FLORIDA DEPARTMENT OF ENVIRONMENTAL PROTECTION 

Division of Water Resource Management, Bureau of Watershed Management

SOUTHWEST DISTRICT • SPRINGS COAST BASIN • 

ANCLOTE RIVER/COASTAL PINELLAS COUNTY PLANNING UNIT 

TMDL Report 

Fecal Coliform TMDL for 

Saint Joes Creek, 

WBID 1668A 

Paul C. Kurisko

April 24, 2008
TMDL Report: Saint Joes Creek, WBID 1668A, Springs Coast Basin, Fecal Coliform 

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Florida Department of Environmental Protection 

Acknowledgments 

This study could not have been accomplished without significant contributions from staff in the 

Florida Department of Environmental Protection’s (FDEP) Watershed Assessment Section. 

Editorial assistance was provided by Jan Mandrup-Poulsen and Kevin Petrus.

Geographic information systems (GIS) and map production assistance were provided by 

Janis Paulsen. 

For additional information on the watershed management approach and impaired waters 

in the Springs Coast Basin, contact 

Fred Calder 

Florida Department of Environmental Protection 

Bureau of Watershed Management 

Watershed Planning and Coordination Section 

2600 Blair Stone Road, Mail Station 3565 

Tallahassee, FL 32399-2400 

Email: fred.calder@dep.state.fl.us

Phone: (850) 245–8555; SunCom: 205–8555 

Fax: (850) 245–8434 

Access to all data used in the development of this report can be obtained by contacting

Kevin Petrus 

Florida Department of Environmental Protection 

Bureau of Watershed Management 

Watershed Assessment Section 

2600 Blair Stone Road, Mail Station 3555 

Tallahassee, FL 32399-2400 

Email: kevin.petrus@dep.state.fl.us

Phone: (850) 245–8459; SunCom: 205–8459 

Fax: (850) 245–8444 
TMDL Report: Saint Joes Creek, WBID 1668A, Springs Coast Basin, Fecal Coliform 

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Contents 

Chapter 1: INTRODUCTION____________________________________ 1

1.1 Purpose of Report _______________________________________________ 1

1.2 Identification of Waterbody ________________________________________ 1

1.3 Background_____________________________________________________ 4

Chapter 2: DESCRIPTION OF WATER QUALITY PROBLEM _________ 5

2.1 Statutory Requirements and Rulemaking History______________________ 5

2.2 Information on Verified Impairment _________________________________ 5

Chapter 3. DESCRIPTION OF APPLICABLE WATER QUALITY 

STANDARDS ______________________________________ 8

3.1 Classification of the Waterbody and Criteria Applicable to the TMDL _____ 8

3.2 Applicable Water Quality Standards and Numeric Water Quality 

Target _________________________________________________________ 8

3.2.1 Fecal Coliform Criterion _____________________________________ 8

Chapter 4: ASSESSMENT OF SOURCES_________________________ 9

4.1 Types of Sources ________________________________________________ 9

4.2 Potential Sources of Fecal Coliform Bacteria in Saint Joes Creek, 

WBID 1668A ____________________________________________________ 9

4.2.1 Point Sources ______________________________________________ 9

4.2.2 Land Uses and Nonpoint Sources ____________________________ 10

Chapter 5: DETERMINATION OF ASSIMILATIVE CAPACITY_________ 16

5.1 Method Used To Determine Loading Capacity ________________________ 16

5.2 Data Used in the Determination of Loading Capacity___________________ 16

5.3 TMDL Development Process _______________________________________ 17

5.4 Critical Conditions/Seasonality_____________________________________ 23

Chapter 6: DETERMINATION OF THE TMDL ______________________ 28

6.1 Expression and Allocation of the TMDL______________________________ 28

6.2 Load Allocation__________________________________________________ 29

6.3 Wasteload Allocation _____________________________________________ 29

6.3.1 NPDES Wastewater Discharges ______________________________ 29

6.3.2 NPDES Stormwater Discharges ______________________________ 29
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6.4 Margin of Safety _________________________________________________ 30

Chapter 7: NEXT STEPS: IMPLEMENTATION PLAN 

DEVELOPMENT AND BEYOND _______________________ 31

7.1 Basin Management Action Plan ____________________________________ 31

References__________________________________________________ 32

Appendices _________________________________________________ 34

Appendix A.1: Summary of Monitoring Results for Fecal Coliform in 

Saint Joes Creek, Main Channel, WBID 1668A ________________________ 34

Appendix A.2: Summary of Monitoring Results for Fecal Coliform in 

Miles Creek, WBID 1668A _________________________________________ 36

Appendix B: Background Information on Federal and State Stormwater 

Programs_______________________________________________________ 37

List of Tables 

Table 2.1. Verified Impairment in Saint Joes Creek, WBID 1668A ________________ 6

Table 2.2. Summary of Fecal Coliform Data for Saint Joes Creek, WBID 1668A, 

March 2004–May 2006_________________________________________ 6

Table 4.1. Classification of 2004 Land Use Categories in Saint Joes Creek, 

WBID 1668A________________________________________________ 11

Table 4.2. Estimated Coliform Loading from Dogs and Cats in Saint Joes Creek, 

WBID 1668A________________________________________________ 13

Table 4.3. Population Density in Pinellas County, Florida, in 2006 _______________ 14

Table 5.1.a. Observed Fecal Coliform Data for Calculating Exceedances to the 

State Criterion for Saint Joes Creek, Main Channel, WBID 1668A ______ 21

Table 5.1.b. Observed Fecal Coliform Data for Calculating Exceedances to the 

State Criterion for Miles Creek, WBID 1668A_______________________ 22

Table 5.2.a. Coliform Target Loads for Flow, Saint Joes Creek, Main Channel _______ 24

Table 5.2.b. Coliform Target Loads for Flow, Miles Creek _______________________ 25

Table 5.3a. Fecal Coliform Percentage Reductions Required for Saint Joes Creek, 

Main Channel _______________________________________________ 26

Table 5.3.b. Fecal Coliform Percentage Reductions Required for Miles Creek _______ 27

Table 6.1. Fecal Coliform TMDL for Saint Joes Creek, WBID 1668A_____________ 29
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List of Figures 

Figure 1.1. Saint Joes Creek, WBID 1668A, and Major Geopolitical Features in 

the Coastal Pinellas County Portion of the Springs Coast Basin _________ 2

Figure 1.2. Saint Joes Creek, WBID 1668A, and Monitoring Locations _____________ 3

Figure 2.1. Fecal Coliform Measurements for Saint Joes Creek, WBID 1668A, 

March 2004–May 2006_________________________________________ 7

Figure 4.1. Principal Land Uses in Saint Joes Creek, WBID 1668A, in 2004 ________ 12

Figure 4.2. Population Density in the Area of Saint Joes Creek, WBID 1668A, in 

2006 ______________________________________________________ 14

Figure 5.1.a. Flow Duration Curve for Saint Joes Creek, Main Channel, 2000–06 

(Estimated Flow)_____________________________________________ 18

Figure 5.1.b. Flow Duration Curve for Miles Creek, 2000–06 (Estimated Flow) _______ 18

Figure 5.2.a. Load Duration Curve for Fecal Coliform in Saint Joes Creek, Main 

Channel, WBID 1668A ________________________________________ 19

Figure 5.2.b. Load Duration Curve for Fecal Coliform in Miles Creek, WBID 1668A____ 20

Websites 

Florida Department of Environmental Protection, Bureau of Watershed 

Management 

Total Maximum Daily Load (TMDL) Program 

http://www.dep.state.fl.us/water/tmdl/index.htm

Identification of Impaired Surface Waters Rule 

https://www.flrules.org/gateway/chapterhome.asp?chapter=62-303

Florida STORET Program 

http://www.dep.state.fl.us/water/storet/index.htm

2006 305(b) Report 

http://www.dep.state.fl.us/water/tmdl/docs/2006_Integrated_Report.pdf

Criteria for Surface Water Quality Classifications 

http://www.dep.state.fl.us/water/wqssp/classes.htm

Water Quality Status and Assessment Reports for the Springs Coast 

Basin 

http://www.dep.state.fl.us/water/basin411/springscoast/index.htm
TMDL Report: Saint Joes Creek, WBID 1668A, Springs Coast Basin, Fecal Coliform 

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Florida Department of Environmental Protection 

U.S. Environmental Protection Agency, National STORET Program 

Region 4: Total Maximum Daily Loads in Florida 

http://www.epa.gov/region4/water/tmdl/florida/

National STORET Program 

http://www.epa.gov/storet/
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Florida Department of Environmental Protection 

Chapter 1: INTRODUCTION 

1.1 Purpose of Report 

This report presents the Total Maximum Daily Load (TMDL) for fecal coliform bacteria for the 

freshwater segment of Saint Joes Creek, located in the Anclote River/Coastal Pinellas County 

Planning Unit, which is part of the larger Springs Coast Basin. The stream was verified as 

impaired for fecal coliform bacteria and was included on the Verified List of impaired waters for 

the Coastal Pinellas County portion of the Springs Coast Basin that was adopted by Secretarial 

Order in December 2007 (Florida Department of Environmental Protection [FDEP], 2007). The 

TMDL establishes the allowable loadings to Saint Joes Creek that would restore the waterbody 

so that it meets the applicable water quality criterion for fecal coliform bacteria. 

