Dr. Knight shines the light of truth brightly on the Adena Springs Ranch application for a water use permit

Make statements of fact that aren’t and then publish them as if they are. It’s a time worn but sometimes useful tactic, like when applying for a water use permit the public hates.

It’s designed to counter those unintelligent nitwits who have the gall to suggest your permit is going to do things your consultants know will happen but which if you admit to publically will surely result in a denied permit.

So instead of saying, for example, that your requested permit to pump 13.2 million gallons every day from the ground (more than the amount pumped by the entire City of Ocala!) will cause a reduction in flow of 5 million gallons per day from Florida’s internationally famous Silver Springs, you say, oh phooey, it’s not going to have any impact at all.

It’s not called lying.  It’s called spin, and Adena Springs Ranch lawyer Ed de la Parte stretched the difference between truth and non-truth to the cellular thickness of an onion skin when he said in his letter-to-the-editor published May 20 in the Gainesville Sun, “The results of the model are that the proposed withdrawal will have virtually no impact on Silver Springs, other natural springs, lakes and private wells.”

Come on, Eddie, really?  That’s ridiculous even for a lawyer getting paid to advocate on behalf of his client’s interests.  Like I said, the “skin” of an onion between each peel is only one cell thick.

And what’s more, if the consultants for a water permit applicant can’t depend upon the facts to be pursuasive I guess they can buy space in the local media and blast public sensibilities with statements designed to foster factless emotional judgements instead.  This is what billionaire Canadian Frank Stronach is doing to get a water permit that if granted will most certainly have, as surely as Ed de la Parte is a very smart lawyer, an impact upon Silver Springs.

Stronach is now buying full paid advertisements in the local media to convince the public that all is well and pumping 13.2 million gallons per day from Silver Springs’ sensitive source-aquifer will have no impact upon the springs’ already stressed mean annual flows. 

Dr. Robert L. Knight, director of the Howard T. Odum Florida Springs Institute, has written a letter, published here with his permission, that sheds important factual light upon some of the spin being spun around the Adena Springs Ranch permit application.

The Gainesville Sun titled Dr. Knight’s letter:

“Adena Springs Ranch in the Court of Public Opinion”

Dr. Robert L. Knight

When was the last time you saw a two-page ad in the Gainesville Sun? Probably not that long ago. It was bought by another billion dollar company. BP Oil has spent millions trying to convince us that the Gulf of Mexico was not harmed by more than 206 million gallons of crude oil from their Deep Water Horizon drilling platform. Now a lawyer working for Adena Springs Ranch, thinks a 2-page newspaper ad will convince the public that he can pump more than 13 million gallons per day (4.8 billion gallons per year) from the aquifer and cause no harmful effects on groundwater levels or flows at nearby Silver Springs.

Adena’s consultants estimated that the aquifer drawdown due to their 134 wells would not be measurable at nearby Silver Springs. What they don’t reveal is that a groundwater decline of about 0.1 foot at Silver Springs equates to a flow decline of more than 5 million gallons per day. This reduction is more than the entire flow of Green Cove Springs, a second magnitude spring on the St. Johns River. It is neither trivial nor unmeasurable. This is about 4 percent of the entire flow of Silver Springs during the recent drought. At this rate it would only take 26 similar groundwater consumptive use permits to legally take all of the flow out of Silver Springs during the next drought.

By the way, there are already over 2,500 active groundwater permits in Marion, Lake, Sumter, Alachua, and Putnam Counties, the area that includes and immediately surrounds the groundwater basin feeding Silver Springs. These existing permits authorize the collective removal of 363 million gallons per day from the Floridan Aquifer, equal to 74 percent of the historic flow at Silver Springs. No wonder one environmental advocate recently warned that Silver Springs may dry up if the St. Johns River Water Management District continues to issue permits like the one Adena has requested.

Adena’s ad also stated that the 10,000 acres of irrigated and fertilized pasture will not increase the existing nitrogen pollution in the groundwater that feeds Silver Springs. In 2006, District scientists reported that agricultural/pasture areas contributed an average of 48 pounds of nitrogen per acre per year to Silver Springs. Given the size of Adena’s proposed cattle operation, the District’s analysis indicates that more than 240 tons of additional nitrate will reach Silver Springs each year, a 50 percent increase over the existing nitrate load.

