December
3, 2002
Mr.
Henry Dean, Executive Director
South
Florida Water Management District
3301
Gun Club Road
West
Palm Beach, Florida 33416-4680
Dear
Mr. Dean,
The
Southwest Florida Watershed Council (SWFWC) has been following Caloosahatchee
River estuarine conditions since the Caloosahatchee MFL Rule was adopted in
September of last year. Such
conditions are of concern to many of our members.
It is apparent that MFLs have been exceeded on occasion since the rule
was adopted, with significant implications for the Recovery and Prevention
strategy and future storage options proposed in the Southwest Florida
Feasibility Study.
Until
the rains of mid-November, the trendline for river flow to the estuary for
November was staying well below 300 cfs daily, and was often zero. This
lead to our concern that the management of the river flows was being driven by
priorities unrelated to the health of the estuary. Upon contacting
District staff, our concern was validated. We were told that unless an MFL
violation was occurring, there would be no flow to the estuary. Since the
SWFWC represents business and political interests whose economy is as dependent
upon river flow as any other users, we question why the MFL Rule is being
interpreted in the way it is.
The
MFL Rule is apparently not being used to guide a management system of flow to
prevent problems. Instead, it is being used in a way that will undoubtedly
result in considerable problems for the Caloosahatchee estuary which will then
require drastic regulatory remedy. How can we get this reversed in our current management
framework?
On
a related topic, we made a request to you in June of this year that the
Caloosahatchee MFL rule be opened for review in September 2002 and that the
SWFWC be notified of any public hearings, document mailings or other activities
relating to the MFL rule for the Caloosahatchee. We also requested official participation in Minimum Aquifer
Level rule development for the Water Table Aquifer in Southwest Florida.
We are concerned that our voice is not being heard, and so we once again
ask for you to consider our request for inclusion.
Sincerely,
Noel
Andress
Chairman
Copy:
Ms. Carol Wehle, Ms. Trudi Williams
