Save Sumter's Water - Refuse Water Permits for Development

Save Sumter's Water - Refuse Water Permits for Development

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Bill Pownall started this petition to Southwest Florida Water Management District and

August 3rd, 2020

To the following Agencies for intervention:  Southwest Florida Water Management District (SWFWMD) & Permitting Department, SWFWMD Board, / Florida Department of Environmental Protection (FDEP) / Environmental Protection Agency (EPA) / Army Corp of Engineers (ACOE) / Florida Department of Economic Opportunity (DEO), formally known as Department of Consumer Affairs) / Ashley Moody, Florida Attorney General

Subject is regarding Buffalo Hide & Cattle Co. for a Villages Land Company Development: Lower Aquifer Test Well # 889547, which is located in a flood zone (18), and against Wildwoods LDR (18) and close proximity to Jumper Creek a potential Army Corp of Engineers jurisdiction among other and many issues.

Insufficient water availability and a recent rezoning that was against local and State law which needs full attention to the agencies herewith:

Development with Lower & Upper Water Well Permitting in Sumter County: A 12,000-28,000 acre, proposed for over 60,000 dwellings, formally a Florida Forever Proposed Acquisition known as Stuart Ranch, Landstone, Big Prairie, Double Rock / Sink Prairie SWFWMD title, in a Withlacoochee Watershed, now annexed into the City of Wildwood, partly a Sumter County, zoned AG, as a proposed development known as The Villages of Southern Oaks (VOSO). (info referenced)

SWFWMD Request:  NO LARGE WITHDRAWL PERMITTING TO EITHER THE UPPER OR LOWER AQUIFER,  including others nearby water permit requests.  DEO Request: Reverse Zoning which is against local city/county laws, this rezoning also violated State Law Chapter 163, Urban Sprawl, 12 out of 13 indicators. (14)

Please take careful consideration of this letter. This time its more development on sensitive lands, requesting large amounts of water, promising super light use per dwelling, on a high density development, touted as Age Restricted but allowing 20% families without a public facilities analysis, forced as an Urban Sprawl and ignoring thousands of residents who opposed it and being taxed on this very development. (13, 8)

There is likely just enough current water resources to allow rural individuals to naturally expand and businesses to naturally grow. This development will double the population of Sumter County! (7, 13, 17)

The following is a statement of facts and studies by cited resources including: USGS, SWFWMD, WRWSA, and EDR.  It is also a request for agencies to step in and help, respectively.

Amy Baker warned that by 2025,”we expect that the forecast of water demand will exceed the water available – an inferior water supply problem.” (19)

Northeast Sumter County will have difficulty meeting its current water demands. (2 & 6)

Not enough water to meet the 2035 Florida expected demand. (7) Florida as a whole.

An area of concern for both SWFWMD & WRWSA is northeast Sumter County, due to several feet of decline, due to its extensive demands particularly in the Wildwood/The Villages area. Current SWFWMD Hydrologic Conditions are extremely below normal (stress emphasized) (6 & 16)

Per WRWA, “Area of concern is Northeast Sumter county where surficial and Upper Floridan aquifer levels are predicted to experience several feet of decline by 2040 due to extensive use of the Upper Floridan aquifer to meet demands of the rapidly growing Villages Wildwood area.” (6)  Drawdown map includes areas that abut this massive proposed development, which has recently been approved for 60,449 dwellings plus 12,278,000sq.ft non-residential and 1,529,000sq.ft. of government space.  What is not necessarily mentioned are the additional needs of basic facilities such as Hospitals, Fire Stations, Libraries, and much more, yet excluding entitlements.  (7, 13, 8 (6: 4-15))

Minimum Flow Levels (MFL) are the standard to gauging water availability. MFL for the Withlacoochee River will not be established until 2024.(12)  How could you (SWFWMD) possibly consider any major permitting application with a lack of future water supply? And the data you do have shows drawdown and shortages that cannot meet future needs already accounted for! (6, 7, 12, 16)