1.2 Identification of Waterbody 

Saint Joes Creek is located within the Long Bayou watershed, in the west-central portion of 

Pinellas County, Florida (Figure 1.1). For assessment purposes, FDEP divided the Saint Joes 

Creek watershed into four water assessment polygons with a unique waterbody identification 

(WBID) number for each waterbody segment (Figure 1.2). The main stem of Saint Joes Creek 

is divided into a tidal and a freshwater segment, identified as WBIDs 1668E and 1668A, 

respectively. Two tributaries, which flow into the tidal segment of the creek, are Bonn Creek 

(WBID 1668D) and Pinellas Park Ditch Number 5 (WBID 1668B). This TMDL report focuses on 

the freshwater segment of Saint Joes Creek (WBID 1668A) and on Miles Creek, a tributary of 

the freshwater segment of the creek. Figure 1.2 shows the stream channels within WBID 

1668A. Separate TMDL reductions were determined for the main channel of Saint Joes Creek 

and the Miles Creek tributary. 

Saint Joes Creek discharges to the Cross Bayou, Long Bayou, and Boca Ciega Bay estuary 

system. It is free flowing until it reaches the uppermost portion of its tidal area. The tidal 

portion, or the upper reaches of WBID 1668E, begins where the creek crosses under 46th

Avenue in the city of St. Petersburg. 

The Saint Joes Creek watershed (WBID 1668A) has a total surface area of about 9 square 

miles (Figure 1.1). All of the watershed lies within Pinellas County. Land use is predominantly 

residential, with 73 percent of the area designated as such. Major urban areas include portions 

of the city of St. Petersburg, Kenneth City, and West and East Lealman (a U.S. Census 

Designated Place [CDP]) (U.S. Census Bureau American FactFinder Website). The population 

of St. Petersburg, as of the 2003 U.S. Census estimate, was 247,610, making it the fourth 

largest city in the state. Based on the population density in St. Petersburg (4,163 

persons/square mile) the estimated existing population in the Saint Joes Creek area (WBID 

1668A) is 37,467 (U.S. Census Bureau State & County QuickFacts Website). 
TMDL Report: Saint Joes Creek, WBID 1668A, Springs Coast Basin, Fecal Coliform 

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Figure 1.1. Saint Joes Creek, WBID 1668A, and Major Geopolitical 

Features in the Coastal Pinellas County Portion of the Springs 

Coast Basin 
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Florida Department of Environmental Protection 

Figure 1.2. Saint Joes Creek, WBID 1668A, and Monitoring Locations 
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Florida Department of Environmental Protection 

1.3 Background 

This report was developed as part of FDEP’s watershed management approach for restoring 

and protecting state waters and addressing TMDL Program requirements. The watershed 

approach, which is implemented using a cyclical management process that rotates through the 

state’s 52 river basins over a 5-year cycle, provides a framework for implementing the TMDL 

Program–related requirements of the 1972 Federal Clean Water Act (U.S. Environmental 

Protection Agency [EPA] Federal Clean Water Act), and the 1999 Florida Watershed 

Restoration Act (FWRA) (Chapter 99-223, Laws of Florida). 

A TMDL represents the maximum amount of a given pollutant that a waterbody can assimilate 

and still meet water quality standards, including its applicable water quality criteria and its 

designated uses. TMDLs are developed for waterbodies that are verified as not meeting their 

water quality standards. They provide important water quality restoration goals that will guide 

restoration activities. 

This TMDL report will be followed by the development and implementation of a Basin 

Management Action Plan, or BMAP, to reduce the amount of fecal coliform bacteria that caused 

the verified impairment of the Saint Joes Creek freshwater segment. These activities will 

depend heavily on the active participation of the Southwest Florida Water Management District 

(SWFWMD), local governments, businesses, and other stakeholders. FDEP will work with 

these organizations and individuals to undertake or continue reductions in the discharge of 

pollutants and achieve the established TMDLs for impaired waterbodies. 
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Florida Department of Environmental Protection 

Chapter 2: DESCRIPTION OF WATER QUALITY 

PROBLEM 

2.1 Statutory Requirements and Rulemaking History 

Section 303(d) of the Federal Clean Water Act requires states to submit to the EPA a list of 

surface waters that do not meet applicable water quality standards (impaired waters) and 

establish a TMDL for each pollutant identified as causing the impairment of the listed waters on 

a schedule. FDEP has developed such lists, commonly referred to as 303(d) lists, since 1992. 

The list of impaired waters in each basin, referred to as the Verified List, is also required by the 

FWRA (Subsection 403.067[4], Florida Statutes [F.S.]), and the state’s 303(d) list is amended 

annually to include basin updates. 

Florida’s 1998 303(d) list included 22 waterbodies (WBIDs) in the Springs Coast Basin. 

However, the FWRA (Section 403.067, F.S.) stated that all previous Florida 303(d) lists were for 

planning purposes only and directed FDEP to develop, and adopt by rule, a new science-based 

methodology to identify impaired waters. After a long rulemaking process, the Environmental 

Regulation Commission adopted the new methodology as Rule 62-303, Florida Administrative 

Code (F.A.C.) (Identification of Impaired Surface Waters Rule, or IWR, April 2001), and as 

amended. 

2.2 Information on Verified Impairment 

FDEP used the IWR to assess water quality impairments in the freshwater segment of Saint 

Joes Creek (WBID 1668A) and verified the impairments for fecal coliform bacteria (see Table 

2.1). Table 2.2 summarizes the data collected during the verification period (January 1, 1999, to 

June 30, 2006). The segment was verified as impaired for fecal coliform bacteria because more 

than 10 percent of values exceeded the Class III freshwater criterion of 400 counts per 100 

milliliters (counts/100mL) for fecal coliform (23 out of 62 samples in the verified period exceeded 

the criterion of 400 counts/100mL). 

The verified impairments were based on data collected by the Pinellas County Watershed 

Management Division and FDEP. The assessment was based on data collected at 3 Pinellas 

County STORET stations (21FLPDEM35 -10, -11, and -12) and 5 FDEP STORET stations 

(Southwest District 21FLTPA STORET Stations -27483438243412, -27483668242429, 

-27484788240469, -2727485048241453, and -27485898241143). Seven of the stations are 

located on the main stem of Saint Joes Creek, and 1 station is located on Miles Creek 

(21FLPDEM35-12). Figure 1.2 shows the locations of the sampling sites. Figure 2.1 displays 

the fecal coliform data collected from 2004 through 2006, and Appendix A tabulates all available 

fecal coliform data for the impaired segment. Fecal coliform values exceeding the criterion of 

400 counts/100mL during this period were used to develop the TMDL, as described in 

Chapter 5. 
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Table 2.1. Verified Impairment in Saint Joes Creek, WBID 1668A 

Parameter Causing Impairment Priority for TMDL 

Development

Projected Year 

for TMDL 

Development*

Fecal Coliform High 2007 

*The TMDL was scheduled to be completed by December 31, 2006, based on a Consent 

Decree between the EPA and EarthJustice, but the Consent Decree allows a nine-month 

extension for completing the TMDL. 

Table 2.2. Summary of Fecal Coliform Data for Saint Joes Creek, 

WBID 1668A, March 2004–May 2006 

Waterbody 

Parameter 

Causing 

Impairment 

Total Number 

of Samples 

30-Day 

Geometric 

Mean 

Percent 

Fecal Coliform 

Samples 

> 400 

counts/100mL 

Minimum 

Concentration 

(counts/100mL) 

Maximum 

Concentration 

(counts/100mL)

Saint Joes Creek 

Main Channel Fecal Coliform 50 N/A 28 1 3,500 

Miles Creek Fecal Coliform 12 N/A 75 86 7,300 

N/A – Not available 
TMDL Report: Saint Joes Creek, WBID 1668A, Springs Coast Basin, Fecal Coliform 

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St Joe's Creek Fecal Coliform Measurements

 From 2004 to 2006 WBID 1668A

0

1000

2000

3000

4000

5000

6000

7000

8000

Mar-04 May-04 Aug-04 Nov-04 Feb-05 May-05 Aug-05 Nov-05 Feb-06 May-06

Date

Fecal Coliforms (counts/100 mL)

21FLPDEM35-10

21FLPDEM35-11

21FLTPA27483438243412

21FLTPA27483668242429

21FLTPA27484788240469

21FLTPA27485048241453

21FLTPA27485898241143

21FLPDEM35-12

Sampling Station

 ID Number

 Fecal Coliform 

Criteria: 400 counts/100 mL

Figure 2.1. Fecal Coliform Measurements for Saint Joes Creek, 

WBID 1668A, March 2004–May 2006 
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Florida Department of Environmental Protection 

Chapter 3. DESCRIPTION OF APPLICABLE WATER 

QUALITY STANDARDS 

3.1 Classification of the Waterbody and Criteria Applicable to the TMDL 

Florida’s surface waters are protected for five designated use classifications, as follows: 

Class I Potable water supplies 

Class II Shellfish propagation or harvesting 

Class III Recreation, propagation, and maintenance of a healthy, wellbalanced population of fish and wildlife 

Class IV Agricultural water supplies 

Class V Navigation, utility, and industrial use (there are no state 

waters currently in this class) 

Saint Joes Creek is a Class III waterbody, with a designated use of recreation, propagation, and 

maintenance of a healthy, well-balanced population of fish and wildlife. The Class III water 

quality criterion applicable to the impairment addressed by this TMDL is for fecal coliform 

bacteria. 

3.2 Applicable Water Quality Standards and Numeric Water Quality Target 

3.2.1 Fecal Coliform Criterion 

Numeric criteria for bacterial quality are expressed in terms of fecal coliform bacteria 

concentrations. The water quality criterion for the protection of Class III waters, as established 

by Rule 62-302, F.A.C., is as follows: 

Fecal Coliform Bacteria: 

The most probable number (MPN) or membrane filter (MF) counts per 100 

mL of fecal coliform bacteria shall not exceed a monthly average of 200, nor 

exceed 400 in 10 percent of the samples, nor exceed 800 on any one day. 

