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

environment. It is because of this obligation to our ratepayers that we have such significant concern regarding EPA' s decision to impose federal numeric nutrient criteria on Floridians. EPA' s, approach to developing numeric nutrient standards has serious scientific flaws that will lead to arbitrary standards creating drastic economic consequences for Floridians. According to technical and economic analysis performed by Carollo Engineers in the enclosed whitepaper, federal numeric nutrient criteria for Florida surface waters will cause wastewater utility rates to double on avera!'re across the -State. Florida municipal wastewater treatment utilities will spend an estimated 524.4 to $ 50. 7 billion in capital costs for additional treatment facilities and incur an estimated $ 0. 4 to $ 1. 3 billion dollars per year in additional operating costs. 1 These cost estimates were calculated using draft numeric nutrient criteria released by the Florida Department of Environmental Protection In July 2009. The Department developed its draft criteria using a variation of EPA' s statistical approach to deriving nutrient criteria, yet in an open letter dated September 16, 2009. EPA criticized the Department' s criteria as not being adequately protective of downstream waters. o ( Vd3 mieBV }insme-1 ui uoped' OlVed : 0600 podeU ONN Wau1143e44v TZ o r' e as CL EPA publicly justifies its intervention into Florida' s water quality standards program based on the occurrence of algal blooms and other periodic nutrient problems in some Florida waters. However, a statewide federal numeric nutrient criteria are not the solution to this problem. Algal blooms violate Florida' s existing nutrient standards, and Florida' s Total Maximum Daily Load (TMDL) program is designed specifically to bring these waters back into compliance with Florida law. EPA' s decision to promulgate federal standards for Florida waters is in direct contradiction to the state primacy envisioned by the Clean Water Act. We ask that you join the FWEA Utility Council in opposing this unneeded federal intervention into state water policy. Floridians deserve to maintain their own science -based nutrient water quality standards program, which protects state water ecosystems and protects utility ratepayers from the economic burdens of unsound federal regulatory policy. If you have any questions or concerns regarding this letter or the attached report, please contact Paul Steinbrecher, the FWEA Utility Council Vice President and Numeric Nutrient Criteria Issue Chair, at 904) 665 -6827. Encl: Technologies to ,Weer Numeric Nutrient Criteria at Florida' s l7on7estic Water Reelaination Facllltles CC: Charles Bronson, Commissioner, Florida Department of Agriculture and Consumer Services Bill McCollum, Florida Attorney General Alex Sink, Chief Financial Officer, Florida Department of Financial Services Jeff Atwater, President, Florida Senate Larry Cretul, Speaker, Florida House of Representatives Michael Sole, Secretary, Florida Department of Environmental Protection Representative Trudi Williams, Chair, Agriculture & Natural Resources Policy Committee Gary Williams, Executive Director, Florida Rural Water Association Dominic Calabro, President, Florida TaxWatch David Childs, Hopping Green & Sams  14.1. c TECHNOLOGIES TO MEET NUMERIC NUTRIENT CRITERIA AT FLORIDA' S DOMESTIC WATER RECLAMATION FACILITIES November 18, 2009 Packet Pg. 109  14. 1. c Table of Contents ExecutiveSummary ........................................................................................... .............................. 2 Existing and Proposed Nutrient Standards ...... ............................... Current Nutrient Removal Technology ............................................................. .............................. 5 Additional Technologies to Meet Proposed Numeric Nutrient Criteria ............ .............................. 5 Challenges Associated with Reverse Osmosis Systems .................................... .............................. 7 Q Costs to Meet the Numeric Nutrient Criteria a W ASpecific Case Study ........................................................................... .............................. 8 c TheBig Picture ...................................................................................... ..............................9 Sampleof Utilities ................................................................................ ............................. 10 Q Conclusions .................. 11 3 J C O p cv to a 0 rn 0 O a v U Z Z m E t v cv Q Carollo Engineers 1 Packet Pg. 110  14.1. c TECHNOLOGIES TO MEET NUMERIC NUTRIENT CRITERIA AT FLORIDA' S DOMESTIC WATER RECLAMTION FACILITIES EXECUTIVE SUMMARY The consent decree between the US Environmental Protection Agency (EPA) and a coalition of environmental groups over the need to set numeric nutrient criteria (NNC) for surface waters in the State of Florida will have severe consequences for Florida' s wastewater utilities and the customers they serve. If the expected NNC to be proposed by EPA are implemented in the state' s water quality regulations, all Florida wastewater facilities that discharge reclaimed water to rivers, streams, lakes and estuaries will likely be required to meet new, very low limits on the discharge of total nitrogen (TN) a=rid total phosphorus ( TP). These new limits are anticipated to require a reduction in the current discharge of TN by 40 to 80% and TP by 90 to 95 %. Should the proposed numeric nutrient criteria become incorporated in the discharge permits for these treatment plants, Florida utilities will spend an estimated $ 24.4 to $ 50. 7 billion in capital