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

 

 

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