This is not surprising since 15,000 cows produce nitrogen waste equivalent to 165,000 people. None of this cow urine and manure will receive treatment, it will be spread on irrigated pastures where a large portion will inevitably seep into the aquifer. Florida regulators recently mandated a 79 percent nitrate load reduction for Silver Springs. Meeting this target will cost local utilities such as the City of Ocala millions of dollars to implement. Adena’s ad assures us that they will prepare a “certified nutrient management plan” similar to plans used to manage water quality in the Everglades. What Adena’s ad fails to mention is that over 2 billion tax-payer dollars has already been spent to clean up pollution from farms in the Everglades Agricultural Area.

Less water and more pollution in Marion County’s groundwater and springs are not in the public interest.

And there are other misleading statements in Adena’s advertisement. For example:

Adena claims that sinkholes and karst geology are “just not an issue”. This statement is false. The whole area is mapped by the Florida Geological Survey as “more vulnerable” to groundwater contamination from the land surface, and there are karst features and relic sinkholes on the property.

In the current Adena proposal, there is no control mechanism to capture and treat surface runoff from the site flowing to wetlands, creeks, and the adjacent Ocklawaha River, an Outstanding Florida Water. Nutrients carried by this runoff are likely to be significant during summer downpours and tropical storms.

Adena says that reduced flows in the Silver River have re-appeared as increased flows in the Ocklawaha and Rainbow Rivers. This is false. The average flow in all three of these rivers has been steadily declining, providing strong evidence that flow declines are regional and are being caused by a combination of low rainfall and excessive groundwater pumping.

If you want science, take a look at the District’s 50-Year Retrospective Study of Silver Springs http://www.floridaswater.com/technicalreports/pdfs/SP/SJ2007-SP4.pdf. Don’t look for real science in a paid advertisement from a high-priced water attorney working for a Canadian billionaire. If Frank Stronach was sincere when he gave his pledge to “have no negative effect on the environment”, then he needs to visit Silver Springs and listen to the public’s opinion.

Spin is quickly unwound by the light of truth and Dr. Knight shines it brightly on the Adena Springs Ranch application for a water permit.

More staff to be fired at SWFWMD? Rumors are rampant. Morale is in the pits.

Rumors that another very significant number of staff from SWFWMD are going to be laid off continue to seethe and swirl at the district’s headquarters in Brooksville. The number of unfortunate folks to get the boot in the middle of this country’s historic recession is unspecified but the rumor mill has it at 60 to 107 staff members.

Talk says it could hit several of the district’s central management departments (or should they now be referred to as bureaus like state agencies?) The buzz is that Information Technology, General Services, Finance Department and Management Services are being targeted.

The credence of the rumor is being reinforced by the number of people doing the whispering who are all saying the same thing. These are folks who would not typically be in communication with each other. Something is going on at SWFWMD and it’s going to destroy further the already badly damaged morale of a once highly respected, science-based public agency.

I didn’t think the morale could get any lower. Turns out I’m wrong. One can only hope the rumors are not true. This is the wrong time, the wrong way and probably the wrong reason to be doing this.

If true, the blame can be laid squarely at the feet of CEO Rick Scott, his boy Herschel Vinyard, DEP’s Tallahassee minions and a bobbing-head Governing Board that doesn’t know or care that the ability of the agency for which it has responsibility is being systematically rendered ineffective and incapacitated. Maybe the word destroyed would be more applicable.

Certainly the thread of blame should also reach back to a regulatory reform sub-committee of Scott’s transition team who vigorously promoted the idea that water management districts are simply bloated, arrogant bureaucracies that need to be erased from Florida’s regulatory scene. I seem to remember Tampa “water” lawyer Doug Manson was the chair of that subcommittee and maybe it’s significant that one of the lawyers in his firm at that time is now general counsel for the governing board at SWFWMD. She was his Tallahassee "operative" for several years. (Want to bet her job is not going to be one of those on the chopping block?)

If this is happening at the other four districts as well, anyone who has any concern for water resource management and the impact these reductions will have on Florida as a quality place to live, work, and play in the future should be up in arms.

Here’s the thing. If the layoffs are because the job of water management as a government necessity has been reduced to the point that it takes fewer staff to carry it out, then so be it. But if it’s because the legislature and governor cut water resource management funding for political reasons and without adequately considering the impact upon the districts’ collective ability to do what is needed, then that’s incompetence and dereliction of duty at the highest level.

I fear, and the facts are beginning to show, that the reality is the latter.

The next election cannot come soon enough.

Florida’s Remaining Natural Environment - Death by a Thousand Pricks

A prick is defined by Merriam Webster as the act of piercing something with a fine, sharp point leaving a mark or shallow hole.  There are other meanings you’ll find in Encyclopedia Britannica Company’s Merriam Webster dictionary but for the sake of propriety I need to stick with this one, although one might find other definitions more applicable.

