Form for Compliance with E.O. 12866 Docket Requirements

Title of Regulation: Water Quality Standards for the State of Florida’s Estuaries, Coastal 

Waters, and South Florida Inland Flowing Waters

 

Contact person: Erica Fleisig 

Phone number: 202-566-1057 

Was this regulation reviewed by OMB under Executive Order 12866 - Regulatory Planning 

and Review?

X Yes No 

If you checked “no”, you are done with this form. Simply place it in the docket for your 

regulation. If you checked “yes”, please fill out the remainder of the form before placing it in 

the docket. Also docket any relevant documents referenced in the form.

For regulations that are checked “Yes” above:

This regulation was reviewed by OMB under Executive Order 12866 - Regulatory Planning and 

Review. 

Attached is the draft regulation and any other documents sent to OMB for review, such as 

analyses and assessments. E.O. 12866 requires agencies to make these publicly available.

E.O. 12866 also requires agencies to identify the substantive changes between the draft 

regulation sent to OMB for review and the regulation subsequently announced [Please check the 

appropriate box below:] 

 X EPA made substantive changes to this regulation

(includes changes initiated by EPA or OMB). 

Attached is a document which: (1) identifies all the substantive changes made, and (2) 

notes those changes OMB suggested or recommended.

 No substantive changes were made to this regulation

Therefore, no further attachments are required.

If you have questions about this regulation, please call the EPA contact person listed above.
Economic Analysis of Proposed Water Quality Standards for the State of 

Florida’s Estuaries, Coastal Waters, and South Florida Inland Flowing 

Waters

January 2012

Draft for Internal Review – Do Not Quote or Cite

U.S. Environmental Protection Agency

Office of Water

Office of Science and Technology

1200 Pennsylvania Avenue N.W.

Washington, D.C. 20460
January 2012 i

Draft for Internal Review Only-Do Not Quote or Cite

Table of Contents

Executive Summary.................................................................................................................................... 1

1 Introduction ...................................................................................................................................1-1

1.1 Requirement for the Proposed Rule.................................................................................................1-1

1.2 Purpose and Scope of the Analysis..................................................................................................1-1

1.3 Organization of this Report .............................................................................................................1-2

2 Baseline for the Analysis...............................................................................................................2-1

2.1 Current Regulatory Framework.......................................................................................................2-1

2.1.1 Water Quality Standards.......................................................................................................2-1

2.1.2 Restoration of Designated Uses in Impaired Waters ............................................................2-3

2.1.3 Existing Regulations for Point Source Dischargers..............................................................2-4

2.1.4 Existing Regulations for Urban Areas ..................................................................................2-6

2.1.5 Existing Requirements for Agriculture .................................................................................2-8

2.1.6 Existing Requirements for Forestry ....................................................................................2-13

2.1.7 Existing Requirements for Septic Systems.........................................................................2-13

2.1.8 Existing Requirements for Air Sources...............................................................................2-14

2.2 Existing Nutrient Discharges.........................................................................................................2-14

2.2.1 Wastewater Point Sources...................................................................................................2-14

2.2.2 Stormwater..........................................................................................................................2-16

2.2.3 Agriculture ..........................................................................................................................2-17

2.2.4 Septic Systems ....................................................................................................................2-17

2.2.5 Atmospheric Deposition .....................................................................................................2-17

2.3 Current Water Quality Impairments..............................................................................................2-18

2.3.1 Category 5 Waters on State 303(d) List..............................................................................2-18

2.3.2 Nutrient TMDLs .................................................................................................................2-19

2.4 Summary of Assumptions and Uncertainties ................................................................................2-23

2.4.1 Regulatory Framework .......................................................................................................2-23

2.4.2 Sources of Nutrients............................................................................................................2-24

2.4.3 Water Quality......................................................................................................................2-25

3 Description of the Proposed Rule.................................................................................................3-1

3.1 Proposed Criteria.............................................................................................................................3-1

3.1.1 Coastal Waters ......................................................................................................................3-1

3.1.2 Estuaries................................................................................................................................3-1

3.1.3 South Florida Marine Waters................................................................................................3-1

3.1.4 Downstream Protection Values.............................................................................................3-1
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3.1.5 Tidal Creeks..........................................................................................................................3-1

3.1.6 Marine Lakes.........................................................................................................................3-1

4 Potentially Incrementally Impaired Waters ...............................................................................4-1

4.1 Data .................................................................................................................................................4-1

4.2 Method.............................................................................................................................................4-2

4.3 Results.............................................................................................................................................4-3

4.3.1 Land Use Potentially Affected..............................................................................................4-4

5 Potential Costs for Municipal Wastewater Sources...................................................................5-1

5.1 Data .................................................................................................................................................5-1

5.2 Method.............................................................................................................................................5-1

5.2.1 Reasonable Potential.............................................................................................................5-1

5.2.2 Projected Effluent Limits......................................................................................................5-2

5.2.3 Potential Compliance Options...............................................................................................5-2

5.2.4 Potentially Affected Sources.................................................................................................5-5

5.2.5 Unit Control Costs ................................................................................................................5-7

5.2.6 Potential Total Costs.............................................................................................................5-8

6 Potential Costs for Industrial Wastewater Sources....................................................................6-1

6.1 Data .................................................................................................................................................6-1

6.2 Method.............................................................................................................................................6-2

6.2.1 Reasonable Potential.............................................................................................................6-2

6.2.2 Potential Compliance Options...............................................................................................6-2

6.2.3 Potential Control Costs .........................................................................................................6-5

7 Potential Costs to Urban Stormwater Sources ...........................................................................7-1

7.1 Data .................................................................................................................................................7-1

7.2 Method.............................................................................................................................................7-1

7.2.1 Required Controls.................................................................................................................7-1

7.2.2 Phase I MS4 Urban Land......................................................................................................7-2

7.2.3 Phase II MS4 Urban Land.....................................................................................................7-2

7.2.4 Urban Land Outside MS4s....................................................................................................7-3

7.2.5 Summary of Potentially Affected Area.................................................................................7-3

7.3 Potential Costs.................................................................................................................................7-4

8 Potential Costs to Agricultural Sources.......................................................................................8-1

8.1 Data .................................................................................................................................................8-1

8.2 Method.............................................................................................................................................8-1

8.3 Potential Costs.................................................................................................................................8-3
January 2012 iii

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9 Potential Costs for Septic Systems...............................................................................................9-1

9.1 Data .................................................................................................................................................9-1

9.2 Method.............................................................................................................................................9-1

9.3 Potential Costs.................................................................................................................................9-2

9.3.1 Unit Costs..............................................................................................................................9-2

9.3.2 Total Potential Costs.............................................................................................................9-3

10 Government Expenditures................................................................Error! Bookmark not defined.1

10.1 New TMDLs................................................................................................................................10-11

10.2 Site Specific Alternative Criteria.................................................................................................10-22

10.3 Ambient Monitoring....................................................................................................................10-22

11 Summary of Potential Costs.......................................................................................................11-1

12 Description of Benefits of Reducing Nutrient Loads to Florida Estuaries.............................12-1

12.1 Effect of Nutrients on Bays, Estuaries and Coasts........................................................................12-1

12.1.1 Ecological Effects..........................................................................................................12-1

12.1.2 Primary and Secondary Eutrophication Responses .......................................................12-3

12.1.3 Mitigating Factors..........................................................................................................12-4

12.2 Impacts of Nutrients on Environmental Goods and Services........................................................12-5

12.2.1 Impacts of Harmful Algal Blooms (HABs)...................................................................12-5

12.2.2 Impacts of Submerged Aquatic Vegetation Loss...........................................................12-5

12.2.3 Impacts of Degraded Water Quality ..............................................................................12-6

12.3 Types of Benefits Associated with Nutrient Reductions...............................................................12-6

12.3.1 Human Health Improvements........................................................................................12-7

12.3.2 Ecological Improvements..............................................................................................12-8

13 Potential Incremental Benefits of the Numeric Nutrient Criteria ..........................................13-1

13.1 Water Quality Index ......................................................................................................................13-1

13.1.1 Estimated Baseline Water Quality.................................................................................13-3

13.1.2 Estimated Water Quality from Attaining Criteria..........................................................13-7

13.1.3 Estimated Incremental Change in Water Quality due to the Proposed Rule .................13-7

13.2 Estimating Value of Water Quality Improvements.......................................................................13-8

13.2.1 Meta Analysis of Valuation Studies ..............................................................................13-9

13.2.2 Function Transfer to Proposed Rule ............................................................................13-10

13.2.3 Estimating Annual Household WTP for Water Quality Improvements......................13-12

13.2.4 Estimating Total WTP for Water Quality Improvements............................................13-14

13.3 Uncertainty and Limitations........................................................................................................13-15

14 References ....................................................................................................................................14-1
January 2012 iv

Draft for Internal Review Only-Do Not Quote or Cite

Appendix A. Proposed Numeric Nutrient Criteria ..........................................................................A-1

Appendix B. Municipal WWTP Cost Estimates ..............................................................................B-1

Appendix C. Sample Industrial Discharger Analyses......................................................................C-1

Appendix D. Analysis of Downstream Protection Values................................................................D-1
January 2012 v

Draft for Internal Review Only-Do Not Quote or Cite

List of Exhibits

Exhibit ES-1: NPDES-Permitted Wastewater Dischargers Potentially Affected by Proposed Rule............2

Exhibit ES-2: Acres Enrolled in FDACS BMP Program..............................................................................3

Exhibit ES-3: Summary of Potential Incremental Impairment under the Proposed Criteria ........................6

Exhibit ES-4: Potential Annual Costs Associated with Numeric Nutrient Criteria (2010 dollars) ............10

Exhibit ES-5: Types of Benefits Associated with Environmental Policies ................................................12

Exhibit ES-6: Potential Annual State Benefits Associated with the Proposed Criteria (Millions of 2010$)

............................................................................................................................................................13

Exhibit 2-1: Numeric Nutrient Criteria for Lakes and Flowing Waters in Florida....................................2-2

Exhibit 2-2: Plans Developed under the Northern Everglades and Estuaries Protection Program..........2-10

Exhibit 2-3: Federal Agricultural Assistance Programs by Acres Enrolled and Program Spending.......2-12

Exhibit 2-4: NPDES Dischargers with Numeric Effluent Limits and Monitoring Requirements for 

Nitrogen and Phosphorus in Florida1

...............................................................................................2-14

Exhibit 2-5: Summary of NPDES Dischargers in Florida Potentially Affected by Numeric Nutrient 

Criteria for Estuaries, Bays, and Coastal Waters1

............................................................................2-16

Exhibit 2-6: Summary of MS4 Stormwater Control Projects in Florida..................................................2-17

Exhibit 2-7: Summary of Agricultural Lands Enrolled in FDACS BMP Program .................................2-17

Exhibit 2-8: Summary of CWA Section 303(d) Listed Estuary Impairments for Nutrients in Florida1

..2-18

Exhibit 2-9: Summary of Nutrient-Related TMDLs for Estuaries and Coasts in Florida........................2-20

Exhibit 2-10: Map of Baseline WBID Impairments related to Nutrients in Florida................................2-23

Exhibit 4-1: Summary of Potential Incremental Impairments Under the Proposed Rule..........................4-3

Exhibit 4-2: Map of Potential Incremental Waters Not Attaining the Proposed Criteria ..........................4-4

Exhibit 4-3: Summary Land Use in Watersheds Surrounding Potential Incremental WBIDs of this 

Proposed Rule ....................................................................................................................................4-5

Exhibit 5-1: Comparison of Common BNR Configurations......................................................................5-3

Exhibit 5-2: Potential Treatment Required for Municipal Wastewater Treatment Plants.........................5-7

Exhibit 5-3: Unit Costs for BNR (2010 dollars)........................................................................................5-7

Exhibit 5-4: Summary of Potential Municipal WWTP Compliance Costs................................................5-8

Exhibit 5-5: Summary of Sensitivity Analysis for Potential Municipal WWTP Compliance Costs 

(millions 2010 dollars).......................................................................................................................5-9

Exhibit 6-1: Summary of Potentially Affected Industrial Dischargers......................................................6-1

Exhibit 6-2: Effectiveness of Common Removal Mechanisms for Reducing Various Fractions of Nitrogen 

and Phosphorus..................................................................................................................................6-3
January 2012 vi

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Exhibit 6-3: Estimated Statewide Annual Industrial Control Costs............ Error! Bookmark not defined.

Exhibit 7-1: Urban Land Area in Watersheds Surrounding Potential Incremental Waters not Attaining the 

Proposed Criteria ...............................................................................................................................7-1

Exhibit 7-2: Urban Land in Watersheds Surrounding Potential Incremental Impairments Potentially 

Needing Controls...............................................................................................................................7-3

Exhibit 7-3: Estimated Incremental Urban Stormwater Costs...................................................................7-4

Exhibit 8-1: Agricultural Land Use in Watersheds Draining to Potentially Incrementally Impaired WBIDs

...........................................................................................................................................................8-1

Exhibit 8-2: Example Agricultural BMP Program Elements for the Caloosahatchee River and St. Lucie 

River Watersheds...............................................................................................................................8-2

Exhibit 8-3: Total Acres Enrolled in FDACS BMP Program....................................................................8-3

Exhibit 8-4: Potential Agricultural Control Costs Associated with Incrementally Impaired Estuaries.....8-4

Exhibit 9-1: Summary of Estimated Upgraded Septic System Costs........................................................9-3

Exhibit 10-1: Summary of Estimated Government Expenditures............................................................10-2

Exhibit 11-1: Summary of Potential Annual Costs Associated with Numeric Nutrient Criteria (2010 

dollars).............................................................................................................................................11-1

Exhibit 11-2: Uncertainties of the Analysis.............................................................................................11-1

Exhibit 12-1: Eutrophication Impacts and Responses for Estuaries and Coastal Waters........................12-2

Exhibit 12-2: Types of Benefits Associated with Environmental Policies..............................................12-7

Exhibit 13-1: Comparison of Ranges of Numerical Scores Associated with Narrative Classes in Two WQI 

Systems............................................................................................................................................13-3

Exhibit 13-2: Percent Exceedence and Estimated Baseline WQI, TN.....................................................13-5

Exhibit 13-3: Percent Exceedence and Estimated Baseline WQI, TP .....................................................13-5

Exhibit 13-4: Percent Exceedence and Estimated Baseline WQI, Chl-a .................................................13-6

Exhibit 13-5: Estimated Percentage of Incrementally Impaired Coastal and Estuary Miles in FL by WQI 

Classifications..................................................................................................................................13-7

Exhibit 13-6: Total Potential Improved Coastal and Estuary WBIDs and Miles ....................................13-8

Exhibit 13-7: Independent Variable Assignments.................................................................................13-11

Exhibit 13-8: Average Annual Household Willingness to Pay for Water Quality Improvement in Florida 

Estuaries and Coastal Waters (2010$) Across all WBIDs.............................................................13-13

Exhibit 13-9: Total Annual State Benefits Associated with the Proposed Criteria (Millions of 2010$)...13-

14

Exhibit 13-10: Total Annual State Benefits Associated with the Proposed Criteria, Higher Baseline Water 

Quality Scenario (Millions of 2010$)............................................................................................13-15

Exhibit A-1: Proposed Chlorophyll-a Criteria for Coastal Waters...........................................................A-1
January 2012 vii

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Exhibit A-2: Proposed Nutrient Criteria for Estuaries..............................................................................A-2

Exhibit A-3: Proposed Nutrient Criteria for South Florida Marine Waters..............................................A-6

Exhibit B-1: Potential Costs to Municipal WWTPs for Compliance with Numeric Nutrient Criteria .....B-1

Exhibit C-1: Effluent Data Summary, Kinder Morgan Tampaplex Bulk Terminal1 ................................C-1

Exhibit C-2: Potential Incremental Costs, Kinder Morgan Tampaplex Bulk Terminal............................C-2

Exhibit C-3: Effluent Data Summary, Mosaic Fertilizer – Riverview Chemical Complex1 ....................C-3

Exhibit C-4: Potential Incremental Costs, Mosaic Fertilizer – Riverview Chemical Complex................C-4

Exhibit C-5: Effluent Data Summary, Trademark Nitrogen Corporation.................................................C-5

Exhibit C-6: Effluent Data Summary, Anheuser Busch Inc., Main Street Sod Farm...............................C-6

Exhibit C-7: Potential Incremental Costs, Anheuser Busch – Main Street Sod Farm..............................C-7

Exhibit C-8: Effluent Data Summary, Coca-Cola North America, Dunedin............................................C-8

Exhibit C-9: Potential Incremental Costs, Coca Cola North America - Dunedin.....................................C-9

Exhibit C-10: Effluent Data Summary, Tampa Phosphate Terminal and Warehouse............................C-11

Exhibit C-11: Potential Incremental Costs, Tampa Phosphate Terminal and Warehouse......................C-12

Exhibit C-12: Effluent Data Summary, YARA North America, Inc. .....................................................C-13

Exhibit C-13: Effluent Data Summary, Smurfit Stone - Fernandina Beach Mill ...................................C-18

Exhibit C-14: Potential Incremental Costs, Rayonier Performance Fibers, LLC...................................C-20

Exhibit C-15: Effluent Data Summary, Smurfit Stone - Seminole Mill.................................................C-21

Exhibit C-16: Potential Incremental Costs, Smurfit Stone – Seminole Mill ..........................................C-22

Exhibit D-1: Summary of Potential Incremental Costs Associated with DPVs .......................................D-2
January 2012 viii

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Acronyms and Abbreviations

A2

/O Anaerobic-anoxic oxidation

ANMP Agricultural nutrient management plan

BMAP Basin Management Action Plan

BMP Best management practice

BNR Biological nutrient removal

BOD Biochemical oxygen demand

C&D Construction and development

CAFO Confined animal feeding operation

cfs Cubic feet per second

CH Chlorophyll a

COI Cost of illness

CREP Conservation Reserve Enhancement Program

CRP Conservation Reserve Program

CSP Conservation Stewardship Program 

CTA Conservation Technical Assistance 

CWA Clean Water Act

DPV Downstream protection value

DO Dissolved Oxygen

DOF Department of Forestry

EAA Everglades Agriculture Area

EPA U.S. Environmental Protection Agency

EQIP Environmental Quality Incentive Program

F.A.C. Florida Administrative Code

FC Fecal coliform

FDACS Florida Department of Agriculture and Consumer Services

FDEP Florida Department of Environmental Protection

FDOF Florida Division of Forestry

FDOH Florida Department of Health

F.S. Florida Statutes

FWRA Florida Watershed Restoration Act

GAC Granulated activated carbon

GIS Geographic information systems

GLCI Grazing Land Conservation Initiative

HABs Harmful algal blooms

HUC Hydrologic unit code

IPM Integrated pest management

IWR Impaired Waters Rule

LSJR Lower St. Johns River

MEP Maximum extent practicable

MLE Modified Ludzack-Ettinger

MS4 Municipal separate storm sewer system

NAICS North American Industry Classification System

NO2 Nitrate

NO3 Nitrite
January 2012 ix

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NOI Notice of intent

NRCS Natural Resource Conservation Service

NPDES National Pollutant Discharge Elimination System

NWIS National Water Information System

O&M Operation and maintenance

OCBWG Orange Creek Basin Working Group

OIG Office of Inspector General

OSTDS Onsite sewage treatment and disposal system

PAC Powered activated carbon

PCS Permit compliance system

Pt-Co Platinum cobalt units

RA Reasonable assurance

RBC Rotating biological contactor

SBR Sequencing batch reactor

SCR Selective catalytic reduction

SDT Secchi disk transparency

SDM Secchi disk measurement

SFWMD South Florida Water Management District

SIC Standard industrial classification

SJWMD St. Johns Water Management District

SMP Strategic monitoring plans

SMZ Special Management Zone

SSAC Site specific alternative criteria

SWET Soil and Water Engineering Technology

SWIM Surface Water Improvement and Management

SWMP Stormwater management program

TMDL Total maximum daily load

TN Total nitrogen

TP Total phosphorus

TSI Trophic state index

TSS Total suspended solids

UCT University of Cape Town

USDA United States Department of Agriculture

USGS United States Geological Survey

WAFR Wastewater facility regulation

WBID Waterbody identification

WLA Wasteload allocation

WOD Works of the District

WQBEL Water quality-based effluent limit

WQI Water quality index

WQL Water quality ladder

WQS Water quality standards

WRF Water reclamation facility

WTP Willingness to pay

WWTP Wastewater treatment plant
January 2012 Executive Summary

Draft for Internal Review Only-Do Not Quote or Cite

ES-1

Executive Summary

The U.S. Environmental Protection Agency (EPA) is proposing numeric nutrient criteria applicable to 

estuaries, coastal waters, and south Florida inland flowing waters in the State of Florida. The proposed 

criteria will supplement the state’s existing narrative nutrient criterion. Although the proposed rule does 

not establish any requirements directly applicable to regulated entities or other sources of nutrient 

pollution, EPA developed this economic analysis to provide information on potential costs and benefits 

that may be associated with state implementation requirements that may be necessary to assure attainment 

of water quality standards (WQS).

ES.1 Background and Purpose

The State of Florida currently uses a narrative criterion to protect waters from nutrient pollution. In 

January of 2009, EPA determined that new or revised WQS for nutrients in the form of numeric nutrient 

criteria are necessary in Florida to meet the requirements of the Clean Water Act (CWA) (U.S. EPA, 

2009a). In August of 2009, EPA entered into a phased Consent Decree with several environmental 

organizations that challenged the Agency for not having promulgated numeric nutrient criteria for the 

state. In that Consent Decree, EPA committed to promulgating numeric nutrient criteria for inland, 

estuarine, and coastal waters in Florida. When promulgated, this rule will satisfy the requirements of the 

Consent Decree.

The proposed rule establishes numeric water quality criteria for nutrients applicable to estuaries, coastal 

waters, and south Florida inland flowing waters in Florida. EPA determined the proposed criteria to be 

protective of the state’s designated uses for these waters. The proposed rule does not establish any 

requirements directly applicable to regulated entities or other sources of nutrient pollution. Nonetheless, 

state implementation of the criteria may result in new or revised National Pollutant Discharge Elimination 

System (NPDES) permit conditions for point source dischargers and nutrient control requirements for 

other sources (e.g., agriculture, urban runoff, and septic systems). Therefore, to provide information on 

such potential impacts, this report provides EPA’s estimates of the potential costs and benefits of actions 

the State of Florida could take to implement the proposed criteria, and thus may be indirectly associated 

with the proposed rule. 

ES.2 Baseline for the Analysis

The baseline for estimating the potential costs and benefits that may be associated with the proposed rule

is the conditions and requirements that would exist without the proposed rule. These conditions include 

the current narrative nutrient criterion and procedures for identifying impaired waters, and the actions that 

would be needed to attain the narrative criterion (including those that have not yet been implemented). 

There are waters in Florida currently listed as impaired under the narrative criterion. FDEP has developed 

total maximum daily loads (TMDLs) for many of these waters, and has developed or is developing Basin 

Management Action Plans (BMAPs) to implement some of those TMDLs. Under TMDLs, point sources 

may receive revised water quality based effluent limits (WQBELs) for total nitrogen (TN) and/or total 

phosphates (TP). Under BMAPs, nonpoint sources, including agriculture, urban stormwater, and septic 

systems, may be required to implement additional nutrient controls. For this analysis, EPA also considers 

the baseline to include its 2010 numeric nutrient criteria for lakes and flowing waters, and the controls, 

costs, and benefits that may be necessary to attain those criteria.

Point Sources
January 2012 Executive Summary

Draft for Internal Review Only-Do Not Quote or Cite

ES-2

EPA’s permit compliance system (PCS) database indicates that there are 198 municipal wastewater 

dischargers and 245 industrial dischargers with individual permits. Some of these permittees discharge to 

lakes and flowing waters that are not affected by the estuarine waters, coastal waters, or South Florida 

inland waters rule. For example, of the 198 municipal wastewater treatment plants (WWTP), EPA 

determined that only 107 discharge to estuarine waters, coastal waters, or South Florida inland waters. 

Given the nature of influent wastewater at municipal WWTPs, it is likely that all WWTPs have the 

potential to discharge nutrients. To identify industrial dischargers likely to discharge nutrients, EPA 

identified those dischargers in PCS with either numeric effluent limits and/or monitoring requirements for 

nitrogen and phosphorus. Based on these industrial categories, Exhibit ES-1summarizes the number of 

NPDES-permitted wastewater dischargers in Florida that may be affected by the rule. 

Exhibit ES-1: NPDES-Permitted Wastewater Dischargers Potentially Affected by 

Proposed Rule

Discharger Category Number of Dischargers

Major Municipal1 69

Minor Municipal1 38

Total Municipal 107

Major Industrial2 27

Minor Industrial2 24

Total Industrial 51

Total 158

1.Based on treatment train descriptions in FDEP (2009) and permits, WLAs in TMDLs and existing regulations, 

assuming dischargers would have to install advanced BNR for compliance under the rule.

2. U.S. EPA (2011).

The Grizzle-Figg Act of 1990 (F.S. 403.086) requires facilities discharging into Old Tampa Bay, Tampa 

Bay, Hillsborough Bay, Boca Ciega Bay, St. Joseph Sound, Clearwater Bay, Sarasota Bay, Little Sarasota 

Bay, Roberts Bay, Lemon Bay, or Charlotte Harbor Bay, or into any river, stream, channel, canal, bay, 

bayou, sound, or other water tributary thereto, to provide advanced waste treatment. The Act also 

regulates wastewater discharges through ocean outfalls by prohibiting the construction of new ocean 

outfalls and the expansion of existing ocean outfalls for domestic wastewater discharge.

Urban Sources

Urban runoff from fertilizers applied to lawns, gardens, and golf courses, decomposition of natural rock 

and soils, air deposition from vehicle exhaust or power plants, detergents used to wash cars on the street, 

and pet waste can account for significant nutrient pollution in watersheds. There are a number of rules and 

programs in place that regulate these sources. For example, the state’s Urban Turf Fertilizer Rule limits 

the nutrient content of urban fertilizers, which decreases the amount of runoff from its application. There 

are also 36 local governments in Florida with strict rainy season urban fertilizer application bans as of 

May, 2011 (Sierra Club Florida, 2011). Municipal separate storm sewer systems (MS4s) develop and 

implement management plans that include measures that may reduce runoff of nutrients such as public 

education and pollution prevention/good housekeeping activities. To date, FDEP has issued 27 Phase 1 

(large and medium-sized) MS4 permits and 128 Phase II (small) MS4 permits in Florida (FDEP, 2010c). 
January 2012 Executive Summary

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ES-3

Lastly, FDEP’s 1982 Stormwater Rule requires treatment of stormwater from new development and 

redevelopment prior to discharge.

Agricultural Sources

GIS analysis indicates that there are 7.2 million acres of agricultural land in the state of Florida. These 

lands may represent significant sources of nutrients from fertilizer and waste runoff, and are subject to 

several federal and state pollution control regulations. A number of rules and programs address nutrient 

discharges from these sources. Chapter 62-670, F.S. requires all concentrated animal feeding operations 

(CAFOs) in the state of Florida that discharge water offsite to file an application for a NPDES permit with 

FDEP. It also prohibits discharge of process wastewater and runoff from any major egg production 

facility to surface waters except in the event of a 25-year, 24-hour storm event. In addition, dairy 

operations within the Lake Okeechobee Drainage Basin [as defined in 62-670.200(8)] and its tributaries 

are also required to implement BMPs for the purpose of reducing phosphorus inputs to the lake. In 1999, 

the Florida Watershed Restoration Act (FWRA) established BMPs as the primary instrument for 

implementing the TMDL program in Florida. Under the FWRA (Section 403.067, F.S.), implementation 

of BMPs that FDEP has verified as effective and FDACS has adopted by rule provides a presumption of 

compliance with state WQS. Under the program, landowners must maintain records and provide 

documentation regarding their implementation of BMPs and reasons why certain BMPs are applicable to 

their specific situation. Exhibit ES-2 shows the number of acres that farmers have enrolled in the 

FDACS BMP program, by land use type.

Exhibit ES-2: Acres Enrolled in FDACS BMP Program 

Land Use Number of Acres1 Land Use Number of Acres1

Cropland and Pastureland 57,828 Poultry Feeding Operations 308

Improved Pastures 604,137 Nurseries and Vineyards 7,619

Unimproved Pastures 187,799 Tree Nurseries 2,794

Woodland Pastures 85,730 Sod Farms 6,113

Row Crops 55,797 Ornamentals 7,366

Field Crops 607,440 Specialty Farms 496

Tree Crops 102,137 Horse Farms 585

Citrus Groves 301,415 Diaries 6,163

Fruit Orchards 3,792 Aquaculture 15

Other Groves 324 Tropical Fish Farms 19

Abandoned Groves 12 Other Open Lands 11,715

Feeding Operations 389 Fallow Crop Land 2,269

Cattle Feeding Operations 854

Total 2,053,115

1. Based on FDACS BMP program NOI GIS data layer.

There are also several statutes and regulations governing the discharge of phosphorus in the Lake 

Okeechobee watershed, including the Northern Everglades and Estuaries Protection Program. To 

encourage implementation of BMPs and various conservation measures, there are several national 

programs including the Conservation Stewardship Program, Conservation Reserve Enhancement 
January 2012 Executive Summary

Draft for Internal Review Only-Do Not Quote or Cite

ES-4

Program, Conservation Technical Assistance, Environmental Quality Incentives Program, and Grazing 

Land Conservation Initiative.

Forestry

The Florida Division of Forestry (FDOF) controls nonpoint forestry discharges of nutrients through the 

implementation of BMPs, as developed by the BMP Technical Advisory Committee and published in the 

Silviculture Best Management Practices Manual (FDOF, 2009). According to the manual, the BMPs 

reflect “the minimum standards necessary for protecting and maintaining the State’s water quality as well 

as certain wildlife habitat values, during forestry activities,” and address many sources of pollution 

including sedimentation, nutrients, and turbidity. 

FDOF periodically conducts state-wide surveys of silviculture practices to assess compliance levels, 

identify areas and foresters in need of further education, and evaluate the effectiveness of BMPs. There

have been 15 surveys since 1981, with the most recent in 2009. Over that period, the average compliance 

rate for all BMPs was 94%, with 84% in 1985 and 98% compliance in 2009. The 2009 survey also 

reported that the implemented BMPs are generally effective at preventing significant impacts to relevant 

waterbodies (FDOF, 2010).

The manual contains 143 BMPs, within 14 categories organized by their application to different land 

types, waterbodies, activities, and special conditions. 

Septic Systems

According to a Florida Department of Health database, there are a total of 944,006 septic systems in 

Florida, of which 802,500 are active (FDOH, 2011). Most of Florida’s septic systems are over 30 years 

old and were installed under standards less stringent than current standards for septic system installation. 

As a result, Florida has identified approximately $10.3 billion in capital needs to address water quality or 

water quality-related public health problems from decentralized wastewater treatment systems (U.S. EPA 

2010c). These costs represent capital expenditures associated with the rehabilitation or replacement of 

septic systems and clustered (community) systems. 

In Florida, the Bureau of Onsite Sewage Programs in the Florida Department of Health (FDOH) and the 

environmental health section of County Health Departments regulate the use of onsite sewage treatment 

and disposal systems (OSTDSs). Unless a variance from these prohibitions has been granted by FDOH,

FDOH does not permit the use of an OSTDS where the estimated domestic sewage flow is over 10,000 

gpd or the commercial sewage flow is over 5,000 gpd, where there is a likelihood that the system will 

receive toxic, hazardous or industrial wastes, where a sewer system is available, or if any system or flow 

is currently regulated by FDEP.

Summary of Baseline Requirements

To estimate the potential incremental impacts that may be associated with the rule, EPA assumed that the 

following actions have been or will be implemented in the absence of the rule, and did not estimate costs 

associated with these actions as part of this analysis:

 Actions necessary to meet existing NPDES permit conditions for municipal and industrial 

wastewater

 Actions resulting from draft or approved TMDLs and BMAPs

 Controls required by the Grizzle-Figg Act of 1990

 Controls on low-density residential land, in compliance with the Urban Turf Fertilizer Rule
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ES-5

 Controls on land developed after 1982, in compliance with the 1982 Stormwater Rule

 Controls required by the FDEP Dairy Rule and EPA CAFO regulations

 Agriculture land enrolled in BMPs under FDACS

 Requirements for the Lake Okeechobee watershed

 BMPs for the forestry sector

EPA estimated potential costs compared to a baseline of controls that could be needed to attain FDEP’s 

July 2009 draft numeric nutrient criteria. EPA also considered the baseline to include its 2010 numeric 

nutrient criteria for lakes and flowing waters, and the controls, costs, and benefits that may be necessary 

to attain those criteria.

ES.3 Description of the Proposed Rule and Potential Incremental Impairment

EPA is proposing numeric water quality criteria to protect ecological systems and aquatic life from 

nitrogen and phosphorus pollution in estuaries and coastal waters within the State of Florida, and flowing 

waters in south Florida. These proposed criteria apply to Florida waters that are designated as Class I, 

Class II or Class III waters and they implement the State’s narrative nutrient provision at Subsection 62-

302.530(47)(b), Florida Administrative Code (F.A.C.), which provides that “[i]n no case shall nutrient 

concentrations of a body of water be altered so as to cause an imbalance in natural populations of aquatic 

flora or fauna.”

To evaluate estuarine and South Florida marine waters not already listed as impaired under the narrative 

criteria for nutrient-related causes that may be identified as impaired under the proposed criteria, EPA 

analyzed the most recent five years of available water quality monitoring data for each potentially 

affected segment with sufficient monitoring data. Sufficient data include at least four measurements per 

year (for three consecutive years), with at least one measurement between May and September and one

measurement between October and April each year. 

To estimate the waterbodies (specifically identified as WBIDs) that may be listed as incrementally 

impaired under Florida’s listing procedures, EPA identified WBID with each segment using GIS. Each 

segment does not fall completely within a single WBID. Thus, to ensure that the WBID is accounted for 

in the analysis, EPA identified WBIDs containing at least 10% of an incrementally impaired segment, 

excluding those WBIDs that are currently impaired or under a TMDL (to remove baseline impaired 

WBIDs). Exhibit ES-3 summarizes results of this analysis.
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ES-6

Exhibit ES-3: Summary of Potential Incremental Impairment under the 

Proposed Criteria

Category Number of Coastal and Estuarine WBIDs

Total in State 1,143

Total in Analysis1 952

Nutrient Data in IWR Run 442 513

Sufficient Data Available3 410

Potentially Exceeding Criteria4 230

IWR = Impaired Waters Rule

TMDL = total maximum daily load

1. Excluding waters for which FDEP has already developed a TMDL or listed as impaired for 

nutrients and DO

2. Data within last 5 years meeting data quality requirements.

3. Sufficient to calculate annual geometric means; based on at least 4 samples with at least one 

sample from May to September and one sample from October to April in a given year.

4. Based on annual geometric mean exceeding the applicable criterion more than once in a three 

year period.

To estimate the urban areas, agricultural land, and septic systems that may need controls to attain the 

proposed criteria in incrementally impaired waters, EPA used GIS analysis to identify the watersheds [10-

digit Hydrologic Unit Code (HUC)] associated with these incrementally impaired WBIDs. Each WBID in 

the state may not fall completely within a single 10-digit HUC. Thus, to ensure that lands (and sources) 

affecting water quality for each WBID are accounted for in the analysis and that incidentally overlapping 

HUCs are not included, EPA identified watersheds containing at least 10% of an incrementally impaired 

WBID, excluding those watersheds that contain at least 10% of a WBID that is currently impaired or 

under a TMDL (to remove baseline impaired watersheds). EPA estimated controls for agricultural land, 

urban land, and septic systems within these potentially affected watersheds.

ES.4 Potential Costs to Municipal WWTPs 

Point source dischargers receive water quality based effluent limitations (WQBELs) in permits based on 

analysis of reasonable potential to exceed water quality criteria. Because untreated municipal wastewater 

is typically high in nutrients, for this analysis, EPA assumed that all municipal WWTPs would receive 

WQBELs consistent with no mixing zones or dilution (i.e., criteria applied end-of-pipe). Potential 

controls that would facilitate attaining these limitations include biological nutrient removal (BNR), 

chemical precipitation, and effluent reuse. 

For this analysis, EPA also assumed that WWTPs would implement advanced BNR as the most costeffective treatment option. Although other treatment options may be able to reduce TN and TP 

concentrations below the levels achieved by BNR, those options tend to be significantly more expensive. 

EPA believes that other strategies to reduce nutrient loading to the watershed would likely be 

implemented before requiring these more expensive alternatives (in some cases, requiring dischargers to 

obtain a variance from meeting the criteria). EPA also estimated additional costs for the second pollutant 

when current TMDLs may have only addressed one nutrient pollutant (e.g., a WWTP under a current 

TMDL for TN may incur further costs for the TP criteria set in this proposal). 

Thus, EPA estimated the potential costs to WWTPs based on a range of estimated unit costs for BNR.

EPA estimated that potential compliance costs (annualized capital at 7% over 20 years plus annual O&M) 

to municipals WWTPs could range from approximately $94.2 million to $117.5 million annually. The 
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ES-7

low end of this range excludes costs to dischargers to waters on the 303(d) list for nutrient-related causes 

since controls would likely be needed in the absence of the proposed rule. However, existing nutrientrelated TMDLs for Florida waters sometimes establish WLAs for only the limiting pollutant. For most 

estuaries and coastal waters, the growth-limiting nutrient (i.e., the chemical which largely controls the rate 

of primary production) is nitrogen, therefore the high end of the range includes potential incremental costs 

to facilities for TP on currently listed waters.

ES.5 Potential Costs to Industrial Wastewater Sources

Unlike municipal WWTPs, industrial facilities do not necessarily discharge nitrogen or phosphorus. Also, 

though some facilities may use the same treatments as WWTPs (such as BNR and chemical 

precipitation), treatment options for reducing nutrient loads from industrial sources can vary due to 

industry- or facility-specific conditions. In some cases, industrial facilities may also be able to pursue 

options such as BMPs, product substitution, process modification or optimization, or retention pond 

installation. 

To estimate the potential costs to industrial facilities that may be indirectly associated with EPA’s rule, 

EPA first assumed that controls on dischargers to 303(d) listed waters or waters covered under a TMDL 

are not attributable to the proposed rule because those costs would occur in the absence of the proposed

rule. Of the remaining industrial facilities, EPA estimated the costs of nutrient controls that may be 

necessary to meet the proposed criteria in different industrial categories. EPA estimated statewide control 

costs (annualized capital at 7% over 20 years plus annual O&M) for industrial facilities could amount to 

approximately $7.6 million, annually.