For fecal coliform, the criterion states that monthly averages shall be expressed as geometric 

means, based on a minimum of 10 samples taken over a 30-day period. However, during the 

development of load curves for the impaired segment (as described in subsequent chapters), 

there were insufficient data (fewer than 10 samples in a given month) available to evaluate the 

geometric mean criterion for fecal coliform bacteria. Therefore, the fecal coliform criterion 

selected for the TMDL is that values are not to exceed 400 counts/100mL in more than 10 

percent of the samples. The 10 percent exceedance allowed by the water quality criterion was 

not used directly in estimating the target load, but was included in the TMDL margin of safety 

(MOS) (described in Section 6.4). 
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Chapter 4: ASSESSMENT OF SOURCES 

4.1 Types of Sources 

An important part of the TMDL analysis is the identification of pollutant source categories, 

source subcategories, or individual sources of the pollutant causing impairment in the 

watershed and the amount of pollutant loading contributed by each of these sources. Sources 

are broadly classified as either “point sources” or “nonpoint sources.” Historically, the term 

“point sources” has meant discharges to surface waters that typically have a continuous flow via 

a discernable, confined, and discrete conveyance, such as a pipe. Domestic and industrial 

wastewater treatment facilities (WWTFs) are examples of traditional point sources. In contrast, 

the term “nonpoint sources” was used to describe intermittent, rainfall-driven, diffuse sources of 

pollution associated with everyday human activities, including runoff from urban land uses, 

agriculture, silviculture, and mining; discharges from failing septic systems; and atmospheric 

deposition. 

However, the 1987 amendments to the Clean Water Act redefined certain nonpoint sources of 

pollution as point sources subject to regulation under the EPA’s National Pollutant Discharge 

Elimination System (NPDES) Program. These nonpoint sources included certain urban 

stormwater discharges, including those from local government master drainage systems, 

construction sites over 5 acres, and a wide variety of industries (see Appendix B for background 

information on the federal and state stormwater programs). 

To be consistent with Clean Water Act definitions, the term “point source” will be used to 

describe traditional point sources (such as domestic and industrial wastewater discharges) and 

stormwater systems requiring an NPDES stormwater permit when allocating pollutant load 

reductions required by a TMDL (see Section 6.1). However, the methodologies used to 

estimate nonpoint source loads do not distinguish between NPDES stormwater discharges and 

non-NPDES stormwater discharges, and as such, this source assessment section does not 

make any distinction between the two types of stormwater. 

4.2 Potential Sources of Fecal Coliform Bacteria in Saint Joes Creek, WBID 

1668A 

4.2.1 Point Sources 

There are no permitted domestic WWTFs that discharge fecal coliform loads into the freshwater 

segment of Saint Joes Creek. One facility, the Pinellas County Utilities’ South Cross Bayou 

Water Reclamation Facility (NPDES No. FL0040436), discharges to the tidal segment of Saint 

Joes Creek, downstream of the reach that is the focus of this report. 
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Municipal Separate Storm Sewer System Permittees 

Municipal separate storm sewer systems (MS4s) may also discharge pollutants to waterbodies 

in response to storm events. To address stormwater discharges, the EPA developed the 

NPDES stormwater permitting program in two phases. Phase I, promulgated in 1990, 

addresses large and medium-size MS4s located in incorporated areas and counties with 

populations of 100,000 or more. Phase II permitting began in 2003. Regulated Phase II MS4s, 

defined in Section 62-624.800, F.A.C., typically cover urbanized areas serving jurisdictions with 

a population of at least 10,000 or discharging into Class I or Class II waters, or into Outstanding 

Florida Waters. 

There are two Phase I MS4 permits that cover the stormwater collection systems in the Saint 

Joes Creek watershed. Saint Joes Creek falls under the Phase I MS4 permits to Pinellas 

County (No. FLS000005) and the city of St. Petersburg (No. FLS000007). The copermittees of 

the Pinellas County permit are the town of Kenneth City and the Florida Department of 

Transportation (FDOT). Currently, no local governments in the watershed have applied for 

coverage under the Phase II NPDES MS4 permit. 

4.2.2 Land Uses and Nonpoint Sources 

Nonpoint source pollution, unlike pollution from industrial and sewage treatment plants, comes 

from many diffuse sources. It is caused by rainfall moving over and through the ground. As the 

runoff moves, it picks up and carries away natural and human-made pollutants, finally 

depositing them into lakes, rivers, wetlands, coastal waters, and even underground sources of 

drinking water (EPA, 1994). Potential nonpoint sources of fecal coliform bacteria include 

loadings from surface runoff, wildlife, livestock, pets, leaking sewer lines, and leaking septic 

tanks. 

Wildlife 

Wildlife deposit coliform bacteria with their feces onto land surfaces, where they can be 

transported during storm events to nearby streams. Some wildlife (such as otters, beavers, 

raccoons, and birds) deposit their feces directly into the water. The bacterial load from naturally 

occurring wildlife is assumed to be background. In addition, any strategy employed to control 

this source would probably have a negligible impact on attaining water quality standards. 

Agricultural Animals 

Agricultural animals are the source of several types of coliform bacteria loading to streams. 

Agricultural activities, including runoff from pastureland and cattle in streams, can affect water 

quality. A review of the land use categories found no Florida Land Use Cover Classification 

System (FLUCCS) codes involving animal feeding operations, or specialty farms that contain 

animals. 

Land Uses 

The spatial distribution and acreage of different land use categories were identified using the 

SWFWMD 2004 land use coverage (scale 1:40,000) contained in FDEP’s geographic 

information system (GIS) library. Land use categories in Saint Joes Creek were aggregated 

using the simplified Level 1 codes (Table 4.1). Figure 4.1 shows the acreage of the principal 

land uses draining into the main channel and Miles Creek tributary, which make up the 
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Florida Department of Environmental Protection 

watershed area in this segment. The urban and built-up category predominates, covering about 

97 percent of the total area, with residential areas making up 73 percent of the total. The 

agricultural land uses (0.1 percent) are associated with nurseries, which are not typically 

sources of fecal coliform bacteria. 

Table 4.1. Classification of 2004 Land Use Categories in Saint 

Joes Creek, WBID 1668A 

FLUCCS 

Code Land Use Acreage Percentage of Total 

1000 Recreational and Open Land 66 1% 

1100 Residential Low Density < 2 Dwelling Units/Acre 52 1% 

1200 Residential Medium Density 2-5 Dwelling Units/Acre 33 1% 

1300 Residential High Density 6 or more Dwelling Units/Acre 4,159 71% 

1400 Commercial 615 11% 

1500 Industrial 293 5% 

1700 Institutional 252 4% 

2000 Agricultural 3 0.1% 

4000 Forests 3 0.1% 

5000 Water 102 2% 

6000 Wetlands 8 0.1% 

8000 Transportation, Communication and Utilities 263 4% 

Totals 5,847 100% 
TMDL Report: Saint Joes Creek, WBID 1668A, Springs Coast Basin, Fecal Coliform 

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Florida Department of Environmental Protection 

Figure 4.1. Principal Land Uses in Saint Joes Creek, WBID 1668A, in 2004 
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Florida Department of Environmental Protection 

Urban Development 

Coliform bacteria loading from urban areas is attributable to multiple sources, including 

stormwater runoff, leaks and overflows from sanitary sewer systems, illicit discharges of sanitary 

waste, runoff from improper disposal of waste materials, leaking septic systems, and domestic 

animals. 

Since nearly 73 percent of the land area in the watershed is residential, it is possible that pets, 

especially dogs, are affecting coliform bacteria levels in Saint Joes Creek. FDEP obtained data 

on the number of dogs and cats in the area from the Pinellas County Animal Service 

Department (Pinellas County Environmental Management, November 2007); using these 

estimates, the coliform loading from dogs and cats may be estimated (Table 4.2), Assuming 

that 10 percent of coliforms reach the waterbody and are viable upon reaching it, the 

approximate total loading is 4.23 x 1012 organisms/day. 

Table 4.2. Estimated Coliform Loading from Dogs and Cats in Saint 

Joes Creek, WBID 1668A 

Pet 

Estimated 

Number of 

Pets in 

WBID 

1668A 

Estimated 

Loading 

of Total 

Estimated 

Number of 

Pets with 

Impact to 

WBID 

Estimated 

Counts/Pet/Day1 Estimated Counts/Day 

Dogs 5,533 10% 553 5.0 x 109 2.77 x 1012

Cats 2,917 10% 292 5.0 x 109 1.46 x 1012

1 From the EPA document, Protocol for Developing Pathogen TMDLs, January 2001, pp. 5-7. 

Population 

According to the U.S. Census Bureau, the population density in Pinellas County in 2006 was at 

or less than 3,302.4 persons per square mile (Table 4.3). The U.S. Census Bureau reports that 

the total population in 2006 for Pinellas County, which includes (but is not exclusive to) WBID 

1668A, was 924,413, with 495,191 housing units (2005 estimate). For all of Pinellas County, 

the bureau reported a housing unit density of 1,769 housing units per square mile. Pinellas 

County is above the average housing unit density of Florida of 153 housing units per square 

mile. In the Saint Joes Creek area, the estimated population density is about 4,163 people per 

square mile (U.S. Census Bureau for the city of St Petersburg). See Figure 4.2 for a U.S. 