The Lower Aquifer is very expensive and is not accessible to the existing residents. Neither will these residents nor municipalities be able to receive municipal water from this development.(6) Nor will surrounding residents ever be granted access to this developer’s water as their utilities are not public, they are private utilities only servicing those who purchase their built products. If that were to change, and this development offered utilities to others, it would be an unfeasibly possibility, due to the cost of piping; as this is an Urban Sprawl development around rural parcels. The Lower Aquifer is typically brackish and can not be determined on quantity and quality. (1 & 6)

Little is known of the Lower Aquifer except both the Upper and Lower aquifers behave as one and are not contained. Quantity and quality are unknown. (1, 6)      When water is removed from the Lower aquifer, the Upper aquifer water level responded adversely in decline.   Although a mild decline, this study only pumped water for 2 days, which is not a clear snapshot of an aquifer’s reaction, nor is pumping from the Lower, and discharging on the surface, a true study. (3)  In fact, this method, whereby discharging on the surface is the recommendation to equalize the aquifer, not to test its recharge.  

How much more will the levels drop when both aquifers are pumping simultaneously and without ceasing? The following study showed that pumping from a Lower aquifer without reducing the equal amount from the Upper aquifer caused the water level to drop 1 ft for up to 141 square miles away! (4) This study was done on the Floridan Aquifer System, the same system we all rely on today.

What is not 141 sq. miles away? “The Green Swamp” of Lake County, an Area of Critical State Concern (ACSC); it is only 20 miles from this proposed development. The Green Swamp is identified as Florida's first area of critical state concern, per fts. statue 380.0551. If the aquifers behave as one as factually stated, it is very reasonable that a Lower Aquifer Permit will adversely affect the Green Swamp. (4)

Areas of critical state concern are recognized as having a significant positive contribution to environmental, natural, historical, and or archaeological resources. These parcels have all these attributes. (5, 10, 13) The uncontrolled development of area of critical state concern would cause substantial deterioration of the valuable resources they provide. Therefore, under this designation, the state land planning agency is granted the power to recommend actions that the local government as well as state and regional agencies must accomplish in order to avoid the predicted negative results of uncontrolled or inadequate development of the area. For example, the state land planning agency can require actions such as re-visitations of the local comprehensive plan as well as adoption of land development regulations, density requirements, and special permitting requirements. The green swamp was designated an area of critical state concern for three primary reasons, 1. Recharge of the Floridan aquifer 2. Wetlands 3. Flood detention (11)    The proposed development, has all the same environmental attributes. (10)

The conservation standards this developer will be using, whereby harvesting the recharge water as “reclaimed” while placing impermeable soils on top of Group D soils. (5) Further subtracting from the recharge of the aquifer. (10) Also known as, burning the wick at both ends. This practice also manipulates the amount of water their residents actually use, while excluding the permitting process.

In addition to the wetlands and hydric soils, this rezoning and land use is not consistent with Sumter County’s Codes regarding density per units. Policy Constrained Soils, b. 2. If the total of the actual constrained area plus the wetlands and 100-year floodplain area is fifty 50 percent or more of the proposed development tract, the development shall be subject to the density and minimum lot size adjustments of subsection 2:  Subsection 2c:  Where central water and sewer system are provided – One-forth 1/4th acre. (5) Be it known, this parcel was first unsuccessfully tried through Sumter County in 2017 – 2019, then passed to Wildwood.

Furthermore, Flood hazard area Section e 2. a & b.: within 100 year flood plain shall be limited to 1 residential unit per five acres in Urban development area (note: this is not an urban area, despite the rezoning and sewers have yet to be confirmed by the developers utility.) (5) Dwellings, or b.: 1 residential unit per ten acres for agricultural category. This was zoned Agricultural (1 per 10 acres) until June 8th City of Wildwood hearing. Clerk papers filed 3/20/20. (13)  Please address these major wrongs, it was against their code.  As of the time of this letter, The City of Wildwood is now proposing an Ord: 2020-30 for July 27th, 7pm to RETRACT Ord 02019-56 filed with the clerk on 3/10/20 amending the Joint Planning Agreement (JPA) & Comp Plan. (20). And another Comp Plan change and Land Development Regulations just announced (Ord 2020-46 & 2020-47). (20)