ES.6 Potential Costs for Urban Stormwater Controls

Some areas served by MS4s in incrementally impaired watersheds may require additional nutrient 

controls. However, it is difficult to identify the additional controls that may be necessary to attain the 

proposed criteria without site specific analysis. Full implementation of existing stormwater management 

programs could be sufficient to attain the proposed criteria in some watersheds. In others, water quality 

monitoring after full implementation of existing stormwater management programs may indicate a need 

for additional controls. 

Current nutrient-related TMDLs in Florida allocate between 5% and 85% of nutrient load reductions to

stormwater sources within the watershedsUrban stormwater controls may remove up to 51% of TN and 

75% of TP (Schueler et al., 2007). FDEP’s 1982 Stormwater Rule establishes that stormwater design 

criteria adopted by FDEP and the water management districts shall achieve at least 80% reduction of the 

average annual load of pollutants that cause or contribute to violations of WQS (95% reduction for 

outstanding natural resource waters). 

In its evaluation of EPA’s proposed numeric nutrient criteria rule, FDEP (2010b) assumed that nutrient 

reductions mandated in the 1982 Stormwater Rule would be sufficient to comply with the proposed 

criteria. EPA assumed that the amount of urban land within Phase I MS4s that may require additional 

nutrient controls could range from none [current implementation of BMPs to the maximum extent 

practicable (MEP) is sufficient] to all Phase I MS4 urban land developed before 1982 in watersheds 

surrounding incrementally impaired WBIDs. Under these assumptions, EPA estimated through GIS 

analysis that additional stormwater controls may be needed on up to 31,200 acres of Phase I MS4 urban 

land (approximately 68% of Phase I MS4 urban acres surrounding incrementally impaired WBIDs).

Because over-application of fertilizers on lawns and gardens is the primary source of nutrient pollution 

from low density urban areas, EPA assumed that sufficient nutrient reductions could be achieved from 
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ES-8

low density Phase II MS4 areas and other low density urban areas not covered under EPA’s NPDES 

stormwater program by full implementation of existing regulations such as the Urban Turf Fertilizer Rule. 

For higher density Phase II MS4 urban areas and other higher density urban areas not covered under 

EPA’s NPDES stormwater program, EPA assumed that additional stormwater controls could be needed in 

incrementally impaired watersheds. Again, using FDEP’s assumption that urban lands developed after 

1982 would not need additional controls, EPA used GIS analysis to estimate that 34,500 acres of urban 

land within Phase II MS4s and 21,400 acres of urban land outside MS4s may need additional controls to 

reduce nutrients discharges to surface waters (approximately 62% and 71% of Phase II MS4 urban land 

and non-MS4 urban land, respectively, surrounding incrementally-impaired WBIDs).

Costs for stormwater controls can vary widely and depend on the type of land requiring control. For this 

analysis, EPA estimated unit costs from data on existing stormwater projects in Florida obtained from 

FDEP (2010a). The cost of these projects ranges from $62 per acre to $60,300 per acre, with a median 

cost of $6,800 per acre. Using the median cost per acre and the estimated number of acres needing 

additional controls, EPA estimated that costs for additional nutrient controls for stormwater could range 

from $55.2 to $86.0 million per year.

ES.7 Potential Costs for Agricultural Controls

EPA estimated that an incremental level of control of nutrient runoff from agricultural land could be 

needed on about 16,600 acres (approximately 82% of all agricultural land surrounding potentially 

incrementally impaired WBIDs). For this analysis, EPA estimated the BMP programs that could be 

needed to attain the numeric criteria based on a study of agricultural BMPs to meet TMDL targets in the 

Caloosahatchee River, St. Lucie River, and Lake Okeechobee watersheds (SWET, 2008). SWET (2008) 

developed scenarios of a mix of BMPs at three levels of control: an owner implemented program 

consisting of a set of practices that land owners might implement without incentives; a typical program 

consisting of practices that land owners might implement under a reasonably funded cost share program; 

and an alternative program of more aggressive controls to supplement the owner and typical programs if 

additional reductions are necessary. 

The BMPs in the owner implemented and typical program are similar to the BMPs adopted by FDACS. 

The alternative BMP program, which includes stormwater chemical treatment, is not yet required in the 

study basins which have significant contributions from agriculture. Thus, for this analysis, EPA assumed 

that nutrient controls for agricultural sources are best represented by the owner and typical programs. 

EPA estimated potential nutrient control costs to agriculture by using GIS analysis to assess the amount 

of land used for different categories of agricultural operations in incrementally impaired watersheds, and 

the category-specific unit costs of the owner and typical BMP programs estimated by SWET (2008). 

BMPs implemented under the FDACS program represent a level of control that is similar to the owner 

implemented and typical BMP programs. However, the level of compliance with the FDACS BMP 

program in incrementally impaired watersheds is uncertain (FDACS 2011). Therefore, EPA estimated a 

range of agricultural costs by including and excluding land enrolled in the FDACS BMP program. Using 

these assumptions, EPA estimated that the cost of additional agricultural BMPs that may be needed to 

attain the proposed criteria could range from approximately $0.27 to $0.28 million per year. 

ES.9 Potential Costs for Septic System Controls

Some nutrient reductions from septic systems may be necessary for incrementally impaired waters to 

meet the proposed criteria. Properly operated and maintained systems usually provide treatment 

equivalent to secondary wastewater treatment (Petrus, 2003). However, even properly functioning septic 
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ES-9

systems could impact water quality. Nutrient loading reduction strategies could include greater use of 

inspection programs and repair of failing systems, upgrading existing systems to advanced nutrient 

removal, decentralized cluster systems where a responsible management entity would ensure reliable 

operation and maintenance, and connecting households and businesses to wastewater treatment plants. 

Based on current practice in Florida, EPA assumed for this analysis that the most likely compliance 

strategy to reduce nutrients loads from septic systems would be to upgrade existing convention septic 

systems to advanced nutrient removal systems.

Septic systems in close proximity to surface waters are most likely to contribute the greatest nutrient load 

to the waterbody. Most of the existing nutrient-related TMDLs identify failing septic systems as 

contributing to nutrient impairments in surface waters. The Middle St. Johns River Nutrient TMDL 

considers wastewater from failed septic tanks within 50 feet as direct discharges of untreated wastewater 

to the stream network; for systems outside of the 50-feet boundary, FDEP combines septic system loads 

with the nonpoint source loading for residential areas (Gao, 2009). In addition, Florida Administrative 

Code requires that in most cases septic systems “shall not be located laterally within 75 feet of the 

boundaries of surface waterbodies” (FAC 64E-6.005(3)). 

EPA assumed that some septic systems located near incrementally impaired estuaries, coasts, and south

Florida inland waters may be required to upgrade to advanced nutrient removal systems. However, the 

distance that septic systems can be safely located relative to these surface waters depends on a variety of 

site-specific factors. Given the uncertainty, EPA conservatively assumed that septic systems located 

within 500 feet of incrementally impaired waters may require upgrading to account for some downstream 

transport of nutrients from nearby waters that may not be classified as incrementally impaired. GIS 

analysis indicates that there are 7,325 active septic systems within 500 feet of any water body in 

watersheds associated with incrementally impaired waters.

Manufacturer estimates of capital costs to upgrade a conventional septic system to an advanced nutrient 

removal system (including installation costs) range from $2,000 per system to $6,500 per system, with 

annual O&M costs of $650 per year (Chang et al., 2010). Thus, annual costs could range from 

approximately $800 to $1,300 for each upgrade (capital costs annualized at 7% over 20 years plus annual 

O&M). Multiplying these unit costs by the total number of septic systems possibly needing upgrades 

yields a cost estimate ranging from $5.9 to $9.5 million annually.

ES.10 Government Expenditures

FDEP may incur costs associated with development of additional TMDLs. Because existing TMDLs for 

estuaries, coastal waters, and south Florida inland waters cover an average of four WBIDs each, EPA 

estimated that FDEP may need to develop 58 new TMDLs to address the 230 incrementally impaired 

WBIDs. EPA (2001) indicates that TMDL development for two similar pollutants costs an average of 

approximately $47,000. Thus, total TMDL development cost could be approximately $2.7 million. 

Currently, FDEP operates its TMDL schedule based on a five-phase cycle that rotates through the five 

basins over five years (FDEP, 2003). Under this schedule, completion of TMDLs for high priority waters 

will take 9 years; it will take an additional 5 years to complete the process for medium priority waters.

Thus, assuming all the incremental impairments are high priority and FDEP develops the new TMDLs 

over a 9-year period, annual costs could be approximately $0.3 million.

ES.11 Summary of Costs

Exhibit ES-4 summarizes the estimates of potential annual incremental control costs for each source.
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ES-10

Exhibit ES-4: Potential Annual Costs Associated with Numeric Nutrient Criteria (2010 

dollars)

Source Sector Type of Expenditure Annual Cost (millions)

Municipal Wastewater1 BNR to reduce TN and/or TP $94.2 - $117.5

Industrial Dischargers2

BNR to reduce TN and TP; 

chemical precipitation to reduce 

TP

$7.6

Urban Stormwater3 Stormwater controls $55.2 - $86.0

Agriculture4 Owner/typical BMP program $0.3 - $0.3

Septic Systems5 Upgrade to advanced nutrient 

treatment $5.9 - $9.5

Government/Program 

Implementation6 TMDL development $0.3

Total -- $163.5 - $221.2

Note: Detail may not add to total due to independent rounding.

BNR = biological nutrient removal; TMDL = total maximum daily load; TN = total nitrogen; TP = total phosphorus

1. Based on upgrading existing treatment processes to advanced BNR.

2. Based on extrapolation of average annual costs per flow for random sample of dischargers stratified by industrial 

category.

3. Based on median stormwater control costs from FDEP (2010a), and scenario of need for structural controls on 

land developed before 1982.

4. Based on implementing nutrient management on all crop land outside of incrementally and baseline impaired 

watersheds and scenarios in which all agricultural land not enrolled in the FDACS BMP program in incrementally 

impaired watersheds incurs owner/typical program costs from SWET (2008) or all agricultural land in incrementally 

impaired watersheds incurs owner/typical costs based on SWET (2008).

5. Based on upgrading to advanced nutrient removal active septic systems within 500 feet of water (based on GIS 

land use data) in the watersheds surrounding potential incrementally impaired WBIDs.

6. Based on average costs to complete TMDLs for incrementally impaired waters under a 9-year schedule.

ES.12 Description of Potential Benefits

Reduction in nutrient concentrations to meet numeric nutrient standards in Florida estuaries, coasts, and 

south Florida inland waters improves ecological function and enhance provision of environmental goods 

and services. One of the adverse effects of excess nutrient loading is eutrophication, or the increase in 

organic carbon to an aquatic ecosystem caused by primary production stimulated by excess nutrients. This 

can lead to increases in the occurrence and intensity of water column phytoplankton, including harmful 

algal blooms (e.g. nuisance and/or toxic species), loss of critical submerged aquatic vegetation (SAV)1

, 

and reduced and/or diurnally variable dissolved oxygen (DO). In turn, these ecological responses can lead 

to significant or even complete losses in environmental goods and services provided by the affected 

waterbodies, such as commercial and recreational fishing, swimming, diving, and snorkeling.

Eutrophication is a major concern for many bays, estuaries, and coasts within the United States, and is 

particularly severe for many Florida waters. Florida’s 2008 Integrated Report stated that 94 estuaries 

encompassing approximately 900 square miles of water are impaired for nutrients, with nutrients ranked 

as the second most common source of impairment (FDEP 2008a).

2

. One additional coastal body 

 1 Submerged aquatic vegetation such as seagrass is a major determinant of the trophic structures of coastal ecosystems, providing 

food, habitat, and shelter for a wide range of fish species, marine mammals, reptiles, and birds. 

2 The 2010 report indicates cause of impairment as trophic status index (TSI), which measures the potential for algal or aquatic 

weed growth, the components of which include total nitrogen, total phosphorus, and chlorophyll.
January 2012 Executive Summary

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ES-11

representing 102 square miles is also impaired for chlorophyll, typically considered an indicator of algal 

growth associated with eutrophication (FDEP, 2008a).

Eutrophication of estuaries, coasts, and south Florida inland waters may have a significant impact on the 

value of environmental goods and services provided by the affected waterbodies. Low DO events in a 

single water body can cause millions of dollars in economic losses from recreational and commercial 

fishing alone (CENR, 2010). Additionally, the losses of SAV resulting from eutrophication can have 

profound economic impacts. For example, FDEP has estimated that each acre of seagrass is worth over 

$20,000 to the economy of Florida annually, or over $44 billion statewide (Carlson and Yarbro, 2008). In 

2009, Florida seagrass communities supported an estimated harvest of $23 million for just six species of 

commercial fish and shellfish dependent on seagrass (Crist, 2010).

In the environment and economy in Florida, the tourism-focused goods and services provided by its bays, 

estuaries, and coastal waters are particularly valuable. The tourism industry in nearshore counties in 

Florida contributes approximately $12.4 billion (2004 dollars) to the state’s economy annually3 (NOEP, 

2006). Coral reefs are an especially important contributor to the tourism sector in the state. Reef-related 

recreational expenditures on activities such as snorkeling, scuba diving, fishing, and glass bottom boating 

in four counties in southeastern Florida for a one year period in 2000-2001 totaled $5.4 billion (Johns et 

al., 2001).

Reductions of nutrient loading to estuaries, coasts, and south Florida inland waters in Florida result in 

decreased eutrophication and its associated adverse impacts to the environment and economy. Exhibit 

ES-5 shows the types of benefits often associated with environmental policies, including improvements in 

water quality, and the types of methods that can be used to assign value to such benefits. Categories that 

may be applicable to nutrient reductions in Florida include:

 Reduced human health risks such as skin irritation, gastrointestinal illness, and other symptoms 

associated with exposure to harmful algal blooms (HABs), 

 Ecological benefits including improved fish and shellfish harvests, improved recreational 

opportunities, and enhanced ecosystem services such as biodiversity conservation, nutrient cycling, and 

many others, and

 Other benefits such as aesthetic improvements and reduced biofouling. 

 3 Tourism data is for 2004, the most recent year for which data is available. Dollar values presented in this chapter are in 2010 

dollars, inflated from original year dollars using CPI, except where otherwise noted.
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ES-12

Exhibit ES-5: Types of Benefits Associated with Environmental Policies

Category Examples Valuation Methods

Human Health Improvements

Mortality risk reductions Reduced risk of fatality from 

cancer and acute risks

Averting behavior, hedonics, 

stated preference

Morbidity risk reductions Reduced risk of nonfatal illness Averting behavior, hedonics, 

stated preference

Ecological Improvements

Market products Harvests or extraction of food, 

fuel, fiber, timber, fur, and leather Production function

Recreation activities and 

aesthetics

Wildlife viewing, fishing, boating, 

swimming, hiking, scenic views

Production function, averting 

behaviors, hedonics, recreation 

demand, stated preference

Valued ecosystem functions

Climate moderation, flood 

moderation, groundwater 

recharge, sediment trapping, soil 

retention, nutrient cycling, 

pollination by wild species, 

biodiversity, water filtration, soil 

fertilization, pest control

Production function, averting 

behaviors, stated preference

Nonuse values Relevant species populations, 

communities, or ecosystems Stated preference

Other Benefits

Aesthetic improvements Visibility, taste, odor Averting behaviors, hedonics, 

stated preference

Reduced materials damage Reduced soiling and corrosion Averting behaviors, production 

function, cost function

Source: U.S. EPA (2010a)

Reducing excess nutrients in estuaries, coastal waters, and south Florida inland waters can result in 

significant economic benefits to Florida citizens. These benefits include maintenance of valuable coastalbased fishing and tourism industries in the state and increased coastal property values. There could also 

be significant indirect economic benefits including reduction in healthcare costs (due to avoided harmful 

algal blooms), the avoidance of costs associated with the need to find alternative recreational locations, 

enhanced opportunities for angling competitions, wildlife watching, and camping, and non-use values 

such as habitat protection. Numeric nutrient criteria can also result in avoidance of future restoration costs 

because numeric criteria are easily measurable qualities of water that can be used to assess whether or not 

waters are in danger of becoming impaired, allowing for a more cost-effective approach of pollutant 

reductions prior to waters being impaired.

Some of the benefits of reducing nutrients can be monetized, at least in part, by translating changes in 

nutrient concentrations into an indicator of water quality (a water quality index, WQI) and valuing these 

improvements in terms of willingness to pay (WTP) for the types of uses that are supported by different 

water quality levels. The parameters used to formulate the WQI are based on waterbody type, scientific 

understanding of ecosystem response to varying conditions, and available data. For this preliminary 

analysis, EPA developed a WQI of the proposed nutrient criteria parameters only, although other 

parameters affect overall water quality. Thus, the benefits may overstate or understate potential water 

quality improvement under the proposed criteria depending on how other parameters affect water quality. 

(Note, none of the incrementally affected waters appear on FDEP’s list of impaired waters.) 
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ES-13

EPA developed baseline and post-compliance WQI values assuming that the waters not in attainment are 

at least of ‘fair’ water quality, given that FDEP has not already listed these waters as impaired under the 

current narrative nutrient criterion, and that attaining the proposed criteria represents ‘good’ water quality.

EPA used information on the percent exceedance of the proposed criteria across the incremental 

nonattainment waters to estimate the level between these two points representative of baseline water 

quality.

4 EPA developed baseline WQI estimates for each WBID using three scenarios: 1) baseline WQI 

estimated from exceedences of TN criteria (a scenario in which nitrogen is the limiting nutrient of 

concern); 2) baseline WQI estimated from exceedences of TP criteria ( a scenario in which phosphorus is 

the limiting nutrient of concern); and 3) baseline WQI estimated from exceedences of Chl-a criteria (a 

scenario in which Chl-a is the primary concern). The difference in WQI between baseline conditions and 

attainment of the proposed criteria is a measure of the change in water quality that may be attributable to 

nutrient pollution controls. However, some of these controls may represent baseline requirements and are 

not accounted for in this analysis. EPA assumed that all waters not currently attaining the proposed 

criteria will come into attainment, but did not estimate any water quality improvements in waters that 

already attain the proposed criteria.

EPA then used regression analysis to determine average household WTP for improvements in water 

quality. EPA calculated the average household WTP at the WBID-level for both full-time and part-time 

residents. EPA estimated total benefits at the WBID level by multiplying average household WTP with 

the number of households in each category and the percentage of miles or area that comprise a given 

WBID. This method results in monetized benefits associated with attaining the proposed criteria ranging

from $83.7 to $100.1 million, as shown in Error! Reference source not found.. However, benefits are 

overstated to the degree that improvements can be attributed to baseline controls.

Exhibit ES-6: Potential Annual State Benefits Associated with the Proposed 

Criteria (Millions of 2010$)

Baseline WQI Based on % 

of TN Exceedance

Baseline WQI Based on % 

of TP Exceedance

Baseline WQI Based on % 

of Ch-a Exceedance

$100.1 $86.8 $83.7

Ch-a = chlorophyll a

TN = total nitrogen

TP = total phosphorus

WQI = water quality index

 4 In cases in which exceedence data are not available for one or more pollutants in a waterbody, data for another pollutant are 

substituted, with the following order of preference: TN, TP, Chl-a.
January 2012 1. Introduction

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1-1

1 Introduction

The U.S. Environmental Protection Agency (EPA) is proposing numeric nutrient criteria applicable to 

estuaries, coastal waters, and south Florida inland flowing waters. The proposed criteria will augment the 

state’s existing narrative nutrient criteria. Although the proposed rule does not establish any requirements 

directly applicable to regulated entities or other sources of nutrient pollution, state implementation may 

result in new or revised National Pollutant Discharge Elimination System (NPDES) permit conditions for 

point source dischargers and controls on nonpoint sources of nutrient loadings. This analysis provides

information on the potential for both costs and benefits to be associated with state actions that may be 

necessary to assure attainment of state water quality designated uses protected by the criteria in the 

proposed rule.

1.1 Requirement for the Proposed Rule

Section 303(c) of the Clean Water Act (CWA) requires states to adopt water quality standards (WQS) for 

waters of the United States within their applicable jurisdictions. Section 303(c)(2)(A) and EPA’s 

implementing regulations at 40 CFR part 131 require that state WQS include the designated use or uses of 

the waters and the criteria necessary to protect those uses. EPA’s regulations at 40 CFR § 131.11(a)(1) 

provide that states “adopt those water quality criteria that protect the designated use,” and that such 

criteria “must be based on sound scientific rationale and must contain sufficient parameters or 

constituents to protect the designated use.”

CWA section 303(c) also requires states to review their WQS at least once every three years and, if 

appropriate, revise or adopt new standards. States must submit these new or revised WQS to EPA for 

review and approval or disapproval. Section 303(c) also directs the EPA Administrator to promulgate 

WQS to supersede state standards that it has disapproved or determined that a new or revised standard is 

needed to meet CWA requirements.

On January 14, 2009, EPA made a determination under section 303(c)(4)(B) of the CWA that numeric 

nutrient water quality criteria for lakes and flowing waters and for estuaries, coastal waters, and south 

Florida inland waters are necessary for the State of Florida to meet the requirements of CWA section 

303(c). As a result of an August 2009 Consent Decree with multiple environmental organizations, EPA 

proposed numeric nutrient water quality standards for lakes and flowing waters in Florida in January 

2010, and established final standards in December 2010. When promulgated, this rule will satisfy the 

requirements of the Consent Decree for estuaries, coastal waters, and south Florida inland flowing waters.

1.2 Purpose and Scope of the Analysis 

The proposed rule establishes water quality criteria applicable to estuaries, coastal waters, and south 

Florida inland waters in Florida. The proposed rule does not establish any requirements directly 

applicable to regulated entities or other sources of nutrient pollution to these waters. Nonetheless, state 

implementation of the criteria may result in new or revised National Pollutant Discharge Elimination 

System (NPDES) permit conditions for point source dischargers and nutrient control requirements on 

other sources (e.g., agriculture, urban runoff, and septic systems). Therefore, the purpose of this analysis 

is to provide estimates (within the limits of uncertainties regarding future implementation by the State of 

Florida) of the potential costs and benefits that may ultimately be associated with the proposed rule to 

inform the public regarding these potential impacts. Actual impacts will depend on the particular 

implementation strategy pursued by the state.
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This report provides an assessment of the potential costs and benefits associated with implementation of 

the proposed rule above and beyond those that may result without the proposed rule. It is possible that 

implementation of existing criteria (e.g., narrative nutrient criteria) would eventually lead to imposition of 

controls deemed necessary to comply with the proposed rule because both criteria target the same 

endpoint of “no imbalance of flora and fauna,” such that the difference in costs is only a matter of timing. 

Under such a scenario, the proposed rule may result in cost savings by addressing the need for controls 

sooner rather than later and avoiding more costly restoration as well as providing support to Florida for 

future TMDLs by completing one of the early steps in the TMDL process. However, with this analysis, 

EPA is conveying information related to the potential costs and benefits of implementing its numeric 

nutrient criteria as an “increment” to the costs and benefits associated with ongoing efforts to implement 

existing criteria. EPA refers to these existing conditions and requirements (e.g., existing criteria, actions 

required under existing nutrient-related TMDLs) as the “baseline.”

To identify the potential incremental impact above the baseline, EPA evaluated potential changes to 

NPDES permit conditions for municipal and industrial wastewater facilities since these point sources may 

receive water quality based effluent limitations (WQBELs). For nonpoint sources, EPA identified waters 

that may not meet EPA’s criteria but are not currently listed by the state as impaired for nutrient-related 

causes, and used land use data surrounding incrementally impaired watersheds (that are not also in 

baseline impaired watersheds) as an indication of the types of controls that will be needed to attain the 

criteria. EPA based its estimates of the types of controls and costs for different sources that may be 

needed on those currently being required throughout the state in watersheds impaired under existing 

criteria. The data and methods behind each of these components of the analysis are described in detail 

within the report and appendices.

To estimate potential incremental benefits, EPA identified the potential adverse effects associated with 

excess nutrient loadings in estuaries, coastal waters, and south Florida inland waters, and the categories of 

benefits that may result from attaining criteria. For quantitative estimates, EPA conducted a benefits 

transfer of studies that provide estimates of the value of water quality improvements. To do this, EPA 

linked changes in water quality to incremental benefits through use of a water quality index.

Numeric nutrient criteria provide a means of developing protective numeric effluent limits for wastewater 

point sources, and information that may help in limiting loads from nonpoint sources to prevent 

impairment in waters that do not yet exceed the criteria. Thus, there is also potential for benefits from 

attaining designated uses where such uses are impaired and protecting designated uses from future 

impairment and the associated loss of value. However, the estimates of costs and benefits in this report do 

not account for prevention of future impairments. 

1.3 Organization of this Report

The remainder of this report is organized as follows:

 Section 2 describes the baseline for estimating potential incremental compliance actions.

 Section 3 provides a description of the proposed rule.

 Section 4 provides as assessment of the potentially incrementally impaired waters under the rule.

 Section 5 provides estimates of controls and costs for wastewater point source dischargers.

 Section 6 provides estimates of controls and costs for industrial point sources.

 Section 7 provides discussion of the potential for incremental controls for urban runoff.
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 Section 8 provides estimates of controls and costs for agriculture.

 Section 9 provides estimates of controls and costs for septic systems.

 Section 10 provides estimates of potential government expenditures.

 Section 11 summarizes the potential costs and describes the uncertainties of the analysis.

 Section 12 provides a description of potential incremental benefits.

 Section 13 provides monetized estimates of potential benefits.

 Section 14 provides references.

 Appendix A provides the proposed nutrient criteria.

 Appendix B provides facility-specific cost estimates for municipal WWTPs.

 Appendix C provides detailed analysis for each of sample industrial dischargers.

 Appendix D provides an analysis of whether the numeric nutrient criteria are being attained at “pour 

points.”
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2 Baseline for the Analysis

As described in Section 1, this report conveys information related to the potential costs and benefits of 

implementing the proposed numeric nutrient criteria as an increment to ongoing efforts to attain existing 

nutrient criteria. This section describes these existing conditions. Because a number of existing programs 

and requirements are not yet fully implemented, current water quality may not reflect the ultimate 

conditions that would result without the proposed rule. This section describes the information and 

assumptions EPA used to establish a baseline for identifying the incremental requirements, costs, and 

benefits that may be associated with the proposed rule.

2.1 Current Regulatory Framework

The current regulatory framework for controlling nutrients in Florida waters includes existing WQS, and 

state and federal requirements for dischargers of nutrients.

2.1.1 Water Quality Standards

WQS include designated uses of waters (e.g., aquatic life support, recreation, drinking water), water 

quality criteria to protect the uses, and antidegradation policy. WQS also include implementation 

procedures specifically addressing identification of impaired waters to the extent the procedures further 

define designated uses and protective criteria.

Current Water Quality Criteria

For nutrients, FDEP water quality criteria for estuaries are narrative in form: Chapter 62-302.530, Florida 

Administrative Code (F.A.C.), states that “in no case shall nutrient concentrations of a body of water be 

altered so as to cause an imbalance in natural populations of flora or fauna.” The proposed criteria address 

this aspect of the narrative criterion. The narrative criterion also states that (for all waters of the state) “the 

discharge of nutrients shall continue to be limited as needed to prevent violations of other standards 

contained in this chapter (Chapter 62-302, F.A.C.). Man-induced nutrient enrichment (total nitrogen or 

total phosphorus) shall be considered degradation in relation to the provisions of Sections 62-302.300, 62-

302.700, and 62-4.242, F.A.C.”

In December 2010, EPA established numeric criteria for TN, TP, and chlorophyll-a for freshwater lakes 

and flowing waters in Florida that are not to be exceeded more than once in a three year period. Exhibit 

2-1 summarizes these criteria, which vary by region (for streams) and characteristics of the waters (for 

lakes). 
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Exhibit 2-1: Numeric Nutrient Criteria for Lakes and Flowing Waters in Florida

Region/Type of Water Chlorophyll-a 

(mg/L)

TN Criteria 

(mg/L)

TP Criteria 

(mg/L)

Nitrate + Nitrite 

Criteria (mg/L)

Colored Lakes1 0.020 1.27 0.050 NA

Clear Lakes (high alkalinity)2 0.020 1.05 0.031 NA

Clear Lakes (low alkalinity)3 0.006 0.50 0.011 NA

Panhandle East Flowing Waters NA 1.03 0.18 NA

Panhandle West Flowing Waters NA 0.67 0.06 NA

North Central Flowing Waters NA 1.87 0.30 NA

West Central Flowing Waters NA 1.65 0.49 NA

Peninsula Flowing Waters NA 1.54 0.12 NA

Springs NA NA NA 0.35

Chl-a = chlorophyll-a

Pt-Co = platinum-cobalt

NA = not applicable

TN = total nitrogen

TP = total phosphorus

1. Long-term Color > 40 Pt-Co

2. Long-term Color ≤ 40 Pt-Co and Alkalinity > 20 mg/L CaCO3.

3. Long-term Color ≤ 40 Pt-Co and Alkalinity ≤ 20 mg/L CaCO3.

For streams that are upstream of lakes, a more stringent downstream protection value (DPV) may apply.

The applicable DPVs are expressed as an annual geometric mean value not to be exceeded more than 

once in a three year period.

CWA Section 303(d) Listing Procedures 

Florida WQS also contain procedures for identifying impaired waters. FDEP first evaluates existing water 

quality data to develop a Planning List of potentially impaired waters for further assessment. FDEP then 

assesses waters on the Planning List through additional data gathering and strategic monitoring. Waters 

that FDEP determines are impaired as a result of pollutant discharges are placed on the Verified List,

which also represents the CWA Section 303(d) list of impaired waters for which it will develop a TMDL. 

FDEP uses chlorophyll-a concentration as the primary means for assessing whether an estuary should be 

assessed further for nutrient impairment. FDEP also considers other information indicating an imbalance 

in flora or fauna due to nutrient enrichment, including, but not limited to, algal blooms, excessive 

macrophyte growth, decrease in the distribution (either in density or areal coverage) of seagrass or other 

submerged aquatic vegetation, changes in algal species richness, and excessive diel oxygen swings 

(Chapter 62-303, F.A.C.). FDEP includes estuaries, estuary segments, or open coastal waters on the 

planning list for nutrients if the annual mean chlorophyll-a for any year is greater than 11 μg/l or if data 

indicate annual mean chlorophyll-a values have increased by more than 50% over historical values for at 

least two consecutive years. 

To be placed on the verified list, FDEP requires sufficient data from the last five years preceding the 

planning list assessment, combined with historical data (if needed to establish historical chlorophyll-a 

levels). If data are insufficient, FDEP must collect additional data to meet the requirements. Once these 

additional data are collected, FDEP determines if there is sufficient information to develop a site-specific 

threshold that better reflects conditions beyond which an imbalance in flora or fauna occurs in the water. 

If there is insufficient information, FDEP will reevaluate the data using the thresholds from the planning 

list. However, FDEP need not use these same thresholds in developing the TMDL.
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2.1.2 Restoration of Designated Uses in Impaired Waters

FDEP implements nutrient criteria through TMDLs (see Section 2.3.2) and the NPDES permit program 

(see Section 2.1.3). A TMDL is a calculation of the maximum amount of a given pollutant that a water

body can receive and still meet WQS, and an allocation of that amount to point and nonpoint source 

categories. FDEP typically uses site specific data to translate narrative criteria into numeric concentration 

targets, numeric load targets, or percent reduction requirements. Numeric nutrient concentration targets in 

TMDLs for TN and TP in estuaries, bays, and coasts range from 0.51 mg/L to 5.4 mg/L and 0.044 mg/L 

to 0.18 mg/L, respectively.

FDEP develops Reasonable Assurance (RA) Plans and Basin Management Action Plans (BMAPs) to 

implement the controls necessary to attain TMDLs in impaired water bodies. 

Reasonable Assurance Plans

RA plans provide reasonable assurance that proposed pollution control mechanisms will result in the 

restoration of designated uses in impaired waters. There are two nutrient-related RA plans for estuaries 

and coasts in Florida: Tampa Bay and Florida Keys. 

The Tampa Bay Comprehensive Conservation and Management Plan (TBNEP, 1996) established 

restoration of seagrass in the bay to levels estimated in the 1950s as a primary goal for overall bay 

restoration. In establishing and addressing this goal, the TBNEP cited a number of studies from the 1990s 

that clearly established nitrogen as the limiting nutrient in the Tampa Bay estuary and indicated that 

phosphorus loadings to the bay from the enriched Bone Valley region were not controlling estuarine 

production. The Tampa Bay Estuary Program (TBEP) partners adopted a “hold-the-line” target for TN 

loadings that capped the segment TN loads at levels that would ensure adequate water clarity and light to 

sustain seagrass recovery based on average annual 1992-1994 TN for the four mainstem bay segments:

 Old Tampa Bay: 486 tons/year,

 Hillsborough Bay: 1451 tons/year,

 Middle Tampa Bay: 799 tons/year, and

 Lower Tampa Bay: 349 tons/year.

In January 1998, in accordance with the Clean Water Act Section 303(d)(2), the State of Florida 

submitted for EPA approval a proposed TMDL for Tampa Bay, including the 1992-1994 bay-segment TN 

loads listed above. EPA approved the Tampa Bay TMDL as submitted by FDEP on June 18, 1998. 

Subsequent to the TMDL, the TBEP developed an RA plan to outline the load allocations and control 

measures necessary to restore designated uses to the estuary system. FDEP concluded that the most recent 

RA plan “constitutes reasonable progress towards continued attainment of water quality standards of 

Tampa Bay related to nutrients.” 

FDEP (2008b) also concluded that the plan provides continued reasonable assurance that impairment of 

designated uses related to nutrients in Tampa Bay will be adequately addressed. The TBEP (2010; 2011) 

reports that, since 1996, the Bay has attained the annual water quality targets (FDEP-approved 

chlorophyll-a thresholds) over 87% of the time, and seagrass coverage has expanded by approximately 

5,980 acres to a baywide total of 32,900 acres (5,100 acres from the goal of 38,000 acres).

FDEP developed an RA Plan for the Florida Keys in cooperation with local governments, state agencies, 

and federal agencies within the Florida Keys. The plan sets forth actions that have been taken or are 

planned to be taken to reduce nutrient loadings to near shore waters throughout the Florida Keys to attain
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WQS and restore beneficial uses. FDEP reviewed and accepted the plan and sent it to EPA for review and

comment in February 2009. EPA has not yet taken action and the Department has not included the results 

in the recently adopted Group 5 Verified List of Impaired Waters. In the proposed RA Plans, FDEP 

expects applicable water quality targets (insignificant increase above farfield concentrations) to be 

achieved by 2020, when all committed wastewater and stormwater management activities are complete.

Basin Management Action Plans

To implement TMDLs, FDEP may develop BMAPs with local stakeholders. State law requires FDEP to 

adopt BMAPs by Secretarial Order. These Orders are enforceable. BMAPs set forth the strategy for 

achieving the pollutant reductions established in the TMDL, including permit limits on wastewater 

facilities, urban and agricultural best management practices (BMPs), conservation programs, financial 

assistance, and revenue generating activities.

FDEP has adopted five nutrient BMAPs to date, including one for eight estuarine segments in the Lower 

St. John’s River (LSJR). The BMAPs rely heavily on existing programs [e.g., NPDES program, BMP 

manuals (see Section 2.1.5)]. For example, existing BMAPs for the LSJR, Orange Creek watershed, and 

Upper Ocklawaha River rely on voluntary implementation of BMPs by farmers through the Florida 

Department of Agriculture and Consumer Services (FDACS) BMP program. However, Subsection 

403.067(7)(b), F.S., requires that nonpoint pollutant sources (such as agriculture) included in a BMAP 

demonstrate compliance with pollutant reductions established to meet a TMDL either by implementing 

BMPs or by conducting water quality monitoring prescribed by FDEP or a water management district. 

Thus, if necessary, farmers could be required to implement approved BMPs.

2.1.3 Existing Regulations for Point Source Dischargers

Permitting

A number of rules and programs regulate point source dischargers into estuarine, coastal, and South 

Florida inland flowing waters. Rules 62-620.320(1) and 62-620.620(1)(g), F.A.C., establish that a permit 

shall be issued only if the applicant affirmatively provides FDEP with reasonable assurance that the 

construction, modification, or operation of the discharge facility will not discharge or cause pollution in 

contravention of WQS. As part of the permit application process, the applicant must supply data 

characterizing the pollutants that may be discharged and provide reasonable assurance that the discharge 

will not violate water quality criteria in the receiving water.

FDEP’s permit writer’s guidance manual (FDEP, 2006b) indicates that at a minimum permit writers 

should include limits in permits for a parameter if there is evidence that the discharge could cause or 

contribute to instream violations. However, FDEP may also include limits based on EPA’s reasonable 

potential approach, which requires sufficient effluent data as described in its Technical Support Document

for Water Quality-Based Toxics Control (U.S. EPA, 1991), or based on the judgment of the permit writer 

that a limit is necessary to provide RA that the facility will operate in a way that will not cause water 

quality violations (FDEP, 2006b). For example, for the current narrative nutrient criterion for waters not 

covered under a TMDL, permit writers determine whether the discharge contains phosphorus or nitrogen, 

and examine the quality of the receiving water and any other affected waters with regard to nutrient levels 

and biological impacts. 

Based on this analysis, permit writers determine the level of nutrients that would “cause an imbalance in 

natural populations of aquatic flora and fauna” and translates those levels into numeric “targets” for the 

receiving water and any other affected waters. If there is reasonable potential, permit writers calculate 

permit limits to ensure that such a discharge will not cause or contribute to an exceedance of the nutrient 
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target levels. FDEP’s permit writer’s guidance manual (FDEP, 2006b) indicates that WQBELs are 

calculated based on EPA’s Technical Support Document for Water Quality-Based Toxics Control (U.S. 

EPA, 1991). If sufficient data are not available to determine reasonable potential, the permit can be issued 

with an effluent limit based on water quality criteria in Florida and an administrative order attached to the 

permit that requires the studies necessary to determine reasonable assurance with a schedule to return the 

facility to compliance with the final permit limits (FDEP, 2006b).

TMDLs (WLAs)

Existing requirements for point sources also include wasteload allocations (WLAs) established in existing 

nutrient-related TMDLs and revised NPDES permit conditions that reflect these allocations. Generally, 

the WLAs are based on existing allowable or permitted loads or a specified percent reduction. For 

example, under the Roberts Bay TMDL, the three point source dischargers receive a WLA based on a TN 

concentration of 3 mg/L (U.S. EPA Region 4, 2005). Thus, effluent limits in the NPDES permits 

remained the same, and reflect advanced wastewater treatment (AWT) standards. In the Escambia Bay 

TMDL, WLAs for point sources are percent reductions in loads (23% for TN and 30.5% for TP) (U.S. 

