Florida Department of Environmental Protection
June 18, 2018
Dear Secretary Valenstein:
We appreciate the Department undertaking a public comment process as part of its rulemaking to seek Clean Water Act Section 404 delegation from the EPA. However, rulemaking is only a part of the application the Department will be submitting on behalf of the people of Florida, and no public input process has been provided by DEP for the other components of the application. These include the very important memoranda of agreement (MOAs) between the state and the EPA, USACE, and potentially the USFWS; the waters Florida believes should be retained by the USACE; and how the program would be staffed and structured within DEP and the water management districts.