[Although] the Lower Aquifer has the potential to supply significant quantities of groundwater, the cost of developing this source is much higher and the sustainable yield of the aquifer is not yet defined. (6)  How can SWFWMD permit something that is not to be defined?  This is the exact reasoning why we ask for No Upper aquifer as well; we feel the Lower is just a trick through this permitting stage and will ultimately rely on the Upper aquifer. Either choice is a grave mistake based on this data.  Our local governments (even combined) cannot provide its citizens a Lower Aquifer due to cost. (6)  Please understand the County will not be able to afford nor have the capabilities of supplying any rural residents with municipal public water, regardless of aquifer location. This is a big reason why Urban Sprawl is extremely costly. (14)  WRWSA’s report says, it will be crucial for the (water) Districts to continue providing funding for a Lower Aquifer distribution system. (6)     Sumter residents truly lack the funds, and the ability to run water pipes to the rural residents as this Urban Sprawl development will suck the living life from the current residents of Sumter County.

Sumter County’s geology, confinement, formations completely vary from short distances, therefore two Lower Aquifer wells will not have the same properties even in close proximity. (1 & 4) 

The largest draw downs are predicted to occur in the rapidly growing Villages/Wildwood area of Northeast Sumter County. (6, fig 4-15).

If the Lower Aquifer is so productive in quantity and quality, then allow the developer who has a permitted functional Lower aquifer well in NE Sumter, to relieve the stressed upper aquifer of Northeast Sumter County by transitioning to Lower aquifer water. As they state on the Villages CDD website, the upper aquifer is being utilized for irrigation purposes. (15)  Please consider this statement thoroughly. It is suspected that the Lower is not an ideal source of water, but WRWSA is suggesting it as a source since there mission is to find alternative water sources. If they don’t find a source, they may no longer be needed as a Water Supply Authority. The outcome is anticipated to be a steady use of the Upper Aquifer even if a Lower was approved.  

In NE Florida, two large paper plants were shut down on two occasions, lasting 2 weeks and another last more than a month. Upper aquifer levels responded immediately after each shutdown. .indicate the similar plant shutdowns have occurred, thus providing test cases for determining the relative degree of interconnection between the Upper and Lower Floridian aquifers and the hydraulic connection within zones in the Lower Floridan Aquifer. During these shutdowns, both the Upper and Lower aquifers had decreased pumpage. (1)  

In central Florida, the Oldsmar permeable zone is the deepest basal freshwater zone of the Floridan aquifer system. Test data from wells in Marion Romp 132 and Bushnell Romp 102.5 indicate fracture and cavernous porosity in the massive dolostone unit of the Oldsmar Formation. (1)   Fracture & Cavernous porosity; they are not contained! 

The Upper and Lower aquifers behave as one aquifer system. (1)

Additionally, some of the numbered middle confining units were found to be semi-confining, very leaky, or have hydraulic properties within the same order of magnitude as the aquifers above, below, or both above and below. Although the term “confining unit” is not totally abandoned within this revised framework, a new term “composite unit” is introduced for lithostratigraphic units that cannot be defined as either a confining unit or an aquifer unit over their entire extent. This approach is a departure from the previous framework of the late 1980’s, in that stratigraphy is used to consistently subdivide the aquifer system into upper and lower aquifers across the State of Florida. (1)

The US Department of Interior /US Geological Survey put together a study test well in a lower Floridan aquifer. Their study was to determine if the upper aquifer was affected by lower aquifer pumping. In part it reads, pumping well #11 at the rate of 748 gallons per minute which is about 1 millions gallons per day, resulted in a maximum steady state drawdown of 36.2 feet in the lower Floridan aquifer was greater than 1 foot over 146sq mile area. Simulated steady state drawdown in an overlying upper Florida aquifer that resulted from Inter-aquifer leakage was greater than 1ft over 141sq mile area and was 2.3 ft (lower) at the site of the well 11 . (4) 

