ROR C A
FORESTRY
ASSOCIAT

402 EAST JEFFERSON STREET POST OFFICE BOX 1696 TALLAHASSEE, FLORIDA 32302-1696
(904) 222-5646 FAX (904) 222*6179
Wm. Earl Smith, President Wm, Carroll Lamb, Executive Vice President

September 1, 1993


Tom Swibart
Fla. Dept of Environmental Protection
3900 Commonwealth Boulevard
Tallahassee, Florida 32399-3000

Dear Mr. Swihart:
I had the opportunity to attend the August 31 public workshop on the latest revisions to the
state water policy. On behalf of the Florida Forestry Association, I submit the following
comments for your consideration.
The Florida Forestry Association views the revision process that you are currently
undertaking as a priority. We participated in the 1992 public workshops and outlined our
concerns at that time. As we review the current draft, a number of issues could have a
great impact on our members.
Our first concern is with the use of the word ecosystem. Phil Gornicki of our staff has been
monitoring the meetings of the Partners for a Better Florida Commission, the DEP
Ecosystem Action Team, and other groups as they attempt to develop a definition for
ecosystem management. To his knowledge, the term has not been defined.
Without an accepted definition, I believe it is inappropriate to include this in the draft. The
impact that it could have on our landowners depends largely on how it is defined.
We oppose Section 17-40.475, referring to the establishment of protection areas a'doining
surface water bodies and wetlands. While I realize this issue was addressed often during the
public workshop, it certainly deserves to be reiterated. We believe this section gives the
Water Management Districts the "green light" to create buffer zones along water bodies
similar to the Wekiva and the Econ Rivers.
Aside from the legislative and legal arguments raised by Frank Mathews, these buffers have
a great impact on the property rights of the landowners along those waterbodies. I was
directly involved in the Econ River protection zone and cannot overestimate the impact that
the restriction has on the landowners. Timber harvest has been limited within the zone as
well as any expansion of current farming practices.








Tbm Swihart (continued)
Sept 1, 1993

Page Two

We oppose any policies that would further restrict private property without compensation
to the landowner. I urge you to delete Section 17-40.475 in it's entirety.

Finally, I ask that you include a reference to the revised Silviculture Best Management
Practices Manual (see enclosed). The appropriate place might be in Section 17-40.432,
Surface Water Protection and Management.

In 1992, Agriculture Commissioner Bob Crawford established a BMP Technical Advisory
Committee which included representatives from state and federal government, university,
forest industry and environmental groups. The Manual establishes practices for our
industry to follow to achieve water quality goals. In addition, general ecological consideration
and wildlife habitat values have been included. We believe it is very appropriate to include a
reference and definition of this document. With this, many of our concerns could be
addressed.

I appreciate the opportunity to submit comments and will give you a call to answer any
questions you may have.
Sincerely,


Mike Joyner
Government Relations Director

MJ:dwb
Enclosure

be: Jeff Vowell
Gorman Eidson


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