FAA Unmanned Aircraft Systems

Ms. Jacqueline Jackson
Manager, UAS Tactical
Operations (AFS-85/AJV-115)
FAA Headquarters
490 L'Enfant Plaza, SW, Suite 3200
Washington, DC 20024

Subject: Public Entity Validation

Reference: FAA Unmanned Aircraft Systems Test Site Selection - Screening Information Request (SIR) DTFACT-13-R-00002, dated February 14, 2013

Dear Ms. Jackson:

The South Florida Water Management District has advised this office that the Federal Aviation Administration requires the district to obtain a letter from the Florida Attorney General certifying that the district is "an entity of the state." This letter serves as the official confirmation by Florida's Attorney General that the South Florida Water Management District qualifies as a public entity of the State.

Chapter 373, Florida Statutes, divides the State of Florida into "water management districts" and creates and provides for the operation of water management districts. The South Florida Water Management District was created by the Florida Legislature in section 373.069(1)(e), Florida Statutes.

Section 1.01(8), Florida Statutes, provides that:

"The words 'public body,' 'body politic,' or 'political subdivision' include counties, cities, towns, villages, special tax school districts, special road and bridge districts, bridge districts, and all other districts in this state." (e.s.)

Thus, a water management district in Florida, such as the South Florida Water Management District, would appear to fall within the scope of the definition contained in paragraph 9.2.2.2 of the above referenced FAA SIR[1] and would appear to have the ability to qualify for a certificate of authorization as provided therein.

In sum, under Florida law, the South Florida Water Management District is considered to be a political subdivision and a public entity of this state. This letter constitutes the Florida Attorney General's assurance that the district is a political subdivision of the state and may not be understood to constitute comment on any other issue or matter.

Sincerely,

Pam Bondi
Attorney General

PB/tgh
______________________________________________________________________

[1] Paragraph 9.2.2.2 states in part that "[a] public entity is defined as follows: . . . (B) any department, agency, special purpose district, or other instrumentality of a State or States or local government[.]"