Letter: Propsed Rule On the Highlands Ridge WUCA

Material Information

Letter: Propsed Rule On the Highlands Ridge WUCA


Subjects / Keywords:
Quantum efficiency ( jstor )
Irrigation systems ( jstor )
Efficiency objectives ( jstor )
Spatial Coverage:
North America -- United States of America -- Florida


Letter: Propsed Rule On the Highlands Ridge WUCA, June 15, 1990, To: Joseph Casper From: Kenneth Kuhl
General Note:
Box 10, Folder 15 ( SF Water Use Caution Rule - 1990-1991 ), Item 9
Digitized by the Legal Technology Institute in the Levin College of Law at the University of Florida.

Record Information

Source Institution:
Levin College of Law, University of Florida
Holding Location:
Levin College of Law, University of Florida
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All applicable rights reserved by the source institution and holding location.


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Southern Operating Division
106 S.W. CR 721
TELEPHONE Okeechobee. Florida 34974-8918 FLORIDA RANCH
(813) 763-3041 FOREST PRODUCTS
(813) 763-3545 FORESTRY
(813) 763-4332 MACHINERY

June 15, 1990

Joseph S. Casper
4908 W. Nassau Street
Tampa, Florida 33607

RE: Proposed Rule on the Highlands Ridge WUCA

Dear Mr. Casper:

I attended the public hearing on the Highlands Ridge WUCA
proposed rule held in Avon Park on June 13, 1990. I greatly
appreciated the opportunity to ask questions concerning the
latest draft which was presented at your last governing board
meeting. I expressed several concerns and suggestions at the
hearing and would like to summarize these for your consideration

The agricultural industry is interested in conserving water
as is attested by the industry's efforts to convert to more
cfficitnt -ieiivery systems in the last decade. It simply falls
within the purview of good business management.

Some of the first questions to arise within the agricultural
community regarding the efficiency aspects of the rule were,
"What are the current efficiency ratings for our irrigation
systems" and "Can we comply with the efficiency requirements
in the future"? I feel this has not received adequate attention
by your staff. The District has clearly moved from a "system"
efficiency mandate to a "permit based" efficiency requirement.
This change has caused some confusion and makes it difficult,
at best, for the grower to know where he stands until the
District reviews his monthly report.. I-f efficiency requirements
are incorporated by the District as an additional vehicle (i.e.
in addition to metering) to insure that users comply with
allocated quantities, then a simple methodology to determine
system efficiency should be developed. The grower should be
able to determine his compliance status before he invests
additional money and before he encounters a regulatory


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Proposed Rule June 15, 1990 Page 2

The average system efficiencies determined by IFAS, which have
been referenced throughout this process, were never intended
for use in a regulatory framework. This information was
published as an educational tool for growers to use as guidelines
when selecting the appropriate' irrigation system. Based on my
regulatory experience, its extremely dangerous to adopt data
intended to serve an educational role as the foundation of a
regulatory program. Before relying on such data, the following
questions should be addressed:

1) Were these averages computed on systems and under
hydrologic conditions commonly encountered on the ridge?

2) Was this data collected during periods of water stress
typical of the citrus irrigation cycle?

3) How many systems were evaluated to generate the average

4) Were the systems evaluated representative of systems used
in central Florida in regards to materials, number of
emitters used currently per acre, power sources, and
pumping systems?
5) Have tree spacings and system designs changed measurably
since this table was published?

Efficiency dasft collected for regulatory purposes should be
the result of a comprehensive study conducted under conditions
representative of the ridge. Methodologies utilized to calculate
these data should be understood and reproduceable by individual
growers. The agricultural community should be able to apply
the efficiency methodology utilized by the regulator to their
individual situations before they invest in a new system or
make major changes in existing system. In addition, the only
system which can attain the 85% efficiency (based on the IFAS
averages) by the year 2000 is drip. This may or may not be
a suitable system on the ridge. Using an unattainable efficiency
as the basis for water allocations for new systems installed
after July 1990 or existing systems by the year 2000 is not a
reasonable approach.

I ask that you and your staff reconsider the efficiency aspects
of this rule., Currently, you are proposing both metering and
efficiency mandates to meet one common objective. That objective
is compliance with allocated quantities. The metering function
will satisfy this objective, but I seriously question the purpose
of the efficiency schedule. If you maintain the efficiency
element in the final draft, I think the efficiency ratings

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-. L I LA. 11 1 il hi L 11

Proposed Rule

June 15, 1990

should be revisited. Better data could be generated via
cooperation with growers in the area, or perhaps a range of
efficiencies would be more appropriate based on the IFAS data
if they are not utilized for calculating permitted quantities.

Again, thank you for this opportunity to submit comments on
this topic.

Coordinator of Environmental
and Governmental Affairs


c.c. Pat R. ilton

John Tallent

Page 3


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