JAN-02-1998 11:47 CLIT U r ....
4 CITY OF TAMPA
Office of the City Attorney
James D. Palernmo
January 2, 1998
Jake Varn, Esquire
Steel, Hector and Davis
215 South Monroe, Suite 601
Tallahassee, FL 32301
I am providing the initial comments from the City of Tampa on the
draft permit for your review prior to the January 7th meeting. We
are looking forward to working with you at that time.
Consolidated Public Water Su dlv System Permit Review Comments
Page 001: I am unclear as to why the SCHRW is separated from
other 11 wellfields.
Page 002: last sentence at bottom: "approval", verbal or written?
Page 003,Spec Cond #1: 2 different Regulation Dept Directors
throughout the remaining permit is somewhat confusing. Perhaps
this should be taken to the next level, i.e. their boss? Who
will decide if conflicts arise?
Page 003, Spec Cond# 2: Will the Cone ranch and East Brandon
wellfields be classified as the Central System? May want to add
them to the list of 11 or 12.
Page 003,Spec Cond#3: I do not believe that we want to submit our
water conservation info and GPDC info through WCRWSA to SWFWMD.
There may be other reports as well. We will be happy to copy
Page 004,SC#6D: Which Reg Dept Director? See above comment.
Page 005,SC#7A3): SWFWMD should not get into the issues of water
pressure or water quality. This is the Dept of Health's area
315 East Kennedy Blvd., 5th Floor Tampa, Florida 33602
813/274-8996 Fax: 8131274-809
813 274 8809 p.01/03
PloP A LEGAL DEPT.
813 274 8809
JAN-02-1998 11:47 CIIY U- I
Tampa comments; page 2
Page 005, SC#7A6): ASR should be for raw and finished water.
Page 006, SC8C,first sentence: States that SWFWMD may require
mitigation of lakes and wetlands. Is this true for after minimum
flows and levels are set? I thought the scientific studies
determined the levels which would result in no adverse
environmental impacts. This mandate could be an additional cost
and would reduce the overall yield of a wellfield based on the
last sentence in the paragraph. I need clarification on this
Page 006,SC#8H: It is important that this plan not reduce the
flow available in the river. May or may not be significant.
Page 008,SC#10: The 110 GPCD in 2008 requirement could be a
problem. This problem arises annually for Tampa. We have many
small commercial business that get calculated into the
"residential" per capital, thus making the City's per capital
higher than it actually is. Are these the same numbers for the
Water Use Caution Area documents? Also, last sentence in para
states "per capital rate requirements may be adjusted through
rulemaking". I thought we were to be granted a waiver to the
rulemaking or was that just for MFLs?
Page 009,SC310C: The 10 % unaccounted for water limit is low
based on AWWA standards. It will depend upon their definition for
unaccounted for water;ie, does it include line flushing and fire
Page 009, SC1ODI)c: I don't think we are able to determine the #
of mobile homes we serve.
Page 013, SC#12, first lines: Again, I thought this permit or the
Partnership documents control.
Page 014,SC#12,last para: Regulatory levels can only be exceeded
during the "first 8 weeks of each Water Year"( Oct, Nov, Dec ?).
How will WCRWSA be able to provide all of that extra ground water
from the central system in a drought for the City of Tampa (and
other members) that Don Pollman has said would be available?
I did not have a page 015 but I had two 014s.
Page 016: I am unclear as to how the requirements for the SCHRWF
overlap with other permittees.
The City of Tampa proposes that the Tampa Bypass Canal permit be
included in the partnership plan with the City and the WCRWSA as
the joint permittees. We are also in the process of renewing our
permit for the Hillsborough River. The City shall remain the
JP +-2-198 11:47 CITY OF TMPA LEGL DEPT. 813 274 889
Tampa comments, page 3
sole permitted on the River.
a surface water project and
permit be issued jointly to
When the WCRWSA is prepared to have
permit, the City proposes that this
the City and the WCRWSA.
The City of Tampa is looking forward to working with the SWFWMD
and the member governments in resolving these issues.
Kathy M. Fry
Assistant City Attorney
Member Government Attorneys
David L. Tippin, P.E.
Mike Bennet, P.E.
Don Conn, Esq. WCRWSA