EPA Region 4, 2007); however, effluent limits for TN and TP in NPDES permits for the 2 municipal 

WWTPs covered by the TMDL are based on AWT levels for TN (annual average of 3 mg/L) and TP 

(annual average of 1 mg/L for TP).

Grizzle-Figg Act

In addition, the Grizzle-Figg Act of 1990 (F.S. 403.086) requires facilities discharging into Old Tampa 

Bay, Tampa Bay, Hillsborough Bay, Boca Ciega Bay, St. Joseph Sound, Clearwater Bay, Sarasota Bay, 

Little Sarasota Bay, Roberts Bay, Lemon Bay, or Charlotte Harbor Bay, or into any river, stream, 

channel, canal, bay, bayou, sound, or other water tributary thereto, to provide advanced waste treatment, 

as defined below:

 Annual average biochemical oxygen demand (BOD) less than 5mg/L

 Annual average suspended solids less than 5mg/L

 Annual average TN less than 3mg/L

 Annual average TP less than 1mg/L

 High level disinfection. 

These requirements do not apply to facilities permitted prior to February 1, 1987, and which discharge 

secondary treated effluent, followed by water hyacinth treatment, to tributaries of tributaries of the named 

waters; to facilities permitted to discharge to the nontidally influenced portions of the Peace River, or to 

septic tanks or other means of individual waste disposal (which are otherwise subject to state regulation). 

In addition, in those waters where the concentrations of phosphorus have been shown not to be a limiting 

nutrient or a contaminant, FDEP may waive or alter the compliance levels for phosphorus. 

The Act also regulates wastewater discharges through ocean outfalls by prohibiting the construction of 

new ocean outfalls and the expansion of existing ocean outfalls for domestic wastewater discharge, 

requiring that all discharges of domestic wastewater through ocean outfalls meet advanced wastewater 

treatment and management requirements no later than December 31, 2018, and requiring all domestic 

wastewater facilities that discharged through an ocean outfall on July 1, 2008 to install a functioning 

reuse system (i.e., provides a minimum of 60% of the facility’s actual annual flow for reuse applications 

by December 31, 2025), and prohibits the discharge of domestic wastewater through ocean outfalls after 
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December 31, 2025, except as a backup discharge that is part of a functioning reuse system authorized by 

FDEP.

Indian River Lagoon and Monroe County Regulations

There are also regulations requiring advanced waste treatment for dischargers to Indian River Lagoon and 

Monroe County waters:

 Indian River Lagoon System and Basin Act of 1990, contained in Chapter 90-262, Laws of Florida

 Monroe County, Chapter 99-395, Laws of Florida - by July 1, 2010 domestic wastewater discharges 

greater than 100,000 gpd must have advanced waste treatment.

2.1.4 Existing Regulations for Urban Areas

Urban runoff from fertilizers applied to lawns, gardens, and golf courses, decomposition of natural rock 

and soils, air deposition from vehicle exhaust or power plants, detergents used to wash cars on the street, 

and pet waste can account for significant nutrient pollution in watersheds. A number of rules and 

programs regulate discharges from urban areas.

Urban Turf Fertilizer Rule

To address nutrients from fertilizers, the FDACS adopted the statewide Urban Turf Fertilizer Rule, which

limits the phosphorus and nitrogen content in fertilizers for urban turf and lawns. The rule requires that all 

fertilizer products labeled for use on urban turf, sports turf, and lawns be limited to the amount of nitrogen 

and phosphorus needed to support healthy turf maintenance. FDACS estimated a 20% to 25% reduction 

in nitrogen and a 15% reduction in phosphorus in every bag of fertilizer sold to the public. The rule also 

restricts phosphorous and nitrogen application rates in fertilizers.5 The rule became effective December 

31, 2007, with a requirement for fertilizer labels to reflect compliance by July 1, 2009. 

Local Fertilizer Ordinances

As of May 2011, there are 36 local governments in Florida with strict rainy season urban fertilizer 

application bans (Sierra Club Florida, 2011). These bans typically prohibit application of fertilizer 

containing nitrogen and/or phosphorous during the four rainy summer months (from June 1-September 

30), set a specific distance from water bodies which must remain fertilizer-free, specify yearly application 

limit for nitrogen and/or phosphorus, and use of slow-release/controlled release nitrogen products (Sierra 

Club Florida, 2011). Pinellas County also included a fertilizer sales restriction in its ordinance.

EPA Stormwater Program

EPA’s Phase I stormwater rule covers large and medium-size MS4s [Clean Water Act Section 402(p) 

sources], and the Phase II rule covers small MS4s (systems serving less than 100,000 people). Generally, 

Phase I MS4s are covered by individual permits and Phase II MS4s are covered by a general permit.

There are 27 Phase I NPDES MS4 permits in Florida and 128 Phase II permits.

Each regulated MS4 is required to develop and implement a stormwater management program (SWMP) 

to reduce the contamination of stormwater runoff and prohibit illicit discharges. The MS4 Program 

 5 A maximum of 0.25 lbs phosphorus oxide (P2O5) per 1000 sq. ft. per application and not to exceed 0.5 lbs P2O5 per 1000 sq. ft. 

per year. Application rates above these levels would require a soil sample of the application site to justify an increase in P2O5. A 

maximum of 0.7 lbs of readily available nitrogen per 1000 sq. ft. at any one time based on the soluble fraction of nitrogen 

formulated in the fertilizer. A maximum of 1 lb TN per 1000 sq. ft. to be applied at any one time, not exceeding the annual 

nitrogen recommendations in the Fertilizer Guidelines for Established Turf Grass Lawns in Three Regions of Florida. 

Application rates above these levels would require a turf tissue test at the application site to justify the increase in TN.
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contains elements called minimum control measures that when implemented should result in a significant 

reduction in pollutants discharged into receiving waters:

 Public Education/Outreach – educate the community on the pollution potential of common activities, 

increase awareness of the direct links between land activities, rainfall-runoff, storm drains, and local 

water resources, and provide the public clear guidance on steps and specific actions that they can take to 

reduce their stormwater pollution-potential through use of brochures/pamphlets, mailers, posters, and 

training for local business employees

 Participation/Involvement – build on community capital to help spread the message on preventing 

stormwater pollution, to undertake group activities that highlight storm drain pollution, and contribute 

volunteer community actions to restore and protect local water resources; includes facilitating 

opportunities for direct action, educational, and volunteer programs such as riparian planting days, 

volunteer monitoring programs, storm drain marking, or stream-clean up programs

 Illicit Discharge Detection and Elimination – develop a program to detect and eliminate illicit 

discharges which primarily includes developing a storm sewer system map, an ordinance prohibiting 

illicit discharges, a plan to detect and address these illicit discharges, and an education program on the 

hazards associated with illicit discharges

 Construction Site Runoff Control – develop a program to reduce pollutants in stormwater runoff for 

construction sites disturbing one or more acres which primarily includes developing an ordinance, 

requirements to implement erosion and sediment control BMPs, requirements to control other waste at the 

construction site, procedures for reviewing construction site plans, procedures to receive and consider 

information submitted by the public, and procedures for inspections and enforcement of stormwater 

requirements at construction sites. 

 Post-Construction Runoff Control – address post-construction stormwater runoff from new 

development and redevelopments that disturb one or more acres which primarily includes developing 

strategies to implement a combination of structural and non-structural BMPs, an ordinance to address 

post-construction runoff, and a program to ensure adequate long-term operation and maintenance of 

BMPs. 

 Pollution Prevention/Good Housekeeping – develop inspection and maintenance procedures and 

schedules for stormwater BMPs, implement BMPs to treat pollutants from transportation infrastructure, 

maintenance areas, storage yards, sand and salt storage areas, and waste transfer stations, establish 

procedures for properly disposing of pollutants removed from the MS4, and identify ways to incorporate 

water quality controls into new and existing flood management projects.

Florida Stormwater Rule

A 1982 Florida rule [as authorized in Chapter 403, Florida Statues (F.S.)] requires treatment of 

stormwater from new development and redevelopment prior to discharge using BMPs designed to achieve 

a specific level of treatment (i.e., performance standards). The rule also requires that older systems be 

managed as needed to restore or maintain the beneficial uses of waters, and that water management 

districts establish stormwater pollutant load reduction goals to be adopted as part of a Surface Water 

Improvement and Management (SWIM) plan, other watershed plan, or rule. 

In addition, Chapter 62-40, F.A.C., “Water Resource Implementation Rule,” establishes that stormwater 

design criteria adopted by FDEP and the water management districts shall achieve at least 80% reduction 

of the average annual load of pollutants that cause or contribute to violations of WQS (95% reduction for 
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outstanding natural resource waters). The rule also states that the pollutant loading from older stormwater 

management systems shall be reduced as necessary to restore or maintain the designated uses of waters.

2.1.5 Existing Requirements for Agriculture

Phosphorus and nitrogen in agricultural runoff come from application of fertilizer to crops and pastures, 

and animal wastes. A number of rules and programs address nutrient discharges from these sources.

FDEP Dairy Rule and CAFO Requirements

Chapter 62-670, F.S. requires all concentrated animal feeding operations (CAFOs) in the state of Florida 

that discharge water offsite to file an application for a NPDES permit with FDEP. It also prohibits 

discharge of process wastewater and runoff from any major egg production facility to surface waters 

except in the event of a 25-year, 24-hour storm event. In addition, dairy operations within the Lake 

Okeechobee Drainage Basin [as defined in 62-670.200(8)] and its tributaries are also required to 

implement BMPs for the purpose of reducing phosphorus inputs to the lake. Specifically, dairy farms in 

the Lake Okeechobee Drainage Basin must provide fencing to keep dairy cows away from surface water 

and have a system for waste collection, storage, and treatment, particularly in areas of high-intensity use. 

The rule also contains requirements for land application of waste, setback distance from surface water 

sources, and groundwater monitoring. The Dairy Rule does not establish a specific off-site phosphorus 

discharge concentration limitation, but rather requires BMPs to be incorporated into the operation of 

dairies. These BMPs need to provide reasonable assurances that each dairy could meet state water quality 

standards and that acceptable phosphorus levels in off-farm discharges would be achieved (Chapter 62-

670, F.A.C.). Although the Interim Lake Okeechobee SWIM Plan (SFWMD, 1989) established a 

maximum discharge limitation of 1.2 mg/L total phosphorus, the dairies are exempt from permitting and 

enforcement under the Works of the District (WOD) Program6

, since they are under the jurisdiction of the 

Dairy Rule.

The national CAFO rule, 40 CFR 122.23(d), requires CAFOs that have the potential to discharge be 

evaluated on a case-by-case assessment to determine whether the CAFO, due to its individual attributes, 

discharges or has potential to discharge. Discharges from the CAFO include discharges of manure, litter, 

or process wastewater from land application areas under the control of the CAFO. Agricultural 

stormwater discharges from CAFO areas (i.e., areas where animal waste has been applied in accordance 

with site specific nutrient management practices that ensure appropriate agricultural utilization of the 

nutrients) are exempt. 

Agricultural BMP Manuals

In 1999, the Florida Watershed Restoration Act (FWRA) established BMPs as the primary instrument for 

implementing the TMDL program in Florida. Under the FWRA (Section 403.067, F.S.), implementation 

of BMPs that FDEP has verified as effective and FDACS has adopted by rule provides a presumption of 

compliance with state WQS. Participation in this program also provides a release from the provisions of 

Section 376.307(5), F.S. which requires that funds be paid for damages from the discharge of pollutants. 

As part of the manual development process, FDEP verifies the BMPs as effective at reducing pollutant 

loading to waters. Under the program, landowners maintain records and provide documentation regarding 

the selection of BMPs utilized and reasons why certain BMPs are not applicable to their specific situation. 

 6 Each of the five water management districts in Florida has a WOD program. WOD represent canals, water control structures, 

rights-of-way, lakes and flowing waters and other water resources for which each district has responsibility or owns. 
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The BMP manuals provide assessment tools to assist operators in determining the appropriate and 

applicable BMPs according to the type of farm and the basin where the farm is located.

For example, there are three levels of BMPs for cow/calf operations. Level I BMPs are those that are 

largely applicable to all ranchers, and include nutrient management, alternative water sources for cattle, 

grazing management, general erosion and sediment control, water resource management, animal mortality 

disposal, conservation buffers and fences, integrated pest management (IPM), and wellhead, wetlands, 

and springs protection. Ranchers may have to implement Level II and III BMPs based on assessments 

identifying water quality risk features that require special attention or protection; these BMPs focus on 

high intensity areas, livestock use exclusion, and address the need for grade stabilization structures for 

sediment control and list situations that require comprehensive grazing management practices. 

For container nurseries, BMP practices include erosion control, fertilization management, irrigation 

management, pesticide management, nursery layout, waste management, and container substrate and 

planting practices. FDACS requests that nurseries assess current practices to identify which BMPs are 

already in practice and to identify any additional BMPs necessary.

Sod growers must implement a minimum number of BMPs to establish a foundation for environmental 

protection. Depending on site specific conditions or geographic location, the farmer could be exempt from 

implementing some of the minimum BMPs. As part of minimum BMP requirements farms must 

implement nutrient management, irrigation scheduling and maintenance, sediment and erosion control 

measures, integrated pest management, wellhead, wetlands and springs protection, ditch construction and 

maintenance, conservation buffers, stormwater management and mowing management. In addition, 

growers must also use the BMP decision-tree in the manual to identify other BMPs that are applicable to 

the operation. For example, growers who run seasonal sod farming operations may have fewer BMPs, 

while those farming in spring recharge basins or special regulatory areas may have additional BMPs that 

apply.

There are several citrus BMP manuals for different locations such as Gulf citrus, Indian and Peace River 

citrus, and Florida Ridge citrus. For citrus growers, the suggested BMPs include reducing the impact of 

pesticide use, reducing excessive nutrients, minimizing sediment transport and growth of aquatic plants, 

and reducing runoff flowing off-site. 

For vegetable and agronomic crops, farmers first must inventory current farm practices and then use the 

manual to identify additional BMPs applicable to their farming operation. These may include farm ponds, 

filter strips, flood protection, IPM, irrigation scheduling, maintenance and evaluation, fertilization 

management, riparian buffers, erosion control measures, wellhead and wetlands protection, access road 

mitigation, and ditch construction and maintenance.

Under the FDACS program, farmers must submit a notice of intent (NOI) identifying the approved BMPs 

they intend to implement. Implementing the approved BMPs provides a presumption of compliance with 

state WQS and makes producers eligible for cost-share for certain BMPs.

Northern Everglades and Estuaries Protection Program

The Northern Everglades and Estuaries Protection Program (formerly the Lake Okeechobee Protection 

Act; Section 373.4595, F.S.) is a phased watershed program to reduce phosphorus loads and implement 

long-term solutions to meet the TMDL for Lake Okeechobee and its tributaries. The initial phase of 

phosphorus load reductions is based on the District's Technical Publication 81-2 and WOD program, with 

subsequent phases of phosphorus load reductions based on the TMDLs (the TMDL boundary corresponds 

to the revised rule boundary).
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Under the program, the SFWMD developed the Lake Okeechobee Watershed Construction Project Phase 

II Technical Plan, the Caloosahatchee River Watershed Protection Plan and the St. Lucie River Watershed 

Protection Plan. The major provisions and goals of these three plans are described in Exhibit 2-2.

Exhibit 2-2: Plans Developed under the Northern Everglades and Estuaries Protection 

Program

Plan Key Provisions and Goals

Lake Okeechobee 

Watershed 

Construction 

Project Phase II 

Technical Plan 

(SFWMD, 2008)

 Implement BMPs on >1.7 million acres of farmland or demonstrate compliance 

through monitoring 

 Adopt regulations to reduce impacts of development on water quality and flow

 Build treatment wetlands to clean water flowing into the lake

 Use “green” nutrient control technologies to reduce phosphorus loads

 Create >900,000 acre-feet of water storage north of the lake through a 

combination of above-ground reservoirs, underground storage and alternative 

water storage projects on public and private lands.

Caloosahatchee 

River Watershed 

Protection Plan 

(SFWMD, 2009a)

 BMPs on >430,000 acres of agriculture and 145,000 acres of urban lands

 Complete proposed regulatory rule revisions

 Construct approximately 36,000 acres of reservoirs and 15,000 acres of 

Stormwater Treatment Areas (STAs) and Water Quality Treatment Areas

 Target reduction of TP loads of up to 166 metric tons per year (39%) and TN

loads of up to 1,840 metric tons per year (38%) 

 Restore more than 2,000 acres of wetlands within the watershed

 Provide approximately 400,000 acre-feet of water storage within the watershed 

St. Lucie River 

Watershed 

Protection Plan 

(SFWMD, 2009b)

 BMPs on >297,000 acres of agriculture and 84,000 acres of urban lands

 Complete proposed regulatory rule revisions

 Construct approximately 11,800 acres of reservoirs and >8,500 acres of STAs

 Reduce TP loads by up to 209 metric tons (55%) and TN loads by up to 1,210 

metric tons (56%)

 Restore 95,000 acres of wetlands and natural areas within the watershed

 Remove >8 million cubic yards of sediment

 Provide approximately 200,000 acre-feet of water storage within watershed

Water Management District Rules

A number of water management districts in Florida have specific rules in the F.A.C. governing 

agricultural discharges to surface waters. The applicable regulations, by Water Management District, are 

summarized below.

South Florida Water Management District

F.A.C. Section 40E-61:

 Addresses the reduction of phosphorus to Lake Okeechobee based on the SWIM Plan. 

 Each parcel of land within the watershed must have a permit and comply with water quality 

performance limitations.

 Requires individual permits for parcels of land used for improved pasture, vegetable farms, and hog, 

poultry or goat farms located in certain sub-basins that require farms to meet annual average phosphorus 

limits, as well as bi-weekly monitoring.

 Parcels of land used for urban stormwater, nurseries, golf courses, land spreading of sludge, sugar 

cane, sod farms, or horse farms located in individual permit sub-basins must obtain a general permit that 
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requires submitting an application or NOI with a statement indicating how phosphorus discharges will be 

controlled and meeting off-site phosphorus discharge concentration limits.

 Landowners located in other sub-basins are covered under a general permit, however, they do not have 

to submit an application/NOI assuming they do not exceed applicable phosphorus discharge limits.

F.A.C. Section 40E-63:

 Requires that any lands in the Everglades Agriculture Area which discharges water have a permit with 

goal of reducing phosphorous loads by 25%.

 A parcel of land qualifies for a general permit if it is a residential property <40 acres in size, not 

served by a central drainage system, or if it is commercial or industrial property <5 acres not served by a 

central drainage system. 

 Individual permits are required for all structures which discharge water that do not qualify for a 

general or master permit. In the permit application, permittees describe BMP implementation and 

operation and provide a water quality monitoring plan.

 Master permits (same requirements as individual permits) are for lands that are contiguous, have 

interconnected drainage systems, or coordinated BMP plans. 

F.A.C. Section 5M-3:

 Enforces implementation of agricultural BMPs in the Lake Okeechobee watershed. 

 Defines the phosphorus management requirements of agricultural producers necessary to receive a 

presumption of compliance with state water quality standards including those established under TMDLs. 

 Farmer implementation of manuals provides a presumption of compliance with WQS for those 

pollutants addressed by the practices. It also releases farmers from legal provisions requiring that funds be 

paid for damages from the discharge of pollutants.

Northwest Water Management District

F.A.C. Section 40A-44:

District issues general surface water management permits, letters of conceptual approval, individual 

surface water construction permits, and individual operation and maintenance permits for forestry and 

agricultural surface water management systems.

Applicants must demonstrate that proposed projects will not cause unacceptable water quality and 

quantity impacts, will not cause discharges which result in violations of applicable water quality 

standards, and will not cause unacceptable adverse impacts to natural resources, fish, and wildlife.

St. Johns River Water Management District

F.A.C. Section 40C-44:

 Requires a permit for the maintenance and operation of existing agricultural surface water 

management systems

 Requires reductions in the volume of stormwater and wastewater discharged to waters of the state by 

implementing management practices designed to reduce the volume of water discharged off-site, 

maximizing on-site recycling to satisfy irrigation, freeze protection and pest control needs, implementing 
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and maintaining a Conservation Plan, which includes a Nutrient Management Plan and Pesticide 

Management Plan, and providing treatment of the pollutants generated by the agricultural operation

Southwest Water Management District

F.A.C. Section 40D-26:

 Provides funding assistance for the development of production-scale BMPs for agriculture that will 

result in reductions in water use and improvements in water quality and to natural systems 

 Water quality-related projects eligible for the Program include implementation of BMPs that improve 

ground or surface water quality impacted by ground water withdrawals and that improve natural system 

functions within the Upper Myakka River Watershed.

Agricultural Assistance Programs

To encourage implementation of BMPs and various conservation measures, there are several national 

programs including:

 Conservation Stewardship Program (CSP) – a voluntary conservation program that identifies and 

rewards through incentives those farmers and ranchers who meet the highest standards of conservation 

and environmental management on their operations

 Conservation Reserve Enhancement Program (CREP) – program in which farmers receive payment to 

convert cropland and marginal pastureland to native grasses, trees, wetlands, and related conservation 

buffer practices to improve water quality, soil, and wildlife habitat

 Conservation Technical Assistance (CTA) – program through which Natural Resource Conservation 

Service (NRCS) and its partners provide help to land users to address opportunities, concerns, and 

problems related to the use of natural resources and to help land users make sound natural resource 

management decisions on private, tribal, and other non-federal lands

 Environmental Quality Incentives Program (EQIP) – a voluntary conservation program for farmers 

and ranchers that offers financial and technical help to assist eligible participants install or implement 

structural and management practices on eligible agricultural land 

 Grazing Land Conservation Initiative (GLCI) –financial and technical assistance to landowners to 

support improved management of grazing land resources; successful in assisting landowners apply new 

technology to improve livestock production efficiency while maintaining or improving their natural 

resources.

Exhibit 2-3 presents acres enrolled and levels of spending associated with the CSP, CTA, and EQIP 

programs in Florida for the most recent year available. State-level data on CREP enrollment are currently 

unavailable due to privacy restrictions in the Farm Security and Rural Investment Act of 2002. The GLCI 

does not report state-level data on acres enrolled or spending levels.

Exhibit 2-3: Federal Agricultural Assistance Programs by Acres Enrolled and Program 

Spending

Program Acres Enrolled in Florida Program Spending in Florida (Year)

CSP 65,279 $1.2 million (2010)

CTA Not available $9.3 million (2010)

EQIP 2.2 million1 $16.7 million (2008)2

CSP = Conservation Stewardship Program

CTA = Conservation Technical Assistance

EQIP = Environmental Quality Incentives Program
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Exhibit 2-3: Federal Agricultural Assistance Programs by Acres Enrolled and Program 

Spending

Program Acres Enrolled in Florida Program Spending in Florida (Year)

Sources: USDA (2011), USDA (2010), USDA (2009).

1. This value is an estimate of acres enrolled during fiscal year 2008, calculated by dividing spending in fiscal year 

2008 on contracts issued in 2008 by the average spending per acre on all outstanding contracts in 2008.

2. EQIP spending data presented represents FY2008 spending on contracts issued 1997-2008. Florida EQIP 

spending in 2008 on contracts issued in 2008 only totaled $3.6 million.

2.1.6 Existing Requirements for Forestry

Florida’s Division of Forestry (FDOF) controls nonpoint forestry dischargers of nutrients through the 

implementation of BMPs, as developed by the BMP Technical Advisory Committee and published in the 

Silviculture Best Management Practices Manual (FDOF, 2009). According to the manual, the BMPs 

reflecct “the minimum standards necessary for protecting and maintaining the State’s water quality as 

well as certain wildlife habitat values, during forestry activities,” and address many sources of pollution 

including sedimentation, nutrients, and turbidity. The manual contains 143 BMPs, within 14 categories 

organized by their application to different land types, waterbodies, activities, and special conditions. 

One of the BMPs included in the manual is the designation and management of Special Management 

Zones (SMZs), which are areas associated with particular waterbodies that are subject to specific criteria 

to protect the water from nutrient, debris, and other sources of pollution. There may be one or more 

applicable SMZs for different waterbody types, including the primary zone (where some forestry activity 

may be allowed, but subject to stringent restrictions), the secondary zone (where forestry is not restricted 

but has some special requirements), and the stringer (which is a row of trees left at the bank to act as a 

barrier). 

The manual describes other BMPs according to the waterbody affected or the activity being performed in 

close proximity to it, and many pertain to the SMZs. The most relevant of these with regard to nutrient 

loading are those that relate to the application of fertilizer. For example, there can be no aerial application 

or transfer/loading stations in the primary zones (which are the most sensitive areas adjacent to 

waterbodies). There are also stated guidelines about how much fertilizer should be applied, and at what 

times, to minimize the potential for unintended migration of nutrients to the water, and stated maximum 

per-acre application rates.

Currently, BMPs are implemented primarily through educational outreach efforts such as workshops, 

demonstrations, and “master logger” certification classes to achieve forestry BMP implementation 

(FDOF, 2010). FDOF periodically conducts state-wide surveys of silviculture practices to assess 

compliance levels, identify areas and foresters in need of further education, and evaluate the effectiveness 

of the BMPs. There have been 15 surveys since 1984, with the most recent in 2009. Over that period, the 

average compliance rate with all BMPs has been 94%, with 84% in 1985 and 98% compliance in 2009. 

The 2009 survey report also indicated that the implemented BMPs were generally effective at preventing 

significant impacts to the relevant waterbodies, although the report presented little data to support this 

conclusion (FDOF, 2010).

2.1.7 Existing Requirements for Septic Systems 

Nutrients from poorly maintained or failing septic systems or onsite sewage treatment and disposal 

systems (OSTDSs) can threaten both surface and groundwaters. In addition to runoff to surface water 

from mounded leach fields, nutrients can leach into groundwater beneath the system and be carried to 

nearby surface waters.
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In Florida, the Bureau of Onsite Sewage Programs in the Florida Department of Health (FDOH) and the 

environmental health section of County Health Departments regulate the use of OSTDSs. FDOH does not 

permit the use of an OSTDS where the estimated domestic sewage flow is over 10,000 gpd or the 

commercial sewage flow is over 5,000 gpd, where there is a likelihood that the system will receive toxic, 

hazardous or industrial wastes, where a sewer system is available, or if any system or flow is currently 

regulated by FDEP, unless a variance from these prohibitions has been granted by FDOH.

2.1.8 Existing Requirements for Air Sources 

Atmospheric deposition of nitrogen can be a significant source of nutrient loadings to bays, estuaries and 

coastal waters. However, the specific sources of atmospheric nutrients are not typically well known and 

can originate from local, regional, and international sources, including automobiles, power plants, 

volcanoes, and industrial air emissions. 

Florida Air Quality Regulations place an ambient air quality limit on nitrogen dioxide of 0.05 ppm 

(F.A.C. 62-204.240(5)). The major source of nitrogen dioxide is motor vehicle exhaust. Other sources 

include electricity generation, emissions from poultry litter, and other manufacturing processes. There are 

no other nitrogen- or phosphorus-based pollutants that have air quality standards in Florida, and 

atmospheric deposition is not considered to be a primary source of nutrient loading in the Southeastern 

United States (USGS, 2010).

2.2 Existing Nutrient Discharges

Sources of nutrient discharges to estuaries, coastal waters, and south Florida inland waters include 

wastewater point sources (e.g., municipal wastewater treatment plants (WWTPs), industrial facilities), 

urban stormwater, agricultural runoff, septic systems, and atmospheric deposition.

2.2.1 Wastewater Point Sources 

EPA’s permit compliance system (PCS) database indicates that there are 198 municipal wastewater 

dischargers and 245 industrial dischargers with individual permits.7 Many of these permittees discharge to 

lakes and flowing waters and are not affected by the proposed rule. Also, not all industrial dischargers are 

likely to have the potential to discharge nutrients.

Given the nature of influent wastewater at municipal WWTPs, it is likely that all WWTPs have the 

potential to discharge nutrients. To identify industrial dischargers likely to discharge nutrients, EPA 

identified those dischargers in PCS with either numeric effluent limits and/or monitoring requirements for 

nitrogen and phosphorus (Exhibit 2-4). Note that the discharger counts in the exhibit include discharges 

to all waters in the states (e.g., lakes, streams, estuaries, and coastal waters).

Exhibit 2-4: NPDES Dischargers with Numeric Effluent Limits and Monitoring 

Requirements for Nitrogen and Phosphorus in Florida1

SIC 

Code SIC Code Description No. with Nutrient Effluent Limits

No. with Nutrient 

Monitoring Requirements

 7 There are also 34,508 municipal and industrial dischargers covered under generic or general permits. FDEP regulates these 

dischargers based on categories of wastewater facilities or activities that involve the same or similar types of operations or 

wastes. EPA did not include these dischargers in its analysis.
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Majors Minors Majors Minors

0174 Citrus Fruits 1 0 1 0

1099 Miscellaneous Metal Ores, NEC 0 0 0 1

1422 Crushed and Broken Limestone 0 0 0 1

1475 Phosphate rock 14 1 15 5

1479 Chemical and fertilizer mineral mining, NEC 1 0 1 0

2015 Poultry slaughtering and processing 1 0 1 0

2033 Canned fruit and vegetables 1 1 1 1

2034 Dried and Dehydrated Fruits, Vegetables, 

and Soup Mixes 0 1 0 1

2037 Frozen Fruits, Fruit Juices, and Vegetables 0 0 0 1

2082 Malt beverages 0 2 0 2

2085 Distilled and blended liquors 0 1 0 2

2491 Wood Preserving 0 0 0 2

2499 Wood Products, NEC 0 0 0 1

2611 Pulp Mills 2 3 0 0

2621 Paper Mills 0 0 1 0

2631 Paperboard Mills 0 0 2 0

2821 Plastics Materials, Synthetic Resins, and 

Nonvulcanizable Elastomers 0 0 1 0

2824 Manmade Organic Fibers, Except 

Cellulosic 0 0 2 0

2869 Industrial Organic Chemicals, NEC 0 1 0 1

2873 Nitrogenous fertilizers 0 1 0 2

2874 Phosphatic fertilizers 12 16 1 1

2879 Pesticides and agricultural chemicals, NEC 1 0 1 0

2892 Explosives 1 0 1 0

3582 Commercial Laundry, Drycleaning, and 

Pressing Machines 0 0 0 1

3679 Electronic Components, NEC 0 0 0 1

3699 Electrical machinery, equipment, and 

supplies, NEC 0 1 0 1

3822

Automatic Controls for Regulating 

Residential and Commercial Environments 

and Appliances

0 0 0 6

4011 Railroad haul line operating 0 2 0 2

4226 Special Warehousing and Storage, NEC 0 0 0 1

4911 Electric services 6 0 13 0

4931 Electric and Other Services Combined 0 0 0 1

4941 Water supply 0 8 0 20

4952 Wastewater treatment plants 78 0 46 53

4953 Refuse Systems 0 1 0 2

4959 Sanitary Services, NEC 1 0 1 0

5146 Fish and Seafoods 0 0 0 1

5169 Chemicals and Allied Products, NEC 0 0 0 1

5171 Petroleum Bulk stations and Terminals 0 0 0 1

5541 Gasoline Service Stations 0 0 0 1

7996 Amusement parks 0 4 0 6

8422 Arboreta and Botanical or Zoological 

Gardens 0 0 0 1
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Exhibit 2-4: NPDES Dischargers with Numeric Effluent Limits and Monitoring 

Requirements for Nitrogen and Phosphorus in Florida1

SIC 

Code SIC Code Description

No. with Nutrient 

Effluent Limits

No. with Nutrient 

Monitoring Requirements

Majors Minors Majors Minors

8733 Noncommercial Research Organizations 0 0 0 1

9511 Air and Water Resource and Solid Waste 

Management 0 0 0 2

9999 Nonclassifiable 0 1 0 0

Total 119 44 88 123

Source: U.S. EPA (2010b), accessed June 2010.

Major = generally discharge greater than 1 mgd and have the potential to discharge toxics in toxic 

amounts

Minor = generally discharge less than 1 mgd and do not discharge toxics in toxic amounts.

NEC = not elsewhere classified

SIC = Standard industrial classification

1. Including TN, ammonia, nitrate, and organic nitrogen, and TP.

Based on these industrial categories, Exhibit 2-5 summarizes the number of NPDES-permitted 

wastewater dischargers in Florida that may be affected by the proposed rule (i.e., those with potential to 

discharge nutrients to estuaries, coastal waters, or south Florida inland waters). Based on FDEP (2010d) 

analysis, EPA assumed that stormwater treatment areas and drinking water treatment plants would not be 

affected.8

Exhibit 2-5: Summary of NPDES Dischargers in Florida Potentially Affected by Numeric 

Nutrient Criteria for Estuaries, Bays, and Coastal Waters1

Discharger Category Major Dischargers Minor Dischargers Total

Municipal Wastewater 69 38 107

Industrial Wastewater2 27 24 51

Total 96 62 158

Source: U.S. EPA (2011).

SIC = Standard Industrial Classification

TMDL = total maximum daily load

1. Excludes dischargers to lakes and streams except those to South Florida canals (identified based on receiving 

waterbody name and information contained TMDLs, permits, and laboratory reports).

2. For majors dischargers includes SIC codes 1475, 1479, 2015, 2611, 2621, 2631, 2821, 2824, 2874, 2879, 2892, 

and 4911; for minor dischargers includes SIC codes 1099, 1422, 1475, 2033, 2034, 2037, 2082, 2085, 2491, 2499, 

2611, 2869, 2873, 2874, 3582, 3679, 3699, 3822, 4011, 4226, 4931, 4941, 4952, 4953, 5146, 5169, 5171, 5541, 

7996, 8422, 8733, 9511, and 9999.

2.2.2 Stormwater

There are 27 Phase I MS4 permits and 133 Phase II MS4 permits in the state. Most of these permits cover 

discharges to both fresh and marine waterbodies. Under existing permits, these entities implement 

stormwater controls that target a number of pollutants including nutrients. For example, in 2009, FDEP’s 

TMDL Water Quality Restoration Grants Program funded almost $111 million in structural storm water 

controls treating approximately 156,000 acres and estimated to remove approximately 204,000 pounds of 

TN and 30,000 pounds of TP (FDEP, 2010a), as summarized in Exhibit 2-6.

 8 FDEP (2010) assumed that reject wastewater from drinking water facilities (SIC 4941) will be disposed by other means than 

surface water discharge and that stormwater treatment areas (SIC 3822) developed for Everglades restoration efforts within the 

Everglades Protection Area have separate criteria and are not included. 
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Exhibit 2-6: Summary of MS4 Stormwater Control Projects in Florida

Number of Projects Total Cost of 

Projects

Area Treated 

(acres)

TN Reduction 

(lbs/yr)

TP Reduction 

(lb/yr)

40 $110.9 million 155,976 204,054 29,828

Source: FDEP (2010a).

2.2.3 Agriculture

The 2007 Census of Agriculture (USDA NASS, 2009) indicates that there are 47,463 farms and 

9.2 million acres of farmland in Florida. Three million of these acres are cropland, of which 1.6 million 

acres are irrigated. Livestock and poultry inventory includes 1.7 million cattle; 20,000 hogs and pigs; 

11.8 million layers; and 73 million broilers and other chickens.

Farmers implement BMPs as part of the FDACS BMP program described in Section 2.1.5. Exhibit 2-7

shows the number of acres that farmers have enrolled in the FDACS BMP program.

Exhibit 2-7: Summary of Agricultural Lands Enrolled in FDACS BMP Program

FDACS BMP Program Type Number of Acres

Citrus 509,553

Cow/Calf 448,602

Dairies 37,535

Equine 75

Grasses 3,271

Leatherleaf Ferns 144

Nursery 20,662

Poultry Feeding Operations 312

Row Crops 754,713

Sod Farms 33,813

Specialty Farms 306

Tri-County Agricultural Area 3,841

Total 1,812,827

Source: Based on GIS analysis of 2010 FDACS data on enrollments.

2.2.4 Septic Systems

There are 944,006 septic systems in Florida, of which 802,500 are active (FDOH, 2011). Most of the 

septic systems in Florida are over 30 years old and were installed under standards less stringent than 

current standards. In the 2008 Clean Watershed Needs Survey (U.S. EPA, 2010b), the state identified 

approximately $10.3 billion in capital need for decentralized wastewater treatment to address a water 

quality or a water quality-related public health problem existing as of January 1, 2008, or expected to 

occur within the next 20 years. These costs represent capital expenditures associated with the 

rehabilitation and replacement of septic systems and clustered (community) systems. 

2.2.5 Atmospheric Deposition

Atmospheric deposition of nutrients from fossil fuel combustion and other activities can represent a 

substantial source of nutrient loading to waterbodies in Florida (Paerl et al. 2002). The Tampa Bay 

Nitrogen Management Consortium’s 2009 Reasonable Assurance Addendum found that atmospheric 
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deposition contributed 29% of the TN load in Old Tampa Bay, 33% in Middle Tampa Bay, 75% in Lower 

Tampa Bay, and 4% in Hillsborough Bay (TBEP, 2010). In Florida Bay, atmospheric deposition 

accounts for 11% of TN and TP deposition (FDEP, 2010a). 

In current TMDLs, FDEP has utilized several methods to calculate deposition rates. In the nutrient budget 

for the Lower St. Johns River Estuary, FDEP used deposition rates from Pollman and Roy (2003), which 

estimated atmospheric contribution at 2% of TN loading and 10% of inorganic N loading (Magley and 

Joyner, 2008). For Roberts Bay, FDEP (2005a) calculated atmospheric deposition loads by converting 

wet deposition rates from a nearby National Atmospheric Deposition Program monitoring station to total 

nitrogen, and assuming that dry deposition contributed an equal amount to wet deposition (FDEP, 2005). 

In 2004, the most recent year for which data was available, FDEP estimated that atmospheric deposition 

contributed 10,700 pounds of TN per year to Roberts Bay (FDEP, 2005). Gao (2009) used a similar 

method for the Indian River Lagoon, where atmospheric deposition contributes 618,570 pounds of TN per 

year and 13,972 pounds of TP per year, which is 19% of nonpoint source TN and 3% of nonpoint TP

(Gao, 2009). Both the Lower St Johns River Estuary and the Roberts Bay TMDLs indicate that 

phosphorus deposition is not significant.

Given the wide range of deposition rate estimates for Florida estuaries, atmospheric deposition may be a 

significant source of nutrient loading in certain specific estuaries, but the significance of the contribution

to estuaries, coastal waters, and south Florida inland waters statewide that are not currently listed as 

impaired is uncertain.

2.3 Current Water Quality Impairments

FDEP has previously determined that several waterbodies exceed the existing narrative nutrient WQS, as 

identified on the Florida CWA Section 303(d) list.