The significance of a prick is this.  The pain of one prick, while bothersome and certainly undesirable, is perhaps tolerable, but many pricks will cause serious pain, illness and even death.

The normal human reaction after the first prick is do what’s reasonably possible to avoid the pain of another.  Somewhere in the back of one’s mind, following a prick, a voice can be heard saying, “Do not disregard this seemingly minor irritation.  It could be the first of many, and many can be dangerous to one’s well being.”

Though Florida’s environment has suffered the damage of many pricks over the decades, that voice in the back of our collective minds seems to have been quieted.  As a society, it appears we have lost our ability to hear the warning, or perhaps for political reasons we have simply chosen to ignore it.

Florida’s limited remaining natural environment is suffering from many pricks.  There are many examples.  The vast Floridan Aquifer, to suggest one, can withstand the removal of its waters up to a certain point, but thereafter, will begin to suffer perhaps irreparably.  As the number of withdrawal points and removal rates increase, surface water bodies begin to disappear and, beneath the surface, salt water, which surrounds all fresh water in aquifer storage, begins to invade.

In the early 1920’s, the City of St. Petersburg lost its supply of fresh water to salt intrusion from the nearby Gulf.  Its wells were located on the Pinellas peninsular where the zone of fresh water was shallow and limited.  Knowing water would be found further inland, the city moved its wells to northwest Hillsborough County.

As St. Petersburg’s population grew and withdrawals increased, the population within the withdrawal area was also growing.  More and more people began to notice local lakes were declining and wetlands were drying out.  The problem worsened with the arrival of the Pinellas County utility system which also placed wellfields in northwest Hillsborough, as well as further north into Pasco County. There were wet years, but the ability of the system to recover grew ever slower until eventually even hurricanes could not replenish the aquifer enough to sustain the historic average surface water elevations. The endless pricks began to overwhelm the system and the effect was inevitable.

One of the lawyers involved in the ensuing water battles that lasted for decades was Ed de la Parte who worked for Pickens Talley, Pinellas County’s utilities director.  Talley often enjoyed pointing out how vast the Florida Aquifer was and how silly it was to suggest that the paltry millions of gallons per day the city and county were pumping might be harmful.  Fortunately, that pumping has been drastically reduced through the efforts of local activists and the SWFWMD, and the hydrologic system is recovering.  It was an expensive and near tragic lesson.

North Florida is known for having the highest concentration of first magnitude springs in the world.  Today, however, the groundwater system is suffering and the once unmatched beauty and clarity of the springs are showing it.  Too many straws are sucking the lifeblood from the vast underground system that feeds them and nutrients in the form of nitrates from septic tanks, agriculture and golf courses are enriching what remains of their flows.  Algal slime known as lyngbya is killing the native eel grass and clouding the water that was at one time so clean and clear one could drink it by the handful. 

Now, a Canadian billionaire wants permission to put ten thousand cows on 30,000 acres nearby and is claiming the hundreds of tons of manure that will be generated and the withdrawal of 13.2 million gallons per day of water from the same system that feeds Silver Springs will do no harm.  The same Ed de la Parte that believed Pickens Talley 25 years ago when he stated the Floridan Aquifer was so vast the pumping from northwest Hillsborough County was not causing harm is now claiming the same thing in Marion County.  Ed de la Parte is the attorney representing the Canadian billionaire.

Clearly, he does not grasp the concept of death that can be caused by a thousand pricks.  A single cactus spine is of little consequence, but one might not survive a fall into a bed of cacti.  De la Parte should remember the lesson and the cost to his previous client, and the near tragic impact upon northwest Hillsborough County.

It is an old problem when a user claims the impact of his use upon a “commons” is not the one that is causing destruction.  It is the collective use of others that is the genesis of the problem, and thus his use should continue to be acceptable.  This classic point was made by a biology professor of the University of California, Santa Barbara, in 1968, Garrett Hardin.  In his article, “The Tragedy of the Commons,” (Science Magazine, December 13, 1968) he wrote:

The tragedy of the commons develops in this way. Picture a pasture open to all. It is to be expected that each herdsman will try to keep as many cattle as possible on the commons. Such an arrangement may work reasonably satisfactorily for centuries because tribal wars, poaching, and disease keep the numbers of both man and beast well below the carrying capacity of the land. Finally, however, comes the day of reckoning, that is, the day when the long-desired goal of social stability becomes a reality. At this point, the inherent logic of the commons remorselessly generates tragedy.

