Dear friends of
The Florida DEP is in the process of making changes to
HOWEVER - we have some concerns about how DEP is
positioning this rule to eventually develop and we are not the only ones with
concerns. EPA has written a comment letter
to DEP in which they outline a number of concerns.
We have attached a document from DEP's
website which gives EPA's comments and DEP's
responses. This is very technical stuff
and it may not appeal to everyone. We
will be sending you regular updates on what's happening with this rule so you
can weigh in on it as you have time. The
next meeting will be on May 28th at UCF in
http://www.dep.state.fl.us/water/wetlands/erp/rules/sw_swt_rule_dvlpmt.htm
THIS RULE IS EXTREMELY IMPORTANT!!!
It is going to require your help and participation if we
are going to overcome the strong political power from the development community
and others. For those of you who do not
have the time to read through EPA's comments, here are some of the issues that
you will see throughout the coming months in regards to this proposed rule:
1. An independent
review of the Harper Methodology must be done.
DEP is having one done by the University of Florida but the review will
not be completed until the TAC meetings are almost over - which may be too late
to matter;
2. Harper
Methodology treats wetlands as land-uses and leaves pollutant loading rates for
natural wetlands up to the user. THIS IS
A HUGE ISSUE FOR US AND MUST BE RESOLVED IF WE ARE TO HAVE AN IMPROVEMENT OVER
OUR CURRENT RULE! This effectively means
that DEP assumes that wetlands are a source of nutrient pollution, which is a
concept contrary to the Clean Water Act.
3. Pre-project
condition should be treated as the land as it was in its natural condition prior
to ANY development including agriculture and silviculture,
not as it is now. Right now, this is how
the proposed rule reads and the Governor's office is in support of this
position. We need to let the Governor's
office know that this is a critical issue for us and we want them to stick to
their guns. The developers are going to
be lobbying for this policy to be changed and we must not let that happen.
There are other important issues as well,
however, I don't want to bog you down with too many details right now. Please just accept this as a heads up about a
very important issue that will need your attention. The sooner the better!
You will be hearing more from me and please go to the DEP
website when you have time and start educating yourself about this important
policy work that is underway.
For the waters we love!
Linda
--
Linda L. Young
Director
Clean Water Network of FL
850/222-9188
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