Census Bureau map of the area. 
TMDL Report: Saint Joes Creek, WBID 1668A, Springs Coast Basin, Fecal Coliform 

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Florida Department of Environmental Protection 

Table 4.3. Population Density in Pinellas County, Florida, in 2006 

Persons per 

Square Mile

Total 

Population 

Housing Units 

per Square Mile Housing Units 

3,302 924,413 1769 495,191 

Source: U.S. Census Bureau State & County QuickFacts Website, 2007. Available: 

http://quickfacts.census.gov/qfd/states/12/12103.html. 

y 

Figure 4.2. Population Density in the Area of Saint Joes Creek, WBID 

1668A, in 2006 

Septic Tanks 

According to the city of St. Petersburg and Pinellas County Utilities’ websites and sewer service 

maps, nearly all of the residences are connected to the sanitary sewer system, virtually 

eliminating septic tank effluent as a potential source to the creek. According to Pinellas Count

Utilities’ Engineering Division, the area of WBID 1668A north of 38th Ave. in St. Petersburg is 

entirely served by sanitary sewers that connect to the South Cross Bayou Water Reclamation 
TMDL Report: Saint Joes Creek, WBID 1668A, Springs Coast Basin, Fecal Coliform 

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Florida Department of Environmental Protection 

Facility (WRF). The area south of 38th Ave. is sewered by the city of St. Petersburg and is 

connected to all four of the city’s wastewater treatment and WRFs. 

Domestic Sludge 

When domestic wastewater is treated, the solid material that accumulates in the wastewater 

treatment plant must be removed periodically to keep the plant operating properly. The 

collected material, called “residuals,” “biosolids,” or more commonly, “sewage sludge,” is the 

byproduct of these processes. The land application of sludge from domestic WWTFs is a 

potential source of coliform bacteria loading to surrounding surface waters. 

There are no known residual land application sites in the Saint Joes Creek watershed. Pinellas 

County Utilities’ South Cross Bayou WRF produces Class AA sludge residual. Class AA 

residuals (highest quality) are treated to eliminate pathogens and meet strict pollutant criteria. 

As a result, they may be used without restriction and may be sold to the public. Certain Class 

AA products are found in stores and garden centers. The city of St Petersburg’s domestic 

facilities distribute their sludge residuals outside of Pinellas County. 

Reclaimed Water Usage 

Wastewater treatment plants with the ability to reuse effluent for irrigation are called WRFs. All 

of the four St Petersburg facilities and the South Cross Bayou wastewater treatment plants are 

WRFs. The effluent is reused as irrigation water for parks, golf courses and other sport fields, 

parks, cemeteries, and other open spaces where water irrigation is needed or beneficial. The 

effluent may also be used for industrial applications (e.g., closed circuit cooling systems). 

The effluent, although of good water quality, is not potable, and direct human contact should be 

avoided or at least minimized for public health and safety. It is disinfected for fecal coliform 

destruction, tested daily, and stored prior to land application reuse. Effluent is not applied 

during rain events to preclude runoff to waterbodies. The permitted effluent limitation for 75 

percent of fecal coliform values is “below detection limits,” and “any one sample shall not 

exceed 25 fecal coliform values per 100 mL of sample.” 

All of the WRFs have a master reuse plan identifying permitted areas for irrigation and 

distribution. Some of the reclaimed water users are within the Saint Joes Creek watershed. 

The ground water is monitored periodically for fecal coliform bacteria. There is one monitoring 

well in WBID 1668A (St. Petersburg MWC-01). A review of the sampling results revealed that 

nearly all of the fecal coliform values were reported as “non-detect.” 
TMDL Report: Saint Joes Creek, WBID 1668A, Springs Coast Basin, Fecal Coliform 

16 

Florida Department of Environmental Protection 

Chapter 5: DETERMINATION OF ASSIMILATIVE 

CAPACITY 

5.1 Method Used To Determine Loading Capacity 

The methodology used for this TMDL is the “load duration curve.” Also known as the “Kansas 

Approach” because it was developed by the state of Kansas (Stiles, 2002), this method has 

been well documented in the literature, with improved modifications used by the EPA, Region 4. 

Basically, the method relates the pollutant concentration to the flow of the stream to establish 

the existing loading capacity and the allowable pollutant load (TMDL) under a spectrum of flow 

conditions. It then determines the maximum allowable pollutant load and load reduction 

requirement based on the analysis of the critical flow conditions. Using this method, it takes five 

steps to develop the TMDL and establish the required load reduction: 

1. Identify available flow and water quality data, 

2. Develop the flow duration curve, 

3. Develop the load duration curve for the existing loading, 

4. Define the critical conditions, and 

5. Establish the needed load reduction by comparing the existing loading with the allowable 

load under critical conditions. 

5.2 Data Used in the Determination of Loading Capacity 

Fecal coliform bacteria concentrations and flow measurements were used to estimate both the 

allowable and existing coliform loads. TMDLs for fecal coliform bacteria are being developed for 

both the Saint Joes Creek main channel and Miles Creek because the number of criterion 

exceedances in each channel meet the IWR verified impaired listing requirements. 

The primary collectors of water quality data in the watershed are the Pinellas County Watershed 

Management Division and FDEP. For the main channel of Saint Joes Creek, Pinellas County 

STORET stations include two 21FLPDEM35 stations: -10, and -11. FDEP’s (Southwest 

District) main channel stations include five 21FLTPA STORET Stations: -27483438243412, 

-27483668242429, -27484788240469, -2727485048241453, and -27485898241143. For the 

Miles Creek tributary to Saint Joes Creek, the Pinellas County Watershed Management Division 

samples at STORET Station 21FLPDEM35-12 were included in the analysis. 

Figure 1.2 shows the locations of these sampling sites, while Table 2.2 provides a statistical 

overview of the observed data at the sites. Figure 2.1 displays the data for fecal coliform 

bacteria used in this analysis, and Appendix A lists the water quality monitoring results for fecal 

coliform bacteria. 

Flow measurements for TMDL development were obtained from a U.S. Geological Survey 

(USGS) gaging station located on Saint Joes Creek (USGS 02308935, at Pinellas Park, Florida, 

Latitude 27°48'50", Longitude 82°41'45" (Figure 1.2). The flow data from this gage were 

selected for this analysis because most of the fecal coliform data were collected at or near the 

gage site, and flows were measured and recorded during the verified period. 
TMDL Report: Saint Joes Creek, WBID 1668A, Springs Coast Basin, Fecal Coliform 

17 

Florida Department of Environmental Protection 

5.3 TMDL Development Process 

The range of flows from the USGS flow gage was divided into “flow zones.” The concept of 

zones is adopted from Dr. Bruce Cleland (Cleland, August 15, 2002, and September 2003). The 

purpose of the zones is to demarcate hydrologic conditions between drought and peak flood into 

flow ranges such as low, dry, average, moist, and high. 

Expressing the flows in terms of frequency of recurrence (duration) allows exceedances of the 

criterion to be linked to specific flow intervals and durations. For example, if all of the 

exceedances occurred during low-flow conditions, point sources of the pollutant would be 

suspected. Conversely, if all the exceedances took place during higher-flow periods, then 

nonpoint sources of the pollutant would be suspected. 

Following Cleland’s approach (Cleland, September 2003), FDEP selected the following flow 

zones: “High” (0–10), “Moist” (11–40), “Mid-range” (41–60), “Dry” (61–90), and “Low” (91–100). 

To develop the flow duration curves and load duration curves for both the Saint Joes Creek 

main channel and Miles Creek, the daily flow at the downstream end of each channel was 

estimated by multiplying the gage flow by the ratio of each channel’s watershed drainage area 

to the gage drainage area. Figure 5.1.a and Figure 5.1.b present the flow duration curves for 

the Saint Joes Creek main channel and Miles Creek watersheds, respectively. 

Using the flows from the flow duration curves, load duration curves for fecal coliform bacteria 

(Figure 5.2.a and Figure 5.2.b) were calculated using the following equation: 

(1) (observed flow) x (conversion factor) x (state criteria) = ([parameter 

quantity]/day or daily load) 

The equation above yields the load duration curve or allowable load curve, shown as the fecal 

coliform target lines in Figure 5.2.a and Figure 5.2.b. Using Equation 1 (above), a table of fecal 

coliform loads exceeding the load target were calculated, substituting the observed coliform 

exceedances for the state criterion value (Table 5.1.a and Table 5.1.b). All the fecal coliform 

observations were then plotted, and it was noted where the samples were in relation to the 

allowable load curve (above or below the curve). Those above the curves in Figure 5.2.a and 

Figure 5.2.b are noted as exceedances to the state criterion, and are indicated by a red triangle. 
TMDL Report: Saint Joes Creek, WBID 1668A, Springs Coast Basin, Fecal Coliform 

18 

Florida Department of Environmental Protection 

Flow Duration Curve Main Channel

0.1

1

10

100

1000

0 5 10 14 19 24 29 33 39 43 47 52 57 64 67 76 78 85 85 91 94

Flow Duration Interval

Flow (cfs)

Figure 5.1.a. Flow Duration Curve for Saint Joes Creek, Main Channel, 

2000–06 (Estimated Flow) 

Flow Duration Curve Miles Creek

0.1

1.0

10.0

100.0

1000.0

0 5 10 14 19 23 28 32 37 42 47 51 56 61 66 70 76 78 86 88 92 96

Flow Duration Interval

Flow (cfs)

Figure 5.1.b. Flow Duration Curve for Miles Creek, 2000–06 (Estimated 

Flow) 
TMDL Report: Saint Joes Creek, WBID 1668A, Springs Coast Basin, Fecal Coliform 

19 

Florida Department of Environmental Protection 

Fecal Coliform Load in Saint Joes Creek Main Stream

y = (7 x 1013)x -1.7252

R 2 = 0.82

1.E+07

1.E+08

1.E+09

1.E+10

1.E+11

1.E+12

1.E+13

0 10 20 30 40 50 60 70 80 90 100

Duration Interval

Load (CFU/day)

Fecal Coliform Target Non-Exceedances Exceedances Power (Exceedances)