As a rational being, each herdsman seeks to maximize his gain. Explicitly or implicitly, more or less consciously, he asks, "What is the utility to me of adding one more animal to my herd?" This utility has one negative and one positive component.

1) The positive component is a function of the increment of one animal. Since the herdsman receives all the proceeds from the sale of the additional animal, the positive utility is nearly +1.

2) The negative component is a function of the additional overgrazing created by one more animal. Since, however, the effects of overgrazing are shared by all the herdsmen, the negative utility for any particular decision-making herdsman is only a fraction of 1.

Adding together the component partial utilities, the rational herdsman concludes that the only sensible course for him to pursue is to add another animal to his herd. And another; and another... But this is the conclusion reached by each and every rational herdsman sharing a commons. Therein is the tragedy. Each man is locked into a system that compels him to increase his herd without limit--in a world that is limited. Ruin is the destination toward which all men rush, each pursuing his own best interest in a society that believes in the freedom of the commons. Freedom in a commons brings ruin to all.

Some would say that this is a platitude. Would that it were! In a sense, it was learned thousands of years ago, but natural selection favors the forces of psychological denial (8). The individual benefits as an individual from his ability to deny the truth even though society as a whole, of which he is a part, suffers.     (Emphasis added) 

Would it be unthinkable to consider that the environment of Florida may on the brink of suffering its own tragedy of commons?  Florida’s unique natural environment belongs to no one. It belongs to all. Yet we seem determined to abuse and neglect it to extinction.  We are suffering it pricks from a thousand wrongs and yet there are those who would prick it even more and claim it is not their prick that’s destroying it.  This is Ed de la Parte’s song on behalf of the Canadian billionaire and the “prick” he would brandish upon Silver Springs.

Pricks can come in all sizes.  Some are not small, such as the proposed Farmton Tract, a 59,000-acre, 50-year, planned community of 25,000 rooftops, millions of square feet of commercial development straddling both Volusia and Brevard counties.  Even though the project leaders have promised a sizeable portion of the total acreage (80%) will be “conserved forever,” it is still a prick on the larger body of environmental Florida and may have serious impacts on the very unique aquifer system underlying Volusia County.  How many more pricks like this can we stand?

Will it matter, though, if there’s no one to oversee and assure the good things this project proposes are actually delivered?  Hundreds of water management professionals who dedicated much of their lives to protecting natural Florida have been shown the door at the state’s five water management districts.  Those in charge of the store now, are all about firing the bag boys and decreasing the cost of running it and not whether customers will return, all in the name of cutting costs.  How is all the slicing and dicing of Florida’s environmental protections going to bring more business to Florida?  It is an ill conceived, systematic removal of the state’s nose in a misguided attempt to improve its face.

Our business-oriented governor stopped the acquisition of all environmental lands by the water management districts and told them to begin selling off “the surplus.”  Apparently, it is of no concern that the land’s cost to the public will likely be much more than what a fire sale might bring during the currently ongoing recession. Nor is there any concern that the purchases were demanded by a majority of Florida voters on two separate occasions in the first place and that selling any environmental land is something of a breach of public trust.  This is truly one of the dumbest pricks of all and an important one that could stunt Florida’s environmental quality of life for generations if not forever.  Some of the lands that could be purchased at bargain prices now are irreplaceable but will be lost forever if the opportunity to conserve them is allowed to pass.  Protests and plain attempts at persuading common sense are having the same effect as the sounds of falling trees in a forest when there’s no one there to hear.

The list goes on and on.  Tens of millions of acres of natural Florida has already been lost which will never be recovered.  Think Everglades. Think hundreds of miles of beaches covered with condos but no nesting Leatherbacks or Sooty Terns.  The state has already suffered the damning consequences of a million pricks, and yet, we hear everyday how the current administration has devised a new way to prick it again and again. 

He has ordered his regulators to “work with the business community” rather than seek out violators, but instead, they are giving away the store, according to would-be whistleblower Connie Bersok.  “Working with” has come to mean “grant the permit.”

Between the seemingly hellish intent of the legislature to revoke all sensible protections needed to sustain Florida’s natural systems and the mindless destructive policies initiated by a governor with no background in government or the science of ecology, Florida’s unique and once grand natural environment is destined to become a parking lot unless attitudes change, and the attitude I’m talking about is that of the voting public. 