2.3.1 Category 5 Waters on State 303(d) List

Exhibit 2-8 shows the number of waterbody segments or count of waterbody identification (WBIDs) 

labels listed as impaired for nutrients and/or dissolved oxygen (DO). TMDLs for DO impairments 

typically limit TN and/or TP concentrations as a means of achieving the DO targets, although DO 

impairments could also be due to excessive biological oxygen demand or other causes not related to 

excess TN or TP. Category 5 waters are those impaired waters for which a TMDL is needed but has not 

yet been completed. Thus, the list in Exhibit 2-8 does not include WBIDs for which FDEP or EPA has 

developed a draft or final TMDL (see Section 2.3.2 for list of TMDLs). 

Exhibit 2-8: Summary of CWA Section 303(d) Listed Estuary Impairments for Nutrients 

in Florida1

Impairment Listing Number of WBIDs2

Nutrients 36

DO 22

Both (Nutrients and DO) 36

Total 94

Source: FDEP (2011)

DO = Dissolved Oxygen

WBID = waterbody identification

1. Does not include waterbodies for which a TMDL has already been approved.

2. Includes estuaries, coastal waterbodies, and beaches.
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2.3.2 Nutrient TMDLs 

As of 2011, there are approximately 116 WBIDs for estuaries and coastal waters covered under TMDLs 

or RAs for nutrients, as show in Exhibit 2-9. 
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Exhibit 2-9: Summary of Nutrient-Related TMDLs for Estuaries and Coasts in Florida

TMDL/

Waterbody

TMDL 

Year WBIDs

Total Nitrogen Total Phosphorus

TMDL 

(lbs/yr)

Percent 

Reduction

Target 

(mg/L)

TMDL 

(lbs/yr)

Percent 

Reduction

Target 

(mg/L)

Alafia River Tidal 

Segment 2009 1621G - 54% 0.65 - - -

Allen Creek Tidal 2009 1604 - 51.5% 0.75 - - -

Arlington River 2009 2265A - - - - - -

Banana River 

above Barge 

Canal

2009 3057C 116,314 - - 7,825 - -

Banana River 

below Mathers, 

Banana River 

above 520 

Causeway

2009 3057A, 3057B 144,780 - - 12,181 - -

Bessey Creek 2008 3211 29,981 - 0.72 3,373 0.081

Bishop Creek 

Tidal 2009 1569 - 32.3% 0.75 - - -

Black Point 

Channel 2009 1637 164,120 - - - - -

Boggy Bayou 2011 692 8,115 40% - 500 37% -

Brushy Creek 2009 1498 - - 0.75 - - -

Bullfrog Creek 

Tidal Segment 2009 1666A - 47% 0.65 - - -

C-23 Canal 2008 3200 242,202 - 0.72 27,248 - 0.081

C-24 Canal 2008 3197 348,957 - 0.72 39,258 - 0.081

C-44 Canal 2008 3218 242,929 - 0.72 27,330 - 0.081

Caloosahatchee 

River 2009 3240A, 3240B, 3240C 9,086,094 - - - - -

Cockroach Bay 2009 1778 - 54% 0.54 - - -

Coffee Pot Bayou 2009 1700 - 33% 0.63 - - -

Coral Creek -

East Branch 2010 2078B - - 0.74 - - 0.044

Cross Canal -

North Tidal 2009 1625 - 54.8% 0.75 - - -

Double Branch 2009 1513F - 42.75% 0.75 - - -

Escambia Bay 2007 548AA, 

548AC - 22.9% - - 30.5% -

Florida 

Everglades 

(Agriculture Area)

2007

3252A, 

3252C, 3260, 

3263, 

- - - - - 0.1

Florida 

Everglades 

(Protection Area)

2007 3252B, 

3265F, 3265H - - - - - 0.16

Florida Keys 2008 [1] [1] [1] [1] [1] [1] [1]

Hendry Creek 2008 3258B - - 0.74 - - 0.6

Imperial River 2008 3258E 18,865 - 0.74 - - -

Indian River 

above 520 

Causeway

2009 2963D 147,524 - - 11,845 - -

Indian River 

above M. Brewer 2009 2963F 177,220 - - 9,320 - -
January 2012 2. Baseline for the Analysis

Draft for Internal Review Only-Do Not Quote or Cite

2-21

Exhibit 2-9: Summary of Nutrient-Related TMDLs for Estuaries and Coasts in Florida

TMDL/

Waterbody

TMDL 

Year WBIDs

Total Nitrogen Total Phosphorus

TMDL 

(lbs/yr)

Percent 

Reduction

Target 

(mg/L)

TMDL 

(lbs/yr)

Percent 

Reduction

Target 

(mg/L)

Indian River 

above Melbourne 

Causeway

2009 2963B, 2963C 189,068 - - 20,592 - -

Indian River 

above NASA 

Causeway

2009 2963E 173,232 - - 14,793 - -

Klosterman 

Bayou Tidal 

Segment

2008 1508 1,331 - - - - -

Lake Tarpon 

Canal Fresh 2009 1541B - 47% 0.75 - - -

Lake Tarpon 

Canal Marine 2009 1541A - 32.3% 0.75 - 26.5% 0.18

Lake Wauberg 

Outlet 2003 2741 2,062.4 51% 1.01 373.7 50% 0.056

Lower Rocky 

Creek 2009 1563 - 54.5% 0.75 - - -

Lower St. John's 

River 2008 2213A to2213H 3,035,446 - 5.4 - - -

Lower 

Sweetwater 

Creek

2004 1570A 57,565 20% - - - -

Manual Branch 2011 3240I 37,093 20% 0.53 8,490 10% 0.12

McKay Bay 2009 1584B -* 22% 0.62 - - -

Moccasin Creek 2009 1530 - 40.6% 0.75 - 40% 0.18

Mullet Creek Tidal 2009 1575 - 36.7% 0.75 - - -

Myrtle Slough 2009 1995 163,656 24.28% - 39,068 24.38% -

Myrtle Slough 2009 2054 1,300,729 23.67% - 312,000 23.50% -

Newfound Harbor 2009 3044A 30,661 - 3,247 - -

Nonsense Creek 2009 1913 - - 0.89 - -

North Fork St. 

Lucie Estuary 2008 3194B 103,747 - 0.72 11,672 - 0.081

North Fork St. 

Lucie River 2008 3194 140,134 - 0.72 15,765 - 0.081

North Prong 

Alligator Creek 2009 2071 15,481 48.07% - 3,699 47.88% -

Palm River 2009 1536E -* 35% 0.62 - - -

Peace River 

Lower Estuary 2009 2056A 8,525,972 27.81% - 2,038,559 27.79% -

Peace River Mid 

Estuary 2009 2056B 8,097,090 27.23% - 1,936,430 27.23% -

Phillippi Creek 2009 1937 73,365 70% - 20,440 70% -

Prarie Creek 2009 1962 510,831 23.72% - 122,326 23.69% -

Roberts Bay 2005 1968D 679,090 0.6% - - - -

Rocky Creek 2004 1507, 1507A 59,860 61% 0.51 10,585 59% 0.09

Old Tampa Bay 1998 1558F to

1558I 971,995 - - - - -

Hillsborough Bay 1998 1558D, 1558E 2,902,115 - - - - -
January 2012 2. Baseline for the Analysis

Draft for Internal Review Only-Do Not Quote or Cite

2-22

Exhibit 2-9: Summary of Nutrient-Related TMDLs for Estuaries and Coasts in Florida

TMDL/

Waterbody

TMDL 

Year WBIDs

Total Nitrogen Total Phosphorus

TMDL 

(lbs/yr)

Percent 

Reduction

Target 

(mg/L)

TMDL 

(lbs/yr)

Percent 

Reduction

Target 

(mg/L)

Middle Tampa 

Bay 1998 1558B, 1558C 1,597,970 - - - - -

Lower Tampa 

Bay 1998 1558A,1558BZ 697,880 - - - - -

Six Mile Creek 2009 1536F -* 32% 0.62 - - -

Smacks Bayou 2009 1683 37% 0.63 - - -

South Fork St. 

Lucie Estuary 2008 3210 24,463 - 0.72 2,752 - 0.081

South Fork St. 

Lucie River 2008 3210A 90,471 - 0.72 10,178 - 0.081

South Indian 

River 2009 5003B, 5003C 278,273 - - 53,599 - -

South Indian 

River, Indian 

River above 

Sebastian Inlet

2009 5003D, 2963A 684,715 - - 111,594 - -

Spruce Creek 2008 2674A - - - - - 0.16

St. Lucie Estuary 2008 3193 - - 0.72 - - 0.081

Stevenson Creek 2008 1567 39,915 - - - - -

Sweetwater 

Creek 2009 1516 - 22.7% 0.75 - - -

TMDL = total maximum daily load

WBID = waterbody identification

“-” = value not specified or determined in TMDL

“*” = TMDL defined in terms of concentration and not a daily load.

1. Reasonable assurance document for Florida Keys includes WBIDs: 6005EB, 6006A, 6006B, 6009, 6011A to 6011C, 

6012A to 6012D, 6013A to 6013D, 6014A to 6014C, 6016, 6017, 6018, 6019. Load allocations equal an insignificant

increase in natural background concentration at 500 meters (insignificant means less than 10 μg/l for TN and 2 μg/l for TP 

and background means the Halo Zone condition in the absence of anthropogenic loads).

FDEP typically develops plans for implementing TMDLs through the BMAP process. Currently, BMAPs 

cover 8 estuary WBIDs, and an additional 32 WBIDs are covered under Reasonable Assurance 

documents.

For the eight marine WBIDs in the Lower St. Johns River watershed, the BMAP indicates that reductions 

are needed from point and nonpoint sources. For example, the BMAP allows for aggregate permits 

(combined allocations with MS4 allocations) for municipal WWTPs that likely require upgrade to 

advanced water treatment (LSJR TMDL Executive Committee, 2008). For agriculture runoff, the BMAP 

specifies implementation of FDACS BMP manuals and construction and operation of regional storm 

water facilities (LSJR TMDL Executive Committee, 2008). For urban runoff, the BMAP identifies 

continued implementation of MS4 permits, designation of certain non-MS4 areas as Phase II MS4s, and 

voluntary permit trading schemes as measures that would likely reduce nutrient loads (LSJR TMDL 

Executive Committee, 2008). The BMAP also suggests phase-out of septic systems in specific watershed 

areas (LSJR TMDL Executive Committee, 2008).

Exhibit 2-10 provides a map of the WBIDs that are on the state’s CWA Section 303(d) list for nutrients, 

have a nutrient-related TMDL or RA, or that EPA determined to be impaired under the inland waters 

nutrient rule.
January 2012 2. Baseline for the Analysis

Draft for Internal Review Only-Do Not Quote or Cite

2-23

Exhibit 2-10: Map of Baseline WBID Impairments related to Nutrients in Florida

2.4 Summary of Assumptions and Uncertainties

This section summarizes the assumptions EPA made regarding the baseline for analyzing the potential 

incremental impacts of the proposed rule.

2.4.1 Regulatory Framework

The current regulatory framework in Florida with respect to nutrients in estuaries, bays, and coasts 

includes existing water quality criteria and procedures for identifying waters as exceeding the nutrient 

WQS. FDEP is addressing current impairments through requirements on a range of sources, established in 
January 2012 2. Baseline for the Analysis

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2-24

BMAPs. In addition, regulations of specific sources (e.g., storm water, certain agricultural producers) 

address nutrients and other pollutants in discharges, and require actions that will reduce nutrient pollution.

Because the costs and benefits of nutrient controls implemented as a result of existing regulations (e.g., 

MS4 permit requirements, FDEP dairy rule), BMAPs, TMDLs, or 303(d) listings will be incurred without 

the proposed rule, these requirements represent the baseline of this analysis. EPA assumed that additional 

controls would not be needed for these waters or areas even in cases in which existing TMDL or BMAP 

targets are less stringent than EPA’s proposed criteria because EPA assumed that FDEP will likely pursue 

approval of TN and TP targets established under existing TMDLs as site specific alternative criteria 

(SSAC). Thus, EPA did not include in this analysis costs associated with the following:

 Actions necessary to meet existing NPDES permit conditions for municipal and industrial 

wastewater

 Control actions established in existing BMAPs

 Control actions needed to reduce nutrients in waters on the 303(d) list or covered under TMDLs

 BMPs for the forestry sector

 Controls required by the FDEP Dairy Rule and EPA CAFO regulations

 Phase I and Phase II MS4 Permits

 Requirements for urban areas developed after 1982 under Florida’s stormwater rule

 Urban Turf Fertilizer Rule.

EPA also assumed that controls that it estimated may be necessary for attainment of its December 2010 

rule establishing numeric nutrient criteria for lakes and flowing waters in Florida are not attributable to 

the proposed rule. Thus, in estimating the incremental impact of the proposed rule, EPA identified the 

level of new requirements that may be needed in each potential source sector. Note that these assumptions 

could result in over or under estimation of potential costs and benefits because it is uncertain how 

effective baseline controls will be in reducing nutrients to the necessary levels under the proposed rule.

2.4.2 Sources of Nutrients

Municipal WWTPs and industrial wastewater dischargers in certain sectors have a reasonable potential to 

discharge nutrients at levels that may contribute to the exceedance of EPA’s numeric nutrient criteria. 

Nonpoint sources, including urbanized and developed land, agricultural land, and septic systems are also 

possible sources of nutrients. Due to the extent of implementation of BMPs in forestry however, EPA 

assumed that loads from forest land are not likely to be substantial. Thus, this analysis is based on the 

following assumptions:

 All municipal wastewater sources discharging to applicable waters are potentially affected by the 

rule;

 Industrial dischargers in sectors that include dischargers with current effluent limits or monitoring 

requirements for nutrients are potentially affected by the rule; and

 Urban and agricultural land and septic systems may need controls for waters to attain standards.

In contrast, loads from forest land may not substantially impact bays, estuaries, and coasts given the 

existing extent of BMP implementation in the forestry sector. Data are insufficient on atmospheric 

deposition of nutrients to estuaries, coastal waters, and south Florida inland waters for EPA to estimate 

the potential need for controls.
January 2012 2. Baseline for the Analysis

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2-25

2.4.3 Water Quality

FDEP has already listed numerous lakes and flowing waters for nutrient-related impairment under the 

existing narrative nutrient criteria, and developed TMDLs for many of these waters. Some of these 

TMDLs established TN and TP targets, and these targets are either higher or lower than the EPA numeric 

criteria. In estimating the incremental impacts associated with the rule, EPA made the following 

assumptions with respect to current water quality:

 The costs and benefits of nutrient controls for point and nonpoint sources that are already 

required under existing nutrient-related TMDLs are not attributable to this proposed rule.

 Development of TMDLs for waters on the current 303(d) list for nutrient-related impairment and 

the costs and benefits of nutrient controls needed to attain future TMDL targets associated with 

these impaired waters are not attributable to this rule.

 FDEP will likely pursue approval of TN and TP targets established under existing TMDLs as site 

specific alternative criteria (SSAC) such that this rule will not result in incremental costs or 

benefits to waters under existing TMDLs. 

Using these assumptions, EPA identified waters that may be identified as impaired under the rule but are 

not currently on the 303(d) list or under a TMDL (potential incremental impairments). 
January 2012 3. Description of the Proposed Rule

Draft for Internal Review Only-Do Not Quote or Cite

3-1

3 Description of the Proposed Rule

This section describes the proposed rule establishing numeric nutrient criteria for estuaries, coastal 

waters, and canals and natural waters in South Florida, and describes how EPA estimated potential 

attainment of the proposed criteria.

3.1 Proposed Criteria

EPA is proposing criteria for coastal waters and estuaries, inland waters that flow into coastal waters and 

estuaries (downstream protection values), tidal creeks, and marine lakes.

3.1.1 Coastal Waters

The proposed rule establishes numeric criteria for chlorophyll-a for coastal WBIDs not in South Florida. 

The proposed criteria represent annual geometric mean values not to be exceeded more than once in any 

consecutive three year period. Appendix A provides the proposed criteria for the affected WBIDs.

3.1.2 Estuaries

The proposed rule establishes numeric criteria for TN, TP, and chlorophyll-a for 23 estuary watersheds, 

divided into 126 individual segments. The proposed criteria represent annual geometric mean values not 

to be exceeded more than once in any consecutive three year period. Appendix A provides the proposed 

criteria for each segment.

3.1.3 South Florida Marine Waters

The proposed rule establishes numeric criteria for TN, TP, and chlorophyll-a for 40 marine segments 

along the South Florida coast. The proposed criteria represent annual geometric mean values not to be 

exceeded more than once in any consecutive three year period. Appendix A provides the proposed criteria 

for each segment.

3.1.4 Downstream Protection Values

The downstream protection values (DPVs) apply at pour points entering estuary watersheds. The DPV 

criteria are the same as the criteria for the segment to which each pour point empties.

3.1.5 Tidal Creeks

Tidal dominated creeks are small sub-estuaries containing a mix of tidal and freshwater flows. 

3.1.6 Marine Lakes

Marine lakes are land-locked water bodies that maintain marine character through narrow submarine 

connections to the ocean. In Florida, marine lakes have the same conductivity and alkalinity levels as 

some freshwater lakes. Thus, the proposed rule establishes the same proposed criteria for marine lakes 

that EPA promulgated for clear lakes. Note that EPA included analysis of marine lakes in its economic 

analysis for the 2010 inland (freshwater) nutrient criteria rule.
January 2012 4. Potentially Incrementally Impaired Waters

Draft for Internal Review Only-Do Not Quote or Cite

4-1

4 Potentially Incrementally Impaired Waters

This section provides a description of the data and methods EPA used to evaluate whether Florida 

estuaries, coastal waters, and inland flowing waters in South Florida are currently attaining the proposed 

criteria. EPA also presents in this section the results of the analysis, and a summary of land use 

surrounding waters that may not attain the proposed criteria.

4.1 Data

FDEP maintains a database of ambient water quality monitoring data for waters across the state and 

periodically updates this database under the impaired waters rule (IWR). The IWR database does not 

contain data for every WBID potentially affected under the rule because FDEP has not monitored all 

waters. However, the IWR database is the most extensive source of nutrient monitoring data available. 

In 1996, FDEP redesigned its watershed monitoring approach, segregating water quality monitoring into 

three tiers:

 Tier 1 includes regular monitoring, using a probabilistic monitoring design to estimate water 

quality across the state on the basis of a representative subsample of waterbodies.

 Tier 2 provides more intensive monitoring of waterbodies identified as impaired or at risk; 

FDEP implements it through strategic monitoring plans (SMPs) at the state water management 

district level.

 Tier 3 monitoring is intensive monitoring for the development of TMDLs or the investigation of 

variances or site specific alternative criteria (SSAC).

Tier 1 is implemented through two mechanisms: the Status Network and the Trend Network. There are 52 

basins in Florida, divided into 5 districts. Through the Status Network, one basin from each district is 

assessed each year. FDEP established the ordering of these assessments on the basis of various priority 

factors such as whether the water includes surface water drinking sources, whether a TMDL must be 

developed for the water, or whether SWIM plans are underway. FDEP divides waterbodies into categories 

(large lakes, small lakes, large rivers, small rivers, confined aquifers, and unconfined aquifers) and 

randomly chooses a selection of each for monitoring.

Surface water monitoring through the Trend Network consists of 75 fixed location sites in flowing waters 

that are sampled on a monthly basis. These sites enable FDEP to obtain chemistry, discharge, and loading 

data at the point where land use activities may have a large effect on the watershed. In addition, some 

sites are located at or near the Florida State boundary with Alabama and Georgia to obtain chemistry and 

loading data for major streams entering Florida. The sites are not designed to monitor point sources of 

pollution and are specifically located away from known outfalls or other regulated point source 

dischargers.

Special monitoring is also done on a subset of waterbodies that are identified as impaired or potentially 

impaired. After regular monitoring, FDEP identifies data gaps regarding these waterbodies and 

determines the number of samples for each parameter that are needed to allow assessment using the IWR 

process as described in Section 2.1.1. FDEP then prioritized these needs according to EPA’s categories 

for identifying monitoring needs:

 Any WBID on the 1998 303(d) list of impaired waters.
January 2012 4. Potentially Incrementally Impaired Waters

Draft for Internal Review Only-Do Not Quote or Cite

4-2

 Potentially impaired waters for which additional data are needed, including those identified in the 

IWR.

 Waters for which verified impaired threshold has been met, but monitoring must be maintained.

 Waters for which data are insufficient.

 Waters for which there are no data.

FDEP tracks (but does not necessarily monitor) each waterbody it identifies as needing special monitoring 

every quarter to ensure sufficient data to conduct IWR assessment.

The IWR Run 44 database contains measurements of TN, TP, and/or chlorophyll-a from January 2006

through June 2011for 415 estuaries in Florida. 

4.2 Method

Compared to current conditions, potential incrementally impaired waters under the proposed rule 

represent those waters that exceed EPA’s criteria for which FDEP has not already developed a TMDL or 

listed as impaired for nutrients and DO (because TMDLs for DO often target nutrient reductions). Using 

the last 5 years of data (2006 – mid 2011) from IWR Run 44, EPA used the following method for 

identifying potential incrementally impaired estuaries, coastal, and south Florida inland flowing waters:

 Identify all state WBIDs

 Exclude WBIDs for which this rule is not applicable (e.g., lakes and inland flowing water WBIDs 

listed as incrementally impaired under the Florida inland rule)

 Exclude WBIDs for waters on the 303(d) list or for which there is a draft or approved nutrientrelated TMDL (because EPA assumed controls to reduce nutrients already required in the absence 

of EPA’s rule would be sufficient)

 Exclude monitoring data flagged for quality concerns (e.g., result codes indicating QA/QC issues)

 Identify specifically applicable criteria for each segment or WBID on the basis of waterbody type 

(estuaries, beach, coastal) and location (see Appendix A).

o Identifying stations within 500 feet of the pour points of estuaries to which DPVs could 

apply.

 Calculate the annual geometric mean of TN, TP, and chlorophyll-a values from water quality 

stations data within a boundary (e.g., estuarine segment, coastal WBID) identified with GIS, and 

compare to applicable criteria. 

EPA used FDEP’s 2011 draft data procedures for calculating annual geometric means for TN, TP, and 

chlorophyll-a. FDEP specifies that at least four samples, with at least one sample in the summer season 

(May to September) and at least one sample in the winter season (October to April) are needed to 

calculate an annual geometric mean value. EPA assigned nondetects a value of one-half of the detection 

level in these calculations. This procedure ensures that annual assessments represent seasonal variations 

in nutrient concentration. FDEP also states that waters with insufficient data are not to be listed as 

impaired. EPA followed this same methodology and did not consider waters with insufficient data as 

potentially impaired.
January 2012 4. Potentially Incrementally Impaired Waters

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4-3

For coastal WBIDs (See Section 3.1.1), more than one annual geometric mean greater than the applicable 

numeric criterion for TN, TP, or chlorophyll-a in a three year period represents potential incremental 

impairment of the WBID. 

For applicable criteria for estuarine segments and South Florida marine segments (See Sections 3.1.2 and 

3.1.3), EPA used GIS software to match the water quality stations to their applicable segments and

calculated annual geometric means using all data for a given segment. If more than one annual geometric 

mean was greater than the applicable numeric criterion for TN, TP, or chlorophyll-a in a three year 

period, EPA identified the segment to be incrementally impaired. EPA then identified incrementally 

impaired WBIDs to be WBIDs that overlap at least 10% of its area with an incrementally impaired 

segment.

4.3 Results

Exhibit 4-1Error! Reference source not found. summarizes the potential incrementally impaired waters 

under the rule based on the analysis of water quality data described above. 

Exhibit 4-1: Summary of Potential Incremental Impairments Under the 

Proposed Rule

Category Number of Coastal and Estuarine WBIDs

Total in State 1,143

Total in Analysis1 952

Nutrient Data in IWR Run 442 513

Sufficient Data Available3 410

Potentially Exceeding Criteria4,5 230

IWR = Impaired Waters Rule

TMDL = total maximum daily load

1. Excluding waters for which FDEP has already developed a TMDL or listed as impaired for 

nutrients and DO

2. Data within last 5 years meeting data quality requirements.

3. Sufficient to calculate annual geometric means; based on at least 4 samples with at least one 

sample from May to September and one sample from October to April in a given year.

4. Based on annual geometric mean exceeding the applicable criterion more than once in a three 

year period

5. Eight coastal WBIDs meet the applicable coastal nutrient criteria but do not meet estuarine 

criteria for the segments to which they are mapped. To err on the side of estimating the maximum 

likely impacts of the rule, EPA included these WBIDs among the potential incremental impairments.

Note that, based on available data, some waters do not attain proposed criteria for TN, TP, and 

chlorophyll-a while others do not attain proposed criteria for a single pollutant. For the purpose of 

estimating controls for nonpoint sources, EPA did not distinguish among the pollutants and assumed that 

controls to reduce TN, TP, and chlorophyll-a are the same. Exhibit 4-2 shows the locations of 

incrementally impaired estuaries and coastal waters.
January 2012 4. Potentially Incrementally Impaired Waters

Draft for Internal Review Only-Do Not Quote or Cite

4-4

Exhibit 4-2: Map of Potential Incremental Waters Not Attaining the Proposed Criteria

4.3.1 Land Use Potentially Affected

Land use surrounding the potential incrementally impaired waters provides information on the types of

controls that may be needed to attain EPA’s criteria. EPA used 10-digit hydrologic unit codes (HUCs) to 

represent the watersheds for estimating land use. First EPA identified any HUC-10 watershed that 

intersected at least 10% with one of the baseline WBIDs (e.g. 303(d) listed, TMDL, or WBID already 

incrementally impaired under the inland rule) as a baseline HUC-10. Then EPA identified any HUC-10 

watershed that intersected at least 10% with an identified incrementally impaired WBID under this 

proposed rule. However, the 10-digit HUC boundaries do not overlap with most of the WBIDs 
January 2012 4. Potentially Incrementally Impaired Waters

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4-5

potentially affected by the proposed rule (e.g., estuary, coastal, and beach WBIDs). Thus, EPA could not 

use the same method it used for the inland nutrient criteria rule in which it used the percent of each WBID 

that fell within a 10-digit HUC. Rather, EPA assumed that any land in a HUC-10 (excluding baseline 

HUC-10s) potentially draining (adjacent) to an identified incrementally impaired water could need 

controls. Exhibit 4-3 summarizes the area of land in different use categories that surround potential 

incrementally impaired WBIDs identified in this proposed rule. 

Exhibit 4-3: Summary Land Use in Watersheds Surrounding Potential Incremental 

WBIDs of this Proposed Rule

Land Use Type Number of Acres Percent of Total

Agriculture 20,322 1.3%

Communications and Utilities 8,460 0.5%

Forest 662,561 42.3%

Industrial 8,834 0.6%

Other 39,016 2.5%

Transportation Corridors 18,322 1.2%

Urban 131,739 8.4%

Water 70,300 4.5%

Wetlands 605,885 38.7%

Total 1,565,439 100.0%
January 2012 5. Potential Costs for Municipal Wastewater Sources

Draft for Internal Review Only-Do Not Quote or Cite

5-1

5 Potential Costs for Municipal Wastewater Sources

Municipal wastewater dischargers receive WQBELs for pollutants of concern in NPDES permits. This 

section describes EPA’s method for estimating potential revised effluent limitations for TN and TP as a 

result of state implementation of the proposed rule, and the resulting potential pollution control actions 

and costs.

5.1 Data

EPA’s permit compliance system (PCS) database contains the municipal WWTPs with NPDES permits in 

Florida (through February 2011). Receiving waterbody name and information in NPDES permits, 

accompanying NPDES permit fact sheets, and FDEP NPDES laboratory reports indicate whether the 

WWTP discharges to an estuary or coastal water.

EPA also used FDEP’s Wastewater Facility Regulation (WAFR) database and electronically available 

permits to identify existing treatment capabilities at the potentially affected WWTPs to determine whether 

an additional level of treatment would be necessary under the proposed rule.

5.2 Method

EPA evaluated existing FDEP procedures for implementing WQBELs and setting effluent limits based on 

WLAs in existing nutrient TMDLs as a basis for estimating likely state implementation of the numeric 

criteria contained in the proposed rule. NPDES-permitted wastewater sources may receive revised 

WQBELs reflecting the proposed criteria whether or not the receiving WBID is identified as potentially 

incrementally impaired under this proposed rule.

5.2.1 Reasonable Potential

NPDES permitting authorities determine the need for WQBELs for point sources based on analysis of 

reasonable potential to exceed the water quality criteria. The proposed rule does not include 

implementation procedures for determining reasonable potential. However, for pollutants with numeric 

criteria, FDEP generally follows the procedures in EPA’s Technical Support Document for Water 

Quality-Based Toxics Control (U.S. EPA, 1991)for other pollutants with numeric criteria. For example, 

for aquatic life criteria, the Technical Support Document for Water Quality-Based Toxics Control (U.S. 

EPA, 1991)recommends finding that a permittee has reasonable potential if it cannot be demonstrated 

with a high confidence level that the upper bound of the lognormal distribution of effluent concentrations 

is below the criteria at specified low-flow conditions (U.S. EPA, 1991). 

Medium to highly concentrated untreated domestic wastewater typically contains 40 mg/L to 70 mg/L of 

TN and 7 mg/L to 12 mg/L of TP (Metcalf and Eddy, 2003). Effluent concentrations of TN and TP in 

treated domestic wastewater depend on the treatment used. For example, activated sludge with single 

stage nitrification results in typical TN concentrations of 20 mg/L to 30 mg/L and TP concentrations of 

6 mg/L to 10 mg/L (Metcalf and Eddy, 2003). For advanced nutrient removal, technologies are available 

to reliably attain an annual average of 3 mg/L for TN and 0.1 mg/L or less for TP. (U.S. EPA, 2008). 

Based on information from FDEP’s WAFR database and electronically available permits, all municipal 

WWTPs discharging to potentially affected waters operate at least secondary treatment (e.g., activated 

sludge with single stage nitrification), with a number operating advanced nutrient removal. Effluent 

concentrations of 3 mg/L for TN and 0.1 mg/L for TP are the target levels of treatment for this analysis. 
January 2012 5. Potential Costs for Municipal Wastewater Sources

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5-2

To determine reasonable potential on a facility-specific basis, site specific data such as instream nutrient 

concentrations and low flow conditions would be necessary. However, because most WWTPs are likely 

to discharge nutrients at concentrations above applicable TN and/or TP criteria, EPA assumed that all 

WWTPs would have reasonable potential to cause or contribute to an exceedance of the proposed 

numeric criteria.

5.2.2 Projected Effluent Limits

Based on EPA’s Technical Support Document for Water Quality-Based Toxics Control (U.S. EPA, 

1991)procedures, dischargers with reasonable potential would likely receive WQBELs based on Chapter 

62-650, F.A.C., Water Quality Based Effluent Limitations, which requires effluent limits to be based on 

the characteristics of discharge, the receiving water characteristics, and applicable criteria. Because data 

on water low flow conditions and other site specific data are not available for every discharger, EPA 

assumed for this analysis that dischargers would receive effluent limits equal to the numeric nutrient 

criteria (i.e, assumption of no dilution). Applying criteria end-of-pipe would also prevent a discharger 

from causing an additional impairment. 

FDEP’s TMDL Protocol (FDEP, 2006a) states that because point source dischargers already generally 

provide a high level of treatment, initial control strategies to be considered may generally pertain to 

stormwater point and nonpoint sources. For example, in the Roberts Bay Nutrient TMDL (U.S. EPA 

Region 4, 2005), point source WLAs are set at existing permitted loads because each facility had made 

significant reductions in their permitted discharge, and provided treatment beyond technology-based 

effluent treatment levels for nitrogen. 

For this analysis, consistent with FDEP’s existing permitting procedures for TMDLs, EPA assumed 

dischargers would receive WQBELs based on levels attainable with advanced nutrient removal (3 mg/L 

TN and 0.1 mg/L TP; see Section 5.2.3).

5.2.3 Potential Compliance Options

Potential controls to reduce TN and TP in WWTP effluents include biological nutrient removal (BNR), 

chemical precipitation, and effluent reuse. The specific level of performance achieved through 

implementation of advanced wastewater treatment systems can vary based on factors such as influent 

water quality, climate, and operator experience. For example, EPA (2008) reports WWTPs are achieving 

average TN values ranging from 3.5 mg/L to 1.3 mg/L and TP values ranging from 0.43 mg/L to 0.09 

mg/L with advanced nutrient removal technologies that target both nitrogen and phosphorus. 

EPA recognizes that most numeric nutrient criteria for TN and TP criteria for estuaries and DPVs are 

below 3 mg/L TN and 0.1 mg/L or less for TP target performance levels. In these cases, EPA assumed 

that the discharger will either implement technology consistent with levels that attain an annual average 

of 3 mg/L for TN and 0.1 mg/L or less for TP and achieve performance at levels that meet the WQBEL, 

or cannot achieve the required performance level and pursue other means of complying with WQS such 

as site specific alternative criteria, variances, or use designation modifications. 

BNR 

BNR removes TN and TP from wastewater through the use of microorganisms under different 

environmental conditions in the treatment process (Metcalf and Eddy, 2003). There are a number of BNR 

process configurations available. Some BNR systems are designed to remove only TN or only TP, while 

others remove both. BNR configurations vary in their sequencing of environmental conditions (i.e., 
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aerobic, anaerobic, or anoxic)9 and timing (Jeyanayagam, 2005). Common BNR system configurations 

include:

 Modified Ludzack-Ettinger (MLE) Process – continuous-flow suspended-growth process with an 

initial anoxic stage followed by an aerobic stage; used to remove TN

 Anaerobic-Anoxic Oxidation (A2

/O) Process – MLE process preceded by an initial anaerobic stage; 

used to remove both TN and TP

 Step Feed Process – alternating anoxic and aerobic stages; however, influent flow is split to several 

feed locations and the recycle sludge stream is sent to the beginning of the process; used to remove TN

 Bardenpho Process (Four-Stage) – continuous-flow suspended-growth process with alternating 

anoxic/aerobic/anoxic/aerobic stages; used to remove TN

 Modified Bardenpho Process – Bardenpho process with addition of an initial anaerobic zone; used to 

remove both TN and TP 

 Sequencing Batch Reactor (SBR) Process – suspended-growth batch process sequenced to simulate 

the four-stage process; used to remove TN (TP removal is inconsistent)

 Modified University of Cape Town (UCT) Process – A2

/O Process with a second anoxic stage where 

the internal nitrate recycle is returned; used to remove both TN and TP

 Oxidation Ditch – continuous-flow process using looped channels to create time sequenced anoxic, 

aerobic, and anaerobic zones; used to remove both TN and TP.

Exhibit 5-1 provides a comparison of the TN and TP removal capabilities of common BNR 

configurations. Because the performance of each process is dependent on site specific conditions, this 

exhibit represents only a general comparison of treatment performance among different BNR 

configurations.

Exhibit 5-1: Comparison of Common BNR Configurations

Process Nitrogen Removal Phosphorus Removal

MLE Good None

A2/O Good Good

Step Feed Moderate None

Four-Stage Bardenpho Excellent None

Modified (Five-Stage) Bardenpho Excellent Good

SBR Moderate Inconsistent

Modified UCT Good Excellent

Oxidation Ditch Excellent Good

Source: Jeyanayagam (2005).

A2/O = anaerobic-anoxic oxidation

BNR = biological nutrient removal

MLE = Modified Ludzack-Ettinger

SBR = Sequencing Batch Reactor

UCT = University of Cape Town

 9 Anoxic is a condition in which oxygen is available only in the combined form (e.g., NO2- or NO3-). However, anaerobic is a 

condition in which neither free nor combined oxygen is available (WEF and ASCE/EWRI, 2006).
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Most large treatment plants should be able to achieve effluent concentrations of 3 mg/L for TN and 0.1 

mg/L for TP (Jeyanayagam, 2005; CBP, 2002). However, site specific conditions may allow some 

facilities to achieve even lower concentrations. 

For example, the City of Clearwater, Florida, operates two five-stage Bardenpho WWTPs. The second 

anoxic zone in the process provides denitrification of the nitrates created in the aeration zone (U.S. EPA, 

2008). TP is removed biologically in the anaerobic zone, and alum is fed to the second anoxic zone (the 

fourth reaction basin) for the dual purpose of phosphorus polishing and meeting the state requirement of 

low-level trihalomethane levels in the reuse water (U.S. EPA, 2008). In addition, a gravity sand filter is 

used to remove phosphorus tied to suspended solids in the final effluent. The annual average 

concentrations are 2.32 mg/L TN and 0.11 mg/L TP at the Marshall Street plant, and 2.04 mg/L TN and 

0.20 mg/L TP at the Northeast plant. Both plants operate with high efficiency and low variability (U.S. 

EPA, 2008). 

In addition, the Lee County, Fiesta Village WWTP employs oxidation ditches with methanol addition 

prior to denitrification filters to achieve an annual average TN concentration of 1.38 mg/L (U.S. EPA, 

2008). To achieve average effluent TP concentrations of 0.1 mg/L, the facility uses alum addition and the 

denitrification filters to remove particulate phosphorus (U.S. EPA, 2008).

Chemical Precipitation

Chemical precipitation primarily uses aluminum and iron coagulants or lime to form chemical flocs with 

phosphorus. These flocs then settle out to remove phosphorus from the wastewater (Viessman and 

Hammer, 1998). Compared to biological removal of phosphorus, however, chemical processes have 

higher operating costs, produce more sludge, and result in added chemicals in sludge (Metcalf and Eddy, 

2003). When TP levels close to 0.1 mg/L are required, a combination of biological and chemical 

processes may be less costly than either process by itself. In addition, chemical precipitation can be 

coupled with filtration to achieve levels at or below 0.1 mg/L. For example, EPA (2008) provides the 

following examples of WWTPs with low TP effluent concentrations:

 Lee County, Florida: Oxidation ditch with denitrification filter with alum, TP = 0.098 mg/L

 Chelsea, Michigan: Chemical addition with flocculating clarifier, TP = 0.09 mg/L (full-year data)

 McMinnville, Oregon: Chemical addition with tertiary clarifier and filter, TP = 0.058 mg/L (seasonal, 

6 months of data)

 Pinery, Colorado: 5-Stage Bardenpho with chemical and filter, TP = 0.031 mg/L

 Breckenridge, Colorado: Enhanced biological phosphorus removal with chemical addition and filter, 

TP = 0.01 mg/L (literature report)

 Brighton, Michigan: Chemical addition with tertiary filter and infiltration basin, TP = 0.01 mg/L (full 

year data)

Effluent Reuse

Effluent reuse does not reduce the concentration of nutrients in the effluent. However, partial effluent 

reuse (e.g., a portion of the wastewater is discharged to the receiving water and a portion is used in reuse 

applications) can decrease the volume of nutrient-containing wastewater discharged, decreasing the total 

nutrient load to the receiving water sufficient to meet the WQS. If the waterbody has no assimilative 

capacity, only 100% effluent reuse (i.e., no discharge to the receiving water) would be allowable.
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Effluent water can be reused for several nonpotable purposes including agricultural and landscape 

irrigation, industrial uses, and groundwater recharge. Costs associated with reuse applications include 

conveyance systems and storage tanks for reuse water as well as additional treatment that may be needed 

to meet reuse standards (e.g., low bacteria and turbidity concentrations). FDEP has adopted reused water 

standards that ensure protection of human health, such as the APRICOT Act of 1994 that contains 

provisions for backup water discharges and groundwater injection. However, the feasibility of effluent 

reuse as a control option for reducing nutrient loads to receiving waters depends on demand for reuse 

water. 

