SPECIAL PUBLICATION NO. 27 result in discharge to the surface water of the U.S. (this includes "waters of the state"). The NPDES permit is required even for intermittent dis- charges (Mark Latch, DER, personal communication, 1984). PEAT REVENUE AND TAXATION by Kenneth M. Campbell The volume of peat sales in the state of Florida generally increased from 1972 to 1978 (Figure 23). During the same period the value of peat also increased. The value and tonnage fluctuated from 1978 through 1981 prior to a rather drastic decrease in 1982. In 1982, the quantity dropped 25 percent from the estimated tonnage (Boyle and Hendry, 1984) and 24 percent from the previous year. The 1982 value was 47 percent below the predicted level (Boyle and Hendry, 1984) and 45 per- cent less than 1981. Figure 23 reflects these trends as compiled by the U.S. Bureau of Mines. The differences between the predicted and actual numbers for peat mining in Florida is significant in two important ways. First, the differ- ences reflect the recent recession which had a tremendous effect on the mineral industries as a whole, with greatly declined production and value. Secondly, future revenue estimates for peat from the Florida Department of Revenue are based on the trends of the recent past. The recently released 1982 figures may indicate a drastic change in the trend and may require a significant alteration of the previously predicted peat values for 1983- 1984 which were $3.9 million (Figure 23). The peat industry may rebound to its previous levels. However, in light of a 1982 value of $1.575 million, it seems highly unlikely that a value of $3.9 million would be achieved in 1983- 1984. Currently, the vast majority of peat sales in Florida are wholesale and for agricultural purposes and, as such, are exempt from state sales taxes. Some peat products are used in potted plants and sales taxes are col- lected on retail sales of the potted plants. However, the value of the peat and the tax upon that value are not separated from the value and tax on the total sale. Thus, the amount of tax arising from retail sale of peat cannot be determined. Also, there are no records for sales tax applied to peat based potting soils (L. Voorhies, Department of Revenue, personal communication, 1983). As a result, there is no way of estimating the current tax income derived from the exploitation of peat resources in the state of Florida. Estimated tax revenues derived from the imposition of a severance tax on peat could be determined from the revised predicted values for the near future. The Florida Department of Revenue does not currently have such an estimate available.