Review of the EPA's Economic Analysis of Final Water Quality Standards for Nutrients for Lakes and Flowing Waters in Florida (2012) / Chapter Skim
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1 Introduction
1 Introduction
Pages 11-34
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, states are moving toward the use of numeric water quality criteria for nutrients in an attempt to accelerate and standardize the restoration of nutrient-impaired waters. This report was written by a committee of the 11
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The issue has focused national attention on Florida, which is often the case in matters of water resources. TECHNICAL CHALLENGES OF NUTRIENT MANAGEMENT IN FLORIDA Florida has more than 11,000 miles of rivers and streams, over 7,700 lakes, and 27 first-magnitude springs (stateofflorida.com; see Figure 1-1 for the state's major water features)
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From page 13... ...
. Population growth has the potential to affect transport of nitrogen and phosphorus from urban and suburban areas to surface waterbodies through increased discharge of stormwater and wastewater and loss of natural assimilative capacity.
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The specific impacts of these secondary changes are difficult to assess, as they depend specifically on which landscapes are affected and the connectivity between these landscapes and nearby surface waterbodies. Nonetheless, one can expect that nutrient loads to surface waters will increase as forested areas are converted to urban and suburban land (USGS, 1998)
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Intense rainfall can produce heavy runoff (and associated pollutant loads) over short periods of time.
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Soil and Geology Florida water quality is strongly affected by natural variability in soil and geologic materials, as manifested in clear differences in lake physical, chemical, and biological characteristics across Florida's 47 Lake Ecoregions (Griffith et al., 1997)
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Both soil and geologic conditions can produce high background levels of nutrients in Florida waterbodies that make meeting numeric water quality criteria a challenge (as discussed in a subsequent section)
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53 percent of the state's rivers and streams and 81 percent of its lakes (FDEP, 2008) ; poor water quality (for all causes except mercury)
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Furthermore, each polluting sector operates under different legal and regulatory requirements, as described in greater detail in Chapter 2. WATER QUALITY STANDARDS AND THE TMDL PROCESS The Clean Water Act (CWA)
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20 EPA'S ECONOMIC ANALYSIS OF NUTRIENT STANDARDS IN FLORIDA FIGURE 1-6 TMDL Project implementation via Basins Management Action Plans. SOURCE: Florida Department of Environmental Protection (2011)
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. FIGURE 1-8 Relative contribution of the nitrogen load and phosphorus load by sector to the lower St.
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In general, however, Figure 1-9 provides a simplified diagram illustrating the general interaction of water quality standards, NPDES permitting, and TMDLs applicable to all states. Box 1-1 contains definitions of important water quality management terms.
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In 2009 EPA determined that numeric, rather than narrative, nutrient criteria would be necessary in Florida to meet the requirements of the CWA (EPA, 2009)
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that had sued EPA, maintaining that Florida's narrative nutrient criteria were not protective of Florida's waters. Their argument was that the narrative, siteby-site approach to address nutrient pollution problems in Florida was taking too much time and too many resources to allow the state to effectively and expeditiously address its thousands of stream miles and lake acres that violate the narrative nutrient standard.
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From page 25... ...
cited section 303 of the CWA, which requires EPA to "promptly prepare and publish" new or revised water quality standards "in any case where the Administrator determines that a revised or new standard is necessary to meet the requirements of this Act [the Clean Water Act] ." The main fundamental difference between the narrative and numeric nutrient standards is that under the narrative standard waters are listed as impaired because of an imbalance of flora and fauna, which is based on biological condition assessment.
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From page 26... ...
(The reader is referred to the beginning of Chapter 3 for a more in-depth explanation of the differences between the narrative and numeric nutrient criteria.) The numeric nutrient standards established for Florida by EPA on November 14, 2010, are for nitrogen and phosphorus in lakes and flowing waters for different regions of the state, as shown in Table 1-1 (Federal Register, December 6, 2010, 75 FR 75762)
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From page 27... ...
For each ecoregion, lake water quality characteristics were summarized. For colored lakes the numeric nutrient criteria proposed by EPA (2010)
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Interestingly, a comparison of the numeric nutrient criteria with typical TMDL targets in impaired streams and lakes suggests that the numeric criteria are usually less stringent than the TMDL targets that have been developed under the narrative process, except for lakes with phosphorus pollution (see Box 3-1 in Chapter 3)
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From page 29... ...
. First, EPA considers only those additional waters that that are newly identified as impaired based on the numeric nutrient criteria and does not consider waters that Florida has already determined to be impaired based on existing FDEP assessment methodologies.
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It is certain that the total costs of attaining water quality standards in Florida waters impaired by nutrients will be enormous, not only because of ongoing polluting activities and the current state of water quality impairment in Florida but
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Thus, EPA requested that the National Research Council (NRC) conduct a review of the Agency's economic analysis of the incremental costs of state implementation of final numeric nutrient criteria for lakes and flowing waters in Florida.
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Because the numeric nutrient criteria rule is scheduled to take effect March 6, 2012, the EPA needs input quickly on a number of important issues. The committee will evaluate the cost estimates of implementing the numeric criteria, including the relevance and validity of certain assumptions and methods used in the economic analysis.
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From page 33... ...
2010. Economic Impacts and Compliance Costs of Proposed EPA Water Quality Standards for the State of Florida's Lakes and Flowing Waters.
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From page 34... ...
2010. Economic Analysis of Final Water Quality Standards for Nutrients in Lakes and Flowing Waters in Florida.
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