High Flows Moist Conditions Mid Range Flows Dry Conditions Low 

Flows

Figure 5.2.a. Load Duration Curve for Fecal Coliform in Saint Joes Creek, 

Main Channel, WBID 1668A 
TMDL Report: Saint Joes Creek, WBID 1668A, Springs Coast Basin, Fecal Coliform 

20 

Florida Department of Environmental Protection 

Fecal Coliform Load in Miles Creek

1.E+07

1.E+08

1.E+09

1.E+10

1.E+11

1.E+12

1.E+13

1.E+14

0 10 20 30 40 50 60 70 80 90 100

Duration Interval

Load (CFU/day)

Non Exceedances Exceedances Fecal Coliform Target Power (Exceedances)

High

Flows Moist Conditions Mid Range 

Flows

Dry 

Conditions

Low 

Flows

y = (4 x 1015)x -27799

R 2 = 0.97

Figure 5.2.b. Load Duration Curve for Fecal Coliform in Miles Creek, WBID 

1668A 
TMDL Report: Saint Joes Creek, WBID 1668A, Springs Coast Basin, Fecal Coliform 

21 

Florida Department of Environmental Protection 

Table 5.1.a. Observed Fecal Coliform Data for Calculating 

 Exceedances to the State Criterion for Saint 

 Joes Creek, Main Channel, WBID 1668A 

Fecal Coliform Station Sample 

Date 

Flow 

(cfs) 

Flow 

Rank 

(%) 

Fecal 

Coliform 

(CFU/100mL) 

Fecal Coliform 

Load 

(CFU/day) 

21FLTPA 

27485898241143 11/15/2004 4.61 48.2 944 1.06 x 1011

21FLTPA 

27484788240469 11/15/2004 4.61 48.2 416 4.69 x 1010

21FLPDEM35-10 7/5/2005 4.21 52.2 1,400 1.44 x 1011

21FLPDEM35-11 7/5/2005 4.21 52.2 650 6.69 x 1010

21FLPDEM35-11 8/15/2005 14.63 17.2 3,500 1.25 x 1012

21FLPDEM35-10 8/15/2005 14.63 17.2 3,500 1.25 x 1012

21FLPDEM35-11 9/19/2005 2.61 77.9 640 4.08 x 1010

21FLPDEM35-10 9/19/2005 2.61 77.9 500 3.19 x 1010

21FLPDEM35-10 10/31/2005 2.20 85.4 920 4.96 x 1010

21FLPDEM35-11 10/31/2005 2.20 85.4 460 2.48 x 1010

21FLPDEM35-10 4/10/2006 13.43 18.9 1,300 4.27 x 1011

21FLPDEM35-11 4/10/2006 13.43 18.9 420 1.38 x 1011

21FLPDEM35-11 5/10/2006 15.23 16.1 1,400 5.22 x 1011

21FLPDEM35-10 5/10/2006 15.23 16.1 1,000 3.73 x 1011

Note: Flow and concentration data analyzed for the TMDL were from March 2004 through May 2006. The 

Group 5 verification period is from January 1, 1999, through June 30, 2006. Flow data were estimated using 

flow data from USGS Gage 02308935, located in WBID 1668A. 

cfs – cubic feet per second. 

CFU – colony-forming units 
TMDL Report: Saint Joes Creek, WBID 1668A, Springs Coast Basin, Fecal Coliform 

22 

Florida Department of Environmental Protection 

Table 5.1.b. Observed Fecal Coliform Data for Calculating 

Exceedances to the State Criterion for Miles 

Creek, WBID 1668A 

Station Sample 

Date 

Flow 

(cfs) 

Flow 

Rank 

(%) 

Fecal 

Coliform 

(CFU/100mL) 

Fecal 

Coliform 

Load 

(CFU/day) 

21FLPDEM35-12 1/19/2005 1.04 94.4 560 1.43 x 1010

21FLPDEM35-12 3/3/2005 0.16 99.7 2,100 8.10 x 109

21FLPDEM35-12 4/14/2005 2.36 69 620 3.59 x 1010

21FLPDEM35-12 5/19/2005 1.04 94.4 440 1.12 x 1010

21FLPDEM35-12 7/5/2005 3.31 52.2 860 6.97 x 1010

21FLPDEM35-12 8/15/2005 11.5 17.2 5,300 1.49 x 1012

21FLPDEM35-12 10/31/2005 1.73 85.4 660 2.80 x 1010

21FLPDEM35-12 3/2/2006 4.73 38.9 690 7.98 x 1010

21FLPDEM35-12 5/10/2006 12 16.1 7,300 2.14 x 1012

Note: Flow and concentration data analyzed for the TMDL were from January 2005 through May 2006. 

The Group 5 verification period is from January 1, 1999, through June 30, 2006. Flow data were 

estimated using flow data from USGS Gage 02308935, located in WBID 1668A. 

As noted previously, values on the load duration curve can generally be grouped by hydrologic 

conditions to identify the most likely potential sources. Exceedances falling into the 10th through 

40th percentile flows are typically associated with moist conditions when stormwater loads are 

the most likely source, and exceedances falling into the 60th through 90th percentiles are typically 

associated with dry conditions when point sources are likely the dominant source. As shown in 

Figure 5.2.a, the fecal coliform exceedances in the Saint Joes Creek main channel are nearly 

distributed equally within the 10th to 40th percentile, 40th to 60th percentile, and 60th to 90th

percentile of flows, with no exceedances within the 0 to 10th or 90th to 100th percentiles. For 

Miles Creek, as shown in Figure 5.2.b, exceedances occur during most hydrologic conditions 

except for the very highest flows (0 to 10th percentile). 

Table 5.2.a and Table 5.2.b depict the allowable fecal coliform bacteria load for peak flow, low 

flow, and 5-percentile increments in flow for the Saint Joes Creek main channel and Miles 

Creek, respectively. The tables were created by taking the Nth-percentile flow (flow rank in the 

table) from the measured flow data and multiplying each percentile flow by the fecal coliform 

criterion of 400 counts/100mL and converting into bacteria counts/day. This conversion was 

accomplished by multiplying the criterion by [(28317/100)*60*60*24]. The factor 28317/100 

converts counts/100mL into counts per cubic foot, and the 60*60*24 converts seconds to days. 
TMDL Report: Saint Joes Creek, WBID 1668A, Springs Coast Basin, Fecal Coliform 

23 

Florida Department of Environmental Protection 

Finally, the actual needed load reduction for compliance with the state criterion was calculated 

using the following equation: 

 (2) (existing load) – (allowable load) X 100 

 (existing load) 

On the load duration curve, all points higher than the allowable load were considered an 

exceedance of the fecal coliform criterion. A regression analysis was performed to determine 

the best correlation for the exceedances. The existing loading of a given flow duration interval 

was calculated using the regression equation displayed in Figure 5.2.a for Saint Joes Creek, 

and Figure 5.2.b for Miles Creek, and a given flow duration interval between the 10th and 90th

percentile, in 5-percentile increments. The allowable loading of a given flow duration interval 

was calculated using Equation (1), within the flow duration interval with 5-percentile increments. 

Using Equation (2), the load reduction was determined for each flow interval. Table 5.3.a and 

Table 5.3.b list the flow duration intervals, allowable loadings, existing loadings, and needed 

load reductions for fecal coliform bacteria for Saint Joes Creek and Miles Creek, respectively. 

5.4 Critical Conditions/Seasonality 

The critical conditions for coliform loadings in a given watershed depend on the existence of 

point sources and land use patterns in the watershed. Typically, the critical condition for 

nonpoint sources is an extended dry period, followed by a rainfall runoff event. During wet 

weather periods, coliform bacteria that have built up on the land surface under dry weather 

conditions are washed off by rainfall, resulting in wet weather exceedances. However, 

significant nonpoint source contributions could also occur under dry weather conditions without 

any major surface runoff event. This usually happens when nonpoint sources contaminate the 

surficial aquifer, and coliform bacteria are brought into the receiving waters through baseflow. 

Animals with direct access to the receiving water could also contribute to the exceedances 

during dry weather conditions. The critical condition for point source loading typically occurs 

during periods of low stream flow, when dilution is minimized.
TMDL Report: Saint Joes Creek, WBID 1668A, Springs Coast Basin, Fecal Coliform 

24 

Florida Department of Environmental Protection 

Table 5.2.a. Fecal Coliform Target Loads for Flow, Saint 

 Joes Creek, Main Channel 

Allowable Loads 

Flow Rank 

Flow 

Rank 

(%) 

Flow 

(cfs) 

Fecal Coliform 

Load 

(counts/day) 

Flow 

Conditions 

0.04% 414.81 4.06 x 1012 Peak 

0.10% 291.48 2.85 x 1012

0.27% 231.21 2.26 x 1012 1-day 

1% 1 110.04 1.08 x 1012

5% 5 35.17 3.44 x 1011

10% 10 22.04 2.16 x 1011

15% 15 15.83 1.55 x 1011

20% 20 12.42 1.22 x 1011

25% 25 9.82 9.61 x 1010

30% 30 8.02 7.84 x 1010

35% 35 6.61 6.47 x 1010

40% 40 5.61 5.49 x 1010

45% 45 5.01 4.90 x 1010

50% 50 4.21 4.12 x 1010

55% 55 3.81 3.73 x 1010

60% 60 3.41 3.33 x 1010

65% 65 3.21 3.14 x 1010

70% 70 2.81 2.75 x 1010

75% 75 2.81 2.75 x 1010

80% 80 2.40 2.35 x 1010

85% 85 2.20 2.16 x 1010

90% 90 1.72 1.69 x 1010

95% 95 1.11 1.09 x 1010

99% 99 0.32 3.16 x 109

100% 100 0.06 5.88 x 108 Low 
TMDL Report: Saint Joes Creek, WBID 1668A, Springs Coast Basin, Fecal Coliform 