Site Specific Alternative Criteria

If the characteristics of a receiving water allow attainment of designated uses with nutrient concentrations 

higher than EPA’s proposed criteria, SSAC may be developed that could result in less stringent effluent 

limitations. Because dischargers may be required to obtain additional data to assess the appropriateness of 

SSAC, the extent to which dischargers use this mechanism to obtain regulatory relief is uncertain. 

However, there may be a greater likelihood of pursuing SSAC in cases where using data and scientific 

evaluations associated with previous TMDL development efforts can result in significant cost savings.

Variances

Following EPA’s Technical Support Document for Water Quality-Based Toxics Control (U.S. EPA, 

1991) procedures, if dilution is not available, WQBELs based on criteria end-of-pipe could be below the 

levels that can be reliably attained with advanced nutrient removal technologies (3 mg/L TN and 0.1 

mg/L TP). In these cases, the discharger may request a variance for reductions beyond those attainable 

with advanced nutrient removal technologies (e.g., available cost-effective treatment controls).

Section 120.542, F.S. indicates that FDEP is authorized to grant variances to requirements of their rules 

or to rules required by EPA with approval of the variance from EPA. Under Chapter 62-110.104, F.A.C.,

a discharger must demonstrate that any hardship asserted as a basis for the need to receive a specific

variance is peculiar to the affected property and not self-imposed, and that the grant of a variance will be 

consistent with the general intent and purpose of Chapter 403, F.S. (Environmental Control Chapter of 

Florida Statutes), as applicable. 

To demonstrate the need for a variance under these statutes and procedures, dischargers would likely 

prepare documentation of the conditions warranting the variance. For example, to evaluate the potential 

for control costs to cause economic and social hardship, dischargers are likely to follow EPA’s (1995) 

Interim Economic Guidance for Water Quality Standards Workbook which provides worksheets and 

instructions for public and private sector entities. Following EPA (1995), dischargers conduct a two-step 

analysis, first determining whether the control costs would have a substantial adverse financial impact 

and, if so, whether that impact would cause widespread adverse impacts on the surrounding community. 

5.2.4 Potentially Affected Sources

To identify potential incremental treatment needs, EPA compared existing requirements and current 

treatment capabilities for municipal dischargers to the estimated revised effluent limits for TN and TP. 

Completed TMDLs for potentially affected waters provide wasteload allocations (WLAs) for both TN 

and TP for 14 municipal WWTPs, and for only TN for 26 WWTPs. EPA assumed that FDEP would 

likely seek to adopt the current TMDL nutrient targets as SSAC because scientific analysis has 

determined that they represent the maximum allowable nutrient loads for these waters. Because these 

dischargers are already required to meet the WLAs in the TMDLs, EPA assumed that additional treatment 

would only be needed for TP for the dischargers that currently have only WLAs for TN.
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In addition, EPA identified 12 municipal WWTPs discharging to waters listed as impaired for nutrients 

and/or DO on the state’s current 303(d) list. EPA assumed that in the absence of its rule, these dischargers 

would be given WLAs under a TMDL. Thus, costs to reduce nutrients at these WWTPs would be 

attributable to the existing impairment and not the proposed rule. However, EPA also conducted 

sensitivity analyses of the potential for additional controls under the proposed rule if these WLAs require 

reductions for only TN or TP and not both pollutants (as is the case with several existing TMDLs).

Similarly, EPA identified 8 WWTPs discharging to the Atlantic Ocean for which existing regulations 

(e.g., Grizzle-Figg Act) already require treatment to 3 mg/L TN and 1 mg/L TP by 2018, and elimination 

of all discharges (except in emergency situations) by 2025. For this analysis, EPA assumed that no 

additional treatment controls would be needed for compliance with the proposed rule because facilities 

would likely receive a temporary variance or interim limits that would apply until the time in which the 

discharge would need to be eliminated.

Lastly, EPA identified another 2 WWTPs covered under the Grizzle-Figg Act which already requires 

dischargers to meet advanced wastewater treatment levels of 3 mg/L for TN and 1 mg/L for TP. 

Therefore, EPA assumed that only additional treatment for TP would be needed for compliance with 

potential revised effluent limits. 

EPA used FDEP’s WAFR database and electronically available permits to identify existing treatment 

capabilities of WWTPs. There are 11 dischargers already operating treatment processes capable of 

achieving levels of 3 mg/L for TN and 0.1 mg/L for TP (e.g., A2

/O, modified Bardenpho, modified UCT, 

oxidation ditches or other BNR coupled with chemical precipitation). A total of 19 dischargers are already 

operating treatment processes that remove only TN to levels of 3 mg/L (consistent with performance of 

MLE and four-stage Bardenpho processes), and 2 are operating processes that remove only TP to levels 

of 0.1 mg/L (consistent with chemical precipitation without BNR). Note that these counts include 

dischargers covered under baseline regulations or provisions as described above. Municipal WWTPs 

without these configurations or those not operating advanced nutrient removal technologies would likely 

need to retrofit existing treatment to reduce nutrients to the necessary levels. 

Exhibit 5-2 summarizes the varying levels of treatment that could be required by municipal WWTPs 

under the proposed rule based on the current regulatory framework and existing effluent treatment 

controls.
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Exhibit 5-2: Potential Treatment Required for Municipal Wastewater Treatment Plants

Discharger

Category

Number of Dischargers

Reduce TN 

and TP1

Reduce TN 

Only2

Reduce TP 

Only3

No 

Reductions4 Total

Major 9 0 31 29 69

Minor 24 2 1 11 38

Total 33 2 32 40 107

Source: Based on treatment train descriptions in FDEP (2009) and permits, WLAs in TMDLs and existing 

regulations, assuming dischargers would have to install advanced BNR for compliance under the rule.

A2/O = anaerobic-anoxic oxidation

BNR = biological nutrient removal

MLE = Modified Ludzack-Ettinger

TMDL = total maximum daily load

TN = total nitrogen

TP = total phosphorus

UCT = University of Cape Town

WLA = wasteload allocation

1. Includes dischargers without treatment processes capable of achieving the target levels or existing WLA for TN 

and TP, or for which the treatment train description is missing or unclear. 

2. Includes dischargers with chemical precipitation only.

3. Includes dischargers with MLE, four-stage Bardenpho, and BNR specified to achieve less than 3 mg/L, those with 

WLA under a TMDL for TN only, or those covered under the Grizzle-Figg Act.

4. Includes dischargers with A2/O, modified Bardenpho, modified UCT, oxidation ditches, or other BNR coupled with 

chemical precipitation, those with WLAs under a TMDL for both TN and TP, those discharging to waters on the 

303(d) list for nutrients or DO, and ocean dischargers.

5.2.5 Unit Control Costs

EPA (2008) provides unit cost estimates for advanced nutrient removal technologies retrofits and 

expansions for various TN and TP performance levels. Exhibit 5-3 shows retrofit and expansion costs for 

estimates EPA (2008) derived from wastewater treatment cost estimating software (CAPDETWorks). The 

costs for those facilities represent estimated design costs and not actual installed process costs. 

Exhibit 5-3: Unit Costs for BNR (2010 dollars)

Description Capital (million 

$/gpd)1 O&M ($/MG/day)

TN Less Than 3 mg/L

Phased oxidation ditch retrofit $0.52 $49

MLE retrofit $0.79 $91

Step-feed retrofit $0.72 $101

Denitrification filter retrofit $0.79 $173

Average $0.70 $103

TP Less Than 0.1 mg/L

Fermenter, sand filtration, and 1-pt chemical addition retrofit $0.52 $118

2-pt chemical addition and filter retrofit $0.32 $238

2-pt chemical addition and filter expansion $0.32 $238

A/O with fermenter, filter, and chemical addition expansion $1.72 $431

Average $0.72 $256
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Exhibit 5-3: Unit Costs for BNR (2010 dollars)

Description Capital (million 

$/gpd)1 O&M ($/MG/day)

TN Less Than 3 mg/L and TP Less Than 0.1 mg/L

PID retrofit with 1-pt chemical addition, clarifier, and filter $0.99 $221

5-stage Bardenpho and chemical addition retrofit $1.44 $284

Nitrification, chemical addition, and denitrification filter retrofit $0.83 $497

Nitrification with 1-point chemical addition and denitrification 

filter expansion $0.83 $497

5-stage Bardenpho, chemical addition, and filter expansion $2.75 $529

Average $1.37 $405

Source: U.S. EPA (2008). Estimates developed using CAPDETWorks software, and flow of 10 mgd.

A/O = anaerobic/oxic

BNR = biological nutrient removal

gpd = gallons per day

MG = million gallons

mgd = million gallons per day

mg/L = milligrams per liter

O&M = operation and maintenance

TN = total nitrogen

TP = total phosphorus

WWTP = wastewater treatment plant

1. Capital and O&M costs updated from original reported year dollars (May 2007 and July 2007) to June 2010 

dollars using the Engineering News Record Construction Cost Index (index values of 7942, 7959, and 8566 for May 

2007, July 2007, and June 2010, respectively).

5.2.6 Potential Total Costs

EPA estimated potential total control costs based on the treatment scenario shown in Exhibit 5-2 and 

assuming the average unit costs shown in Exhibit 5-3 are indicative of those that similar facilities in 

Florida would incur to implement advanced nutrient removal technologies. Exhibit 5-4 summarizes the 

potential costs to municipal WWTPs, which could total approximately $94.2 million annually (based on 

annualizing capital costs at 7% over 20 years and adding annual O&M. All estimates reflect the unit costs 

multiplied by total flows contained in EPA’s PCS database, as shown in Appendix B. 

Exhibit 5-4: Summary of Potential Municipal WWTP Compliance Costs 

Reductions 

Needed

Facilities Costs (millions 2010 dollars)

Number Flow (mgd) Capital O&M 

($/year)

Total Annual

($/year)1

TN <3 mg/L; 

TP <0.1 mg/L 33 216 $294.8 $31.9 $59.7

TN <3 mg/L 2 0.3 $0.2 $0.01 $0.03

TP <0.1 mg/L 32 213 $153.5 $19.9 $34.4

None 40 660 $0.0 $0.0 $0.0

Total 107 1,089 $449 $52 $94.2

mgd = million gallons per day

mg/L = milligrams per liter

O&M = operation and maintenance

TN = total nitrogen

TP = total phosphorus

WWTP = wastewater treatment plant

1. Capital costs annualized at 7% over 20 years, plus annual O&M.
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5-9

This estimate does not include costs to facilities discharging to 303(d) list waters for nutrient-related 

causes since these controls would likely be needed in the absence of the rule. However, existing nutrient –

related TMDLs for Florida waters sometimes establish WLAs for only the limiting pollutant and not TN 

and TP both. Since EPA is proposing both TN and TP criteria for estuaries and inland flowing waters in 

South Florida, these facilities could receive WLAs for both TN and TP, instead of just the limiting 

pollutant. Exhibit 5-5 summarizes the sensitivity of the cost estimate to the inclusion of these incremental 

impacts.

Exhibit 5-5: Summary of Sensitivity Analysis for Potential Municipal WWTP Compliance 

Costs (millions 2010 dollars)

Compliance Scenario Capital O&M ($/yr) Total Annual ($/yr)1

Base case plus controls for TP for 9 

dischargers to 303(d) listed waters 

without compliance technologies in place2

$553 $65 $117.5

Base case plus controls for TN for 6 

dischargers to 303(d) listed waters 

without compliance technologies in place3

$474 $53 $98

1. Capital costs annualized at 7% over 20 years plus annual O&M costs.

2. Reflects potential that the TMDL could include WLAs for TN only in the absence of the proposed rule.

3. Reflects potential that the TMDL could include WLAs for TP only in the absence of the proposed rule.

For most estuaries and coastal waters, the growth-limiting nutrient (i.e., the chemical which largely 

controls the rate of primary production) is nitrogen, such that it is the reduction in the supply of nitrogen 

that is the primary focus of most estuarine nutrient TMDLs. EPA therefore presents the range from base 

case to base case plus controls for TP for 9 dischargers to 303(d) listed waters in the total cost analysis.
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6-1

6 Potential Costs for Industrial Wastewater Sources

The proposed criteria may result in industrial sources of wastewater to estuaries, coastal waters, and south 

Florida inland waters receiving revised WQBELs in NPDES permits, depending on whether there is

potential for these discharges to cause or contribute to exceedance of a WQS. Unlike municipal WWTPs, 

however, not all industrial dischargers are likely to discharge nutrients because industrial processes, 

treatments, and waste stream compositions vary widely. This section describes how EPA identified 

industrial wastewater sources with the potential to receive revised effluent limitations for TN and TP as a 

result of state implementation of the proposed rule, and the resulting potential pollution control costs.

6.1 Data

EPA’s PCS database provides information on numeric effluent limits and permit monitoring requirements 

for industrial dischargers in Florida (Exhibit 2-4). EPA used the standard industrial classification (SIC) 

codes of those dischargers with current limits or monitoring requirements for nutrients to identify the

universe of facilities with potential to discharge nutrients at levels of concern for the numeric criteria.

10

This analysis resulted in identification of 51 industrial facilities that discharge to estuaries, coastal waters, 

and south Florida inland waters potentially affected by the proposed rule. 

Completed nutrient and DO TMDLs for estuaries, bays, coastal waters, and South Florida canals indicate 

that 4 of the 51 potentially affected dischargers have WLAs for both TN and TP. As with municipal 

WWTPs, EPA assumed that FDEP would likely seek to adopt the current TMDL nutrient targets as SSAC 

because scientific analysis has determined that they represent the maximum allowable nutrient 

concentrations for these waters to meet designated uses. Because these dischargers are currently required

to meet allowable nutrient discharge requirements, EPA assumed that additional treatment would not be 

needed for dischargers under a nutrient-related TMDL. 

In addition, EPA also identified 6 industrial dischargers out of the 51 potentially affected facilities that 

discharge to waters listed as impaired for nutrients and/or DO on the current 303(d) list in Florida. EPA 

assumed that in the absence of the proposed rule, these dischargers would be given WLAs under a 

TMDL. Thus, costs to reduce nutrients at these facilities would be attributable to the existing impairment 

and not the proposed rule.

Exhibit 6-1 categorizes the remaining 41 dischargers possibly subject to WQBELs as a result of EPA’s 

criteria by industrial sector.

Exhibit 6-1: Summary of Potentially Affected Industrial Dischargers

Industrial Category Major Dischargers Minor Dischargers Total Dischargers

Chemicals and Allied Products 1 2 3

Electric Services 12 - 12

Food 2 1 3

Mining 1 1 2

Other - 18 18

Pulp and Paper 3 - 3

Total 19 22 41

U.S. EPA (2011).

 10 PCS contains SIC codes rather than North American Industry Classification System (NAICS) codes. 
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6-2

6.2 Method

Treatment to reduce nutrient levels from industrial sources is facility-specific and varies based on process 

operations, existing treatment train, and composition of waste streams. Thus, EPA estimated the potential 

compliance actions and costs that may be associated with the proposed rule for industrial dischargers 

through evaluation of individual facility permits, fact sheets, and effluent monitoring data.

6.2.1 Reasonable Potential

EPA evaluated the potential need for compliance controls and their costs for each major and minor 

industrial discharger. To estimate potential control costs, EPA first determined whether the dischargers 

would have reasonable potential to cause or contribute to an exceedance of the numeric TN and TP 

criteria using effluent data for discharge flows, TN, and TP from EPA’s PCS database and other

information in the facility’s NPDES permit. For those with reasonable potential, EPA estimated projected 

revised WQBELs, calculated based on available dilution, if any. Where no dilution is available, EPA

assumed that the average monthly effluent limit would be equal to the criterion. In cases in which dilution 

is available, EPA multiplied the applicable criterion by the dilution ratio.

If current data indicated that the facility would not be in compliance with the potential revised WQBEL, 

EPA determined the pollution controls most likely necessary for compliance and the cost of those 

controls. Appendix C provides the detailed analysis for each of the dischargers. 

6.2.2 Potential Compliance Options

Potential controls to reduce TN and TP in industrial effluents may include BNR, chemical precipitation 

with or without filtration, reverse osmosis, and source control.

BNR 

BNR removes TN and TP from wastewater through the use of microorganisms under different 

environmental conditions in the treatment process (Metcalf and Eddy, 2003). A certain amount of 

biological organisms must be present in the wastewater for biological treatment to be feasible for 

industrial wastewater. Thus, EPA assumed BNR a feasible control option for any industrial discharger 

currently operating any type of biological treatment (e.g., activated sludge). Section 5.2.3 discusses 

available BNR process configurations, and provides potential unit cost estimates that may also be 

applicable for industrial waste treatment.

Chemical Precipitation

Chemical precipitation may be a feasible compliance option for industrial facilities. EPA assumed that 

chemical precipitation could be employed at any type of industrial facility. Section 5.2.3 provides detailed 

estimates of potential unit costs for chemical precipitation that may also be applicable for industrial waste 

treatment.

Reverse Osmosis

Advanced BNR is not effective for removing the dissolved fraction of organic nitrogen, and BNR and 

chemical precipitation cannot remove dissolved phosphorus to extremely low levels, as shown in Exhibit 

6-2.
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6-3

Exhibit 6-2: Effectiveness of Common Removal Mechanisms for Reducing Various 

Fractions of Nitrogen and Phosphorus

Pollutant Species Common Removal Mechanism Technology Limit for 

Removal Mechanisms (mg/L)

Ammonia-Nitrogen Nitrification <0.5

Nitrate-Nitrogen Denitrification 1 – 2

Particulate Organic Nitrogen Solids Separation <1

Dissolved Organic Nitrogen None 0.5 – 1.5

Dissolved Phosphorus Microbial Uptake; Chemical Precipitation 0.1

Particulate Phosphorus Solids Separation <0.05

Source: Jeyanayagam (2005)

Industrial wastewater may contain dissolved organic nitrogen and phosphorus concentrations at levels 

above the applicable criteria (note that without facility-specific laboratory analysis of TN and TP 

components, EPA cannot evaluate the fraction of dissolved organic species at each facility). However, 

RO is capable of targeting and removing the dissolved organic fraction from wastewater effluents.

Reverse osmosis entails using a porous membrane to separate desired components (e.g., water) from 

undesired components (e.g., dissolved nitrogen or phosphorus). The membranes control the flow of ionic 

species across the membrane. Under normal osmosis conditions, solvent permeates the membrane from 

the low concentration side to the high concentration side. Under reverse osmosis, the application of 

external pressure on the high concentration side forces the solute to permeate the membrane into the low 

concentration side. According to Ahn and James (1999), RO effectively removes dissolved nonbiodegradable organic matter (including dissolved organic nitrogen). 

There are a number of studies that examine the effectiveness of RO for removing nutrients from domestic 

and industrial wastewater. Most of the available literature pertains to bench- (i.e., laboratory) and pilotscale RO units. However, Merlo et al. (2011) provides full scale data for RO plants treating domestic 

wastewater (note that these plants are not discharging to surface water under NPDES permits but rather 

treat effluent from domestic wastewater treatment plants with RO for use in replenishing groundwater or 

contributing to blended drinking water). Merlo et al. (2011) reported TN removal rates ranging from 84% 

to 91% and removal rates for organic nitrogen from 65% to 95%. The lower removal efficiencies occur 

where RO is preceded by ultrafiltration rather than microfiltration. Phosphate results from van 

Voorthuizen et al. (2005) show removal efficiency rates from 93% to 98%. However, none of the studies 

demonstrate effluent concentrations below 1.4 mg/L TN or 0.1 mg/L phosphate.

Carollo Engineers (2010) estimated capital and O&M costs for RO with microfiltration of $8.10/gpd and 

$3,000/MG, respectively, for Florida dischargers based on bid-data available from eleven wastewater 

treatment plants. The unit costs include costs associated with residual disposal via a brine concentrator.

However, although removal efficiencies are high for TN and TP, limited performance data result in 

significant uncertainty regarding the effluent concentrations that can be achieved with RO. For example, 

it is uncertain whether efficiencies greatly decrease with decreasing influent concentrations or whether 

there is some limit to the technology beyond which it cannot improve. For extremely low TN and TP 

levels, RO may become cost prohibitive due to the need to operate multiple units in series (to increase 

removal rates) or issues regarding residuals disposal.
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6-4

Source Control

Source control targets reductions in pollutants at the source of entry into the wastewater system or within 

a specific treatment process rather than targeting reductions in total effluent. In most cases, it is more cost 

effective for industrial dischargers to control the source of nutrients in the effluent through BMPs, product 

substitution, process modifications, or process optimization than to treat the entire effluent prior to 

discharge. For example, in the Chesapeake Bay most industrial dischargers have reduced nutrient loads 

through pollution prevention (CBP, 2004).

Source control can include a wide variety of activities. For example, to meet its WLA under the LSJR 

TMDL, Anheuser Busch improved pond nutrient removal at its Lem Turner location with hyacinth 

management, a baffle system to improve retention time, and the use of aeration in some zones. To reduce 

the nutrient load at its Main Street location, the discharger increased the crop area to which they land 

applied a portion of the wastewater (Busby, 2009). Also under the LSJR TMDL, Georgia Pacific reduced 

the amount of nutrients added to its treatment ponds (Busby, 2009).

Variance

Section 120.542, F.S. indicates that FDEP is authorized to grant variances to requirements of their rules 

or to rules required by EPA with approval of the variance from EPA. Under Chapter 62-110.104, F.A.C. a 

discharger must demonstrate that any hardship asserted as a basis of the need for a specific variance is 

peculiar to the affected property and not self-imposed, and that the grant of a variance will be consistent 

with the general intent and purpose of Chapter 403, F.S. (Environmental Control Chapter of Florida 

Statutes), as applicable. Any person seeking such a variance shall file a petition containing the following 

information:

 The petitioner’s name and signature

 The statute or rule from which the variance is sought

 Facts showing that a variance should be granted for one of the reasons set forth in Section 403.201, 

F.S.:

There is no practicable means known or available for the adequate control of the pollution

Compliance with the particular requirement or requirements from which a variance is sought will 

necessitate the taking of measures which, because of their extent or cost, must be spread over a 

considerable period of time 

To relieve or prevent hardship of a kind other than those provided for above

The period for which the variance is sought, including the reasons and facts supporting the period

The requirements that the petitioner can meet, including the date or time when they will be met

The steps or measures that the petitioner is taking to meet the requirement from which the variance 

is sought; if the request is pursuant to paragraph 403.201(1)(b), Florida Statutes, the petitioner shall 

include a schedule when compliance will be achieved

The social, economic, and environmental impacts on the applicant and on residents of the area and 

of the state if the variance is granted

The social, economic, and environmental impacts on the applicant and on residents of the area and 

of the state if the variance is denied.
January 2012 6. Potential Costs for Industrial Wastewater Sources

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6-5

Section 403.201, F.S. also states that FDEP should not grant a variance which would result in the 

provision or requirement being less stringent than a comparable federal provision or requirement. 

However, EPA’s numeric nutrient criteria represent a translation of the existing narrative nutrient criteria

in Florida to provide more effective implementation, not a more stringent requirement.

6.2.3 Potential Control Costs

To estimate total statewide costs, EPA calculated the estimated average treatment unit cost for the 

facilities by industrial category. EPA then multiplied the average unit cost by the flow reported in PCS. 

For those facilities for which flow is not reported in PCS, EPA used the average flow of the other major 

or minor facilities in that industrial category (as shown in Appendix C).

Error! Reference source not found. shows EPA’s estimate of potential statewide industrial discharger 

costs.

Exhibit 6-3: Estimated Statewide Annual Industrial Control Costs

Industrial Category Total Number of Facilities Total Annual Costs (million $/yr)

Chemicals and Allied Products 3 $0.30

Electric Services 12 $0

Food 3 $0.17

Mining 2 $0.04

Other 18 $0

Pulp and Paper 3 $7.13

Total 41 $7.6

mgd = million gallons per day

1. Estimated annual cost divided by flow.
January 2012 7. Potential Costs to Urban Stormwater Sources

Draft for Internal Review Only-Do Not Quote or Cite

7-1

7 Potential Costs to Urban Stormwater Sources

State implementation of the proposed criteria may affect urban stormwater dischargers through changes to 

NPDES permit requirements, and the development of TMDLs and BMAPs. This section provides 

estimates of urban land that may require additional nutrient controls as a result of state implementation of 

EPA’s rule and potential control costs that may be needed to attain EPA’s criteria. These estimates are 

only approximations for informational purposes; actual control actions will depend on site specific 

conditions and control strategies.

7.1 Data

As shown in Exhibit 4-3, urban land use (excluding industrial land, mine land, and 

inactive/underdeveloped land) accounts for approximately 8% of the land use in watersheds draining to 

incrementally impaired waterbodies (WBIDs). Under the baseline, a number of urban areas are already 

required to control nutrients in stormwater dischargers through BMP implementation under MS4 NPDES 

permits. As described in Section 4.3.1, EPA identified potentially affected urban land by overlaying land 

use data with the 10-digit HUCs EPA determined to be draining (adjacent) to incrementally impaired 

waterbodies (WBIDs). EPA then identified MS4 permit boundaries around this urban land by analyzing 

these data using GIS permit boundary data from the Florida Geographic Data Library (FGDL). Exhibit 

7-1 summarizes EPA’s analysis identifying urban areas in incrementally impaired watersheds. 

Exhibit 7-1: Urban Land Area in Watersheds Surrounding Potential 

Incremental Waters not Attaining the Proposed Criteria

Urban Land Type Number of Acres

Phase I MS4 46,000

Phase II MS4 65,800

Non-MS4 30,000

Total 131,700

Note: Detail may not add to total due to independent rounding.

7.2 Method

This section describes how EPA estimated the potential costs of additional controls that may be required 

to meet EPA’s proposed numeric nutrient criteria in watersheds that drain to incrementally impaired 

waterbodies (WBIDs) based on baseline permit requirements noted in Section 2.1.4. The incremental 

controls that may be necessary based on state implementation of the proposed criteria depend on existing 

permit requirements and regulations dictating BMP implementation, as well as the relative contribution of 

nutrients to impaired waters from urban runoff. 

7.2.1 Required Controls

FDEP’s existing stormwater rules already require at least an 80% reduction in pollutant loads from urban 

areas developed after 1982. FDEP (2010b) estimated that approximately 78% of all urban land in the state 

was developed prior to 1982. FDEP (2010b) also indicated that additional controls on stormwater runoff 

from the lands developed after 1982 should not be needed to meet EPA’s numeric nutrient criteria for 

lakes and flowing waters. Thus, for this analysis, EPA assumed the same to be true for the proposed 

numeric nutrient criteria for estuaries, coastal waters, and south Florida inland waters. 
January 2012 7. Potential Costs to Urban Stormwater Sources

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7-2

In addition, the primary source of nutrients from low density residential land is from over-application of 

fertilizers on lawns and gardens. Thus, full implementation of the Urban Turf Fertilizer Rule should result 

in further reductions in nutrient loadings to surface waters (existing ambient monitoring data may not yet 

fully reflect nutrient reductions because the rule has only been in effect since July 2009). Other controls 

that target quantity of stormwater runoff from low density residential land may not be as cost-effective as 

the Urban Turf Fertilizer Rule which reduces the source of nutrients in stormwater runoff. Thus, EPA 

excluded low density residential land from the analysis of urban area control costs because baseline 

regulations and controls should be sufficient for compliance with nutrient criteria under the proposed rule. 

To estimate the level of control needed on post-1982 developed lands that are not low density residential, 

EPA used information from existing TMDLs. Nutrient reductions associated with previous completed 

nutrient-related TMDLs for estuaries in Florida indicate that, on average, nonpoint source pollution load 

reductions of approximately 40% are necessary to meet TMDL targets for nutrients (range of 10% to 

70%). In the absence of site specific analysis, the type and location of pollution controls capable of 

achieving a 40% reduction are uncertain. However, urban stormwater controls can remove up to 51% of 

TN and 75% of TP (Schueler et al., 2007). Thus, EPA assumed that installation of stormwater pollution 

controls would result in the nutrient reductions necessary to attain the proposed criteria.

7.2.2 Phase I MS4 Urban Land

Under existing regulations, NPDES permits for Phase I MS4s require implementation of controls to the 

maximum extent practicable (MEP), and do not generally require compliance with numeric effluent 

limits. In fact, EPA’s PCS database indicates that none of the Phase I MS4s in Florida have numeric 

effluent limits. However, it is unclear what level of treatment the MEP represents. Thus, it is uncertain 

whether current stormwater pollution controls to the MEP are fully implemented in Phase I MS4 areas

and whether additional controls would be necessary under the proposed rule. 

Although urban runoff is currently regulated, state implementation of the proposed criteria may result in 

changes to MS4 NPDES permit requirements or additional TMDLs and BMAPs that require additional 

pollution controls. However, the combination of additional pollution controls necessary will likely depend 

on the specific nutrient reduction targets, the controls already in place, and the relative amounts of 

nutrients contained in the urban runoff at each particular location. As a result, stormwater programs 

usually use an iterative approach for assessing compliance that begins with implementation of controls

followed by monitoring and re-evaluation. Estimating the complete set of pollution controls required to 

meet a particular water quality target would usually require site specific analysis.

However, in the absence of such analyses, EPA estimated potential urban control costs using FDEP’s

assumptions that all urban land developed after 1982 would not need to implement additional stormwater 

controls to comply with EPA’s numeric nutrient criteria and that no additional controls would be needed 

on low density residential land. EPA estimated that between 0 acres (current controls to the MEP are 

sufficient) to 31,200 acres [46,000 acres of urban land in watersheds surrounding potential incremental 

waters not attaining the proposed criteria × (100% - 13%) of potentially affected Phase I MS4 land that is

not low density residential × 78% of urban land developed before 1982] of potentially affected Phase I 

MS4 urban land may require additional stormwater pollution controls.

7.2.3 Phase II MS4 Urban Land

NPDES permits for Phase II MS4s require development of a stormwater management plan and 

implementation of six minimum control measures detailed in Section 2.1.4. However, implementing 

structural stormwater controls are not required (the minimum control measures are primarily nonstructural 
January 2012 7. Potential Costs to Urban Stormwater Sources

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7-3

and outreach-based). Thus, some level of incremental control could be needed to reduce nutrients under 

the proposed rule.

GIS analysis of land use data indicates that approximately 21% of potentially affected land in Phase II 

MS4 areas is low density residential. For the urban land that is not low density residential, some 

additional structural BMPs may be necessary to comply with EPA’s numeric nutrient criteria (existing 

TMDLs indicate that needed reductions in nonpoint source pollutant loads range from 10% to 70%, with 

an average of 40%; see Exhibit 2-9). Because nutrient reductions from low density residential land under 

the existing Urban Turf Fertilizer Rule are likely sufficient, and the state of Florida asserts that urban land 

developed after 1982 is already in compliance with EPA’s numeric nutrient criteria, EPA estimated that 

approximately 34,500 acres of Phase II MS4 urban land may require additional stormwater control under 

the proposed rule [55,800 acres of potentially affected Phase II MS4 land × (100% - 21%) of potentially 

affected Phase II MS4 land that is not low density residential × 78% of urban land developed before 

1982]. 

7.2.4 Urban Land Outside MS4s

Some urban land is not covered under EPA’s NPDES stormwater program. However, regulations such as 

the Urban Turf Fertilizer Rule are applicable. GIS analysis of land use data indicates that approximately 

8% of potentially affected non-MS4 urban land is low density residential. Thus, because nutrient 

reductions from low density residential land under the existing Urban Turf Fertilizer Rule are likely 

sufficient, and the state of Florida asserts that urban land developed after 1982 are already in compliance 

with EPA’s numeric nutrient criteria, EPA estimated that approximately 21,400 acres of urban land 

outside of MS4 areas may possibly require additional stormwater controls to meet EPA’s numeric 

nutrient criteria [30,000 acres of potentially affected non-MS4 land × (100% - 8%) of potentially affected 

non-MS4 land that is not low density residential × 78% of urban land developed before 1982]. Note that 

under TMDLs, FDEP may designate areas outside of MS4s that are significant contributors to pollutant 

loads as Phase II MS4s, and require those areas to obtain NPDES permits.

7.2.5 Summary of Potentially Affected Area

Exhibit 7-2 summarizes the acres of urban land in the watersheds surrounding the potential incremental

waters not attaining the proposed criteria that could potentially need incremental controls based on the 

assumptions described above.

Exhibit 7-2: Urban Land in Watersheds Surrounding Potential Incremental Impairments 

Potentially Needing Controls

Urban Land Type Estimated Acres in Watersheds

Surrounding Incremental Impairments

Estimated Acres Potentially 

Needing Controls

Phase I MS4 46,000 0 - 31,200

Phase II MS4 65,800 34,500

Non-MS4 30,000 21,400

Total 131,700 55,900 - 87,100

Note: Detail may not add to total due to independent rounding

1. Phase I MS4s range represents implementation of BMPs to the MEP resulting in compliance with EPA’s rule or 

controls on all pre-1982 developed land that is not low density residential; Phase II MS4s and urban land outside of 

MS4s represent controls on all pre-1982 developed land that is not low density residential.
January 2012 7. Potential Costs to Urban Stormwater Sources

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7.3 Potential Costs

Unit costs for stormwater treatment controls may vary based on the type of land needing controls (e.g., 

pervious versus impervious, high density versus low density). FDEP (2010a) provides unit costs in dollars 

per acre treated for completed stormwater retrofit projects throughout the state. Costs range from $62 per 

acre treated to $60,300 per acre treated depending on site specific characteristics, with a median cost of 

$6,800 per acre. Specific information regarding the characteristics of land potentially requiring controls is 

not available. Thus, EPA estimated control costs based on median unit costs from FDEP (2010a), with 

O&M costs equal to 5% of capital costs [consistent with FDEP (2010b) assumption of O&M equal to 5% 

of capital costs]. These estimates are shown in Exhibit 7-3.

Exhibit 7-3: Estimated Incremental Urban Stormwater Costs

Urban Land 

Type

Estimated Acres Potentially 

Needing Controls1

Capital Costs 

(million $)2

O&M Costs 

(million $/yr)3

Annual Costs 

(million $/yr)4

Phase I MS4 0 - 31,200 $0 - $213.3 $0 - $10.7 $0 - $30.8

Phase II MS4 34,500 $235.9 $11.8 $34.1

Non-MS4 21,400 $146.5 $7.3 $21.2

Total 55,900 - 87,100 $382.4 - $595.7 $19.1 - $29.8 $55.2 - $86.0

1. Phase I MS4 range represents implementation of BMPs to the MEP resulting in compliance with EPA’s rule or 

controls on all pre-1982 developed land that is not low density residential; Phase II MS4 and urban land outside of 

MS4s represent controls on all pre-1982 developed land that is not low density residential.

2. Represents acres potentially needing controls multiplied by median stormwater retrofit costs from FDEP (2010b).

3. Represents 5% of capital costs.

4. Capital costs annualized at 7% over 20 years plus annual O&M costs.
January 2012 8. Potential Costs to Agricultural Sources

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8-1

8 Potential Costs to Agricultural Sources

Agricultural dischargers in Florida do not generally receive discharge permits unless specific regulations 

require them (e.g., the South Florida Water Management District WOD program). However, state 

implementation of the proposed criteria may result in incremental requirements for these dischargers 

through the identification of additional nutrient-impaired waters, and subsequent development of TMDLs 

and BMAPs. This section provides estimates of agricultural land that may require additional nutrient 

controls as a result of state implementation of EPA’s rule and potential control costs that may be needed 

to attain EPA’s criteria. These estimates are only approximations for informational purposes; actual 

control actions will depend on site specific conditions and control strategies.

8.1 Data

As shown in Exhibit 4-3, EPA estimated that agricultural land accounts for just over 1% of land in 

watersheds draining to potentially incrementally impaired waterbodies (WBIDs). Exhibit 8-1 shows the 

agricultural acreage subdivided into the specific type of agricultural operation that presently occurs there.

Exhibit 8-1: Agricultural Land Use in Watersheds 

Draining to Potentially Incrementally Impaired WBIDs

Agricultural Land Use Number of Acres

Cropland and Pastureland 38

Improved Pastures 7,449

Unimproved Pastures 1,511

Woodland Pastures 2,001

Row Crops 253

Hay 4,648

Fruit Orchards 26

Other Groves 59

Poultry Feeding Operations 19

Nurseries and Vineyards 16

Tree Nurseries 279

Ornamentals 256

Horse Farms 61

Aquaculture 4

Other Open Lands 336

Fallow Cropland 3,367

Total 20,322

Based on GIS analysis of land use data from five water management 

districts (for entire state) 

8.2 Method

When developing nutrient TMDLs for impaired waters, site specific analysis is generally needed to 

determine the nutrient reductions required from agricultural nonpoint sources and to identify the 
January 2012 8. Potential Costs to Agricultural Sources

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8-2

appropriate agricultural BMPs capable of attaining the necessary reductions. Reductions obtained from 

any one practice will vary with onsite conditions including soils and proximity to waters, BMP 

implementation, and nutrients applied or produced. 

Because this type of analysis for the waters that may not attain the proposed criteria is beyond the scope 

of this analysis, EPA estimated the potential incremental costs of additional agricultural BMPs that may 

be necessary to meet the proposed criteria using a study of BMP requirements and costs performed for the 

SFWMD as part of development of nutrient TMDLs for the Caloosahatchee River and St. Lucie River 

(SWET, 2008). SWET (2008) develops three types of BMP programs: the set of BMPs that land owners 

would likely implement without incentives (owner program); the set of BMPs that would be implemented 

under a reasonably funded cost share program or modest regulatory approach (typical program); and more 

aggressive and costly controls (alternative program) that could be needed if additional nutrient reductions 

are required. 

