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North Central Florida Water Well Association (NCFWWA)
1111 SW Wacahoota Road
Micanopy, FL 32667
NCFWWA.org
386-454-9355
September 11, 2024
Florida Department of Environmental Protection
3900 Commonwealth Blvd.
Tallahassee, FL 32399
Subject: Comment on Lower Santa Fe and Ichetucknee Rivers (LSFIR) and Priority Springs Minimum Flows and Levels (MFLs)
Dear Sir/Madam,
I am writing on behalf of the North Central Florida Water Well Association (NCFWWA) to express our concerns regarding the proposed regulatory strategy and new rules for restoring the Lower Santa Fe and Ichetucknee Rivers, specifically the prohibition on new private residential irrigation wells.
As a chapter of the Florida Groundwater Association and with 74 years of history, NCFWWA represents approximately seventy licensed Florida Water Well Contractors in North Florida. Our mission is to ensure high-quality well construction while protecting the environment and securing safe water supplies for current and future generations.
We are deeply concerned that the proposed rule could adversely affect the water well industry, small businesses, and property owners. We urge the agency to remove the proposed section of the rule prohibiting the construction and use of new Floridan Aquifer irrigation wells for private residences for the following reasons:
1. **Economic Impact on the Water Well Industry**
The proposed ban would significantly impact Florida's essential water well drilling and service industry, which consists mostly of multi-generational small family businesses. This restriction would result in job losses and revenue declines for thousands of contractors and businesses across the state, severely limiting our ability to operate and serve our customers.
2. **Economic Impact on Property Owners**
Requiring property owners to rely solely on municipal water for irrigation could overload existing systems, necessitating costly upgrades that may lead to higher taxes and water rates. Private wells add value to homes by providing a cost-effective alternative to municipal water. Banning these wells would impose a financial burden on Florida residents.
3. **Water Conservation Control**
Contrary to the rule’s intentions, private wells often promote water conservation and responsible resource management. Well owners, aware of the costs associated with overuse, tend to manage their water usage efficiently. Municipal systems do not inherently guarantee better conservation practices.
4. **Infringement on Property Rights**
Homeowners have traditionally relied on private wells to utilize natural resources on their property. The proposed rule infringes on this right by eliminating the option for private residential irrigation. This level of government interference could set a troubling precedent for future regulations affecting individual freedom and self-sufficiency.
5. **Environmental Impact**
Using well water has a lower environmental impact compared to municipally treated water, which requires significant energy for both treatment and transportation. Private wells provide untreated water, often enriched with natural minerals that can be more beneficial to plants and soil than the treated water supplied by public systems. For residential irrigation, treated water is not only unnecessary but also not recommended. Relying on public water supply for irrigation could worsen the cone of depression in the Floridan Aquifer, which can extend for miles from the well. In contrast, small, widely spaced private irrigation wells create minimal drawdown in the aquifer.
Given these concerns, NCFWWA opposes the current proposed rule language for 62-42.300 Minimum Flows and Levels and Recovery and Prevention Strategies, as published on July 31, 2024. We urge the Florida Department of Environmental Protection to reconsider this proposal and collaborate with stakeholders to develop balanced solutions that protect Florida’s water resources with consideration of homeowners and Florida’s small businesses.
Thank you for considering our perspective. We are eager to engage in discussions and offer our insights based on our extensive experience as licensed professionals in the water well industry.
Sincerely,
The North Central Florida Water Well Association and its membership
A BRIEF HISTORY OF THE N C F W W A
OUR 74TH YEAR
Back in 1950, a small group of well drillers started meeting on someone's porch or someone else's kitchen in the North Central Florida area. Later they held regular monthly meetings, alternating between Hughes Supply in Gainesville and Florida Pump in Ocala, the only suppliers in the area at that time. Some of those early Charter members were Albert Miller, Morris Gary, Joe Hare, Rudy Mackenzie, Hugh Hopewell, Chuck Wooden, Odell Sheppard, and Joe Bemis. They organized the NORTH CENTRAL FLORIDA WELL DRILLERS ASSOCIATION, which is now known as the NORTH CENTRAL FLORIDA WATER WELL ASSOCIATION. We are the oldest and largest chapter in the State Association, which is now known as the FLORIDA GROUND WATER ASSOCIATION (FGWA). Our annual membership is currently at a record number of 164 members. Over the years a large number of our members have served on the State Association Board of Directors. In addition, the following members have served as president of the FWDA/FWWA/FGWA. Albert Miller, Joe Bemis, Wilbur Langley, Allen Hardwicke, Tim Myers and Donald Hall. The purpose of the NORTH CENTRAL FLORIDA WATER WELL ASSOCIATION (NCFWWA) is to promote quality construction of water wells while at the same time protecting our environment to ensure adequate and safe water supplies for current and future generations. Another of our objectives is to have input into the rule making process so that we try to keep the regulations reasonable and rational. We encourage everyone who makes his or her living in the ground water business in the North Central Florida area, in what ever capacity, to become a member of NCFWWA
Officers for 2024
President - Melissa Sheffield
Vice President Robin Hook
Secretary
Treasurer Lester Burch
Board of Directors
Joseph Burch
Buddy Hilliard
Russell Hook
Ronald Myers
John Wright