25 

Florida Department of Environmental Protection 

Table 5.2.b. Fecal Coliform Target Loads for Flow, Miles Creek 

Allowable Loads 

Flow Rank Flow 

Rank (%) 

Flow 

(cfs) 

Fecal Coliform 

Load 

(counts/day) 

Flow 

Conditions 

0.04% 326.33 3.19 x 1012 Peak 

0.10% 229.31 2.24 x 1012

0.27% 181.89 1.78 x 1012 1 - Day 

1% 1 86.56 8.47 x 1011

5% 5 27.67 2.71 x 1011

10% 10 17.34 1.70 x 1011

15% 15 12.45 1.22 x 1011

20% 20 9.77 9.57 x 1010

25% 25 7.72 7.56 x 1010

30% 30 6.31 6.17 x 1010

35% 35 5.20 5.09 x 1010

40% 40 4.41 4.32 x 1010

45% 45 3.94 3.86 x 1010

50% 50 3.31 3.24 x 1010

55% 55 3.00 2.93 x 1010

60% 60 2.68 2.62 x 1010

65% 65 2.52 2.47 x 1010

70% 70 2.21 2.16 x 1010

75% 75 2.21 2.16 x 1010

80% 80 1.89 1.85 x 1010

85% 85 1.73 1.70 x 1010

90% 90 1.36 1.33 x 1010

95% 95 0.87 8.55 x 109

99% 99 0.25 2.48 x 109

100% 100 0.05 4.63 x 108 Low 
TMDL Report: Saint Joes Creek, WBID 1668A, Springs Coast Basin, Fecal Coliform 

26 

Florida Department of Environmental Protection 

Table 5.3.a. Fecal Coliform Percentage Reductions Required 

 for Saint Joes Creek, Main Channel 

Flow 

Ranking 

(%) 

Allowable Load 

(colonies/day) 

Existing Load 

(colonies/day) 

% Reduction 

Required 

10 2.16 x 1011 1.32 x 1012 83.6 

15 1.55 x 1011 6.55 x 1011 76.3 

20 1.22 x 1011 3.99 x 1011 69.5 

25 9.61 x 1010 2.71 x 1011 64.6 

30 7.84 x 1010 1.98 x 1011 60.4 

35 6.47 x 1010 1.52 x 1011 57.4 

40 5.49 x 1010 1.21 x 1011 54.5 

45 4.90 x 1010 9.84 x 1010 50.2 

50 4.12 x 1010 8.20 x 1010 49.8 

55 3.73 x 1010 6.96 x 1010 46.5 

60 3.33 x 1010 5.99 x 1010 44.3 

65 3.14 x 1010 5.22 x 1010 39.9 

70 2.75 x 1010 4.59 x 1010 40.2 

75 2.75 x 1010 4.08 x 1010 32.6 

80 2.35 x 1010 3.65 x 1010 35.5 

85 2.16 x 1010 3.28 x 1010 34.3 

90 1.69 x 1010 2.98 x 1010 43.3 

Median 4.12 x 1010 8.20 x 1010 49.8 
TMDL Report: Saint Joes Creek, WBID 1668A, Springs Coast Basin, Fecal Coliform 

27 

Florida Department of Environmental Protection 

Table 5.3.b. Fecal Coliform Percentage Reductions Required for 

 Miles Creek 

Flow Ranking 

(%) 

Allowable Load 

(colonies/day) 

Existing Load 

(colonies/day) 

% Reduction 

Required 

10 1.70 x 1011 6.64 x 1012 97.4 

15 1.22 x 1011 2.15 x 1012 94.3 

20 9.57 x 1010 9.67 x 1011 90.1 

25 7.56 x 1010 5.20 x 1011 85.5 

30 6.17 x 1010 3.13 x 1011 80.3 

35 5.09 x 1010 2.04 x 1011 75.0 

40 4.32 x 1010 1.41 x 1011 69.3 

45 3.86 x 1010 1.01 x 1011 62.0 

50 3.24 x 1010 7.57 x 1010 57.2 

55 2.93 x 1010 5.81 x 1010 49.5 

60 2.62 x 1010 4.56 x 1010 42.5 

65 2.47 x 1010 3.65 x 1010 32.4 

70 2.16 x 1010 2.97 x 1010 27.3 

75 2.16 x 1010 2.45 x 1010 11.9 

80 1.85 x 1010 2.05 x 1010 9.7 

85 1.70 x 1010 1.73 x 1010 2.0 

90 1.33 x 1010 1.48 x 1010 10.2 

Median 3.24 x 1010 5.81 x 1010 57.2 

As shown in Figure 5.2.a and Figure 5.2.b, exceedances of fecal coliform bacteria in the 

Saint Joes Creek watershed appeared during nearly all flow regimes. In general, exceedances 

on the right side of the curve typically occur during low-flow events, implying a contribution from 

either point sources or baseflow. In contrast, exceedances on the left side of the curve usually 

represent potential sources accumulated on the land surface that could result from the land 

application of biosolids, wildlife, livestock, and pets. As discussed in Chapter 4, there are no 

active permitted facility discharges of fecal coliform loads directly into Saint Joes Creek, WBID 

1668A; therefore, nonpoint sources are the contributory sources to the fecal coliform bacteria 

load. 
TMDL Report: Saint Joes Creek, WBID 1668A, Springs Coast Basin, Fecal Coliform 

28 

Florida Department of Environmental Protection 

Chapter 6: DETERMINATION OF THE TMDL 

6.1 Expression and Allocation of the TMDL 

The objective of a TMDL is to provide a basis for allocating acceptable loads among all of the 

known pollutant sources in a watershed so that appropriate control measures can be 

implemented and water quality standards achieved. A TMDL is expressed as the sum of all 

point source loads (wasteload allocations, or WLAs), nonpoint source loads (load allocations, or 

LAs), and an appropriate margin of safety (MOS), which takes into account any uncertainty 

concerning the relationship between effluent limitations and water quality: 

TMDL = ∑ WLAs + ∑ LAs + MOS

As discussed earlier, the WLA is broken out into separate subcategories for wastewater 

discharges and stormwater discharges regulated under the NPDES Program: 

TMDL ≅ ∑ WLAswastewater + ∑ WLAsNPDES Stormwater + ∑ LAs + MOS 

It should be noted that the various components of the revised TMDL equation may not sum up 

to the value of the TMDL because (a) the WLA for NPDES stormwater is typically based on the 

percent reduction needed for nonpoint sources and is also accounted for within the LA, and (b) 

TMDL components can be expressed in different terms (for example, the WLA for stormwater is 

typically expressed as a percentage reduction, and the WLA for wastewater is typically 

expressed as mass per day). 

WLAs for stormwater discharges are typically expressed as a percentage reduction because it 

is very difficult to quantify the loads from MS4s (given the numerous discharge points) and to 

distinguish loads from MS4s from other nonpoint sources (given the nature of stormwater 

transport). The permitting of stormwater discharges also differs from the permitting of most 

wastewater point sources. Because stormwater discharges cannot be centrally collected, 

monitored, and treated, they are not subject to the same types of effluent limitations as 

wastewater facilities, and instead are required to meet a performance standard of providing 

treatment to the “maximum extent practical” through the implementation of best management 

practices (BMPs). 

This approach is consistent with federal regulations (40 CFR § 130.2[I]), which state that TMDLs 

can be expressed in terms of mass per time (e.g., pounds per day), toxicity, or other 

appropriate measure. The fecal coliform bacteria TMDL for the Saint Joes Creek main 

channel and Miles Creek are expressed in terms of colonies per day for the overall TMDL and 

as a percent reduction for MS4 areas and other nonpoint sources to meet the applicable 

criterion. The TMDL represents the maximum daily fecal coliform load the river can assimilate 

and maintain the applicable fecal coliform bacteria criterion (Table 6.1). 
TMDL Report: Saint Joes Creek, WBID 1668A, Springs Coast Basin, Fecal Coliform 

29 

Florida Department of Environmental Protection 

Table 6.1. Fecal Coliform TMDL for Saint Joes Creek, WBID 

1668A 

WLA 

Channel TMDL TMDL 

(colonies/day) Wastewater 

(colonies/day) 

NPDES 

Stormwater 

(% reduction) 

LA 

(% 

reduction) 

MOS 

Saint Joes 

Main Channel 

Median 10th to 

90th Percentile 4.1 x 1010 N/A 50 50 Implicit 

Miles Creek Median 10th to 

90th Percentile 3.2 x 1010 N/A 57 57 Implicit 

N/A – Not applicable 

6.2 Load Allocation 

Based on a load duration curve approach similar to that developed by the state of Kansas

(Stiles, 2002), the load allocation for nonpoint sources in the Saint Joes Creek main channel is a 

50 percent reduction for all flow periods. For Miles Creek, the load allocation for nonpoint 

sources is a 57 percent reduction of instream coliform concentrations for all flow periods. 

It should be noted that the LA includes loading from stormwater discharges that are not part of 

the NPDES stormwater program (see Appendix B). 

6.3 Wasteload Allocation 

6.3.1 NPDES Wastewater Discharges 

As previously mentioned, there are no permitted domestic wastewater treatment facilities that 

discharge fecal coliform loads into the Saint Joes Creek main channel and Miles Creek. 

6.3.2 NPDES Stormwater Discharges 

The WLA for the Pinellas County, City of St Petersburg, and FDOT MS4 permits calls for 

reductions of 49.8 and 57.2 percent in current anthropogenic fecal coliform loading contributing 

to the criteria exceedances in the Saint Joes Creek’s main channel and Miles Creek, 

respectively. It should be noted that any MS4 permittee is only responsible for reducing the 

loads associated with stormwater outfalls that it owns or otherwise has responsible control over, 

and it is not responsible for reducing other nonpoint source loads in its jurisdiction. 

