e904 754 6878 SWFWMD LEGAL
Water Management District
2379 Broad Street Brooksvllle, Florida 34609-6899 e 1-800-423-1476 (Florida Only)
or (352) 796-7211 SUNCOM 628-4150 T.D.D. Number Only (Florida Only): 1-800-231-6103
Internet address: http://www.dep.state.fl.us/swfwmd
.4 E.Jid OiFCmurin ti:xv"
Roy G. Harrell. Jr.
Choirmon, St. Petersburg
Joe L Davis, Jr.
Vice Chairman. Wauchula
Curtis L Law
Secretary. Land O Lakes
James L Allen
Ramon F. Campo
Rebecca M. Eger
John P. Harliee. IV
Ronald C. Johnon
James L. Marlin
E. D. "Sonny" Vergara
Gene A. Heath
Assistant Executive Director
Edward B. Helvenston
7601 Highway301 North
Tampa. Fida 33037-6759
1-80836-0797 or (813) 965-7481
170 Cenluy Boulevord 115 Corp
Bortow. orido 33830-7700 Venice. R
1-800-4927862 7 c(941) 534-1448 1-800 320
SUNCOM 572-620 SUNCOM
/JA) QA% h
ration Way 2303 Highway 44 West
ido 34292-3524 Inverness. Florida 353-3809
3503 o (941)486-1212 "(352) 637-1360
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12/24/97 14:41 0904 754 6878
TO: John Heuer, Interim Deputy Executive Director
FROM: Ken Weber, Chief Regulation Geologist, Technical Services
SUBJECT: Review of Don Conn's Comments on the Consolidated Permit
Here are my comments on the letter from Don Conn dated December 24, referenced to
his item numbers:
1. The individual facilities should have quantities assigned because there is a
continuing need to limit each facility to prevent adverse impacts. Without such
limitations, a facility could be pumped at a quantity above that at which impacts were
assessed resulting in adverse environmental or existing user impacts.
2. The individual withdrawal points should have quantity limitations for the same
reasons as stated above.
3. We should not impose requirements upon the District through our permits, this
permit is intended to limit the permitted. There is no reason to believe that the District
will not provide a timely response in an emergency situation.
4. This language does closely conform to the Partnership Plan, although I believe
some improvements were made that were going to be considered as changes to the
5. The condition language only says they have to consider pumpage reduction first;
They would not necessarily have to implement that measure if another was found to be
more effective. Our position has always been that reductions in withdrawals is the
primary mechanism for mitigation, and that other measures are secondary and of
6. I believe the intent was to give the District control over mitigation, and
considering that this permit would be issued under the "cooperative scenario", there
shouldn't be substantive disagreements on such issues.
7. This is an area for discussion, but the chances of getting expeditious agreement
on such a weighty issue is unlikely. I suggest we leave it as worded but agree to
continue to meet with them to resolve this issue.
8. I don't believe there are sites that WCRWSA and/or their consultants aren't
12/24/97 14:42 0904 754 6878
aware of, but Clark should be able to give you more information on this one.
9. This condition merely says that the EMP will be used for all sites unless and until
40D-8 levels and criteria are established, at which point for any sites where there is a
conflict 40D-8 would control. It is not anticipated that 40D-8 levels will be set for all of
the sites in the EMP, therefore this dual-coverage is necessary.
10. See answer to 6, above, except that this relates to monitoring. Again, Clark may
be able to help on this one.
11-15. The tables are still being constructed, but you can let WCRWSA know that
pretty much all we are doing is combining the tables from the existing permits. There
may be a few exceptions, but on the whole they are substantively the same sites as
currently monitored. If necessary, we could have Mario, John Parker, Len, and John
Emery point out any sites that are not listed on the existing permits.
16. This one would best be discussed with Jim Robinson and Frank Hearne.
Jim Robinson and I are "tag-teaming" the consolidated permit, and he will be in the
office next week. I will be out from tomorrow through the 6th of January, but will be
calling in and available via phone, fax and E-mail. I can participate in conference calls
and fax or E-mail-in work products if necessary. Let me know if there is anything more
to be done.
cc: Jim Robinson