That voice in back of our cumulative minds is speaking to us.  An awakening is needed before the store is looted, the “common” is destroyed, and it’s just too late.  Let us heed the warning.

Dr. Earl Starnes - Environmental Lands Should Not Be Surplused

Earl Starnes is an historic figure in Florida’s evolution from having no awareness or concern for the impacts of unrestrained growth, to a state where its growth management laws were recognized nation-wide.  He served under Governor Reuben Askew as the Director of State Planning, became the director of the University of Florida’s new urban and regional planning program in the mid-1970s, and joined with other leading planning practitioner/academics such as Carl Feiss and Earnest Bartley at UF, John DeGrove at Florida Atlantic University, and later Richard Rubino at Florida State University to advance the cause of growth management and planning in the state.

As Department of Urban and Regional Planning Professor Emeritus Professor, Starnes co-authored with Florida State University Professor Emeritus Richard Rubino the book, Lessons Learned? The History of Planning in Florida

U.S. Senator and former Governor Bob Graham has described Lesson Learned?  as “a significant contribution to our understanding of the politics and economics of land and water use planning in Florida.”  

Recently, Starnes spoke from his residence in Cedar Key by letter to register his concerns over the Scott administration’s move to surplus environmental lands purchased over the last two decades at the request of Florida’s voting public. 

CEO Scott and his minions at DEP and the water management districts would do well to pay close attention. 

3 July 2012 

Subject: Water Management Districts and Proposed Land Sales 

I do not think the proposed “excess land” sales proposed by the Suwannee River and St. Johns River Water Management Districts is sound public policy. I do understand the fiscal problems of the districts simply because they have been stripped of historic state funding and further restricted in taxing millage rates. However, selling public assets is not wise. It is not wise for those assets were acquired with funds authorized by the majority of Floridians. Such constitutional authorizations, first approved in 1973, and then down through the years in a succession of similar programs. These lands have all been purchased with funds derived from taxes collected across the state from all taxpayers. This writer believes that this alone is sufficient to protect these lands in perpetuity. It is my opinion that the districts and the state of Florida have a fiduciary responsibility to preserve and protect public lands that have been so authorized and purchased by means of these environmental and public lands programs. 

In addition, these lands are protected from future developments which surely could and would have impacts upon the environmental quality of adjacent lands set aside for environmental preservation. Undeveloped lands will continue to serve as unsoiled hydrologic recharge areas as is necessary to maintain a viable and productive Floridan aquifer. We are witnesses to the consequences of losing the recharge capacity of our natural lands by development, including paving, building, and intense agricultural operations all as evidenced by salt water intrusion along Florida’s coastal communities and the steady decline of water flows in our wonderful Florida springs.

Finally, to consider open public lands of minimal capital value set aside for preservation and conservation as wasteland harkens historically to the days of the 1880s.  Those were the days when Hamilton Disston bailed the State of Florida out of bankruptcy by buying 4 million acres of central and south Florida for $1 million. In addition, he gained a bonus of one acre of land for every acre drained above and around Lake Okeechobee. It was bad public policy then and today it is compounded by the fact that we “know better”.  The combined consequence of those policies of the 1880s have cost billions of public dollars in the twentieth and twenty first centuries; and continue to this day.

Floridians must rise to the responsibility for conservative management of the future our resources, land, water, flora, fauna, and quality of both urban and non-urban life. Short term policies derived from politically popular fiscal tightfistedness provides no rationale for selling our public lands or withdrawing from half century of environmental protections.   

Cordially, 

Earl Starnes, Cedar Key

Speak Up and Sign Up for Silver Springs and Florida's Waters

Dear Friends,

One of the luxuries of writing a blog and not a newspaper article is that, while timeliness is important, one’s economic life doesn’t depend upon it.  Thus, it's time to share some thoughts and photos about the event, “Speak up for Silver Springs and Florida Waters,” sponsored by the Florida Conservation Coalition this past weekend (2012.06.23) at Silver River State Park, but before doing so, I hope you’ll do one very meaningful and very important thing. 

Please be sure you’ve signed the petition.

If you didn’t get the chance to sign it at the event, please do so now.

Here’s what the petition is asking Governor Rick Scott to do:

“We urge you to do everything within your power and ability as the Governor of Florida to protect and restore Florida's aquatic resources, beginning with a plan to address and resolve the dire conditions of Silver Springs, Silver River, Rainbow Springs and Rainbow River. Please, consider the establishment of a Resource Planning and Management Committee, under Section 380.045, F.S, or the implementation of a stakeholder task force process similar to those that led to the protection of the Wekiva River.

