11/08/1994 05:30 8135958568 urUNI-Z .
OCKUNZZI & ASSOCIATES
2706 First St. East, Suite Four 813-786-0456
Indian Rocks Beach, Florida 34635 Fax 813-595-8568
To: Jake Varn
From: Bill Ockunzzi
Subject: Recommendations of the Governor's Task Force on Land Use and Water Planning.
Date: November 7, 1994
Thank you for the copy of the above referenced workshop "draft". My comments are organized
by page number and reflect my thoughts as I read through the document. Bottom line: as I
pointed out during our breakfast meeting a few weeks ago, better coordination between the land.
water, and transportation elements of the State Plan is certainly needed. However, the approach
of this document is that water is the "controlling" element or the element with the most potential
to control. If that is the case lets redraw the WMD boundaries or move to a State wide WMD.
page 1, paragraph 2, 4th sentence: Why not say that water planners are planning for water use
(including distribution) "without considering the implications for the state's land use patterns;
economic needs, aspirations, or potential; etc."
page 1, paragraph 3, 3rd and 4th sentences: I thought the WMDs and DEP "protected" water
resources and did not "control the allocation of water resources.." The water supply authorities
should be in the allocation business in a manner consistent with local and regional plans.
The two statements, as written in the draft report, demonstrate the bias toward state control and
lack of concern or knowledge of the relationship between the use of resources and our overall
well being as a society. It seems to me that our water agencies have done a horrible job with
water supply planning as exhibited by the current situation in many areas of the state. If normal
rainfall had not returned to our area this past summer the crisis atmosphere would be much more
severe at the present time. The supply authority's failure to do its job will be corrected by the
officials that manage the organization. The WMDs, on the other hand, are severely out of touch
and basically unsupervised. The WMD regulatory staffs (wetlands, construction, etc.) do a good
job, but WMD planners and the WMD planning function are uncontrollable in the present system.
Frankly, WMDs are too big (breadth of functions, geography, budget, staff, etc.) to be effectively
managed by their present board structure.
page 2, paragraph 2, Ist sentence: I don't agree with the notion that most local plans concentrate
on providing "adequate facilities for" rather than an" adequate supply of" water. The real
problem may be the failure by water managers to realistically look at population, agricultural, and
industrial growth potential (water demand) by area and respond accordingly. It just doesn't make
sense that all the reviews of local plans by state planners from the many reviewing agencies would
overlook the supply issue. Also, why pick on the local government plans. What about
agricultural and industrial demand and uses? Why shouldn't "concurrency", of some form, apply
to these users' I have been told that, even though public water system permits have been cut
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back, permits for agricultural uses are still being issued. The concept that local governments are
totally to blame sounds like buck passing.
page 3, recommendation #5: The report falls far short of this goal. I don't think anything was
abolished or substantially restructured. What the report achieves is something like a
"codification" of the way the present system should work.
page 3, last paragraph: The whole focus is on using" state water resource data" to provide policy
guidance. I thought the premise was to bring together water, land, and transportation planning to
bring water, roads, and land use (people, agriculture, natural systems, etc.) to the same place on
the map? The premise as stated in the report is interpreted to mean the water managers control
everything. From a data point of view, FDOT's data base may be much more credible and
realistic, especially when you look at small area projections (certain corridors, etc.). Also, the
consistency between state data and local data in transportation planning is generally pretty good
and the emphasis is not top/down.
page 4, paragraph 3, 2nd sentence: Notice that the state was supposed to "identify metropolitan
and urban growth centers". This report does not call for map. Until we do a map that
recognizes where urban, suburban, agricultural, etc. development will take place and provide the
growth areas with the "opportunity" to obtain water and transportation facilities to support the
growth desired or allocated, much of this is academic. Simplistically, all of the counties and
regions of the state compete with one another. Protect the resources with a sustainable yield
philosophy and let the areas compete.
page 6, Figure 1: Is the Florida Land Plan developed with a top dowl or bottom up approach.