Basically, three scenarios were performed. For each scenario, pumping reductions in existing upper Florida aquifer wells resulted in decreased magnitude an extent of drawdown when compared to a scenario in which the lower Florida aquifer was pumped without adjusting withdrawals from the upper Florida with her. “Pumping from the lower Florida aquifer (well number 11) without adjusting pumping from the upper Florida aquifer resulted in drawdown exceeding 1 foot over a 141 square mile, …” (4)

Water levels changed by 3 feet between the Lower aquifer levels, “suggesting a change in hydrogeologic units, from MCU I to the LFA.” (1 & 4)

Summary being, the Upper and Lower are connected and you cannot take water from the lower part of the glass without it affecting the water at the top of the glass. (Confucius say) 

Will municipal water be brought to the existing residents? Be advised, we are not talking about piping into a city because this was an Urban Sprawl development, so the surrounding is completely rural.  Will this water suck affect the Green Swamp Area of Critical State Concern (ACSC)? Will the Green Swamp begin to decline and dry up, should SWFWMD establish Minimum Flow Levels before they handout a long-term development that will double the existing size of Sumter County (12)?  Will the Federal Prison of Coleman also experience the sandwich effect of being surrounded by developments and the stressed aquifer results of it?

We can answer these questions: None of the answers are good for the residents who are currently under your authorities.  Thus, this call for your all agencies attention and help.

To SWFWMD and other Agencies:

There are no plan B’s for any of these issues. The only plan that consider every aspect and issue properly was the original zoning of 1 dwelling per 10 acres versus the newly forced rezoning of 24-30 units per acre! (13)  Because of this “wrong” and law-breaking rezoning, it will be causing many “wrongs”. Residents fought this recent rezoning while under Covid stay at home orders. (14) This rezoning was originally passed in February without proper public notification, once informed of their lack for public notice, the City posted 8x11 inch notifications off a 55/60 mph highway plus 25ft right of way. (14) Then unfortunately, the application from The City of Wildwood to DEO provided twisted reasoning (to be polite) (13 & 14). They claimed to the DEO professing this was not Urban Sprawl. Please read the 12 out of 13 Urban Sprawl Indicators for a better understanding of this terrible proposed development. (14 & 13) They also provided poor studies, which lacked true data for multi-family housing needs within an age restricted development that will likely be utilizing 20% for multi-family low-income for affordable housing, allowing for children and no public facilities analysis. (13) The cost of this poorly planned Urban Sprawl is astronomical.  Also, the population data they provided was manipulated by using two neighboring counties data rather than Sumter County’s data and excluding Citrus and Hernando counties population completely. (13, & 17).

Lastly, be it known, that of all the pages of data, research, and applications relating to this development, none compared to the number of pages and thickness of 2999 signatures. (14 & 14b.) All of whom were in opposition to this massive and taxing development. Let that sink in for a moment.

Please Save Sumter.

Respectfully yours,

Bill Pownall

-All referenced documents are available upon request, due to size constraints, the highlighted references are attached.


1.       Revised Hydrogeologic Framework of the Floridan Aquifer System in Florida and Parts of Georgia, Alabama, and South Carolina. USGS. Version 1.1 US Dept of the Interior / US Geological Survey (redacted)

2.       Withlacoochee Regional Water Supply Authority, 2014 (redacted)

3.       Southwest Florida Water Management District (SWFWMD) Hydrogeology, Water Quality, and Well Construction at the ROMP 117 – Lake Okahumpka Well site in Northeast Sumter County, Florida. (redacted)

4.       Hydrogeology and Water Quality of the Floridan Aquifer System and Effect of Lower Floridan Aquifer Pumping on the Upper Floridan Aquifer at Hunter Army Airfield, Chatham County, Georgia. (redacted)