There are two ways you can sign the petition: 

1.  One is by doing it online.  Tap the following link to go to FCC’s webpage:

http://www.change.org/petitions/governor-rick-scott-speak-up-for-silver-springs 

2.  The other is to print the petition, sign it and mail it in, or, print it out and take it to meetings for others to sign along with you.  You can find it here:

http://floridaconservationcoalition.org

Thank you for taking this important action.  Even if the Govenor doesn’t heed our request, he will know there are a lot of folks who are watching out for natural Florida and he would be wise to do so as well.

So you’ll have an idea as to what Chapter 380.045 actually says, the following is the statute you’re asking the Governor to consider.  All it does is set forth a public process by which a geographic area with a resource problem can be assessed by all the interested players, including local governments, and a plan of action developed to address any problem identified.  It is a reasonable and thorough process that should give the public ample opportunity to understand the evidence and develop an informed opinion as whether a problem exists, what’s causing it, and how it should be addressed.

380.045 Resource planning and management committees; objectives; procedures.—

(1) Prior to recommending an area as an area of critical state concern pursuant to s. 380.05, the Governor, acting as the chief planning officer of the state, shall appoint a resource planning and management committee for the area under study by the state land planning agency. The objective of the committee shall be to organize a voluntary, cooperative resource planning and management program to resolve existing, and prevent future, problems which may endanger those resources, facilities, and areas described in s. 380.05(2) within the area under study by the state land planning agency.

(2) The committee shall include, but shall not be limited to, representation from each of the following: elected officials from the local governments within the area under study; the planning office of each of the local governments within the area under study; the state land planning agency; any other state agency under chapter 20 a representative of which the Governor feels is relevant to the compilation of the committee; and a water management district, if appropriate, and regional planning council all or part of whose jurisdiction lies within the area under study. After the appointment of the members, the Governor shall select a chair and vice chair. A staff member of the state land planning agency shall be appointed by the director of such agency to serve as the secretary of the committee. The state land planning agency shall, to the greatest extent possible, provide technical assistance and administrative support to the committee. Meetings will be called as needed by the chair or on the demand of three or more members of the committee. The committee will act on a simple majority of a quorum present and shall make a report within 6 months to the head of the state land planning agency. The committee shall, from the time of appointment, remain in existence for no less than 6 months.

(3) Not later than 12 months after its appointment by the Governor, the committee shall either adopt a proposed voluntary resource planning and management program for the area under study or recommend that a voluntary resource planning and management program not be adopted. The proposed voluntary resource planning and management program shall contain the committee findings with respect to problems that endanger those resources, facilities, and areas described in s. 380.05(2) and shall contain detailed recommendations for state, regional, and local governmental actions necessary to resolve current and prevent future problems identified by the committee. A major objective of the proposed voluntary resource planning and management program shall be the effective coordination of state, regional, and local planning; program implementation; and regulatory activities for comprehensive resource management. The committee shall submit the proposed voluntary resource planning and management program to the head of the state land planning agency, who shall transmit the program along with the recommendations of the agency for monitoring and enforcing the program, as well as any other recommendations deemed appropriate, to the Administration Commission.

(4) The Administration Commission shall by resolution approve, approve as modified, or reject the proposed voluntary resource planning and management program and state land planning agency recommendations; and the Administration Commission shall request each state or regional agency that is responsible for implementing a portion of an approved program to conduct its programs and regulatory activities in a manner consistent with the approved program. Each state and regional agency involved in implementing the program shall cooperate to the maximum extent possible in ensuring that the program is given full effect.

(5) The state land planning agency shall report to the Administration Commission within 12 months of the approval of the program by the commission concerning the implementation and the effects of the approved voluntary resource planning and management program. The report shall include, but shall not be limited to:

(a) An assessment of state agency compliance with the program, including the degree to which the program recommendations have been integrated into agency planning, program implementation, regulatory activities, and rules;

(b) An assessment of the compliance by each affected local government with the program;

(c) An evaluation of state, regional, and local monitoring and enforcement activities and recommendations for improving such activities; and

(d) A recommendation as to whether or not all or any portion of the study area should be designated an area of critical state concern pursuant to s. 380.05.

The state land planning agency may make such other reports to the commission as it deems necessary, including recommending that all or any portion of the study area be designated an area of critical state concern because of special circumstances in the study area or in the implementation of the approved voluntary resource planning and management program.

History.—s. 2, ch. 79-73; s. 1, ch. 84-281; s. 640, ch. 95-148.