While the LA and WLA for fecal coliform bacteria have been expressed as the percent reduction 

needed to attain the applicable Class III criterion, it is the combined reductions from both 

anthropogenic point and nonpoint sources that will result in the required reduction of instream 

fecal coliform concentrations. However, it is not the intent of the TMDL to abate natural 

background conditions.
TMDL Report: Saint Joes Creek, WBID 1668A, Springs Coast Basin, Fecal Coliform 

30 

Florida Department of Environmental Protection 

6.4 Margin of Safety 

Consistent with the recommendations of the Allocation Technical Advisory Committee (FDEP, 

February 1, 2001), an implicit MOS was used in the development of this TMDL. An implicit 

MOS was provided by the conservative decisions associated with the analytical assumptions 

and the development of assimilative capacity, which only focuses on exceedances. An MOS 

was included in the TMDL by not allowing any exceedances of the state criterion, even though 

intermittent natural exceedances of the criterion would be expected and would be taken into 

account when determining impairment. Additionally, the implicit MOS is appropriate, as existing 

loads are based on instream coliform measurements. These measurements include decay 

processes occurring instream and do not represent the maximum load that can be applied to the 

land and transported to the stream during a rain event. 
TMDL Report: Saint Joes Creek, WBID 1668A, Springs Coast Basin, Fecal Coliform 

31 

Florida Department of Environmental Protection 

Chapter 7: NEXT STEPS: IMPLEMENTATION PLAN 

DEVELOPMENT AND BEYOND 

7.1 Basin Management Action Plan 

Following the adoption of this TMDL by rule, the next step in the TMDL process is to develop an 

implementation plan for the TMDL, referred to as the Basin Management Action Plan (BMAP). 

This document will be developed over the next year in cooperation with local stakeholders, who 

will attempt to reach consensus on detailed allocations and on how load reductions will be 

accomplished. The BMAP will include, among other things: 

• Appropriate load reduction allocations among the affected parties, 

• A description of the load reduction activities to be undertaken, including structural 

projects, nonstructural BMPs, and public education and outreach, 

• A description of further research, data collection, or source identification needed in 

order to achieve the TMDL, 

• Timetables for implementation, 

• Confirmed and potential funding mechanisms, 

• Any applicable signed agreement(s), 

• Local ordinances defining actions to be taken or prohibited, 

• Any applicable local water quality standards, permits, or load limitation agreements, 

• Milestones for implementation and water quality improvement, and 

• Implementation tracking, water quality monitoring, and follow-up measures. 

An assessment of progress toward the BMAP milestones will be conducted every five years, 

and revisions to the plan will be made as appropriate, in cooperation with basin stakeholders. 
TMDL Report: Saint Joes Creek, WBID 1668A, Springs Coast Basin, Fecal Coliform 

32 

Florida Department of Environmental Protection 

References 

City of St Petersburg Water Resources Department. June 7, 2007. Personal Communication. 

City of St Petersburg Water Resources Department Website. 2007. Available: 

http://www.stpete.org/water/index.htm. 

Cleland, B. August 15, 2002. TMDL development from the bottom up–Part II: Using load 

duration curves to connect the pieces. Washington, D.C.: America’s Clean Water 

Foundation. Available: http://www.in.gov/idem/programs/water/tmdl/bottomup.pdf. 

Cleland, B. September 2003. TMDL development from the bottom up–Part III: Duration curves 

and wet-weather assessments. Washington, D.C.: America’s Clean Water Foundation. 

Available: http://www.tmdls.net/tipstools/docs/TMDLsCleland.pdf. 

Florida Administrative Code. Chapter 62-302, Surface water quality standards. Available: 

https://www.flrules.org/gateway/chapterhome.asp?chapter=62-302. 

———. Chapter 62-303, Identification of impaired surface waters. Available: 

https://www.flrules.org/gateway/chapterhome.asp?chapter=62-303. 

Florida Department of Environmental Protection. February 1, 2001. A report to the Governor 

and the Legislature on the allocation of total maximum daily loads in Florida. Tallahassee, 

Florida: Bureau of Watershed Management. 

———. February 2005. Florida’s Total Maximum Daily Load Program: The first 5 years, A 

report to the Legislature and Governor. Tallahassee, Florida: Division of Watershed 

Management. Available: 

http://www.dep.state.fl.us/water/tmdl/docs/2005TMDL_Report_final_2-25-05.pdf. 

———. December 2007. Order adopting Verified List of impaired waters and delisting of 

waters. Tallahassee, Florida. Available: 

http://www.dep.state.fl.us/legal/Final_Orders/2007/dep07-1348,etal.pdf. 

———. June 2006. Water quality status report–Springs Coast. Tallahassee, Florida. 

Available: ftp://ftp.dep.state.fl.us/pub/water/basin411/springscoast/status/SpringCst.pdf. 

Florida Department of Health Website. 2007. Available: http://www.doh.state.fl.us/ and 

http://www.doh.state.fl.us/environment/OSTDS/statistics/ostdsstatistics.htm. 

Florida Watershed Restoration Act. Chapter 99-223, Laws of Florida. Available: 

http://election.dos.state.fl.us/laws/99laws/ch_99-223.pdf. 

Pinellas County Environmental Management, Watershed Management Division. November 

2007. Letter to U.S. Environmental Protection Agency. 

Pinellas County Utilities. May 29, 2007. Personal Communication. 

Pinellas County Utilities Website. 2007. Available: http://www.pinellascounty.org/utilities/. 
TMDL Report: Saint Joes Creek, WBID 1668A, Springs Coast Basin, Fecal Coliform 

33 

Florida Department of Environmental Protection 

Southwest Florida Water Management District GIS Data Website. 2007. Available: 

http://www.swfwmd.state.fl.us/data/gis/.

Stiles, T. 2002. A simple method to define bacteria TMDLs in Kansas. Topeka, Kansas: 

Kansas Department of Health and Environment. 

U.S. Census Bureau American FactFinder Website. 2007. Available: 

http://factfinder.census.gov/home/saff/main.html?_lang=en. 

U.S. Census Bureau State & County QuickFacts Website. 2007. Available: 

http://quickfacts.census.gov/qfd/states/12000.html. 

U.S. Environmental Protection Agency. 2007. Federal Clean Water Act. Available: 

http://www.law.cornell.edu/uscode/33/ch26.html. 

———. 1994. Nonpoint source pollution: The nation's largest water quality problem. Pointer 

No. 1. EPA-841-F-94-005. Available: http://www.epa.gov/owow/nps/facts/point1.htm. 

———. January 2001. Protocol for developing pathogen TMDLs, First Edition. Washington, 

D.C.: Office of Water. EPA 841-R-00-002. Available: 

http://www.epa.gov/owow/tmdl/pathogen_all.pdf. 

U.S. Geological Survey Website. 2007. Available: 

http://waterdata.usgs.gov/fl/nwis/dvstat/?format=sites_selection_links&search_site_no=0230

8935&referred_module=sw. 
TMDL Report: Saint Joes Creek, WBID 1668A, Springs Coast Basin, Fecal Coliform 

34 

Florida Department of Environmental Protection 

Appendices 

Appendix A.1: Summary of Monitoring Results for Fecal Coliform in Saint Joes 

Creek, Main Channel, WBID 1668A 

Station Sample 

Date 

Flow 

(cfs) 

Flow 

Rank 

Flow 

Rank 

(%) 

Fecal 

Coliform 

(CFU/100mL) 

Fecal 

Coliform 

Load 

(CFU/day) 

Remark 

Code 

21FLTPA 

27485048241453 3/29/2004 3.61 59.6% 59.6 30 2.65 x 109 B 

21FLTPA 

27485898241143 3/29/2004 3.61 59.6% 59.6 50 4.41 x 109 B 

21FLTPA 

27483438243412 3/29/2004 3.61 59.6% 59.6 180 1.59 x 1010

21FLTPA 

27484788240469 3/29/2004 3.61 59.6% 59.6 210 1.85 x 1010

21FLTPA 

27483668242429 3/29/2004 3.61 59.6% 59.6 310 2.74 x 1010

21FLTPA 

27484788240469 6/14/2004 46.09 3.7% 3.7 40 4.51 x 1010 B 

21FLTPA 

27485048241453 6/14/2004 46.09 3.7% 3.7 45 5.07 x 1010 B 

21FLTPA 

27483438243412 6/14/2004 46.09 3.7% 3.7 85 9.58 x 1010 B 

21FLTPA 

27483668242429 6/14/2004 46.09 3.7% 3.7 115 1.30 x 1011

21FLTPA 

27485048241453 9/20/2004 6.01 38.9% 38.9 1 1.47 x 108 K 

21FLTPA 

27485898241143 9/20/2004 6.01 38.9% 38.9 20 2.94 x 109 B 

21FLTPA 

27484788240469 9/20/2004 6.01 38.9% 38.9 40 5.88 x 109 B 

21FLTPA 

27483438243412 9/20/2004 6.01 38.9% 38.9 40 5.88 x 109 B 

21FLTPA 

27483668242429 9/20/2004 6.01 38.9% 38.9 55 8.09 x 109 B 

21FLTPA 

27484788240469 9/22/2004 6.81 34.4% 34.4 114 1.90 x 1010

21FLTPA 

27483668242429 11/15/2004 4.61 48.2% 48.2 300 3.38 x 1010

21FLTPA 

27485048241453 11/15/2004 4.61 48.2% 48.2 336 3.79 x 1010

21FLTPA 

27484788240469 11/15/2004 4.61 48.2% 48.2 416 4.69 x 1010

21FLTPA 

27485898241143 11/15/2004 4.61 48.2% 48.2 944 1.06 x 1011
TMDL Report: Saint Joes Creek, WBID 1668A, Springs Coast Basin, Fecal Coliform 