The BMPs in SWET’s (2008) owner and typical programs are similar to the BMPs adopted in FDACS 

BMP manuals (Section 2.1.5) and those detailed in existing BMAPs [although it is uncertain whether the 

mix of BMPs farmers are implementing under the FDACS BMP manuals reflect the same level of control 

as the SWET (2008) owner/typical program in all cases]. Exhibit 8-2 shows the BMP program 

components SWET (2008) estimated would be appropriate for each type of agricultural activity.

Exhibit 8-2: Example Agricultural BMP Program Elements for the Caloosahatchee River 

and St. Lucie River Watersheds

Land Use Owner/Typical Program

Citrus Reduced fertilization/nutrient management, grass management between trees, 

additional stormwater retention, and limited wetland restoration/retention

Cow Calf, Improved 

Pastures

P reduced to zero/nutrient management, rotational grazing, new water 

facilities, retention basin by working pens, improved grass management, feed 

placement, critical area fencing, and moderate wetland restoration/retention

Cow Calf, Unimproved 

Pastures

Some rotational grazing, new water facilities, retention basin by working pens, 

improved grass management, feed placement, and moderate wetland 

restoration/retention

Cow Calf, Rangeland 

and Wooded Pasture

Some rotational grazing, new water facilities, retention basin by working pens, 

improved grass management, feed placement, and moderate wetland 

restoration/retention

Field Crop (Hayland) 

Production/Other Areas

P reduced to zero/nutrient management, rotational grazing, new water 

facilities, retention basin by working pens, improved grass management, feed 

placement, critical area fencing, and moderate wetland restoration/retention

Ornamental Nursery Reduced P fertilization, water management, additional stormwater retention, 

cover crop, and limited wetland restoration/retention

Row Crop Reduced P fertilization, water management, additional stormwater retention, 

cover crop, and limited wetland restoration/retention

Horse Farms

P reduced to zero/nutrient management, rotational grazing, new water 

facilities, retention basin by working pens, improved grass management, feed 

placement, critical area fencing, and moderate wetland restoration/retention

R/D = retention/detention

Source: SWET (2008).

SWET (2008) estimates costs for an alternative program which it indicates may be necessary if additional 

nutrient reductions are needed beyond what the owner/typical program could obtain. However, these 

alternative practices, which include stormwater chemical treatment are not yet required in historically 

nutrient impaired watersheds with significant contributions from agriculture (e.g., Lake Okeechobee). 
January 2012 8. Potential Costs to Agricultural Sources

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8-3

Thus, it is highly uncertain whether such controls would ever be required. Therefore, for this analysis,

EPA believes it is reasonable to assume that costs to the agricultural sector are best represented by the 

owner and typical BMP program unit costs described above.

FDEP must verify that FDACS BMPs are reasonably expected to be effective [Section 403.067(7)(c)(3), 

F.S.]. However, it is unclear whether all necessary BMPs are implemented in all cases because individual 

agricultural operators apply the FDACS BMP manuals with little state oversight. Therefore, EPA 

estimated potential incremental costs by applying unit costs based on two scenarios: 1) potentially 

affected agricultural acres that are not currently enrolled in the FDACS BMP program (assuming that 

acreage currently enrolled in FDACS BMP program do not require additional BMPs) and 2) all

potentially affected agricultural acres whether or not they are currently enrolled in the FDACS BMP 

program (assuming that acreage currently enrolled in FDACS BMP program may require additional 

BMPs, although such an estimate may double count some costs). Exhibit 8-3 shows the total acres in the 

state that are enrolled in the FDACS BMP program, by land use.

Exhibit 8-3: Total Acres Enrolled in FDACS BMP Program 

Land Use Number of Acres1 Land Use Number of Acres1

Cropland and Pastureland 57,828 Poultry Feeding Operations 308

Improved Pastures 604,137 Nurseries and Vineyards 7,619

Unimproved Pastures 187,799 Tree Nurseries 2,794

Woodland Pastures 85,730 Sod Farms 6,113

Row Crops 55,797 Ornamentals 7,366

Field Crops 607,440 Specialty Farms 496

Tree Crops 102,137 Horse Farms 585

Citrus Groves 301,415 Diaries 6,163

Fruit Orchards 3,792 Aquaculture 15

Other Groves 324 Tropical Fish Farms 19

Abandoned Groves 12 Other Open Lands 11,715

Feeding Operations 389 Fallow Crop Land 2,269

Cattle Feeding Operations 854

Total 2,053,115

1. Based on FDACS BMP program NOI GIS data layer.

8.3 Potential Costs

Exhibit 8-4 shows estimates of the potential incremental costs to agriculture that may be needed to reduce 

nutrients to levels that attain EPA’s criteria. EPA derived these estimates by multiplying the number of 

potentially affected acres in each category of agricultural operation with the unit costs of the owner plus 

typical programs from SWET (2008).
January 2012 8. Potential Costs to Agricultural Sources

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8-4

Exhibit 8-4: Potential Agricultural Control Costs Associated with Incrementally Impaired 

Estuaries

Agricultural BMP Category Number of Acres1

Owner plus Typical 

Program Unit Cost 

($/ac/yr)2

Total Owner plus 

Typical Program 

Costs ($/yr)

Animal Feeding 19 $18.56 $400

Fruit Orchards3 26 $156.80 $4,000

Cow Calf Production, Improved 

Pastures 7,449 $15.84 $118,000

Cow Calf Production, Rangeland 

and Wooded Pasture 2,001 $4.22 $8,500

Cow Calf Production, Unimproved 

Pastures 1,511 $4.22 $6,400

Cropland and Pasture Land 

(general)4 38 $27.26 $1,000

Field Crop (Hayland) Production 4,640 - 4,648 $18.56 $86,100 - $86,300

Horse Farms 61 $15.84 $1,000

Ornamental Nursery 245 - 256 $70.00 $17,100 - $18,000

Row Crop 253 $70.40 $17,800

Sod/Turf Grass 0 $35.20 $0

Other Areas5 358 $18.56 $6,600

Total6 16,600 - 16,619 -- $266,900 -

$267,800

Note: Detail may not add to total due to independent rounding.

1. Based on GIS analysis of land use data from five water management districts (for entire state) and FDACS BMP 

program NOI GIS data layer. Low end reflects acres in incrementally impaired HUCs (that are not included in HUCs 

for baseline impairment) that are not enrolled in BMPs under FDACS; high end reflects all acres in incrementally 

impaired HUCs, including those that are already enrolled in FDACS BMP enrollment.

2. Cost estimates from SWET (2008); representative of 2010 prices (Bottcher, 2010).

3. Owner/typical BMP unit costs based on costs for citrus crops.

4. Owner/typical BMP unit costs based on average costs for improved pastures, unimproved/wooded pasture, row 

crops, and field crops.

5. Includes FLUCCS Level 3 codes 2230, 2400, 2410, and 2540.

6. Excludes land not in production.
January 2012 9. Potential Costs to Septic Systems

Draft for Internal Review Only-Do Not Quote or Cite

9-1

9 Potential Costs for Septic Systems 

Discharges from septic systems in Florida do not require surface water discharge permits. However, state 

implementation of the proposed criteria may affect these systems through the identification of additional 

impaired waters, and subsequent development of TMDLs and BMAPs. This section provides estimates of 

septic systems that may require additional nutrient controls as a result of state implementation of EPA’s 

rule and potential control costs that may be needed to attain EPA’s criteria. These estimates are only 

approximations for informational purposes; actual control actions will depend on site specific conditions 

and control strategies.

9.1 Data

EPA obtained the locations of septic systems in Florida from the FDOH GIS data file of OSTDSs 

inspected by the Department’s Bureau of Onsite Sewage (FDOH, 2011). These data indicate that there are 

944,006 septic systems in Florida, of which 802,500 are active. EPA used the data from the 802,500 

active septic systems provided by FDOH (2011) to estimate the septic systems that may drain to 

incrementally impaired waterbodies (WBIDs).

9.2 Method

Nutrient reductions from septic systems could be necessary under the proposed rule. Implementation 

strategies could include upgrading existing systems to advanced nutrient removal and connecting 

households and businesses that use septic systems to centralized wastewater treatment. The feasibility of 

connecting to centralized treatment compared to septic upgrades would depend on existing wastewater 

treatment capacity and the costs of the connections. For example, Monroe County estimates that it would 

cost approximately $15,000 per household to connect to a sewer system, including costs for connection 

and sewer piping, septic tank destruction, and treatment plant construction and upgrades. 

Because of the cost, time, and issues associated with new wastewater treatment plant construction, EPA 

assumed that upgrading septic systems would in most cases be the lower cost and more feasible 

compliance strategy for nutrients. In areas where existing centralized treatment capacity is available, 

typical connection costs are also likely to exceed average septic system upgrade costs. For example, the 

City of Jacksonville (2003) estimates that connection costs average $17,840 per house ($15,000 in 2003 

dollars, updated to 2010 dollars using Region CPI), while the Florida Government Utility Authority 

(2009) estimates a range of $5,130 to $15,140 per house for 188 houses in Lehigh Acres. These costs are 

significantly higher than upgrading existing septic systems as described below.

Most of the existing nutrient-related TMDLs for estuaries and coastal waters identify failing septic 

systems as contributing to nutrient impairments in surface waters. Those septic systems in close proximity 

to surface waters are likely to contribute the greatest load to the waterbody. For example, for the Middle 

St. Johns River Nutrient TMDL, FDEP included wastewater from failed septic tanks within 50 feet as 

direct discharges of untreated wastewater to the stream network; for those outside of the 50-feet 

boundary, FDEP combined septic system loads with the nonpoint source loading for residential areas 

(Gao, 2009). 

Properly operated and maintained systems usually provide treatment equivalent to secondary wastewater 

treatment (Petrus, 2003). However, even properly functioning septic systems could impact water quality, 

depending on septic system location and magnitude of the criteria. Site specific data would be needed to 

determine which septic systems are contributing to nutrient impairments and the magnitude of that 
January 2012 9. Potential Costs to Septic Systems

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contribution. In the absence of site specific data on the contributions of septic systems to nutrient loadings 

in the watersheds surrounding the potential incremental waters not attaining the proposed criteria, EPA 

assumed that systems located within 500 feet of waterbodies in the potentially affected watersheds may 

need to reduce nutrient loads. 

9.3 Potential Costs

Because it is generally less expensive to upgrade an existing septic system than to connect to a centralized 

treatment system (as discussed above), EPA based its estimate of potential compliance costs on the 

incremental costs of upgrading conventional septic systems to advanced nutrient-reducing systems. EPA 

assumed that all existing conventional systems are operated and maintained properly (any costs associated 

with improving existing functionality would not be attributable to EPA’s proposed rule).

9.3.1 Unit Costs

Biomicrobics manufactures the RetroFAST system as a retrofit of existing septic systems to improve 

nutrient removal (the system is added to existing septic tank and drainfield systems). The system is a 

fixed-film activated sludge process and ranges from $1,650 plus an additional $400 to $500 for 

installation (Wastewater Technologies, 2010). Capital cost for the upgrade could range from 

approximately $2,000 to $2,100. Anderson et al. (1998) indicated that the system can achieve average TN 

concentrations less than 11 mg/L and TP concentrations of 5.4 mg/L. SeptiTech also manufactures an 

onsite wastewater treatment system utilizing fixed film biological filters. The system costs approximately 

$3,000 to $4,000 to install (Everhart, 2009) and can consistently achieve effluent TN concentrations less 

than 10 mg/L in warmer weather (14 mg/L average over 12 month study period in Massachusetts) (U.S. 

EPA, 2003a).

Aquapoint manufactures the Bioclere onsite wastewater treatment system which uses a fixed film 

biological trickling filter and clarifier to remove organics and nutrients from domestic wastewater. EPA 

(2003a) indicated that TN concentrations from a Bioclere system averaged 16 mg/L over a 13-month 

study period of residential wastewater in Massachusetts. During warmer months effluent concentrations 

were consistently below 10 mg/L. Installation of the system for a single family home to a new or existing 

conventional septic system costs approximately $6,500 (this cost does not include the septic tank and 

drainfield that are already present with existing systems) (McNeer, 2009).

Pursuant to section 369.318, F.S., the Florida Department of Health (FDOH) studied onsite disposal 

system standards needed to achieve nitrogen reductions protective of groundwater quality within the 

Wekiva Study Area. FDOH (2004) reported that a conventional septic tank and drainfield costs from 

$5,500 to $7,000 for a three-bedroom home, and a comparable nitrogen-reducing system with a drip 

irrigation drainfield costs from $7,500 to $9,000 (based on estimates from licensed contractors and 

engineers that design and install nutrient-reducing systems in the area). However, details on the nitrogenreducing system components are insufficient to estimate the incremental costs of upgrading to nitrogen 

removal. For example, it is not clear whether the existing septic tank could be used and the nitrogenreducing technology could be retrofitted or whether the entire system would need to be replaced.

Based on this information, EPA estimated that capital costs for upgrading existing septic systems to 

achieve nutrient removal could range from $2,000 (approximate cost of RetroFAST system for 250

gallons/day) to $6,500 (cost of fixed film biological trickling filter). For O&M costs, EPA relied on a 

study that compared the annual costs associated with various septic system treatment technologies 

including conventional OSTDS and fixed film activated sludge systems similar to those described above. 

Chang et al. (2010) estimated the incremental O&M costs for an advanced system to be $650 per year. 
January 2012 9. Potential Costs to Septic Systems

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9-3

Thus, based on annual O&M costs of $650 and annualizing capital costs at 7% over 20 years, annual costs 

could range from approximately $800 to $1,300 for each upgrade.

9.3.2 Total Potential Costs

The GIS analysis indicates that there are approximately 7,325 septic systems within 500 feet of 

incrementally impaired waterbodies (WBIDs) in the watersheds draining to incrementally impaired 

WBIDs. Exhibit 9-1 shows estimates of the potential incremental costs to septic systems that may need to 

be upgraded to reduce nutrients to levels that attain EPA’s criteria.

Exhibit 9-1: Summary of Estimated Upgraded Septic System Costs 

Number of Active Septic Systems 802,500

Number of Septic Systems within 500 Feet of Potentially 

Incrementally Impaired Waters 7,325

Capital Costs ($) $2,000 - $6,500

O&M Cost ($/yr) $650 

Annual Costs (millions)1 $5.9 - $9.5

Based on adding annual O&M costs to capital costs annualized at 7% rate over 20 years.
January 2012 10. Government Expenditures

Draft for Internal Review Only-Do Not Quote or Cite

10-1

10 Government Expenditures

State implementation of the proposed criteria may result in additional costs related to the development of 

TMDLs for WBIDs added to Florida’s 303(d) list of impaired waters. This section describes how EPA 

estimated potential incremental costs associated with government expenditures to develop additional 

TMDLs.

10.1 New TMDLs

EPA determined that existing nutrient-related TMDLs for estuaries and coastal waters address an average 

of approximately four WBIDs each. Using the average number of WBIDs per TMDL, EPA estimated that 

58 (230 ÷ 4) additional nutrient TMDLs may be required under the proposed rule.

The process for developing TMDLs in Florida includes (FDEP, 2005b):

 gathering and analysis of data

 meeting quality assurance specifications

 computer modeling

 adoption through state’s public rulemaking process

 public hearing before adoption

 development of a BMAP with detailed implementation strategies (1-2 year process after adoption with 

additional public meetings).

FDEP may also hold public meetings after data collection and prior to development of a draft TMDL. 

EPA had previously estimated the cost of developing TMDLs based on performing eight basic steps (U.S. 

EPA, 2001):

 characterizing the watershed 

 modeling and analyzing the waterbody and its pollutants to determine the reduction in the pollutant 

load that would eliminate the impairment

 allocating load reductions to the appropriate sources

 preparing an implementation plan

 developing a TMDL support document for public review

 performing public outreach

 conducting formal public participation and responding to it

 management (including tracking, planning, legal support, etc.).

EPA (2001) indicates that the average cost per case of impairment is approximately $28,000 nationally, 

but can typically range from about $6,000 to $154,000. The lower end of the range ($6,000) reflects the 

typical cost associated with TMDLs that are the easiest to develop and also have the benefit of maximum 

efficiencies (e.g., a TMDL for another pollutant in the same waterbody). The higher end of the range 

represents the cost associated with TMDLs that are most difficult to develop, and for which there is no

benefit of related work done on other TMDLs for the waterbody or the watershed. Although the 
January 2012 10. Government Expenditures

Draft for Internal Review Only-Do Not Quote or Cite

10-2

establishment of numeric nutrient criteria may reduce these higher end TMDL costs, EPA did not account 

for these reductions in this analysis. 

Because more than half of the WBIDs EPA identified as not attaining the proposed criteria exceed more 

than one criterion, EPA assumed that FDEP would address both pollutants in TMDL analyses for each set 

of WBIDs. Thus EPA estimated the cost of developing TMDLs as the cost of a TMDL for one pollutant 

plus the cost of a second TMDL for an additional related pollutant, or approximately $34,000 (the average 

TMDL cost of $28,000 for the first nutrient, plus the low end TMDL cost of $6,000 for the second 

nutrient). Escalating this cost to June 2010 dollars,11 average per TMDL costs could be approximately 

$47,000. Multiplying the average cost per TMDL ($47,000) by an additional 58 TMDLs results in an 

estimated total cost of approximately $2.7 million. 

Currently, FDEP operates its TMDL schedule based on a five-phase cycle that rotates through the five 

basins over five years (FDEP, 2003). Under this schedule, completion of TMDLs for high priority waters 

will take 9 years; it will take an additional 5 years to complete the process for medium priority waters.

Thus, assuming all the incremental impairments are high priority and FDEP develops the new TMDLs 

over a 9-year period, annual costs could be approximately $0.3 million.

Exhibit 10-1: Summary of Estimated Government 

Expenditures

Estimated TMDLs Needed 58

Average Cost of TMDL $47,000

Total Costs (millions) $2.70 

Annual Costs over 9 Years 

(millions) $0.30 

10.2 Site Specific Alternative Criteria

As part of FDEP’s 2009 proposed nutrient criteria revisions, FDEP proposed to adopt many nitrogen and 

phosphorus TMDLs as SSAC. Under EPA’s proposed rule, the state could adopt TMDL targets as SSAC 

as part of its triennial review process for minimal costs. Furthermore, costs to develop SSAC under 

EPA’s proposed rule are likely to be similar to what SSAC development costs have been under the 

current narrative nutrient criteria in Florida, such that this proposed rule causes no additional costs. Thus, 

EPA assumed that incremental costs associated with SSAC, if any, would be minimal.

10.3 Ambient Monitoring

Existing TMDLs and information on the current 303(d) list indicate that state and local agencies are 

regularly monitoring TN and TP in ambient waters. These agencies monitor TN and TP levels even 

though the existing criterion is narrative because FDEP’s nutrient impairment listing method uses a 

trophic state index (TSI) that is calculated based on TN, TP, and chlorophyll-a concentrations. These 

nutrient criteria data are the basis of the extensive IWR database FDEP maintains, and which provides 

baseline water quality data for the analyses in this report. 

Because FDEP is currently monitoring TN, TP, and chlorophyll-a concentrations in many waters, the 

proposed rule is unlikely to have a significant cost impact on monitoring activities throughout the state.

 11 Escalated using the Bureau of Labor Statistics Employment Cost Index for state and local government workers (2001 Index = 

83.6; 2010 Index = 115.4).
January 2012 11. Summary of Potential Costs

Draft for Internal Review Only-Do Not Quote or Cite

11-1

11 Summary of Potential Costs 

The potential costs that may be associated with state implementation of the proposed criteria for estuaries, 

coastal waters, and south Florida inland waters in Florida may include incremental compliance and 

government resource costs. This section provides a summary of EPA’s estimates of these potential costs. 

Exhibit 11-1: Summary of Potential Annual Costs Associated with Numeric Nutrient 

Criteria (2010 dollars)

Source Sector Type of Expenditure Annual Cost (millions)

Municipal Wastewater1 BNR to reduce TN and/or TP $94.2 - $117.5

Industrial Dischargers2

BNR to reduce TN and TP; 

chemical precipitation to reduce 

TP

$7.6

Urban Stormwater3 Stormwater controls $55.2 - $86.0

Agriculture4 Owner/typical BMP program $0.3 - $0.3

Septic Systems5 Upgrade to advanced nutrient 

treatment $5.9 - $9.5

Government/Program 

Implementation6 TMDL development $0.3

Total -- $163.5 - $221.2

Note: Detail may not add to total due to independent rounding.

BNR = biological nutrient removal; TMDL = total maximum daily load; TN = total nitrogen; TP = total phosphorus

1. Based on upgrading existing treatment processes to advanced BNR.

2. Based on average annual costs per flow for dischargers stratified by industrial category.

3. Based on median stormwater control costs from FDEP (2010a), and scenario of need for structural controls on 

land developed before 1982.

4. Based on implementing nutrient management on all crop land outside of incrementally and baseline impaired 

watersheds and scenarios in which all agricultural land not enrolled in the FDACS BMP program in incrementally 

impaired watersheds incurs owner/typical program costs from SWET (2008) or all agricultural land in incrementally 

impaired watersheds incurs owner/typical costs based on SWET (2008).

5. Based on upgrading to advanced nutrient removal active septic systems within 500 feet of water (based on GIS 

land use data) in the watersheds surrounding potential incrementally impaired WBIDs.

6. Based on average costs to complete TMDLs for incrementally impaired waters under a 9-year schedule.

The estimates of potential incremental costs associated with state implementation of EPA’s numeric 

nutrient criteria for estuaries, coastal waters, and south Florida inland waters in Florida are based on 

several assumptions that may over- (+) or underestimate (-) actual costs. Exhibit 11-2 provides a 

summary of the key uncertainties.
January 2012 11. Summary of Potential Costs

Draft for Internal Review Only-Do Not Quote or Cite

11-1

Exhibit 11-2: Uncertainties of the Analysis

Uncertainty/Assumption

Potential Impact 

on Cost 

Estimates

Comment

Several assumptions in estimating costs 

to municipal wastewater dischargers; 

e.g., all dischargers would need to 

achieve TN and TP effluent 

concentrations less than 3 mg/L and 0.1 

mg/L, respectively.

?

EPA did not conduct facility-specific 

analyses, so needed to make these 

assumptions for general analysis.

For municipal wastewater dischargers, 

used same unit costs for capital and O&M 

regardless of the reductions needed.

?

EPA did not consider existing effluent 

quality in estimating potential 

incremental costs.

Industrial dischargers in the Electric 

Services and Other categories would not 

incur incremental compliance costs.

-

Estimate is based on a representative 

sample of dischargers. Could be an 

underestimate if any of the other 

dischargers in the universe would incur 

costs.

Uncertainty with regard to the TN and TP 

concentrations achievable with available 

treatment technologies

? Estimate is based on assumption that 

variance demonstrations can be made.

Implementing controls on all urban land 

that is not low density residential 

developed after 1982 would be sufficient 

for compliance with the proposed criteria.

?

EPA did not have the data to perform 

watershed modeling to determine the 

appropriate mix of controls for each 

urban area that would result in 

attainment of the proposed criteria.

Does not account for the existing level of 

BMP implementation resulting from 

NPDES stormwater permit requirements.

+

Costs are likely overestimated without 

accounting for existing levels of BMP 

implementation.

Median unit costs used for urban 

stormwater controls to represent a 

scenario in which the range of stormwater 

control costs are equally distributed 

throughout each watershed.

?

Stormwater control costs are highly 

variable, with unit costs from FDEP 

(2010a) ranging over three orders of 

magnitude.
January 2012 11. Summary of Potential Costs

Draft for Internal Review Only-Do Not Quote or Cite

11-2

Exhibit 11-2: Uncertainties of the Analysis

Uncertainty/Assumption

Potential Impact 

on Cost 

Estimates

Comment

Agricultural costs estimates assume that 

farmers would implement owner and 

typical BMP programs on all acres in 

incrementally impaired watersheds.

?

EPA did not conduct a watershedspecific analysis of potential agricultural 

controls needed to attain EPA’s 

proposed criteria. In some watersheds, 

point source or urban source controls 

may be sufficient, while in other 

watersheds a more aggressive level of 

BMP implementation may be necessary.

Septic systems located within 500 feet of 

waterbodies in the potentially affected 

watersheds may need to reduce nutrient 

loads.

?

Without site-specific modeling of 

watershed characteristics and soil 

properties it is highly uncertain whether 

septic systems within 500 feet of water 

in the potentially affected watersheds 

are contributing to nutrient loads and 

whether such contributions would need 

to be reduced.

Costs to attain proposed criteria attributed 

to proposed rule. +

Some of these waters may be currently 

in nonattainment of the existing narrative 

nutrient criterion but not yet unidentified 

as such.

EPA considered nutrient source 

categories separately, and assumed 

controls on all categories are needed in 

all instances of criteria exceedances.

+

In some watersheds, controls on a 

subset of potential sources may result in 

attainment of WQS.

BMPs = best management practices

FDEP = Florida Department of Environmental Protection

NPDES = National Pollutant Discharge Elimination System

O&M = Operation and Maintenance

TN = total nitrogen

TP = total phosphorus

Key:

“+” = impacts likely overstated

“–“ = impacts like understated

“?” = direction of impact is uncertain
January 2012 12. Description of Benefits of Reducing Nutrient Loads to Florida Estuaries

Draft for Internal Review Only-Do Not Quote or Cite

12-1

12 Description of Benefits of Reducing Nutrient Loads to Florida 

Estuaries

Elevated concentrations of nutrients in estuaries, coastal waters, and south Florida inland waters in 

Florida may result in adverse ecological effects, and, as a result, decrease provision of environmental 

goods and services and impair designated water uses. Conversely, reduction in nutrient concentrations to 

meet numeric standards will improve ecological function and enhance provision of environmental goods 

and services, and help to attain or maintain designated uses. The following sections discuss the general 

effects of nutrients in estuarine, coastal waters, and south Florida inland waters, and provide qualitative 

assessment of the potential for benefits from nutrient reductions that may result from implementation of 

the proposed rule. 

12.1 Effect of Nutrients on Bays, Estuaries and Coasts 

The influence of growth-limiting chemicals or nutrients, particularly nitrogen and phosphorus, on water 

quality, biota, and habitats of estuarine and coastal aquatic ecosystems is profound. When supplied in 

excess amounts by man’s activities, elevated nutrient concentrations can lead to a series of predictable 

changes in the chemical and physical environment with resultant shifts in water quality and aquatic 

communities, a process which is commonly referred to as anthropogenic eutrophication (Bricker et al., 

2007). The following sections provide general information on the ecological impacts of nutrients and the 

eutrophication process.

12.1.1 Ecological Effects

Eutrophication is the increase in organic carbon to an aquatic ecosystem caused by primary production 

stimulated by excess nutrients, typically compounds containing nitrogen or phosphorus (U.S. EPA, 

2010d). Eutrophication is a major concern for many waters within the United States, and is particularly 

severe for many waters in Florida. The 2008 Integrated Report for Florida indicates that 94 estuaries 

encompassing approximately 900 square miles of water are impaired for nutrients, with nutrients ranked 

as the second most common source of impairment.12 One additional coastal body representing 102 square 

miles is also impaired for chlorophyll, typically considered an indicator of algal growth associated with 

eutrophication (FDEP, 2008a).

For most estuaries and coastal waters, the growth-limiting nutrient (i.e., the chemical which largely 

controls the rate of primary production) is nitrogen, such that it is the reduction in the supply of nitrogen 

that is the primary focus of most estuarine nutrient TMDLs. Phosphorus can be growth-limiting under 

certain circumstances, particularly near an estuary’s freshwater boundary, but phosphorus is generally 

more important in inland waters. EPA (2010c) provides a detailed description of adverse ecological 

effects of nutrients focusing on inland waters.

Eutrophication can lead to a predictable sequence of ecological effects and ultimately to environmental 

degradation, including increases in the occurrence and intensity of water column phytoplankton, including 

harmful algal blooms (e.g., nuisance and/or toxic species), loss of critical submerged aquatic vegetation 

(i.e., SAV), and reduced and/or diurnally variable dissolved oxygen (DO). In turn, ecological degradation 

can lead to significant losses in environmental goods and services provided by the affected waterbodies 

(e.g., reduced commercial and recreational fishing opportunities and reduced swimming, diving, and 

 12 The 2010 report indicates cause of impairment as Trophic Status Index (TSI), which measures the potential for algal or aquatic 

weed growth, the components of which include total nitrogen, total phosphorus, and chlorophyll.
January 2012 12. Description of Benefits of Reducing Nutrient Loads to Florida Estuaries

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12-2

snorkeling opportunities). Exhibit 12-1 provides a conceptual model of the potential ecosystem response 

to nutrients and how the resulting ecological effects translate into impacts to ecological services. 

Exhibit 12-1: Eutrophication Impacts and Responses for Estuaries and Coastal Waters

External Nutrient 

Inputs

Mitigating Natural 

Factors Primary Responses Secondary 

Responses

Impacts

Human/Aquatic Life

Nitrogen and 

Phosphorus

Color

Flushing

Residence

Depth

Turbidity

Grazing

Algal Dominance 

Changes

Decreased Light 

Availability

Increased Organic 

Decomposition

Harmful Algae

Loss of SAV

Low Dissolved 

Oxygen

Increase of Algal Toxins

Loss of Habitat

Fish Kills

Diatoms to 

Flagellates

Benthic Dominance 

to Pelagic 

Dominance

Extreme Chl-a 

Concentrations

Excess Epiphytic 

Growth

Excess Macroalgal 

Growth

Nuisance Blooms

Toxic Blooms

Reduced SAV Spatial 

Coverage

Negative SAV Spatial 

Coverage Trends

Extreme Chl-a 

Concentrations

Bacterial Respiration

Anoxia

Hypoxia

Biological Stress

Commercial and

Recreational Fishing 

Aquaculture

Tourism

Human Health

Swimming

Commercial and

Recreational Fishing 

Aquaculture

Tourism

Diversity

Organism Condition

Ecosystem Function

Nursery Areas

Diversity

Organism Condition

Ecosystem Function

Commercial and

Recreational Fishing 

Aquaculture

Aesthetic Values

Tourism

Diversity

Organism Condition

Ecosystem Function

Source: Adapted from Weaver (2010).

As illustrated in Exhibit 12-1, external nutrient loads are the driving factor in the ecological impacts, but 

the relative impact can be significantly affected by the mitigating factors of light (color, turbidity), estuary 

hydrodynamics (tidal flushing, hydraulic residence time, depth), and biotic interactions (e.g., zooplankton 

grazing). It is typically the interplay between nutrients and the mitigating factors that produces a site 

specific response for a particular estuary, such that equal amounts of nitrogen may have quite variable 

growth responses in different environmental settings.

Exhibit 12-1 shows the primary responses of eutrophication, categorized as algal dominance changes, 

decreased light availability, and increased organic decomposition. As nutrients increase, the primary 

responses can lead to more severe and problematic secondary responses, which are typically the more 

readily observable manifestations of ecosystem degradation. These secondary responses include harmful 

algal blooms, loss of submerged aquatic vegetation, and low DO. In shallow waters, nutrient enrichment 

can lead to increases of attached benthic algae (i.e., epiphytes) or loose macroalgae; whereas deeper 

waters will develop phytoplankton blooms. The sections below discuss primary and secondary responses 

to eutrophication and describe the quantitative relationship between nutrients and some of the primary and 

secondary responses.
January 2012 12. Description of Benefits of Reducing Nutrient Loads to Florida Estuaries

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12-3

12.1.2 Primary and Secondary Eutrophication Responses 

Increases in the supply of nutrients can lead to increased amounts of primary production in the form of 

phytoplankton in the water column. The strong positive relationship between nutrient supply and 

increased algal growth (often measured as concentrations of the primary photopigment chlorophyll-a) has 

been modeled for bays, estuaries, and coasts (e.g., Nielsen et al., 2002; Lewitus et al., 1998; Valiela et al., 

1997), including Florida estuaries (Janicki et al., 2001; Morrison et al., 1996; Glibert et al., 2004). As 

nutrient loading increases, the trophic state of a waterbody can change from a poorly-fertilized and low 

productivity state (termed oligotrophic) or moderately-fertilized and moderately productive state 

(mesotrophic) to a well-fertilized and highly productive state (eutrophic) (Pinckney et al., 2001). 

Eutrophic coastal systems typically maintain high levels of primary productivity (i.e., phytoplankton, 

SAV, periphyton) during the growing season, which for Florida is essentially year-round. In low salinity 

estuaries (i.e., less than 10-12 parts per thousand), eutrophication can shift the water column 

phytoplankton community to one dominated by blue-green algae species which often have physiological 

advantages over other phytoplankton taxa under conditions of low light, high grazing, warm temperatures, 

and low nitrogen to phosphorus supply ratios (Smith et al., 1999). High concentrations of blue-green 

algae (cyanobacteria) constitute harmful algal blooms (HABs) due to their potential to form nuisance 

surface scums, sharply reduce light penetration into the water, provide poor grazing material for 

zooplankton and young-of-year fish, and produce irritating or toxic compounds (e.g., cyanotoxins). 

High concentrations of cyanotoxins have been found to cause health problems in humans and fatal 

poisoning in other animals, fish, and birds, and some cyanotoxins may bioaccumulate in the food chain 

(Miller et al., 2010). Recent research found the cyanobacter Lyngbya spp. in 16 different coastal areas 

throughout Florida, with persistent blooms in the Indian River Lagoon and Broward County reefs on the 

Atlantic Coast, as well as Sanibel Island on the Gulf Coast (Paerl et al., 2009). In higher salinity estuaries 

(i.e., greater than 10-12 parts per thousand), the physiological and biogeochemical-based competitive 

advantages of blue-green algae are reduced, such that blue-green algal blooms are much less prevalent in 

these waters (Howarth and Marino, 2006). 

The reduction of light levels (i.e., decreased depth to which light penetrates or eutrophic zone) due to 

water column algal blooms and turbidity also can adversely affect SAV biomass in bays, estuaries, and 

coasts, reducing their spatial coverage, species diversity, and amount of primary production. In Floridian 

waters as elsewhere, the maximum depth of SAV colonization is highly dependent on the water clarity, as 

indicated by Secchi disk transparency (SDT) depth (Greening and Janicki, 2006; Krause-Jensen et al., 

2008). High nutrients can also lead to the direct growth of epiphytic algae on the SAV which also reduces 

its light harvesting ability. 

Overall, eutrophication can cause a shift in bays, estuaries, and coastal waters from aquatic vegetation 

domination (i.e., most of primary production coming from rooted aquatic plants) or coral domination to 

highly turbid and phytoplankton-dominated systems, with little or no submerged aquatic vegetation or 

corals (Hauxwell et al., 2001; Lapointe et al., 2004). In addition to the loss in primary production and 

reduced food for herbivorous wildlife (e.g., sea turtles, manatees), the loss of the aquatic vegetation has 

the additional ecosystem effect of reducing refuge habitat for zooplankton against fish predators. This 

condition may exacerbate the turbidity of the water, as the reduced herbivorous zooplankton population 

can no longer reduce or control phytoplankton biomass by grazing. 

Eutrophication can lead to increased levels of organic carbon accumulations in the water column 

(Pinckney et al., 2001). When the algal blooms die, sink, and decay, the decomposition of the excess 

organic carbon leads to increased bacterial respiration, particularly in lower depths or in the sediments. 
January 2012 12. Description of Benefits of Reducing Nutrient Loads to Florida Estuaries

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This increased oxygen demand can greatly reduce DO resulting in hypoxia (reduced DO), or even anoxia 

(lack of DO), in the deep or overlying waters. Shallow eutrophic waters may also be subject to large 

diurnal swings in DO because highly productive waters produce excess oxygen via photosynthesis during 

daylight hours but also result in low levels at night due to elevated dark respiratory demand. These 

diurnally variable conditions can lead to biological stress of aquatic biota resulting in impaired biotic 

conditions or even mortality (e.g., fish kills). 

Water quality degradation caused by nutrients can also have significant adverse impacts on coral reef 

ecosystems. Lapointe (1997) found that blooms of macroalgae in reefs are correlated with concentrations 

of nitrogen and phosphorus, and that increases in nutrient loadings can shift the relative dominance of 

reefs from corals toward algae, drastically altering habitat and trophic structure. Nutrient-related blooms 

of the green alga Codium isthmocladum in southeast Florida resulted in an emigration of reef fish and dieoffs of sponges and corals (Lapointe et al., 2005). 

In addition to the biological stress it produces, reduced or absent DO can also lead to altered reductionoxidation (redox) chemistry. Low redox conditions can result in increased ammonia concentrations in the 

water column, and internal recycling of phosphorus from the sediment. The former can be toxic to aquatic 

life under certain temperature and pH conditions, and the latter can be problematic for reducing 

phosphorus loadings. 

12.1.3 Mitigating Factors

As indicated in Exhibit 12-1, there are several mitigating factors that will potentially influence the degree 

or magnitude of response of a waterbody to eutrophication. The amount of color in the water (i.e., the tint 

due to dissolved substances, independent of suspended material) influences the potential nutrient-based 

productivity. Highly colored waters will not be as susceptible to nutrient addition as the depth of light 

penetration will be attenuated and primary productivity lessened. Turbidity due to suspended inorganic 

particles (silts and clays) will also tend to reduce productivity due to both light limitation and the 

adsorption of nutrients to the clay particles. 

Hydraulic residence time (sometimes expressed as its reciprocal, the flushing rate) can mitigate the effect 

of nutrients. If the residence time is sufficiently short, algal blooms will not develop as the growing cells 

are quickly washed away and do not accumulate in the water column. Where such nutrient-laden waters 

flush more slowly, significant algal blooms may develop. Depending on the physical configuration of the 

waterbody, tidal flushing may reduce or increase impacts of eutrophication. In the case of an open coastal 

system, tidal flushing and longshore currents may act to dilute or sweep away algal accumulations. 

Conversely, in the case of complex and/or constricted coastal embayments, tidal action may serve to 

concentrate algal concentrations in interior portions. 

Depth is an important factor since deeper waters tend to be less productive than shallow waters. This is 

due to the euphotic zone occupying a greater proportion of the volume of shallow waters, as well as the 

greater probability for thermal stratification to occur in deeper waters. In addition, where estuaries enter 

the marine environment, the fresher, less dense water flows over the salty, denser marine waters, a 

salinity-based stratification can occur; further compartmentalizing the water column. In either case, algae 

sinking in deeper, dark waters are much less likely to be re-suspended.

Grazing refers to the ingestion of the phytoplankton by herbivorous zooplankton. Zooplankton and 

macroinvertebrates can be an important controlling mechanism for preventing algal blooms from 

developing. The size and composition of the fish community can also influence the biomass and 

effectiveness of the zooplankton grazers in controlling the primary producers. 
January 2012 12. Description of Benefits of Reducing Nutrient Loads to Florida Estuaries

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12.2 Impacts of Nutrients on Environmental Goods and Services

Eutrophication of estuaries, coastal waters, and south Florida inland waters may have a significant impact 

on the value of environmental goods and services provided by these waters. 

