly as illustrated in Figure 6. The text is not so Orlando, written
bad, but the arrows on the figures may need to be reversed. comments
Page 33, Figure 6 should be revised to indicate that Section 339.155(2)(f), F.S., requires that the City representative,
Florida Transportation Plan to be consistent with local plans and Section 339.155(2), F.S., written comments
requires local plans to be consistent with the Florida Transportation Plan. In other words, the
consistency "arrow" should be directed both ways.