August 19, 2002



Ms. Janet G. Llewellyn

Department of Environmental Protection

Office of Water Policy

2600 Blair Stone Road, Mail Station 46

Tallahassee, Florida 32399-2400



Dear Ms. Llewellyn:


The Southwest Florida Watershed Council (SWFWC) would like to take this opportunity to comment on amendments to the Water Resources Implementation Rule (Chapter 62-40, F.A.C.). Specifically, the Council wishes to endorse the new amendment relating to Reservations 62-40.474.  The provisions set out in this new amendment will potentially make it legally possible to prioritize through “reservation” water flows and levels that sustain our water heritage in southwest Florida.


Unfortunately the Minimum Flow Rule adopted in September 2001 for the Caloosahatchee River is inadequate to protect and sustain the fish and wildlife resources and the economic base of the region dependent on it. Minimum flow “exceedences” have occurred twice since the rule was adopted for the Caloosahatchee and inadequate dry season flows have damaged the estuary for many years.


It is also unfortunate that neither the Comprehensive Everglades Restoration Plan nor the Southwest Florida Feasibility Study have identified a solution to this problem other than structural storage proposals that are not planned for many years into the future yet the issuance of Consumptive Use Permits within the Caloosahatchee Basin continue despite this uncertainty. Hence, our interest and support of the reservations language in 62-40.474.


Thank you and please inform us of the final wording for the WRI Rule.





Noel Andress





The mission of the Southwest Florida Watershed Council is to protect, conserve, manage and/or

 restore the land and water resources of the Caloosahatchee and Big Cypress Watersheds through participation and cooperation of all stakeholders in consensus building, planning, and decision making to meet the

economic, natural and cultural needs for this and succeeding generations.


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