The Task Force should make their preference clear. The Florida Transportation Plan should
include: other infrastructure such as powerlines and pipelines; provisions for the economic
distribution of infrastructure; and a man. Certainly we can provide a future transportation map
even if it is just corridors. The Florida Water Plan should include: development of safe yields for
each source and consumptive use standards for people, industry, and agriculture.
page 7, Recommendation 4: The use of the best available data is fine. Projections are not data,
they are goals or aspirations. Some groups want the state to grow and prosper, some groups
want the state to prosper. Whose data will be used. This data use issue comes up several times
in the report. I don't think the authors have hit on an acceptable solution to the problem. The
transportation model may be a good place to start. Eventually the state will have to limit state
funding for any activity that exceeds their best guess of what an area's total demand will amount
to. EPA did the same thing several years ago (2 decades) when every community was trying to
obtain funds to build a sewage treatment plant big enough to serve New York. Of course the
philosophy of each community was "if we build it they will come". EPA correctly funded only
existing needs plus reasonable growth.
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OCKUNZZI & ASSOCIATES page three
page 11, recommendation 7: Add the concept of "safe yield, economical distribution to meet and
provide for the state's economic well being and competitiveness."
page 11, recommendation 8: Add, "e" supply sources; "f" safe yield each source; and "g" how or
who controls access to each source.
With regard to item #2, a twenty year horizon is not nearly long enough. The period should be at
least thirty years and perhaps filly. Updates no more frequent than every ten years. The local
plan updates are too frequent at five year intervals. I think we've learned that we need to stop
planning at some point and implement.
With regard to item #3, we also need to identify policies for the withdrawal and beneficial use of
water resources and water transport from the source to the users. As written the document
focuses on protection.
page 11, State Water Policy: Because this is a "policy" it should recognize that an "adequate
supply of water at the lowest possible cost is critical to Florida's ability to be competitive." The
policy should also recognize that it makes sense, and is good public policy, to develop the
cheaper sources, within sustainable yield limitations, first."
Vpage 13, Florida Land Plan: You should require a map of some kind to indicate where growth
(urban, rural, mining, agricultural, etc.) is expected to exist to guide the planning processes. The
use categories should be very simple, "developed, undeveloped (in the plan time frame),
preservation (no development ever), and conservation (very limited use, such as parks)
Last paragraph. We need to do a much better job of planning for the use and protection of state
lands and resources of all types. This section should be strengthened and more detailed.
V page 14, Recommendation 9: Needs a map requirement.
q page 14, Recommendation 10: Add to item #2, the identification of growth areas, agricultural
V Item 4b. Energy efficiency is fine but the statement seems out of place in this context.
Item 4c. Just a comment; why can we assure an adequate housing supply for some segment of
our population but not be anywhere near as bold in assuring an adequate water supply. I sense a
major "waffle" on the pai L of the Task Force or a deep ideological divide?
Item 4d. Can we use the beach or just protect it? Does protection mean tourists can't walk on
it? The problem with unbalanced assessment and statements like these is they are easily taken out
of context. If the Task Force wants no use the report should be clear. Likewise, if some level of
use is necessary, desirable, etc. then it should be so stated. As planners we now know that the
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apple pie statements cause huge conflicts with practical implementation.
Item 4f If we are to "assure the appropriate use of land..." then the report should also state that
we must be willing to "assure that those appropriate uses will have adequate supplies of water,
fuel, electricity, etc. at the location of the appropriate land use (urban or rural)."
Item 4i. Mitigation should specifically include the notion that activity in high hazard areas (say
the beaches and coastal areas) is necessary and desirable (ports and tourism) and that property
and lives can be protected without the prohibition of development in such areas. Government
can and does require that insurance against risk is in place.
page 15, 1st. paragraph: We should abolish DRIs and FQDs. With "wall to wall" local plans
and state and regional review of same, they have outlived their usefulness as presently defined.