12.2.1 Impacts of Harmful Algal Blooms (HABs)

Exhibit 12-1 shows the link between eutrophication in bays, estuaries, and coasts and the provision of 

environmental goods and services. For example, the occurrence of nuisance or toxic HABs adversely 

affects a number of designated water uses including: contact recreational activities and recreational and 

commercial fishing, and may also pose human health risks. Reductions in recreational opportunities (e.g., 

decrease in catch rates), decline in aesthetic value, adverse public perceptions of the safety of polluted 

water, and potential exposure to health risks may also adversely affect tourism, both locally and at the 

state level. 

A large body of research on HABs in coastal waters in Florida focuses on “red tide” blooms, which are 

caused by dinoflagellate species (Kirkpatrick et al., 2002). Although increased nutrient levels are 

correlated with red tide blooms, numerous other factors also contribute, and it is not possible to directly 

link nutrient reductions with reduced duration and frequency of red tide events (Alcock, 2007). For this 

reason, this analysis does not specifically consider benefits stemming from avoided red tide blooms. 

One major HAB group of concern for bays, estuaries, and coasts are the blue-green algae which pose a 

toxic risk to mammals including wildlife and humans due to the presence of cyanotoxins and other toxic 

compounds released when the algae decay (Fleming and Stephan, 2001). Blue-green algae toxins are 

classified according to mode of action and include hepatotoxins (e.g., microcystins), neurotoxins (e.g., 

anatoxins), skin irritants, and others (WHO, 2003a). The cyanobacterium Lyngbya, which is found in 

coastal waters in Florida, is associated with skin irritation and may promote skin tumors (WHO, 2003b).

Contact recreation includes swimming and other activities (e.g., jet-skiing, kayaking) where direct dermal 

exposure to water is likely. Swimmers’ direct contact with water makes them susceptible to irritants or 

toxins associated with certain types of HABs that may occur with nutrient pollution (Fleming and Stephan 

2001). Although HAB-related beach closures in coastal and estuarine waters in Florida are typically 

associated with red tide events, which may not be linked as directly to nutrient loadings, evidence from 

Maryland demonstrates that cyanobacteria toxins can constitute a sufficient human health risk to warrant 

beach closures in estuarine environments (Fristachi et al. 2008). 

Phlips et al. (2002) examined the distribution of potentially toxic cyanobacteria in waters in Florida. The 

study noted blooms of the cyanobacterium Synechococcus in two large Florida estuaries – Florida Bay 

and the Indian River Lagoon. Paerl et al. (2009) found Lyngbya at sixteen sites along the Florida coast, 

with persistent blooms occurring in three locations. Decreased levels of nutrients associated with the 

numeric nutrient criteria would reduce the number of HABs and thus reduce toxin levels and health risk 

to swimmers, also potentially curtailing more substantial HABs outbreaks such as the one in Grand Lake 

St. Mary’s. 

12.2.2 Impacts of Submerged Aquatic Vegetation Loss

Seagrasses often are a major determinant of the trophic structure of coastal ecosystems, providing food, 

habitat, and shelter for a wide range of fish species and provide feeding grounds for marine mammals, 

reptiles, and birds (Zieman, 1982). Increased nutrient loadings are frequently associated with the loss of 

SAV, especially seagrasses, and can be devastating for estuarine ecosystems, leading to reduction in 

recruitment for coastal commercial fisheries and shellfisheries. Some seagrass habitats also serve as 
January 2012 12. Description of Benefits of Reducing Nutrient Loads to Florida Estuaries

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12-6

nurseries for juveniles of species that spend their adulthoods in other habitats (Beck et al., 2001). 

Seagrasses also improve water quality by increasing DO and absorbing excess nutrients (US EPA, 2006). 

In Florida, seagrass habitat is a highly valuable ecological and societal resource. Florida DEP has 

estimated that each acre of seagrass is worth $20,255 per year, which would translate to a benefit of 

$44.6 billion statewide (Carlson and Yarbro, 2008). In 2009, Florida seagrass communities supported an 

estimated harvest of $23 million for six species of commercial fish and shellfish dependent upon seagrass 

habitat (Crist, 2010). Some commercially fished species that rely upon seagrass habitat include pink 

shrimp, stone crab, spiny lobster, and snapper. SAV in the Florida Keys also provides habitat for over 30 

species of tropical invertebrates that are harvested by the marine collection industry (Florida DEP, 

undated).

Seagrasses also provide forage for threatened and endangered species including manatees and sea turtles 

(Orth et al., 2006; Beck et al., 2001). Nutrient-induced reductions in seagrass habitat could have adverse 

implications for the populations of these species.

12.2.3 Impacts of Degraded Water Quality

Low ambient DO concentrations or anoxia adversely affects fish growth and reproductive success and can 

result in shifts in a fish community to low DO tolerant species, reduced growth rates, and more frequent 

fishkills. In waters with an anoxic bottom layer, the available volume of open water habitat for fish and 

zooplankton is reduced. Excess, decaying organic material and low DO often lead to unsightly or 

aesthetically-unpleasing shorelines (sight and/or odor) that discourage beach recreational activities and 

tourism (Bricker et al., 2007). Unsightly or aesthetically-unpleasing shorelines may also affect waterfront 

property values (U.S. EPA, 2010e). 

Additionally, degradation caused by nutrients can have significant adverse impacts on coral reef 

ecosystems. As noted earlier, Lapointe (1997) found that blooms of macroalgae in reefs are correlated 

with concentrations of nutrients, and that increases in nutrient loadings can shift the reefs from coral 

dominance toward algae dominance, with significant impacts on habitat and trophic structure. This 

degradation diminishes the value of reefs as tourist destinations.

As noted in Exhibit 12-1, the combination of the presence of HABs, loss of SAV, and low DO conditions 

will impact ecological services such as biodiversity (i.e., the number of species and habitats present), 

organism health (i.e., population viability and reproduction), and ecosystem function (e.g., carbon 

sequestration, nutrient cycling, waste assimilation). The effects of eutrophication in altering these types of 

ecological functions are well-documented (e.g., Smith et al., 1999; Hauxwell et al., 2001).

12.3 Types of Benefits Associated with Nutrient Reductions

Implementing nutrient criteria and reducing nutrient concentrations in bays, estuaries, and coasts should 

reduce or prevent the adverse effects of eutrophication and, as a result, enhance the environmental goods 

and services that these waters provide. For impaired bays, estuaries, and coasts, the restoration goal is to 

move these waters from a nutrient-rich, eutrophic state to a lower nutrient state closer to the natural 

condition of the waterbody. For unimpaired waters, the criteria establish benchmarks for limiting loads 

and preventing a loss of designated uses in the future, thus maintaining beneficial uses.

As shown in Exhibit 12-2, EPA has identified the types of benefits often associated with environmental 

policies, including improvements in water quality, and the types of methods that can be used to assign 

value to such benefits. Categories that may be applicable to nutrient reductions in Florida include human 
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health, ecological, and other benefits. The sections below discuss the potential for benefits in these 

categories.

Exhibit 12-2: Types of Benefits Associated with Environmental Policies

Category Examples Valuation Methods

Human Health Improvements

Mortality risk reductions Reduced risk of fatality from 

acute health risks

Averting behavior, hedonics, 

stated preference

Morbidity risk reductions Reduced risk of nonfatal illness

(e.g. gastrointestinal issues)

Averting behavior, hedonics, 

stated preference

Ecological Improvements

Market products

Harvests or extraction of food and 

other naturally-occurring products

and raw materials

Production function

Recreation activities and 

aesthetics

Wildlife viewing, fishing, boating, 

swimming, hiking, scenic views

Production function, averting 

behaviors, hedonics, recreation 

demand, stated preference

Valued ecosystem functions

Sediment trapping, soil retention, 

nutrient cycling, biodiversity, 

water filtration, soil fertilization, 

pest control

Production function, averting 

behaviors, stated preference

Nonuse values

Relevant species populations, 

communities, or ecosystem

health

Stated preference

Other Benefits

Aesthetic improvements Visibility, taste, odor Averting behaviors, hedonics, 

stated preference

Reduced materials damage Reduced soiling and corrosion Averting behaviors, production 

function, cost function

Source: U.S. EPA (2010a)

Note that there may be a lag between nutrient reductions and associated benefits in estuaries and coastal 

waters. In some estuaries, groundwater is a significant source of nutrient loadings, and in these estuaries, 

there may be significant lag periods, as long as decades, between reductions in anthropogenic nutrient 

loadings to groundwater and observed improvements in the estuaries (Glibert et al., 2010).

12.3.1 Human Health Improvements

High concentrations of HABs can pose potential health risk associated with irritants, gastrointestinal 

diseases, and other concerns. As noted above, several Florida estuarine areas have documented chronic 

cyanobacteria blooms, including Florida Bay, Indian River Lagoon, Broward County reefs, and the 

coastal waters of Sanibel Island (Phlips et al., 2002; Paerl et al., 2009). Exposure to contaminated water 

may cause dermal, gastrointestinal, or other symptoms (Phlips et al., 2002). 

To the extent that the criteria and associated nutrient reductions reduce current exposures and illness and 

prevent future exposures and illness, society values these types of reduced health risks. The cost of illness 

(COI), including treatment costs and lost wages, can provide a lower bound on societal value as a 

measure of avoided costs (rather than the preferred willingness-to-pay measure of benefits that includes 

the value of avoided pain and suffering as well as out-of-pocket costs). COI values represent a lower 

bound value because these costs do not include the value of avoiding pain and suffering.
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12.3.2 Ecological Improvements

The goods and services provided by estuaries and coastal waters in Florida are particularly valuable

commercially, due to the large fishing and tourism industries, and ecologically, due to the wide range of 

biodiversity they support. Ecological benefits that may arise from nutrient reductions include market 

benefits, such as those associated with commercial fisheries and shellfisheries, and benefits to other 

markets such as ecotourism; recreational uses, such as boating, fishing, and swimming; ecosystem 

functions, such as nutrient cycling and biodiversity; and benefits that are not associated with use of the 

resources (nonuse benefits), such as preservation of species for future generations (existence and bequest 

values).

Commercial Fisheries and Shellfisheries

Hypoxic events in a single water body can cause millions of dollars in economic losses from recreational 

and commercial fishing alone (CENR, 2010). Numerous species of commercial fish and shellfish rely on 

Florida bays, estuaries, and coasts during at least one life stage. SAV in coastal and estuarine waters serve 

as important habitat to several major commercial species, including pink shrimp, stone crab, spiny lobster 

and snapper (Florida DEP, undated). As described above, anthropogenic nutrient loadings can have 

substantial adverse impacts on availability of SAV, which in turn reduces available habitat for these 

species. 

The reduction in nutrients associated with the adoption of numeric criteria would reduce the probability of 

further habitat loss and could allow for the reestablishment of SAV habitat in areas where it has already 

been lost. The fisheries industries related to the aforementioned commercial species bring in tens of 

millions of dollars to Monroe County alone on an annual basis (Florida DEP, undated). However, since 

multiple factors other than nutrient criteria can determine the presence and abundance of SAV and its 

suitability as habitat, the magnitude of the benefit directly attributable to the criteria would be difficult to 

estimate. 

Tourism

The tourism industry in nearshore counties in Florida contributes approximately $12.35 billion (2004 

dollars) to the state economy annually13 (NOEP, 2006). HABs can lead to public health department 

posting of water quality advisories due to potential health risk associated with irritants, gastrointestinal 

diseases, and other concerns. Reductions in the magnitude and duration of HABs linked to excess 

nutrients will prevent losses to local economies. As noted earlier, recent research funded by NOAA found 

Lyngbya spp. cyanobacteria in sixteen different coastal areas throughout Florida (Paerl et al., 2009). 

Although an analysis of economic impacts on Florida beaches caused by a cyanobacteria bloom is not 

available, studies of tourism impacts resulting from red tide events find substantial adverse effects.14 Lack 

of information on locations and frequencies of cyanobacterial HABs and lost recreational value from 

beach closures in Florida make it difficult to quantify the economic benefits to the tourism sector that may 

be associated with reductions in nutrient loadings and HABs in Florida waters.

Coastal saltwater fishing is a major attraction for both native Floridians and tourists and is a substantial 

boon to the Florida economy. Saltwater anglers averaged 10.8 million fishing trips per year within 

 

13 Tourism data is for 2004, the most recent year for which data is available. Except where otherwise noted, dollar values 

presented in this chapter are in 2010 dollars, inflated from original year dollars using CPI.

14 For example, Larkin and Adams (2006) found that red tide-related HABs reduced restaurant and lodging revenues in the Ft. 

Walton Beach and Destin areas of Northwest Florida by $3 million and $4 million per month, respectively.
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territorial sea in Florida from 2005 to 2009 (NOAA, 2011). Recreational saltwater fishing in Florida has 

an annual impact of $5.4 billion dollars (FFWC, 2010).

Ecotourism is an important sector in the economy of Florida and one which is highly vulnerable to the 

adverse impacts of eutrophication. Water quality aesthetics are directly linked to ecotourism, since 

tourists are drawn by the untouched natural beauty or uniqueness of a particular ecosystem. Florida has 

many unique environments and species, including coral reefs and manatees, that attract visitors. Thus, the 

principal benefits of ecotourism are avoiding loss of tourist dollars arising from declining attendance at 

natural attractions due to water quality degradation, or maintaining growth in income generated by 

increased tourism to natural attractions where water quality has been restored.

These natural attractions are vulnerable to increased nutrients as documented in studies of reefs in 

southeast Florida where blooms of the green alga Codium isthmocladum resulted in an emigration of reef 

fish and die-offs of sponges and corals (Lapointe et al., 2005). Lapointe et al. (2005) found that 

anthropogenic nutrient pollution was likely a contributing factor to these blooms. Controls that reduce 

nutrient levels in surface waters and applied to the watershed (e.g., fertilizer reductions, septic system 

upgrades) may reduce nutrients that runoff directly or indirectly into reefs (see Sections 8 and 9).

Reef-related recreational expenditures on activities such as snorkeling, scuba diving, fishing, and glass 

bottom boating in four counties in southeastern Florida for a one year period in 2000-2001 totaled $5.37 

billion (Johns et al., 2001). Preventing deterioration of water quality will avoid the costs associated with a 

loss of tourism dollars associated with reef damage. For example, Johns et al. (2001) estimated total 

economic contribution of reef related expenditures to income in four Florida counties at nearly $2.5 

billion between June 2000 and May 2001, of which $1.5 billion stemmed from natural reefs. Tourist 

activities primarily included fishing, diving and snorkeling. Natural reefs supported 45,000 full-time and 

part-time jobs during that period (Johns et al., 2001). 

Property Values

Due to population growth, there has been significant development of coastal properties in Florida. 

Previous studies suggest that waterfront property is more desirable when located near unpolluted water, 

and therefore property values increase with improved water quality and vice versa. Improvement of water 

quality following implementation of the numeric nutrient criteria may increase waterfront property 

values. 

Hedonic property models can be used to quantify the difference in property value for a given change in 

water quality in a particular locale. Hedonic models allow estimation of the impact of a unit change in

water quality (i.e., implicit price) on property prices. 

For example, Czajkowski and Bin (2010) estimated the property price impacts of changes of several water 

quality measures in coastal Martin County, South Florida, including temperature, pH, water visibility 

(clarity), salinity, DO, and the general indicator location grade, which is compiled by combining relative 

quality of four of the aforementioned indicators, excluding temperature. The results indicate that even 

small improvements in water quality could be worth thousands of dollars to individual properties. It is 

important to note, however, that this method does not account for nonuse values and that there may be 

some overlap with other values such as recreational use.

The authors found that the impact of all indicators except for DO on sale price was significant. Of the 

measures given, water visibility is the one most directly related to nutrient loadings. The mean marginal 

value of a one percent improvement in water visibility, all other things equal, was $5,263 (Czajkowski 

and Bin, 2010).
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Recreation and Aesthetics

The degradation of water resources resulting from high nutrient concentrations may negatively affect 

recreational opportunities. As stated above, high levels of HABs could lead to beach closures, because of 

potential health risk, reducing the occurrence or quality of recreational activities. In addition to health and 

safety concerns, eutrophication may lead to the aesthetic degradation of water resources. Algal and 

cyanobacterial blooms, and particularly surface scums, are unsightly and can have unpleasant odors, 

causing beachgoers to go elsewhere even when a beach is not closed, diminishing recreational values. The 

color, clarity, and taste of water adversely affect many recreational activities, including recreational 

fishing, boating, diving, snorkeling, and swimming. 

Eutrophication reduces the amount of DO in a waterbody, leading to fish kills. This in turn leads to fewer 

and smaller fish, and a reduction of the game fish population. Reductions in SAV also have adverse 

impacts on fishery stocks. Florida ranks number one nationwide in economic impacts from saltwater 

fishing (FFWC, 2010). Between 2005 and 2009, anglers took an average of 10.8 million saltwater fishing 

trips in the territorial sea of Florida (NOAA, 2011). 

Activities that take place near water, such as hiking, jogging, picnicking, wildlife watching, and camping 

may also be adversely affected by nutrient discharges into the water. While these activities do not involve 

water contact, visually unpleasant water and odors may greatly detract from the enjoyment gained 

through these activities. Decreases in fish populations may cause a reduction in wildlife near the resource, 

affecting wildlife viewing. Additionally, toxic cyanobacteria may poison birds and other wildlife through 

bioaccumulation, reducing the wildlife population near a waterbody (Landsberg and Shumway, 1998). 

Improved water quality from reducing nutrient discharges will enhance the recreational uses of water 

resources, thereby resulting in welfare gain to recreational users of these resources. Improved water 

quality from reducing nutrient concentrations may translate into three components of recreational 

benefits: (1) an increase in the value of a recreational trip resulting from a more enjoyable experience, (2) 

an increase in recreational participation, and (3) and increase in the number of available recreational sites. 

Valued Ecosystem Functions

Attainment of the nutrient criteria should improve ecological functions such as biodiversity and protection 

of sensitive species. Since eutrophication tends to drive ecosystems to physical and chemical conditions 

(turbidity, low DO, highly organic sediments) which are tolerated by a smaller suite of biota, reduction in 

nutrients will allow the re-establishment of SAV and pollution-intolerant species (Greening and Janicki, 

2006). 

The ability of SAV to re-establish in Florida estuaries under conditions of reduced nutrient loading is 

already documented. For example, Tampa Bay recovered nearly 8,000 acres of seagrass between 1982 

and 2008 following reductions in nutrient loadings due to more stringent wastewater and stormwater 

standards enacted in the 1980s and nitrogen management measures introduced in the watershed in the 

early 1990s (Tampa Bay NMC, 2010). Increased species diversity is often linked to ecological capacity to 

resist disturbance.

Estuarine and coastal waters provide habitat for numerous endangered and threatened species (Smith, 

2003). Florida is home to 53 federally listed endangered or threatened animal species and 54 endangered 

or threatened plant species, several of which are coastal aquatic species (U.S. FWS, 2011). The value of 

these species is indicated by federal and state expenditures on conservation efforts to protect and restore 

them. Expenditures for the West Indian manatee alone totaled nearly $10 million for fiscal year 2003, 

although this spending is not solely in Florida (U.S. GAO, 2005). 
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Attempting to isolate the effects of nutrients from other stressors of special concern in Florida and 

elsewhere is difficult. Symbolic threatened and endangered species such as the Florida manatee and 

several sea turtle species are affected somewhat by water quality and nutrient conditions through the food 

chain (e.g., effects on aquatic macrophytes), although other factors (e.g., water temperature, hydrological 

variation, direct human interference) are also important. 

In the case of the Florida manatee, preferred manatee habitat is characterized by the availability of good 

quality SAV (Smith, 1993). In coastal waters, manatees feed primarily on submerged aquatic 

macrophytes such as Thalassia hemprichii and Syringodium filiforme (U.S. FWS, 2001). Nutrient loading 

to estuaries promotes the growth of epiphytic algae and decreased light transparency, thus reducing 

available SAV forage (Nelson, 2009). Reduced watershed loadings to meet nutrient criteria will improve 

the quality of the preferred habitat for this keystone species.

Losses of sensitive species are generally linked to loss of their habitat, either by outright modification or 

elimination or by the alteration of the highly specific combination of physical, chemical or biological 

factors that provide the specialized niche. These changes can be attributed to a variety of causes but 

eutrophication can be a major factor since changes in the nutrient regime can lead to differences in the 

way competitive interactions occur between species and lead to major shifts in community composition.

This is particularly relevant in the case of seagrasses and other SAV, which provides habitat for a wide 

range of biota but which is sensitive to anthropogenic nutrient loadings.

Nonuse Values

Even if no human activities or uses are affected by environmental changes caused by nutrient runoff, such 

environmental changes may still affect social welfare. For a variety of reasons, including bequest, 

altruism, and existence motivations, individuals may value the knowledge that water quality is being 

maintained, that ecosystems are being protected, and that populations of individual species are healthy 

independent of any use. It is difficult to quantify the relationship between changes in pollutant discharges 

and the improvements in societal well-being that are not associated with current use of the affected 

ecosystem or habitat. 

That nonuse values exist is indisputable, as evidenced, for example, by society’s willingness to contribute 

to organizations whose mission is to purchase and preserve lands or habitats to avert development 

(although some portion of these donations may be motivated by use values). Notwithstanding challenges 

involved in estimation of nonuse values, there is a substantial literature devoted to such issues (Bateman 

et al., 2006). These studies use stated preference methods, which are the only option for eliciting

estimates of individuals’ willingness to pay for resources they do not directly use. This literature provides 

insight into analysts’ ability to estimate nonuse values within various types of policy contexts, and for 

various types of resources.

Various studies have found that individuals are willing to pay for water quality improvements, including 

nutrient reductions affecting wildlife habitat regardless of whether or not they are direct uses (e.g., 

anglers). Hazen and Sawyer (2008) report that the average non-use value, expressed in terms of a onetime tax to be put into a trust fund to maintain the Indian River Lagoon estuary in Florida, was $13.75 

among visitors who had not engaged on recreational activities on the lagoon in the past year, and $38.38 

among visitors who had. For local residents, willingness to pay the one-time tax was $106.22 per 

respondent. Another study by Bendle and Bell (1995) found that Florida households valued protection of 

the West Indian Manatee population in Florida at an average of $22.34 per year per household.
January 2012 13. Potential Incremental Benefits of the Numeric Nutrient Criteria

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13 Potential Incremental Benefits of the Numeric Nutrient Criteria

As discussed in Section 12, excessive nutrient concentrations may have a wide range of effects on 

estuaries, coastal waters, and south Florida inland waters in Florida, impacting environmental services 

valued by humans, such as recreational uses of the waters. This section provides estimates of the potential 

magnitude of the benefits of reducing nutrient concentrations to meet the proposed numeric water quality 

criteria, based on existing literature.EPA quantified the potential magnitude of the potential benefits by 

comparison to an index of water quality, and valuing improvements in water quality based on a metaanalysis of valuation studies for the types of uses supported by different water quality levels.

These benefits are attributable to all the nutrient pollution control actions that will be implemented, 

including those to meet baseline requirements to the extent that they will affect future water quality in the 

estuary, coastal waters, and south Florida inland waters currently not in attainment of the proposed 

criteria. 

13.1 Water Quality Index

Researchers have developed the concept of a water quality index (WQI) to translate measurements of 

multiple parameters of water quality into a single numerical indicator that can be easily interpreted by 

policy makers and the general public. Once an overall WQI value is calculated, it can be related to 

suitability for potential uses. For example, Vaughan (1986) developed a conceptual water quality ladder

to indicate whether water quality is suitable for various anthropogenic uses of freshwater systems, and 

identified “minimally acceptable parameter concentration levels” for each of the five potential uses (i.e., 

boating, rough fishing, game fishing, swimming, and drinking without treatment). Vaughan (1986) 

deemed water quality acceptable for each use if all of the parameters met the identified threshold 

concentration levels.

Water quality is measured differently in freshwater and marine contexts. The nature of anthropogenic and 

ecological uses for estuaries and coastal marine differs significantly from those of freshwater aquatic 

systems with many water uses not relevant to a marine setting (e.g., drinking water, irrigation, coldwater 

fishery). For purposes of the WQI, water quality attainment should be linked to appropriate marine uses. 

Under the Florida Surface Water Quality Standards (62-302.400 F.A.C.), the designated Florida water 

uses include: 

 Potable Water Supplies (Class I)

 Shellfish Propagation or Harvesting (Class II)

 Fish Consumption; Recreation, Propagation and Maintenance of a Healthy, Well-Balanced Population 

of Fish and Wildlife (Class III)

 Fish Consumption; Recreation or Limited Recreation; and/or Propagation and Maintenance of a 

Limited Population of Fish and Wildlife (Class III-Limited)

 Agricultural Water Supplies (Class IV)

 Navigation, Utility and Industrial Use (Class V)

These water quality classifications are arranged in order of the degree of protection required, with Class I 

water generally having the most stringent water quality criteria and Class V the least. 
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For Florida marine waters, potable and agricultural water supplies are not relevant. In addition, Class IIILimited waterbodies are restricted to those with human-induced physical or habitat conditions that 

prevent attainment of Class III uses. Since this designated use is not linked to attainment of chemical 

water quality, it is also not relevant for application to a WQI. 

In contrast, Outstanding Resource Waters (i.e., waters so designated under Special Protection, 

Outstanding Florida Waters, Outstanding National Resource Waters (62-302.700 F.A.C)) represent an 

additional designation for coastal waters. Outstanding resource waters are based on state or federal 

recognition (e.g., State Aquatic Preserves, National Estuary Program).

The following are the anthropogenic and ecological uses in coastal and marine settings, listed in 

approximate order of decreasing water quality requirements: 

1. Outstanding resource waters

2. Shellfish Propagation or Harvesting 

3. Fish Consumption; Recreation, Propagation and Maintenance of a Healthy, Well-Balanced 

Population of Fish and Wildlife

4. Navigation, Utility and Industrial Use

WQI are synthetic summations of water quality parameters of interest, and researchers may include or 

delete parameters for various purposes. For example, Brown et al. (1970) incorporated nine water quality 

parameters relevant to evaluation of riverine systems in which water quality was heavily influenced by 

point source discharges (e.g., wastewater treatment plants). In modifying the WQI for previous analyses

(U.S. EPA 2009b), EPA removed pH and temperature from the calculations, and included chlorophyll-a

only for water quality assessments of estuarine waters. For the waters affected by the proposed rule, 

parameters in these indices other than those for which EPA is proposing criteria (TN, TP, chlorophyll-a)

are either implicitly accounted for under the proposed criteria (DO, BOD, TSS) because of the related 

effects of control actions, or are less relevant to the marine setting (FC). Therefore, for this analysis, EPA 

used only TN, TP, and chlorophyll-a in the WQI.

For this analysis, EPA developed a WQI based on five threshold values marking boundaries of freshwater 

quality use classifications (U.S. EPA, 2002; U.S. EPA, 2009b). Several researchers (e.g., Cude, 2001, 

CCME, 2001, BISF, 2003, Wazniak et al., 2007) have employed WQI scoring systems with five 

increments of water quality, with each step corresponding to a numeric range, qualitative descriptor, 

and/or a letter grade, including several for estuaries and coastal waters.

These five levels of water quality are generally equated to qualitative narrative classifications 

(“Excellent”, “Good”, “Fair”, “Poor”, and “Highly Degraded”) that are easily recognized by the public. 

These qualitative classifications have also been interpreted with descriptive conditions of the degree of 

water quality standard violations (CCME, 2001, BISF, 2003), such that:

 Excellent = virtual absence of threat or impairment, close to pristine or natural conditions.

 Good = minor threat or impairment, rarely departs from natural conditions.

 Fair = occasionally impaired or threatened. Sometimes departs from natural conditions.

 Poor or Degraded = frequently threatened or impaired. Often departs from natural levels.

 Very Poor or Very Degraded = almost always threatened or impaired. Usually departs from natural 

levels.
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These qualitative water quality descriptors correspond to numerical thresholds within a range between 

100 and 0, but the exact value of those thresholds are dependent on the WQI method used (Exhibit 13-1).

For example, the Bay Institute of San Francisco index has five ranges15: a narrow upper range (100-95), 

three wide middle ranges (94-80, 79-65, 64-45), and a broad lower range (<45) (BISF, 2003). The narrow 

upper range applies stringent criteria to the most sensitive beneficial uses higher on the ladder (i.e., 

outstanding resource waters). The wide middle ranges acknowledge that most parameter values will fall 

somewhere around the median of the distribution. Finally, the broad lowest range represents those 

situations for which the majority of water quality parameters do not meet criteria and the water is 

acknowledged to be highly degraded.

The WQI used by the State of Maryland to compare water quality and ecological health in coastal bay 

segments compares the median values for TN, TP, Chl a, and DO to established threshold values deemed 

protective of several ecological endpoints, including maintenance of seagrasses, avoidance of 

phytoplankton bloom conditions and maintenance of DO values for fish and benthic communities 

(Wazniak et al., 2007). The index joins these together into one number between zero and one (normalized 

to 0 to 100 in Exhibit 13-1) and categorizes results into five ranges of water quality. A score of 100 

indicates habitat suitable for fish and aquatic grass survival, while a value of zero indicates unsuitable 

habitat for either fish or aquatic grasses. Intermediate values indicate that the system is variable and that 

some ecosystem functions (grass beds or fish) may be expected to be absent some of the time.

Exhibit 13-1: Comparison of Ranges of Numerical Scores Associated with Narrative 

Classes in Two WQI Systems

WSI type Numerical Score Narrative Scale

San Francisco Bay WQI1

95-100 Excellent

80-94 Good

65-79 Fair

45-64 Poor

<44 Very Poor

Maryland WQI2

80-100 Excellent

60-80 Good

40-60 Poor

20-40 Degraded

<20 Very Degraded

1. BISF (2003)

2. Wazniak et al. (2007)

For this analysis, EPA used the two WQI systems above to develop estimates of baseline and postcompliance WQI levels for WBIDs that are identified as potentially incrementally impaired under the 

proposed rule.

13.1.1 Estimated Baseline Water Quality

Estimating the potential change in water quality from attainment of the proposed criteria along an index 

of water quality requires estimation of the baseline water quality condition. The waters that EPA 

 15 CCME defines five WQI rankings: excellent, good, fair, marginal, and poor.
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identified for this analysis as potentially incrementally affected are not among those currently listed by 

FDEP as impaired for nutrient or nutrient-related causes (see Section 4 for the method EPA used to 

identify incrementally affected waters). These potentially incrementally affected waters are shown in

Exhibit 4-2.

As discussed above, EPA assumed that waters attaining the proposed criteria meet the definition of 

“good” water quality. Further, EPA assumed that waters which have been previously investigated by and 

identified under prior CWA Section 303(d) lists as “impaired” (due to violations of water quality 

standards, narrative criteria, presence of nuisance algal blooms, etc.) and thus requiring a TMDL reflect 

“poor” water quality conditions, indicative of waters that are “frequently threatened or impaired and often 

depart from natural levels.” As indicated in Exhibit 13-1, there is agreement that a score of 60 signals the 

lower threshold below which water is of poor quality. For this analysis, EPA assumed that none of the 

waters it identified as potentially incrementally impaired under the proposed rule meet the definition of 

poor water quality. EPA assumed that these waters are of better than poor water quality because they are 

not already listed as impaired under the existing narrative nutrient criterion, or under a nutrient-related 

TMDL.

Waters that FDEP has not yet identified as impaired but that exceed one or more proposed criteria may

fall into the “fair” category, representing waters that are “occasionally impaired or threatened; sometimes 

departing from natural conditions.” EPA assumed that such waters have WQI scores ranging between 60 

and 80 (between poor and good). However, rather than treat all waters that are not listed as impacted but 

that exceed proposed criteria identically (e.g., WQI score = 70), EPA used available water quality data to 

develop a gradient of water quality conditions within the “fair” category such that waterbody WQI scores 

may be identified as closer to the “good” or to the “poor” threshold values. 

For this analysis, EPA used the relative magnitude of exceedence as indication of relative water quality 

within the “fair” interval (60 ≤ WQI < 80). While relatively higher exceedence of water quality standards 

usually indicates poorer water quality for most parameters (e.g., toxics, total dissolved solids), the 

response to nutrients is not as easily interpreted. However, for this analysis, EPA used this method 

(mapping magnitude of percent exceedence of nutrient criteria to the WQI) to focus on the improvements 

due to meeting the proposed criteria, as these waters are not identified for any water quality violation 

other than with respect to the proposed criteria [based on comparison to the existing 303(d) list)].

EPA estimated WQI scores for individual WBIDs by comparing the average annual geometric mean for 

each parameter to the proposed criterion, and estimating the magnitude of criteria exceedence (e.g., 0.02 

indicates that the average of the annual geometric means is 2% above the criterion). EPA ranked and 

distributed the values along a range of 60 to 80 WQI scores such that waterbodies with poorer water 

quality (i.e., higher magnitude of exceedence) are just above a WQI score of 60, and the waters with 

better scores (lower magnitude of exceedence) approximate a WQI score of 80. 

As waterbodies may be evaluated for one to three criteria, a given WBID may be associated with multiple 

WQI estimates under this method. EPA developed baseline WQI estimates for each WBID using three 

scenarios: 1) baseline WQI estimated from exceedences of TN criteria (a scenario in which nitrogen is the 

limiting nutrient of concern); 2) baseline WQI estimated from exceedences of TP criteria (a scenario in 

which phosphorus is the limiting nutrient of concern); and 3) baseline WQI estimated from exceedences 

of Chl-a criteria (a scenario in which Chl-a is the primary concern). If data for a WBID are unavailable 

for one or more pollutants, EPA substituted average criteria exceedence for another pollutant for the same 

WBID, with the following order of preference: TN, TP, Chl-a. With this method, the estimated WQI is 

not a composite index across all parameters. If EPA were to instead estimate such a composite index, it 
January 2012 13. Potential Incremental Benefits of the Numeric Nutrient Criteria

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13-5

would be unclear how to weight each parameter in calculating the index. Lacking information to prefer 

one baseline method over the others, EPA used all three descriptions of baseline water quality to calculate 

a range of benefits

EPA used the three scenarios for this analysis since each parameter can be potentially growth-limiting to 

primary production due to nutrient or light requirements. Scientists consider primary production in 

estuarine and coastal marine systems to be limited primarily by nitrogen. However, the nature of the 

limiting factor can change spatially or temporally due to fluctuation in the nitrogen to phosphorus 

delivery rates shifting the relative abundance of these nutrients. Estuaries and coastal systems subject to 

high nutrient loads may, at various times, display nitrogen limitation, phosphorus limitation, or colimitation by both nutrients (Conley, 2000). In very turbid waters, light availability may be the limiting 

factor. Accordingly, EPA considered the potential water quality improvement realized under these 

scenarios to estimate the range of benefits. 

Exhibit 13-2,

Exhibit 13-3, and

Exhibit 13-4 show the relationship between the percent exceedence and estimated Baseline WQI scores 

for each pollutant, with WBIDs on the horizontal axis, ranked and arrayed from lower to higher water 

quality according to each parameter. 

Exhibit 13-2: Percent Exceedence and Estimated Baseline WQI, TN

Exhibit 13-3: Percent Exceedence and Estimated Baseline WQI, TP
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Exhibit 13-4: Percent Exceedence and Estimated Baseline WQI, Chl-a

Exhibit 13-5 shows the distribution of incrementally impaired WBID miles by WQI value for each of the 

three baseline scenarios. When baseline WQI is estimated based on exceedence of TN criteria, 16% of 

incrementally impaired waters have baseline WQI values between 60 and 65, 5% have baseline WQI 

values between 65 and 70, 17% have WQI values between 70 and 75, and 62% have baseline values 

between 75 and 80. When baseline WQI is estimated based on exceedence of TP criteria, 2% of 

incrementally impaired waters have baseline WQI values between 60 and 65, 1% have baseline WQI 

values between 65 and 70, 26% have WQI values between 70 and 75, and 71% have baseline values 

between 75 and 80. When baseline WQI is estimated based on exceedence of Chl-a criteria, 3% of 

incrementally impaired waters have baseline WQI values between 60 and 65, 1% have baseline WQI 

values between 65 and 70, 20% have WQI values between 70 and 75, and 77% have baseline values 

between 75 and 80.
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13-7

Exhibit 13-5: Estimated Percentage of Incrementally Impaired Coastal and Estuary 

Miles in FL by WQI Classifications

Baseline WQI

Baseline WQI Based on 

% of TN Exceedance

Baseline WQI Based 

on % of TP 

Exceedance

Baseline WQI Based on 

% of Ch-a Exceedance

Total 

Miles

Percent of 

Total

Total 

Miles

Percent of 

Total Total Miles Percent of Total

60 ≤ WQI < 65 860 16% 114 2% 142 3%

65 ≤ WQI <70 270 5% 36 1% 36 1%

70 ≤ WQI < 75 944 17% 1,446 26% 1,081 20%

75 ≤ WQI ≤ 80 3,455 62% 3,933 71% 4,270 77%

Total Miles1 5,530 100% 5,530 100% 5,530 100%

1. Includes miles for all incrementally impaired estuarine, coastal, and south Florida marine WBIDs.

Ch-a = chlorophyll a

TN = total nitrogen

TP = total phosphorus

WBID = water body identification

WQI = water quality index

13.1.2 Estimated Water Quality from Attaining Criteria

Although the numerical ranges of the two WQI methods listed in Exhibit 13-1 differ, there appears to be 

some agreement that “good” water quality is associated with a score of >80; which is also true for many 

other WQIs, including those used in freshwaters (Brown et al., 1970; Cude, 2001; CCME, 2001). 

Based on the description that good water has “a minor threat of impairment and rarely departs from 

national conditions,” EPA assumed that “good” water quality status is associated with attainment of all 

water quality standards and support of all designated uses. This condition and numerical score is also 

consistent with the expected water quality and ecological conditions for Florida marine waters which 

meet their site-specific criteria. [In comparison, meeting the proposed criteria does not elevate marine 

waters to an “excellent” category since that category is likely a function of other factors independent of 

water chemistry (e.g.,, an undeveloped watershed, no nearby discharges).] EPA assumed that attaining 

the proposed criteria is representative of ‘good’ water quality, or a WQI score of 80.

