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Agenda 11/18/2008 Item #16C 6 Agenda Item No. 16C6 November 18, 2008 Page 1 of 5 EXECUTIVE SUMMARY Recommendation to approve the communication of concerns from the Collier County Water-Sewer District by letter, under the signature of the Chair of the Board of County Commissioners, Ex-Officio the Governing Board of the Collier County Water-Sewer District, to the South Florida Water Management District relative to the proposed creation of Florida Administrative Code Chapter 40E-IO ("Picayune Strand Reservation"). OBJECTIVE: To approve the communication of concerns from the Collier County Water-Sewer District by letter, under the signature of the Chair of the Board of County Commissioners, Ex-Officio the Governing Board of the Collier County Water-Sewer District, to the South Florida Water Management District (SFWMD) relative to the proposed creation of Florida Administrative Code Chapter 40E-1O ("Picayune Strand Reservation") . CONSIDERATION: SFWMD has initiated rulemaking to create Florida Administrative Code Chapter 40E-10 ("Picayune Strand Reservation"). This rulemaking is a legal mechanism for reserving, or setting aside, a specified amount of water within the Picayune Strand reservation area to protect those waters for the natural system and to prevent its consumptive use. SFWMD has determined that all freshwater within the Picayune Strand reservation area should be prevented from consumptive use. The Public Utilities Division, representing the Collier County Water-Sewer District, has been actively involved in the rulemaking process, attending several rulemaking workshops and providing comment relative to its concerns. The primary concerns relative to the proposed rule, in its current iteration, are: . Problems exist concerning the technical reports relied upon by SFWMD staff in drafting the proposed rule and determining that a full reservation of water within the Picayune Strand reservation area is appropriate. . SFWMD has failed to respond to concerns regarding the proposed rule that Collier County staff has expressed to the peer review panel. . Collier County has a water use permit application pending before SFWMD - since 2006 - that requests freshwater allocations that may have a potential to impact the Picayune Strand reservation area, which may be prohibited if the proposed rule takes effect prior to permit issuance. Staff has prepared a letter addressing the concerns of the Public Utilities Division, attached to this Executive Summary as Appendix A. The letter will be transmitted via hand-delivery to SFWMD's Governing Board upon approval and signature. .~- FISCAL IMPACT: While there is no immediate fiscal impact associated with this item, there is potential for negative fiscal impact to the Public Utilities Division if the rule is promulgated in its current iteration. Agenda Item No. 16C6 November 18. 2008 Page 2 of 5 GROWTH MANAGEMENT IMPACT: There IS no growth management impact associated with this item. LEGAL CONSIDERATIONS: No legal issues are raised in this Executive Summary.- JAK RECOMMENDA TION: To approve the communication of concerns from the Collier County Water-Sewer District by letter, under the signature of the Chair of the Board of County Commissioners, Ex-Officio the Governing Board of the Collier County Water- Sewer District, to the South Florida Water Management District relative to the proposed creation of Florida Administrative Code Chapter 40E-IO ("Picayune Strand Reservation"). PREPARED BY: Paul E. Mattausch, Director, Collier County Water Department Agenda Item No. 16C6 November 18, 2008 Page 3 of 5 November 18, 2008 VIA TELEF ACSIMILE (561) 242-5499 AND MAIL Scott Burns Director, Everglades Water Supply Policy South Florida Water Management District Post Office Box 24680 West Palm Beach, FL 33416-4680 Re: Proposed Picayune Strand Reservation Rule Dear Mr. Burns: Please accept this letter as the comments of the Collier County Water-Sewer District (CCWSD), with respect to the proposed creation of Florida Administrative Code Chapter 40E-IO ("Picayune Strand Reservation") by the South Florida Water Management District (SFWMD). While the CCWSD strongly supports SFWMD's efforts to conserve water resources, serious concerns still remain with the proposed rule which must be addressed. The primary concerns relative to the proposed rule, in its current iteration, are: I. Problems exist concerning the technical reports relied upon by SFWMD staff in drafting the proposed rule and determining that a full reservation of water within the Picayune Strand reservation area is appropriate. 2. SFWMD has failed to respond to concerns regarding the proposed rule that Collier County staff has expressed to the peer review panel. 3. Collier County has a water use permit application pending before SFWMD - since 2006 - that requests freshwater allocations that may have a potential to impact the Picayune Strand reservation area, which may be prohibited if the proposed rule takes effect prior to permit issuance. The Collier County Water-Sewer District thanks the South Florida Water Management District for this opportunity to comment on the proposed creation of Florida Administrative Code Chapter 40E-l 0 ("Picayune Strand Reservation"). If you have any questions concerning the comments contained herein, please contact Paul Mattausch, Director, Water Department, Collier County Water-Sewer District. We look forward to continuing to work with the South Florida Water Management District in protecting water resources in order to provide a sustainable South Florida. Sincerely Yours; I Agenda item No. 16C6 November 18, 2008 Page 4 of 5 Tom Henning Chair, Collier County Board of County Commissioners Ex-Officio, the Board of the Collier County Water-Sewer District Attachment cc: Eric Buermann, Chair, SFWMD Governing Board Michael Collins, Member, SFWMD Governing Board Charles J. Dauray, Member, SFWMD Governing Board Shannon A. Estenoz, Member, SFWMD Governing Board Paul C. Huck, Jr., Member, SFWMD Governing Board Melissa L. Meeker, Member, SFWMD Governing Board Jerry Montgomery, Member, SFWMD Governing Board Patrick J. Rooney, Jr., Esq., Member, SFWMD Governing Board Carol Wehle, Executive Director, SFWMD Chip Merriam, Deputy Executive Director, SFWMD Thomas Olliff, Assistant Executive Director, SFWMD James V. Mudd, County Manager Leo Ochs, Deputy County Manager Jeffrey Klatzkow, County Attorney James W. DeLony, Administrator, Public Utilities Division Paul Mattausch, Director, Water Department Phil Gramatges, Interim Director, Public Utilities Engineering Department Edward de la Parte, Jr., Esq., de la Parte and Gilbert, P.A. Kristin Yerkes, Esq., de la Parte and Gilbert, P.A. Amy Duffey, Esq., de la Parte and Gilbert, P.A. 2 Page 1 of 1 Agenda item No. 16C6 November 18, 2008 Page 5 of 5 COLLIER COUNTY BOARD OF COUNTY COMMISSIONERS Item Number: Item Summary: 16C6 Meeting Date: Recommendation to approve the communication of concerns from the Collier County Water- Sewer District, by letter, under the signature of the Chair of the Board of County Commissioners, Ex-Officio, the Governing Board of the Collier County Water-Sewer District, to the South Florida Water Management District relative to the proposed creation of Florida Administrative Code Chapter 40E-10 (Picayune Strand Reservation), 11/18/20089:00:00 AM Approved By Paul Mattausch Water Director Date Public Utilities Water 11/12/200812:02 PM Approved By Thomas Wides Operations Director Date Public Utilities Public Utilities Operations 111121200812:46 PM Approved By Jeff Klatzkow Assistant County Attorney Date County Attorney County Attorney Office 11112120081:49 PM Approved By James W. Delony Public Utilities Administrator Date Public Utilities Public Utilities Administration 11/1212008 1 :51 PM Approved By John A. Yonkosky Director of the Office of Management Date County Manager's Office Office of Management & Budget 11/1212008 3:22 PM Approved By James V. Mudd County Manager Date Board of County Commissioners County Manager's Office 11/12/20085:01 PM file://C:\AgendaTest\Export\116-November%20 18,%202008\16.%20CONSENT%20AGE... 11/12/2008