Perhaps the plans for resources/facilities of state or regional significance should be required to go
through the DRI process to assure that the resource or facility is properly used and that public
input on the planned use is adequate. Having the regional planning councils approve plans for
state facilities in their areas would help integrate state property into local plans. The relationship
between MPOs and FDOT with respect to transportation could be a model for this type of
page 16, third bullet: The independent, single function, MPOs should be abolished or folded into
some other organization to better integrate transportation planning into comprehensive planning.
page 16, Recommendation 12: The Transportation Plan needs a map. This would be the easiest
place to demonstrate that a state map can and would be effective in integrating the levels of plans
page 17. Recommendations for Regional Planning; The role ofRPCs needs to be more clearly
articulated. Ideally the state plan map should be a compilation of the regional plan maps and the
RPCs should plan for state resources in their areas (or review the plans for state resources). The
FDOT/MPO model is a place to start.
page 19, Recommendation 14: Again, sources and yields are not specifically addressed.
page 21, Figure 2: The District Water Plans' (1st. bullet) "priorities" should be required to be set
based on costs to the consumer (voter), safe yield, etc. As written this is a plan with human
consumption and needs at the bottom of the food chain.
page 22, Recommendation 16. This is where the "allocation of water" begins. The Water
Supply Authority should be required to "obtain" and "develop" water supply sources, within the
constraints of safe yields and economic competition, to meet the needs of their area. Add
"develop the resource" to Figure 3.
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OCKUNZZI & ASSOCIATES page five
page 25, Figure 4: Strategic Regional Policy Plans should be required to include a map.
page 26, Recommendation 18, #4. The remainder of any safe yield for a specific resource should
page 27, #7. WMDs should be required to use planning data that reflects the amount and location
of future growth. The WMDs should not be in the business of making these decisions.
page 29, recommendation 20: Basically the state agencies should be prohibited from involving
themselves in local preference issues. Examples include: housing types, clustering vs. large lots,
urban form, etc.
page 30, Recommendation 21: Another report?
page 31, Recommendation 23: I don't think the WMDs are the gurus of best available data for
predicting the future. Economics, social and cultural trends, etc. are far beyond their capabilities.
The water planners should focus on identifying sources of supply and protecting the resource
through enforcement of safe yield limitations.
Recommendation 23, 2nd paragraph: doublespeak?!
The report is a good effort and a start. However, it seems to be written from a strong
preservation/conservation/top down/water management perspective. As a consumer, I don't
think the responsibility for developing the resource that my drinking water will come from is any
more clearly defined. As noted earlier the report seems to "codify" the way the existing water
management supply laws are supposed to work in an ideal context. The more specific direction
will help the existing situation, but fall far short of solving the problem. A major omission is an
assessment of the WMD board structure and its appropriateness to carry out the many functions
assigned to WMDs Why are they so far behind with the resource assessments and plans?
Why did the Task Force not attempt to apply the "transportation/land use planning model" to
water planning? It seems to me that, overall, our roads and land use densities are planned in a
complementary and coordinated manner. The issue in transportation is funding to build the roads
fast enough or concurrency provides the temporary "fix". The density may still be desirable but it
has to wait for the roads to be adequate. The relationship between a state agency (FDOT) and
local government/appointee commission (MPOs) gets the job done in transportation. The same
arrangement would work better for water. The fact that the Task Force found so few
improvements necessary for transportation speaks volumes about the success of the structure and
process now being utilized. A little bit of this success in the transportation arena is related to
structure and lot of the success is related to accountability to the public. Transportation
managers are focused. At present our water planners are not accountable. I suspect the supply
authority in our area will become much more accountable and directed now that all of our region's
jurisdictions are beginning to feel the same pressures. WMDs need focus and accountability.
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OCKUNZZI & ASSOCIATES
For example, why not let the WMDs regress to their original purpose, "protect each source" and
have some organization composed of local and state officials develop the allocation plan. I think
accountability and results would be much better and more cost effective.
Thanks for allowing me the opportunity to comment. I know we disagree on some issues. Good
Please note my new phone number and address. Home phone is 813-595-7006.
Post-t" brand fax transmittal memo 7671 #of pal .
Dept. Phone #
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