Title: Letter re: Minimum Flows and Levels Rough Draft
Full Citation
Permanent Link: http://ufdc.ufl.edu/WL00004978/00001
 Material Information
Title: Letter re: Minimum Flows and Levels Rough Draft
Physical Description: Book
Language: English
Spatial Coverage: North America -- United States of America -- Florida
Abstract: Jake Varn Collection - Letter re: Minimum Flows and Levels Rough Draft (JDV Box 39)
General Note: Box 29, Folder 13 ( JDV - Florida Homebuilders 1997-1998 Water - 1997-98 ), Item 3
Funding: Digitized by the Legal Technology Institute in the Levin College of Law at the University of Florida.
 Record Information
Bibliographic ID: WL00004978
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.

Full Text

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Affairs Department

Number Ope including cavmr sheo

prre Keith Hetrick
Director of Regulatory Affairs

Phaos: 904-2244316
Fax phone 904-224-7933


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Dear : u ,I,.

You have reque ted that we provide you with our view of what
"local sources firs means to our user group.

The Florida Home Builders Association represents builders
state-wide and we have even formed an internal Water Policy Task
Force, consisting of builders from all around the state, including
those from water ri h and water scarce areas. Included herein is
a copy of our Association's water policies which includes a "local
sources first" polity (policy 17).

Our Associ tio has actively participated in the water debates
in the Legisla ure ver the past three years and the legislation
that emerged this past session. Never have I seen a more
contentious i sue develop as did the "local sources first" issue,
which came to head t the end of this past session. Never have I
seen the press mis the boat as completely as they did on the
"local sources firs issue at the end of this past session.

I would note jt the outset that the "local sources first"
issue was very divisive in our Association early-on. Afte 11, our
builders in water ich Polk County have an interest in preserving
"their" water while builders in Peeinellas would like to be
able to transpo t, if needed and economically feasible.
Ultimately, we ca to the conclusion that "local sources first"
should not be a m date. In fact we oppose any such mandate.

The basis fo this view is that the concept of "local sources
first" really cre tes a very divisive nonproductive "Hatfields vs.
H Moeey" problem i.e. everyone fighting to protect "their" water.
More importantly, my Association agrees that the solution to water
development and reduction should be addressed regionally and not
simply locally. Ultimately, the concept f-"lael c-uroca firot'
would be a Major ohalrg -in- lorida water lawt that wateL-s a-
tatewid. rcoCuroo. We believe that Florida water law and the
doctrine of the "reasonable beneficial use standard" should-be
r-etined, as= i&. "Local oouroos firet" ii- it puitta L fun *ru.s
counter. to, baio Florida weteL Law. pbVwI4 m VA dde4vdIC 4Jt{4 P",w
5hloVA O's i) wkS vmet uj~A< Mr afJp-J4utwL 1Q jj.q
Further, and most importantly, the issue of "local sources
first" diverts peoples attention from the real issues that persist,
itasIt forth in the very valuable legislation that was passed this
past session. That is, the Legislature needs to provide meaningful
oversight and review of WMD efforts to produce more water. This
past session, significant provisions were included in
Representative Laurent's bill that require WMD budgetary
accountability in assessing needs and providing water, along with
local government, to meet the needs of all existing and future
uses. Each session, water budgets and needs)should be reviewed and
action taken if 9d re not being p

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Page 2

As to our policy re: "local sources first" we do not object to
WMDs balancing and considering the proximity of the proposed source
of water to the area in which it is to be used against other
economically and technically feasible alternatives as part of the
consumptive use "public interest" considerations in the issuance of
a permit. This approach is something that both our water rich and
water scarce builders can live with. However, we would object to
a "shall consider" approach to "local sources first" or any other
mandatory approach which elevates the concept or mandates the
consideration above all other relevant considerations a water
management district must make in the issuance of a consumptive use

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