5.       Sumter County Code Municode. Section 13-413, Policy 1a b2., 13-414 & 13-412 (2c.) & e. Flood hazard area (2: a & b) Sumter County Conservation Map, Attached 1992 Wildwood Comp Plan, redacted: Map V-II-18 Hydrologic Group “D” Soils located on  this parcel, approx. 80%. Map VII-18c “Constrained Areas for Development, approx. 92% of this proposed amendment. Map VII-5 Group “D” Soils, approx. 60% of this location. Wildwoods Comp includes a map of “Constrained Areas for Development” which encompasses approximately 92% of this proposed development. SWFWMD Floodplain Mapping Application MAP (Big Prairie) Flood A & AE.  Sumter County Unified Comp Plan Floodplains Map, Flood zone map 4-2. (redacted)

6.       Withlacoochee Regional Water Supply Authority Regional Water Supply (WRWSA) Plan Update Final November 2019, redacted, xvi, xx, xxi, xviii, xix, 1-9-1-10, 3-16, 3-17, 4-20, 5-42, 4-15 & Apex 4-2 Figure 3 Drawdown in Layer 7. (redacted)

7.       EDR / Office of Economic & Demographic Research Annual Assessment of Florida’s Water Resources and Conservation Lands 2020 Edition. P.130 (redacted) Per Amy Baker, “by 2025 we expect the forecast of water demand will exceed the water available.”

8.       20-01 ESR/Ord 0202-2  SWFWMD technical comment Email, not including public analysis & unusual for no land use entitlements, FDOT concerns letter. Florida Chapter 163 law with concerns, highlighted.

9.       Letter to the media addressing the lack of ethical representation and public notification, City of Wildwood’s lack of public notification. (redacted).

10.   SWFWMD Florida Forever List, Double Rock / Sink Prairie #27A Proposed Acquisition and SWFWMD Description

11.   The Withlacoochee River Watershed: Biophysical & Regulatory Characteristics (redacted)

12.   Southwest Florida Water Management District (SWFWMD) 2019 Minimum Flows, Minimum Water Levels & Reservations & Priority List. Pending data. (redacted)

13.   Comp Plan & Rezoning Ordinances CP-1911-001 & Ord 02020-5, RZ 1911-002, Ord 02020-3, 02020-26) DEO Plan Amendment 20-02 ESR, Includes the Environmental Study. (redacted),

14.   Residents Presented Data including 12 URBAN SPRAWL INDICATORS to the City of Wildwoods rezoning RZ 1911-002 / Ord 02020-26 Opposing this rezoning and with 2999 Petitions, 2 Photos of 2 posted signs along 471, a Highway of 55 mph with a right of way of at least 25ft from the shoulder. 1 photo of a close up before it faded and curled. Wildwood’s posted signs are 8.5x11, difficult to see at minimum. Previous notification Code & Current Code, recently changed. Letters and notification to City of Wildwood while under stay at home orders & lack of public notifications and presented at their Covid meeting true Urban Sprawl Indicators. (redacted)

15.   Villages Community Development Districts (website) Irrigation Information of water use

16.   Southwest Florida Water Management District March 2020 Hydrologic Conditions (redacted)

17.   BEBR Florida Estimates of Population (redacted)

18.   Wildwood’s Land Development Regulations, on Flood, Water Source Development. SWFWMD Water Management Information System (WMIS) Lower Aquifer Test Well Map location. FEMA Flood Zone Map w/ Jumper Creek, and General Pre-Rezoning Map.

19.   Amy Baker’s 2025 forecast for demand to exceed water availability. Tampa Bay times January 25, 2020.  

20.   City of Wildwood Resolution 2020-30 to un-do their comp plan 17-02ESR, named 2019-56 or Ord 2017-20. City of Wildwood’s May 8th, 2017 meeting vote, Adopted / Unanimous, meeting taped per their minutes and filed (1703-001). New Comp Plan Change on same development and Land Development Regulations change Ord 02020-46 & 02020-47 public notification, newly proposed.

0 have signed. Let’s get to 200!
At 200 signatures, this petition is more likely to be featured in recommendations!