Fort Walton Beach Council agenda — 12-24-2010 Regular — reading text

Q Distribution of Annual Compliance 0 Cost -End of Pipe Enforcement U U Total Annual Cost $ 4. 8 Billion) z z a a Unimpaired E U M Newly Impaired a Currently Impaired, no TM DL Current TMDL November 2010 Cardno ENTRIX Executive Summa f7Pack1t Pg. 104  14. 11. 16 Economic Analysis of the Proposed Numeric Nutrient Criteria for Florida Figure ES-4 Distribution of Annual Compliance Cost by Water Body Category In addition, the EPA' s estimate of benefits is highly uncertain, and it is reasonable to assume that the benefits from the proposed federal NNC should be large enough to equal or outweigh the costs. EPA points to the potential economic value of improved water quality in both its preamble and in a separate Technical Support Document. Both discussions have the same two flaws. First, information and validation showing that specific locations will benefit in meaningful, measurable ways from imposing the criteria are lacking. As a general matter, economic benefits arising from these types of actions are site -specific and EPA' s benefits assessment provides no information about the potential site -specific benefits ( and their relationship to costs). In this sense, problems with EPA' s economic benefits estimates mirror the flaws with several aspects of the technical approach to setting the proposed federal NNC (i.e., lack of clear connection between the required nutrient reduction and the anticipated ecological response). Secondly, even when focusing on " generic" rather than site -specific benefits, the studies cited by the EPA do not provide reliable estimates of water quality improvements. November 2010 Cardno ENTRIX Executive S Packet Pg. 105  14. 1. b Cavan ENTR X / Shaping the Future Q a W c Q 3 J C C O CO Q. M a 0 vs 0 R C Q N O U U Z Z C E t v ca r Q Toll -free 800 368 7511 www.cardnoentrix.com Australia • Belgium • Canada • Ecuador • Indonesia • Kenya • New Zealand • Papua New Guinea www. cardno. com Peru • United Arab Emirates • United Kingdom • United States • Oper Packet Pg. 106  Vd3 jjsuieBV j!nsme-1 ui uoped' 31:Ped : 0600 : podaM ONN WOUJI43eW C0 CL pled" - 11*tY* counci 1 I WEAUti* CL ED Protecting Floridas Clean Water Environment P.O. Box 2814 • W-Wdermere, FL -34786-28 14 • 407-36-7751 * Fax 407-370-3595 mfiveauc.org December 3, 2009 Governor Charlie Crist Office of the Governor PL- 05 The Capitol Tallahassee, FL 32399- 0001 Re: Numeric Nutrient Criteria Cost Implications for Florida POTWs Dear Governor Crist, The Florida Water Environment Association Utility Council ( FWEA Utility Council) respectfully submits this letter to alert you to an issue of critical importance to Florida' s municipal wastewater treatment community: the U. S. Environmental Protection Agency' s ( EPA' s) decision to promulgate federal numeric nutrient standards for Florida surface waters. EPA plans to propose stringent numeric nutrient water quality standards for Florida by January 2010 for streams, canals, and lakes and by January 2011 for coastal. waters. EPA determined that Florida -- and only Florida -- needs federal standards in this short tit-neframe, even though Florida has one of the most sophisticated water quality standards programs in the nation. As the state' s preeminent association of local government and private utilities in Florida that own and operate domestic wastewater treatment, disposal, reuse, and recycling facilities, the FWEA Utility Council has taken a leadership role in opposing EPA' s decision to develop federal nutrient standards for Florida waters. Utility Council members treat the wastewater produced by over 7 million Florida residents, and these residents pay for our capital projects and operating costs through their utility bills. FWEA Utility Council members thus have an obligation to ensure that our ratepayers' money is efficiently spent on prqjects that benefit the