35 

Florida Department of Environmental Protection 

Station Sample 

Date 

Flow 

(cfs) 

Flow 

Rank 

Flow 

Rank 

(%) 

Fecal 

Coliform 

(CFU/100mL) 

Fecal 

Coliform 

Load 

(CFU/day) 

Remark 

Code 

21FLTPA 

27485048241453 12/13/2004 2.20 85.4% 85.4 15 8.09 x 108 B 

21FLTPA 

27483438243412 12/13/2004 2.20 85.4% 85.4 40 2.16 x 109 B 

21FLTPA 

27483668242429 12/13/2004 2.20 85.4% 85.4 50 2.70 x 109 B 

21FLTPA 

27485898241143 12/13/2004 2.20 85.4% 85.4 80 4.31 x 109 B 

21FLTPA 

27484788240469 12/13/2004 2.20 85.4% 85.4 25 1.35 x 109 B 

21FLTPA 

27483438243412 1/18/2005 0.96 95.8% 95.8 25 5.88 x 108 B 

21FLPDEM35-11 1/19/2005 1.32 94.4% 94.4 20 6.47 x 108

21FLPDEM35-10 1/19/2005 1.32 94.4% 94.4 100 3.24 x 109

21FLPDEM35-10 3/3/2005 0.20 99.7% 99.7 120 5.88 x 108 B 

21FLPDEM35-11 4/14/2005 3.01 69.0% 69 80 5.88 x 109 B 

21FLPDEM35-10 4/14/2005 3.01 69.0% 69 80 5.88 x 109 B 

21FLPDEM35-10 5/19/2005 1.32 94.4% 94.4 80 2.59 x 109 B 

21FLPDEM35-11 5/19/2005 1.32 94.4% 94.4 180 5.82 x 109 B 

21FLPDEM35-11 7/5/2005 4.21 52.2% 52.2 650 6.69 x 1010

21FLPDEM35-10 7/5/2005 4.21 52.2% 52.2 1,400 1.44 x 1011 B 

21FLPDEM35-11 8/15/2005 14.63 17.2% 17.2 3,500 1.25 x 1012 B 

21FLPDEM35-10 8/15/2005 14.63 17.2% 17.2 3,500 1.25 x 1012 B 

21FLPDEM35-10 9/19/2005 2.61 77.9% 77.9 500 3.19 x 1010

21FLPDEM35-11 9/19/2005 2.61 77.9% 77.9 640 4.08 x 1010

21FLPDEM35-11 10/31/2005 2.20 85.4% 85.4 460 2.48 x 1010

21FLPDEM35-10 10/31/2005 2.20 85.4% 85.4 920 4.96 x 1010

21FLPDEM35-11 11/16/2005 1.30 94.5% 94.5 28 8.92 x 108 B 

21FLPDEM35-10 11/16/2005 1.30 94.5% 94.5 57 1.82 x 109 B 

21FLPDEM35-10 1/19/2006 2.20 85.4% 85.4 43 2.32 x 109 B 

21FLPDEM35-11 1/19/2006 2.20 85.4% 85.4 120 6.47 x 109

21FLPDEM35-11 3/2/2006 6.01 38.9% 38.9 26 3.82 x 109 B 

21FLPDEM35-10 3/2/2006 6.01 38.9% 38.9 97 1.43 x 1010

21FLPDEM35-11 4/10/2006 13.43 18.9% 18.9 420 1.38 x 1011

21FLPDEM35-10 4/10/2006 13.43 18.9% 18.9 1,300 4.27 x 1011 B 

21FLPDEM35-10 5/10/2006 15.23 16.1% 16.1 1,000 3.73 x 1011

21FLPDEM35-11 5/10/2006 15.23 16.1% 16.1 1,400 5.22 x 1011 J 

Note: Flow and concentration data analyzed for the TMDL were from March 2004 through May 2006. The Group 5 verification 

period is from January 1, 1999, through June 30, 2006. Flow data were from USGS Gage 02308935, located in WBID 1668A on 

Saint Joes Creek. 

Bold fecal coliform numbers indicate measurements that exceeded the 400 criteria.cfs – cubic feet per second 

Remark Codes: B- Results based on colony counts outside the acceptable range 

 J – Estimated value 

 K – Actual value is known to be less than the value given 
TMDL Report: Saint Joes Creek, WBID 1668A, Springs Coast Basin, Fecal Coliform 

36 

Florida Department of Environmental Protection 

Appendix A.2: Summary of Monitoring Results for Fecal Coliform in Miles 

Creek, WBID 1668A 

Station Sample 

Date 

Estimated 

Flow 

(cfs) 

Flow Rank Flow Rank 

(%) 

Fecal Coliform 

(counts/100mL) 

Fecal 

Coliform 

Load 

(counts/day) 

Remark 

Code 

21FLPDEM35-12 1/19/2005 1.04 94.4% 94.4 560 1.43 x 1010

21FLPDEM35-12 3/3/2005 0.16 99.7% 99.7 2,100 8.10 x 109

21FLPDEM35-12 4/14/2005 2.36 69.0% 69.0 620 3.59 x 1010

21FLPDEM35-12 5/19/2005 1.04 94.4% 94.4 440 1.12 x 1010

21FLPDEM35-12 7/5/2005 3.31 52.2% 52.2 860 6.97 x 1010

21FLPDEM35-12 8/15/2005 11.51 17.2% 17.2 5,300 1.49 x 1012 B 

21FLPDEM35-12 9/19/2005 2.05 77.9% 77.9 400 2.01 x 1010

21FLPDEM35-12 10/31/2005 1.73 85.4% 85.4 660 2.80 x 1010

21FLPDEM35-12 11/16/2005 1.02 94.5% 94.5 86 2.16 x 109

21FLPDEM35-12 1/19/2006 1.73 85.4% 85.4 330 1.40 x 1010

21FLPDEM35-12 3/2/2006 4.73 38.9% 38.9 690 7.98 x 1010 B 

21FLPDEM35-12 5/10/2006 11.98 16.1% 16.1 7,300 2.14 x 1012 B 

Note: Flow and concentration data analyzed for the TMDL were from January 2005 through May 2006. The Group 5 verification 

period is from January 1, 1999, through June 30, 2006. Flow data was estimated using data from USGS Gage 02308935, located in 

WBID 1668A, on Saint Joes Creek. 

Bold fecal coliform numbers indicate measurements that exceeded the 400 criteria. 

Remark Codes: B- Results based on colony counts outside the acceptable range 

 J – Estimated value 

 K – Actual value is known to be less than the value given 
TMDL Report: Saint Joes Creek, WBID 1668A, Springs Coast Basin, Fecal Coliform 

37 

Florida Department of Environmental Protection 

Appendix B: Background Information on Federal and State 

Stormwater Programs 

In 1982, Florida became the first state in the country to implement statewide regulations to 

address the issue of nonpoint source pollution by requiring new development and 

redevelopment to treat stormwater before it is discharged. The Stormwater Rule, as authorized 

in Chapter 403, F.S., was established as a technology-based program that relies on the 

implementation of BMPs that are designed to achieve a specific level of treatment (i.e., 

performance standards) as set forth in Rule 62-40, F.A.C. 

The rule requires the state’s water management districts to establish stormwater pollutant load 

reduction goals (PLRGs) and adopt them as part of a Surface Water Improvement and 

Management (SWIM) plan, other watershed plan, or rule. Stormwater PLRGs are a major 

component of the load allocation part of a TMDL. To date, stormwater PLRGs have been 

established for Tampa Bay, Lake Thonotosassa, the Winter Haven Chain of Lakes, the 

Everglades, Lake Okeechobee, and Lake Apopka. 

In 1987, the U.S. Congress established Section 402(p) as part of the federal Clean Water Act 

Reauthorization. This section of the law amended the scope of the federal NPDES permitting 

program to designate certain stormwater discharges as “point sources” of pollution. The EPA 

promulgated regulations and began the implementation of the Phase I NPDES stormwater 

program in 1990. These stormwater discharges include certain discharges that are associated 

with industrial activities designated by specific standard industrial classification (SIC) codes, 

construction sites disturbing 5 or more acres of land, and master drainage systems of local 

governments with a population above 100,000, which are better known as MS4s. However, 

because the master drainage systems of most local governments in Florida are interconnected, 

the EPA implemented Phase I of the MS4 permitting program on a countywide basis, which 

brought in all cities (incorporated areas), Chapter 298 urban water control districts, and FDOT 

throughout the 15 counties meeting the population criteria. FDEP received authorization to 

implement the NPDES stormwater program in 2000. 

An important difference between the NPDES and other state stormwater permitting programs is 

that the NPDES Program covers both new and existing discharges, while the other state 

programs focus on new discharges. Additionally, Phase II of the NPDES Program, 

implemented in 2003, expands the need for these permits to construction sites between 1 and 5 

acres, and to local governments with as few as 1,000 people. While these urban stormwater 

discharges are now technically referred to as “point sources” for the purpose of regulation, they 

are still diffuse sources of pollution that cannot be easily collected and treated by a central 

treatment facility, as are other point sources of pollution such as domestic and industrial 

wastewater discharges. It should be noted that all MS4 permits issued in Florida include a 

reopener clause that allows permit revisions to implement TMDLs when the implementation plan 

is formally adopted. 
Florida Department of Environmental Protection 

Division of Water Resource Management 

Bureau of Watershed Management 

2600 Blair Stone Road, Mail Station 3565 

Tallahassee, Florida 32399-2400 

(850) 245-8555 

http://www.dep.state.fl.us/water/