13.1.3 Estimated Incremental Change in Water Quality due to the Proposed Rule

To estimate benefits of water quality improvements associated with the criteria, EPA assumed that all 

incrementally waterbodies will improve from the estimated baseline water quality (as represented by the 

estimated WQI value) to “good” (as represented by a WQI value of 80). The difference in WQI 

(hereafter denoted as ΔWQI) between baseline conditions and compliance with the numeric criteria is a 

measure of the change in water quality that may be attributable to attaining the proposed criteria. To 

monetize benefits of the regulation, EPA calculated the improvement in water quality for all 

incrementally impaired waterbodies for which it estimated a ΔWQI of greater than de minimis (0.01 WQI 

units). EPA did not monetize water quality improvements below 0.01 WQI units because it does not 

expect any value to be placed on such small improvements as the water quality is essentially unchanged. 

As shown in Exhibit 13-6, a total of 5,530 estuarine and coastal miles are potentially incrementally 

impaired under the proposed criteria and thus may attain higher water quality by coming into compliance 

with the proposed criteria for the scenario in which baseline WQI is estimated based on exceedence of TN 

criteria. This mileage accounts for improvements in 100% of the impaired waterbodies and 26% of the 
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13-8

estuarine and coastal miles in the state. In the other two scenarios, 4 WBIDs (56 miles) have baseline 

water quality values that are only slightly below 80 and therefore have de minimis improvements. Thus, a 

total of 5,474 miles (99% of impaired miles and 26% of all miles in the state) are expected to improve in 

these scenarios. Larger improvements in water quality are expected when baseline WQI is estimated 

using exceedence of TN criteria. For example, in this scenario, 20% of the incrementally impaired miles 

(5% of state miles) are expected to have WQI improvements greater than 10 points. Conversely, in the 

other two scenarios, only 3% of the incrementally impaired miles (1% of state miles) are expected to have 

WQI improvements greater than 10 points.

Exhibit 13-6: Total Potential Improved Coastal and Estuary WBIDs and Miles

Change in WQI

Total number 

of WBIDs

Improved

Total Miles 

Improved

Percent of Total 

Miles in Analysis

Percent of Total 

Miles in State

Baseline WQI Based on % of TN Exceedance

0.01 ≤ ΔWQI < 1.0 42 569 10% 3%

1.0 ≤ ΔWQI < 5.0 102 2,887 52% 14%

5.0 ≤ ΔWQI <10 43 944 17% 4%

10 ≤ ΔWQI 43 1,130 20% 5%

Total 230 5,530 100% 26%

Baseline WQI Based on % of TP Exceedance

0.01 ≤ ΔWQI < 1.0 33 395 7% 2%

1.0 ≤ ΔWQI < 5.0 129 3,482 63% 16%

5.0 ≤ ΔWQI <10 54 1,446 26% 7%

10 ≤ ΔWQI 10 151 3% 1%

Total 226 5,474 99% 26%

Baseline WQI Based on % of Ch-a Exceedance

0.01 ≤ ΔWQI < 1.0 59 779 14% 4%

1.0 ≤ ΔWQI < 5.0 125 3,435 62% 16%

5.0 ≤ ΔWQI <10 33 1,081 20% 5%

10 ≤ ΔWQI 9 178 3% 1%

Total 226 5,474 99% 26%

Ch-a = chlorophyll a

TN = total nitrogen

TP = total phosphorus

WBID = waterbody identification

WQI = water quality index

13.2 Estimating Value of Water Quality Improvements

To estimate nonmarket benefits of water quality improvements resulting from the rule, EPA used a 

benefits transfer approach. Benefits transfer involves adapting existing research to evaluate a proposed 

policy impacting similar environmental goods and services in a different place and/or time (Desvousges et 

al., 1998; VandenBerg et al., 2001), and may involve the transfer of unit values or valuation functions, the 

latter of which may include techniques of meta-analysis. Benefit transfer techniques are often the only 

feasible option for providing information to inform environmental policy decisions due to resource 

constraints.
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13-9

Comprehensive estimates of the total value of environmental goods and services include both use and 

nonuse values. Stated preference methods, or benefit transfers based on stated preference studies, are 

generally accepted techniques for estimating these values (Desvousges et al., 1998). Stated preference 

methods rely on surveys that assess respondents’ stated willingness to pay (WTP) for water quality 

improvements. 

To estimate the benefits associated with the proposed rule, EPA used a meta-analysis approach as 

opposed to a unit value based approach or to borrowing a specific benefits function from literature.

Transferring the mean or median values from the original studies may lead to a significant error, because 

the likelihood of finding a good fit between a single (or multiple) study site and a policy site is usually 

low (Boyle and Bergstrom 1992; Spash and Vatn 2006).16 However, if these mean or median values 

contribute to a body of WTP estimates and if these estimates are systematically related to variations in 

resource, study, and site characteristics, then meta-regression analysis may provide a viable tool for 

estimating a more universal transfer function with distinct advantages over unit value or other functionbased transfer methods (Rosenberger and Johnston, 2007). In addition, the use of meta-analysis allows the 

WTP function to be adjusted to reflect resource and population characteristics as well as the expected 

magnitude of environmental improvement at the policy sites.

13.2.1 Meta Analysis of Valuation Studies

To estimate the potential nonmarket benefits associated with attaining the proposed criteria, EPA used a 

benefits transfer function based on a meta-analysis presented in EPA (2009b). EPA identified 45 

valuation studies that use stated preference techniques to elicit benefit values for water quality 

improvements. To examine the relative influence of study, economic, and resource characteristics on 

WTP for improving surface water quality, the Agency conducted a regression-based meta-analysis of 115 

estimates of WTP for water quality improvements, provided by the 45 original studies. 

The general approach to the meta-analysis including analytic methods and model specifications follow 

standard methods used by Johnston et al. (2005) and Shrestha et al. (2007), among many others (e.g., 

Rosenberger and Phipps, 2007). The estimated regression equation provides a means of forecasting WTP

based on variables that represent potential water quality improvements: 

(Eq. 13-1)

In this function, ln(WTP) , the natural log of WTP for water quality improvements, is the dependent 

variable in the meta-analysis. The metadata include independent variables characterizing specific details 

of the resources valued, such as:

 geographic region and scale (e.g., the number of waterbodies)

 resource characteristics (e.g., baseline conditions, the extent of water quality change, and ecological 

services affected by resource improvements)

 characteristics of surveyed populations (e.g., users, nonusers)

 16 Within a benefit transfer context, transfer error is often inversely related to the correspondence between a study site and a 

policy site among various dimensions (Rosenberger and Phipps, 2007).
January 2012 13. Potential Incremental Benefits of the Numeric Nutrient Criteria

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13-10

 other details specific to each study.

Exhibit 13-7, later in this section, provides a summary of the estimated regression equation. EPA (2009b)

provides detail on the metadata, model specification, and justification for the functional form. 

13.2.2 Function Transfer to Proposed Rule

EPA assigned a value to each model variable corresponding with theory, characteristics of the water 

resources, and sites affected by the regulation and the policy context. 

EPA followed Johnston et al. (2006) in assigning values for methodological attributes (i.e., variables 

characterizing the study methodology used in the original source studies), which are set at mean values 

from the metadata except in cases where theoretical considerations dictate alternative specifications. This 

approach follows general guidance from Bergstrom and Taylor (2006) that meta-analysis benefit transfer 

should incorporate theoretical expectations and structures. As such, EPA assigned three of the 

methodology variables – discrete, WQI_study, and outlier_bids – values of one. Year_index is 9.68, 

which corresponds to the mean year that the studies were conducted, 2002, and Nonparam is zero because 

most studies included in metadata used parametric methods to estimate WTP values. Other study and 

methodology variables (volunt, mail, lump_sum, non_reviewed, median_WTP) are also zero (See Exhibit 

13-7 for an explanation of the variable assignments).

EPA used Florida-specific median household income data from the U.S. Census Bureau (2010) to assign 

the income variable for all full time residents in Florida, and income data from Smith and House (2006) to 

assign an income value for seasonal residents.

17 EPA set the nonusers variable to zero, because water 

quality improvements resulting from nutrient reductions would benefit both users and nonusers of the 

affected resources. The dummy variables denoting multiple regions (mr) and the Mountain Plain (mp) 

regional dummy are zero because the water quality improvement will be restricted to waterbodies in 

Florida. 

The default model value is a resource change taking place in saltwater bodies. Therefore, EPA set all 

waterbody type variables (i.e. regional_fresh, single_lake, single_river, salt_pond, multiple_river, 

num_riv_pond) to zero because the only expected water quality improvements in estuaries and coastal 

reaches.

Water quality improvements resulting from the proposed nutrient criteria are likely to enhance a variety 

of water resource uses, including fishing, swimming, and boating. Therefore, variables denoting multiple 

uses (allmult) and recreational fishing (fish_use) have a value of one, while the variable denoting 

nonspecified uses (nonspec) is zero. EPA assigned baseline water quality (baseline) and change in water 

quality (quality_ch) WBID-specific values (see Section 13.1.1).

For a broader discussion of issues involved in the specification of variable levels for meta-analysis benefit 

transfer, see EPA (2009b) and Johnston et al. (2005; 2006).

 17 EPA used the Consumer Price Index to adjust the value from the 2006 survey and study to 2010 dollars. Inflation-adjusted 

income for seasonal residents is $67,364. Income for full-time Florida residents is $47,450.
January 2012 13. Potential Incremental Benefits of the Numeric Nutrient Criteria

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13-11

Exhibit 13-7: Independent Variable Assignments

Variable Coefficient Assigned 

Value Explanation

Study and Methodology Variables

intercept 5.7109 N/A N/A

year_index -0.08043 9.68 Set to 9.68 to reflect the mean year that the studies in the 

data set were conducted. 

discrete -0.1248 1

Set to one to reflect survey efforts that employed discrete 

choice elicitation methods, which are preferred over other 

approaches, such as open-ended and payment card 

methods.

volunt -1.3233 0

Set to zero because hypothetical voluntary payment 

mechanisms are not even potentially incentive compatible 

(Mitchell and Carson 1989).

mail -0.2013 0 Set to zero because mail surveys may be of less quality 

than in-person interviews.

lump_sum 0.5569 0 Set to zero because the policy option will be paid for over a 

period of years.

WQI -0.3275 1 Set to one because of the methodological use of the WQI in 

the meta-analysis.

nonparam -0.6698 0

Set to zero because most studies used in the meta analysis 

used regression analysis to calculate willingness to pay 

values.

non_reviewed -0.2718 0 Set to zero to reflect a preference for studies published in 

peer-reviewed journals.

median_WTP -0.5358 0

Set to zero because only average or mean WTP values in 

combination with the number of affected households will 

mathematically yield total benefits if the distribution of WTP 

is not perfectly symmetrical.

outlier_bids -0.8837 1

Set to one because survey data that exclude such 

responses are preferable; outlier bids are often excluded 

from the analysis of stated preference data because these 

bids (often identified as greater than a certain percentage 

of a respondent’s income) may indicate that 

a respondent did not consider his or her budget constraints 

and or supplementary goods.

Surveyed Population

income 0.0000027 Varies

Median annual household income data from the 2005 -

2009 American Communities Survey and Smith et al 

(2006); median household income values assigned 

separately for full time state residents and part time 

seasonal residents (U.S. Census Bureau 2010 and Smith 

ea al. 2006).

nonusers -0.4036 0

Set to zero in order to estimate the total value for aquatic 

habitat improvements, including both use and nonuse 

values; for nonuser population, the total value of water 

resource improvements includes nonuse values only 

(Freeman 2003). 

Waterbody Type Variables

single_river -0.4279 0 The criteria are only for salt waterbodies, therefore all 

waterbody type variables are set to zero because the 

default value in the model is a resource change taking 

place in estuaries.

single_lake -0.06316 0

multiple_river -1.4752 0

regional_fresh 0.1588 0

salt_pond 0.9849 0
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13-12

Exhibit 13-7: Independent Variable Assignments

Variable Coefficient Assigned 

Value Explanation

Geographic Region and Scale Variables

num_riv_

pond 0.1173 0

Indicates the number of rivers or salt ponds affected by a 

policy, and is set to zero because the criteria affect the 

entire state; this variable assignment is constant across 

study regions.

mr -0.8846 0

Regional variables are omitted from the predictive portion 

of the analysis (i.e., set to zero) because they are not 

relevant to FL. mp 1.6337 0

Resource Improvement Variables

allmult -0.3728 1 Set to one because multiple species may benefit from 

water quality improvements

nonspec -0.4042 0 Set to zero because multiple species may benefit from 

water quality improvements. 

lnquality_ch 0.4065 Varies Set to the natural log of the change in the WQI for a given 

WBID.

fish_use -0.3317 1

Set to one because a variety of aquatic species may 

benefit, therefore enhancing recreational fishing 

opportunities.

fishplus 0.4432 0 Set to zero because a fish population change of 50% or 

greater is unlikely.

lnbase 0.02610 Varies Set to the natural log of the base WQI for a given WBID

N/A means not applicable 

13.2.3 Estimating Annual Household WTP for Water Quality Improvements

Using this regression function, EPA calculated the estimated economic values of water quality 

improvements by WBID. For each WBID, coefficient estimates for each variable, taken from metaanalysis results (Exhibit 13-7, column 2) are multiplied by the variable levels provided above (Exhibit 

13-7, column 3). The sum of these products represents the predicted natural log of WTP (ln_WTP) for a 

given WBID, as indicated by WTP = exp(ln_WTP + σe

2

/2)(Equation 13-2). The final step uses a 

standard formula to transform this predicted natural log into the desired WTP estimate. This formula is 

given by:

WTP = exp(ln_WTP + σe

2

/2) (Equation 13-2)

Where: 

exp(·) = the exponential operator

ln_WTP = the predicted natural log of WTP for WQ improvements in a given WBID

σe

2 = the model residual variance (0.1876) taken from EPA (2009b)

18.

 18 EPA estimated the meta-analysis regression using a multilevel, random-effects specification. The fundamental distinction 

between these models and classical linear models is the two-part modeling of the equation error to account for hierarchical data.

Here, the meta-data are comprised of multiple observations per study, and there is a corresponding possibility of correlated errors 

among observations that share a common study or author. The common approach to modeling such potential correlation is to 

divide the residual variance of estimates into two parts, a random error that is independently and identically distributed across all 

studies and for each observation, and a random effect that represents systematic variation related to each study. The model is 
January 2012 13. Potential Incremental Benefits of the Numeric Nutrient Criteria

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13-13

However, estimates derived from regression models are subject to some degree of error and uncertainty. 

To better characterize the uncertainty or error bounds around predicted WTP, EPA used a procedure 

described by Krinsky and Robb (1986). This involves sampling the variance–covariance matrix of the 

estimated coefficients, which is a standard output of the statistical package used to estimate the metaanalysis model. WTP values are then calculated for each drawing from the variance–covariance matrix 

and an empirical distribution of WTP values is constructed. By varying the number of drawings, it is 

possible to generate an empirical distribution with a desired degree of accuracy (Krinsky and Robb,

1986). The low and high estimate of WTP values are then identified based on the 5th and 95th percentile 

of WTP values from the empirical distribution. These bounds may help decision-makers understand the 

uncertainty associated with the benefit results.

EPA used the Krinsky and Robb (1986) procedure to estimate the 5th, 50th, and 95th percentiles of total 

WTP (reflecting the 90 percent confidence interval of estimates) for both full time and part time seasonal 

residents, based on the results of the total WTP regression model. EPA estimated that seasonal residents 

will live in the state for approximately four months of the year; therefore EPA weighted household WTP 

values for seasonal residents by 33.3%. Error! Reference source not found. presents the results of these 

calculations, for each of the three scenarios.

Although the confidence limits for WTP estimates related to the covariance matrix of meta-analysis 

parameter estimates can be estimated, these limits do not assess the sensitivity of results to changes in 

meta-regression model assumptions or specifications (cf. Johnston et al., 2005; 2006) or assumptions 

implied in benefit aggregation (cf. Loomis, 1996; Loomis et al., 2000; Bateman et al., 2006). As noted 

above, however, a number of assumptions and specifications lead to conservative benefit estimates. These 

assumptions and uncertainties are also discussed further in Section 13.3.

As shown in Exhibit 13-8, average annual household WTP for full time residents for these water quality

improvements may be approximately $12-$14, depending on the exceedence data used to estimate 

baseline water quality. Part time residents have lower average annual household WTP, with estimates of 

approximately $4-$5, depending on the scenario.

Exhibit 13-8: Average Annual Household Willingness to Pay for Water Quality 

Improvement in Florida Estuaries and Coastal Waters (2010$) Across all WBIDs

State Resident Type

Baseline WQI

Based on % of TN 

Exceedance

Baseline WQI

Based on % of TP 

Exceedance

Baseline WQI

Based on % of Ch-a

Exceedance

Full Time FL Resident $13.78 $11.95 $11.53

Part Time Winter 

Resident $4.91 $4.26 $4.11

Ch-a = chlorophyll a

TN = total nitrogen

TP = total phosphorus

WBID = water body identification

WQI = water quality index

 

estimated as a two-level hierarchy, with level one corresponding to non-use value estimates (individual observations), and level 

two corresponding to individual studies. The random-effect may be interpreted as a deviation from the mean equation intercept 

associated with individual studies (Bateman and Jones, 2003).
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13-14

13.2.4 Estimating Total WTP for Water Quality Improvements

To calculate total WTP at the WBID level, EPA used the mean per-household WTP for both full-time and 

part-time residents (under all three scenarios) by WBID shown above, and then multiplied by the number 

of households in each category in 2010 and the percentage of miles or area that comprise a given WBID. 

EPA calculated the number of full-time households in the state by dividing the population estimates by 

the average number of people per household (U.S. Census Bureau, 2010), and the number of part-time 

households by dividing the number of seasonal residents from Smith and House (2006) by the average 

number of people per household (U.S. Census Bureau, 2010). To account for the growth in the number of 

seasonal households between 2006 and 2010, EPA calculated an annual growth rate for the population of 

the state of Florida, and applied this growth rate to the population estimates from Smith and House

(2006). The total WTP equation for each reach is provided below (Equation 12-3)

( , ) ) WBID WBID baseline WBID TWTP = WTP WQI ∆WQI × StateHH × PercentMiles (Equation 13-3))

Where:

TWTPWBID = the WBID-level welfare change from improved water quality 

WTPWBID = the estimated WTP for water quality improvement for a given WBID based on 

baseline WQI (WQI baseline) and the expected change in water quality under the 

post-compliance scenario (ΔWQI)

StateHH = the number of full-time or seasonal households in Florida

PercentMilesWBID= the percentage of total miles (coastal and estuary miles) in the state of Florida 

that are comprised of a given WBID. 

Finally, EPA aggregated WBID-level benefits to the state level for full time and part time households. As 

presented in Exhibit 13-9, full time resident annual benefits range from $82.4 million (mean estimate) for 

improvements in estuaries and coastal waters to $98.5 million (mean estimate), depending on the assumed

baseline water quality. Seasonal resident annual benefits are much smaller, with mean estimates of $1.3

between $1.6 million for the three scenarios. Total benefits may range from $83.7 million to $100.1

million per year.

Exhibit 13-9: Total Annual State Benefits Associated with the Proposed Criteria

(Millions of 2010$) 

State Resident 

Type

Baseline WQI Based on 

% of TN Exceedance

Baseline WQI Based on 

% of TP Exceedance

Baseline WQI Based on 

% of Ch-a Exceedance

Lower 

5% 

Bound 

Mean 

Upper 

95% 

Bound 

Lower 

5% 

Bound 

Mean 

Upper 

95% 

Bound 

Lower 

5% 

Bound 

Mean 

Upper 

95% 

Bound 

Full Time FL 

Resident $42.9 $98.5 $185.7 $35.7 $85.4 $165.2 $33.9 $82.4 $160.8

Part Time Winter 

Resident $0.7 $1.6 $3.1 $0.5 $1.4 $2.8 $0.5 $1.3 $2.7

Total $43.6 $100.1 $188.8 $36.3 $86.8 $167.9 $34.5 $83.7 $163.5

Ch-a = chlorophyll a

TN = total nitrogen

TP = total phosphorus

WBID = water body identification

WQI = water quality index
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Note that a portion of these benefits would be attributable to controls that are not yet fully implemented 

but would result in reductions in nutrient concentrations in estuaries, coastal waters, and south Florida

inland waters. It is not possible to identify the water quality that would result after full implementation of 

such controls. Thus, the portion of benefits attributable to controls beyond the cost analysis (because these 

controls are part of the baseline and required in the absence of the rule) is uncertain.

There is substantial uncertainty regarding the baseline water quality of the waters that may be 

incrementally impaired under the proposed rule. Since these waters are currently unlisted for impairment, 

water quality may be representative of better than “fair”/WQI = 60. To investigate the sensitivity of the 

benefits estimates to the assumption regarding baseline water quality, EPA estimated the three scenarios 

assuming that the baseline WQI values fall between 70 and 80 (i.e., baseline water quality is substantially 

better than “fair”), compared to between 60 and 80. Benefits to Florida residents under this alternative 

assumption are smaller than under the base assumption, as the potential improvement for incrementally 

impaired waters is smaller. Exhibit 13-10 presents the results of this alternative analysis. Total annual 

state benefits may range from $65 to $67.3 in this scenario.

Exhibit 13-10: Total Annual State Benefits Associated with the Proposed Criteria, 

Higher Baseline Water Quality Scenario (Millions of 2010$)

State Resident 

Type

Baseline WQI Based on 

% of TN Exceedance

Baseline WQI Based on 

% of TP Exceedance

Baseline WQI Based on 

% of Ch-a Exceedance

Lower 

5% 

Bound 

Mean 

Upper 

95% 

Bound 

Lower 

5% 

Bound 

Mean 

Upper 

95% 

Bound 

Lower 

5% 

Bound 

Mean 

Upper 

95% 

Bound 

Full Time FL 

Resident $23.5 $64.3 $134.2 $24.7 $66.2 $136.7 $23.4 $63.9 $133.3

Part Time 

Winter Resident $0.4 $1.0 $2.2 $0.4 $1.1 $2.3 $0.4 $1.0 $2.2

Total $23.9 $65.3 $136.4 $25.1 $67.3 $138.9 $23.8 $65.0 $135.6

Ch-a = chlorophyll a

TN = total nitrogen

TP = total phosphorus

WBID = water body identification

WQI = water quality

13.3 Uncertainty and Limitations

There are a number of uncertainties and limitations associated with the analysis of benefits, including the 

extent to which the monetized estimates can be attributed to the proposed rule. For this preliminary 

analysis, EPA estimated the potential magnitude of benefits associated with attaining the proposed 

criteria. These benefits will be attributable to the range of nutrient pollution controls needed to achieve 

the necessary pollutant reductions, including those associated with baseline requirements. However, the 

costs of these actions are appropriately not part of this analysis.

Another source of substantial uncertainty relates to the estimation of the potential change in water quality 

represented by attaining the proposed criteria in incrementally affected waters. EPA estimated baseline 

WQIs for each WBID based on historical observations of exceedances of the proposed criteria. To the 

extent that this relationship is imperfect, estimates of baseline WQI may be biased. Additionally, baseline 

WQI for each WBID is estimated independently for each pollutant (with either the lowest or highest WQI 
January 2012 13. Potential Incremental Benefits of the Numeric Nutrient Criteria

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13-16

value for each WBID selected to estimate benefits). This method does not address the simultaneous effect 

that multiple pollutants may have on water quality. Additionally, parameters other than TN, TP and Chl-a

(e.g., pathogens) may impair designated use and be influenced by nutrients (e.g., DO). Future analysis 

should incorporate the estimated baseline water quality scores with data for other parameters of 

importance for attaining designated uses. However, none of the WBIDs identified here as incrementally 

impaired are listed as impaired for other pollutants in the 303(d) list in Florida. 

Finally, a number of issues and uncertainties are common to all benefit transfers, which involve adapting 

research conducted for another purpose in the available literature to address the policy questions at hand. 

Because benefits analysis of environmental regulations rarely affords enough time to develop original 

stated preference surveys that are specific to the policy effects, benefit transfer is often the only option to 

inform a policy decision. As a result, they are well represented in benefit-cost analyses (Smith et al.,

2002). 

Benefit transfers are by definition characterized by a difference between the context in which resource 

values are estimated and that in which benefit estimates are desired (Rosenberger and Phipps, 2007). The 

ability of meta-analysis to adjust for the influence of study, economic, and resource characteristics on 

WTP can minimize, but not eliminate, potential biases (Smith et al., 2002; Rosenberger and Stanley,

2006; Rosenberger and Phipps, 2007). As is typical in applied benefit transfers, the original studies 

underlying the meta-analysis model used in this analysis provides an imperfect match to the context in 

which values are desired. Therefore, some beneficial effects may not be accounted for while others may 

be overestimated. 

Some related and additional limitations inherent to the meta-analysis model and the subsequent benefit 

transfer include the numerous uncertainties and associated assumptions required to aggregate WTP across 

spatial jurisdictions, as detailed by Loomis (1996), Loomis et al. (2000) and Bateman et al. (2006), among 

others. While these uncertainties are well known, the literature does not agree on appropriate, 

standardized guidance for benefit aggregations, and applied benefit-cost analysis almost universally 

requires simplifying assumptions in order to generate defensible welfare aggregations. In an ideal context, 

analysts would have information necessary to estimate spatially referenced distance decay relationships 

for all changes resulting from policies under consideration (cf. Bateman et al., 2006). However, even the 

most advanced literature provides only simple illustrations of such issues, and none methodologically 

sufficient to support regulatory analysis. 

In analyzing benefits of the rule, EPA estimated nutrient loading reduction benefits to Florida residents 

(both full- and part-time) only. Although residents of other states may hold values for water resources 

outside of their home states if such resources have personal, regional, or national significance, EPA did 

not have sufficient information to estimate WTP for Florida water quality improvements as valued by outof-state residents. As a result, the population considered in the benefits analysis of the rule does not 

represent all the households that are likely to hold values for water resources in the state of Florida. Even 

if per household WTP for out-of-state residents are small, they may be substantial in the aggregate if these 

values are held by a substantial fraction of the population.

Some resource valuation studies have found that respondents in the typical contingent market situation 

may overstate their WTP compared to their likely behavior in a real-world situation. However, the 

magnitude of hypothetical bias on the estimated WTP is uncertain. Following standard benefit transfer 

approaches, including meta-analysis transfers, this analysis reflects the assumption that each source study 

provides a valid, unbiased estimate of the welfare measure under consideration (cf. Moeltner et al., 2007; 
January 2012 13. Potential Incremental Benefits of the Numeric Nutrient Criteria

Draft for Internal Review Only-Do Not Quote or Cite

13-17

Rosenberger and Phipps, 2007). To minimize potential hypothetical bias, EPA set independent variable 

values to reflect best benefit transfer practices.

The estimation of WTP may be sensitive to differences in the environmental water quality measures. 

Studies that did not use the WQI were mapped to the WQI so a comparison could be made across studies. 

The dummy variable (WQI) captures the effect of a study using (WQI=1) or not using the WQI (WQI=0). 

This showed that studies that did not use the WQI had lower WTP values, which indicates that there may 

have been some systematic biases in the mapping of studies that did not use the WQI. In analyzing the 

benefits of this regulation, EPA set the WQI variable to one to reduce uncertainty in WTP estimates 

associated with studies that did not include WQI as a native survey instrument. EPA (2009b) provides a 

detailed discussion of water quality measures used in the original studies included in the meta-analysis.

Transfer error may occur when benefit estimates from a study site are adopted to forecast the benefits of a 

policy site. Rosenberger and Stanley (2006) define transfer error as the difference between the transferred 

and actual – generally unknown – value. While meta-analysis is fairly accurate when estimating benefit 

functions, transfer error may be a problem in cases where the sample size is small. While meta-analyses 

have been shown to outperform other function-based transfer methods in many cases, this result is not 

universal (Shrestha et al., 2007). However, results reviewed by Rosenberger and Phipps (2007) are “very 

promising” regarding the performance of meta-analytic benefit transfers relative to alternative transfer 

methods.

Finally, there may be a lag between nutrient reductions and associated benefits in estuaries and coastal 

waters. The length of this lag, however, varies considerably depending on the source of nutrient loadings 

to estuaries. In some estuaries, for example, groundwater is a significant source of nutrient loadings, and 

there may be significant lag periods, as long as decades, between reductions in anthropogenic nutrient 

loadings to groundwater and observed improvements in the estuaries (Glibert et al., 2010). Given this 

variability, EPA does not estimate a constant lag period for the attainment of benefits from water quality 

improvements. Instead, the estimate presented above represent the potential benefits of full attainment of 

the proposed criteria.
January 2012 14. References

Draft for Internal Review Only-Do Not Quote or Cite

14-1

14 References 

Ahn, H., and T. James. 1999. Variability, uncertainty, and sensitivity of phosphorus deposition load 

estimates in south Florida. Ecosystem Restoration Department, South Florida Water Management 

District. As cited in Gao, X. 2006. TMDL Report: Nutrient and Unionized Ammonia TMDLs for 

Lake Jesup, WBIDs 2981 and 2981A. Florida Department of Environmental Protection.

Alcock, F. 2007. An Assessment of Florida Red Tide: Causes, Consequences and Management Strategies. 

Mote Marine Laboratory Technical Report #1190. Electronically available at: 

http://www.mote.org/clientuploads/Documents/MPI/Final_MPI_RedTide_no_embargo_bar.pdf

Anderson, D.L., M.B. Tyl, R.J. Otis, T.G. Mayer, K.M. Sherman. 1998. Onsite Wastewater Nutrient 

Reduction Systems (OWNRS) for Nutrient Sensitive Environments. In On-Site Wastewater 

Treatment: Proceedings of the Eighth National Symposium on Individual and Small Community 

Sewage Systems, ed. D.M. Sievers. American Society of Agricultural Engineers, St. Joseph, MI.

Bateman, I.J., B.H. Day, S. Georgiou and I. Lake. 2006. “The Aggregation of Environmental Benefit 

Values: Welfare Measures, Distance Decay and Total WTP.” Ecological Economics 60(2): 450-460.

Bay Institute of San Francisco (BISF). 2003. San Francisco Bay Water Quality Index: Indicator Analysis 

and Evaluation. San Francicso, Bay Institute of San Francisco (BISF): 1-21.

Beck, M.W., K.L. Heck, Jr., K.W. Able, D.L. Childers, D.B. Eggleston, B.M. Gillanders, B. Halpern, 

C.G. Hays, K. Hoshino, T.J. Minello, R.J. Orth, P.F. Sheridan, and M.P. Weinstein. 2001. The 

Identification, Conservation, and Management of Estuarine and Marine Nurseries for Fish and 

Invertebrates. Bioscience. 51(8): 633-641.

Bendle, B.J. and F.W. Bell. 1995. An Estimation of the Total Willingness to Pay by Floridians to Protect 

the Endangered West Indian Manatee through Donations. As cited in Letson, D. and J.W. Milon 

(eds.). 2002. Florida Coastal Environmental Resources: A Guide to Economic Valuation and Impact 

Analysis. Florida Sea Grant under NOAA Grant #NA16RG-2195. Electronically available at: 

http://nsgl.gso.uri.edu/flsgp/flsgph02002.pdf.

Bergstrom, J.C. and L.O. Taylor. 2006. “Using Meta-Analysis for Benefits Transfer: Theory and 

Practice.” Ecological Economics 60(2):351-360.

Bottcher, D. Soil and Water Engineering Technology, Inc. 2010. Personal communication. July.

Boyle, K.J. and J.C. Bergstrom. 1992. “Benefit Transfer Studies: Myths, Pragmatism and Idealism.” 

Water Resources Research 28(3):657-663.

Bricker, S., B. Longstaff, W. Dennison, A. Jones, K. Boicourt, C. Wicks, and J. Woerner. 2007. Effects of 

Nutrient Enrichment in the Nation’s Estuaries: A Decade of Change. NOAA Coastal Ocean Program 

Decision Analysis Series No. 26. National Centers for Coastal Ocean Science, Silver Spring, MD. 

328 pp.

Brown, R.M., McClelland, N.I., Deininger, R.A., and Tozer, R.G. (1970). “A Water Quality Index- Do 

We Dare?” Presented at the National Symposium on Data and Instrumentation for Water Quality 

Management. Water & Sewage Works. Madison, Wisconsin.

Bureau of Labor Statistics (BLS). 2010. Employment Cost Index – March 2010. Table 11. Employment 

Cost Index for wages and salaries, for State and local government workers, by occupational group and 

industry, Professional and related.
January 2012 14. References

Draft for Internal Review Only-Do Not Quote or Cite

14-2

Busby, T. Wildwood Consulting. 2009. Personal communication. August.

Canadian Council of Ministers of the Environment (CCME). 2001. "CCME Water Quality Index 1.0 

Technical Report." Canadian Water Quality Guidelines for the Protection of Aquatic Life.

Carlson, P. and L. Yarbro. 2008. Seagrass Mapping and Monitoring: Big Bend and Beyond. Presented at 

Florida Water Resources Monitoring Council Meeting, St. Petersburg, FL, September 24-25, 2008. 

Carollo Engineers. 2009. “Technologies to Meet Numeric Nutrient Criteria at Florida’s Domestic Water 

Reclamation Facilities.” Letter to Governor Charlie Crist Re: Numeric Nutrient Criteria Cost 

Implications for Florida POTWs. Dated December 3, 2009. 

Chang, N., M. Wanielista, A. Daranpob, F. Hossain, Z. Xuan, J. Miao, S. Liu, Z. Marimon, and S. 

Debusk. 2010. Onsite Sewage Treatment and Disposal Systems Evaluation for Nutrient Removal. 

Stormwater Management Academy, University of Central Florida. January.

Chesapeake Bay Program (CBP). 2004. What’s the Status of Point Source Nitrogen Reduction in the 

Chesapeake Bay Watershed? http://archive.chesapeakebay.net/pubs/waterqualitycriteria/docpointsource_for_tribtools.pdf.

Chesapeake Bay Program (CBP). 2002. Nutrient Reduction Technology Cost Estimations for Point 

Sources in the Chesapeake Bay Watershed. November.

City of Jacksonville. 2003. River Accord: Phasing Out Septic Tanks in Failure Areas. 

http://www.coj.net/Mayor/River+Accord/Septic+Tanks.htm Accessed 8/24/2010.

Committee on Environment and Natural Resources (CENR). 2010. Scientific Assessment of Hypoxia in 

U.S. Coastal Waters. Interagency Working Group on Harmful Algal Blooms, Hypoxia, and Human 

Health of the Joint Subcommittee on Ocean Science and Technology. Washington, DC.

Conley, Daniel J. 2000. Biogeochemical Nutrient Cycles and Nutrient Management Strategies. 

Hydrobiologia. 410: 87–96

Crist, C. 2010. Seagrass Awareness Month. Statement by the Governor of the State of Florida. 

Electronically available at: http://www.dep.state.fl.us/secretary/news/2010/03/files/seagrass.pdf

Cude, C. G. 2001. Oregon Water Quality Index: “A Tool for Evaluating Water Quality Management 

Effectiveness.” Journal of the American Water Resources Association 37(1):125-137.

Czajkowski, J. and O. Bin. 2010. Do Homebuyers Differentiate between Technical and Non-Technical 

Measures of Water Quality? Evidence from a Hedonic Analysis in South Florida. Eastern Carolina 

Department of Economics Working Paper ECU1007. 

Desvousges, W.H., F.R. Johnson, and H.S. Banzhaf. 1998. Environmental Policy Analysis with Limited 

Information: Principles and Applications of the Transfer Method. Northampton, MA: Edward Elgar 

Publishers.

Everhart, Scott. 2009. SeptiTech Sales Representative. Personal communication. May.

Fleming, L. and W. Stephan. 2001. Frequently Asked Questions About Blue Green Algae 

(Cyanobacteria) and their Toxins. Report to the Florida Harmful Algae Bloom Taskforce.

Florida Department of Agricultural and Consumer Services (FDACS), Office of Agricultural Water 

Policy (OAWP)’s BMP program. March 2011. GIS Data by special request: 

OAWP_bmp_enrollment_03312011_distribution. http://www.floridaagwaterpolicy.com/
January 2012 14. References

Draft for Internal Review Only-Do Not Quote or Cite

14-3

Florida Department of Environmental Protection (FDEP). 2011. What’s New: Statewide Septic Tank 

Evaluation Program. Last updated February 2, 2011. Electronically available at: 

http://www.doh.state.fl.us/environment/ostds/New.htm.

Florida Department of Environmental Protection (FDEP). 2010a. Site-Specific Information in Support of 

Establishing Numeric Nutrient Criteria for Florida Bay. Electronically available at: 

http://publicfiles.dep.state.fl.us/dear/sas/nutrient/estuarine/wpb/florida_keys_081810.pdf.

Florida Department of Environmental Protection (FDEP). 2010b. TMDL Water Quality Restoration 

Grants. February. Online at http://www.dep.state.fl.us/water/watersheds/docs/tmdl-grant-nutrientcosts-0210.pdf.

Florida Department of Environmental Protection (FDEP). 2010c. NPDES Permitted Phase I and Phase II 

MS4s in Florida. Updated 11/01/2010. Accessed 12/21/2011.

Florida Department of Environmental Protection (FDEP). 2010d. FDEP Review of EPA’s “Preliminary 

Estimate of Potential Compliance Costs and Benefits Associated with EPA’s Proposed Numeric 

Nutrient Criteria for Florida.”

Florida Department of Environmental Protection (FDEP). 2009. Wastewater Facility Information: 

Wastewater Facility Regulation (WAFR) database. 

http://www.dep.state.fl.us/water/wastewater/facinfo.htm. Accessed June 2009.

Florida Department of Environmental Protection (FDEP). 2008a. Integrated Water Quality Assessment 

for Florida: 2008 305(b) and 303(d) List Update. Division of Environmental Assessment and 

Restoration. Bureau of Watershed Management. Available electronically at: 

http://www.dep.state.fl.us/water/docs/2008_Integrated_Report.pdf.

Florida Department of Environmental Protection (FDEP). 2008b. Letter to Ms. Holly Greening, Tampa 

Bay Estuary Program. May 28.

Florida Department of Environmental Protection (FDEP). 2006a. TMDL Protocol. Version 6.0. Task 

Assignment 003.03/05-003.

Florida Department of Environmental Protection (FDEP). 2006b. Guide to Permitting Wastewater 

Facilities or Activities under Chapter 62-620, F.A.C.

Florida Department of Environmental Protection (FDEP). 2005a. TMDL Report: Nutrient TMDL for 

Roberts Bay (WBID 1968D). Prepared for United States Environmental Protection Agency, Region 4. 

Florida Department of Environmental Protection (FDEP). 2005b. Florida’s Total Maximum Daily Load 

Program: the First 5 Years, A Report to the Legislature and Governor. Division of Water Resource 

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

05.pdf

Florida Department of Environmental Protection (FDEP). 2003. The Total Maximum Daily Load 

Program – Overview. http://www.dep.state.fl.us/water/tmdl/docs/TMDL_Program_Overview.pdf

Florida Department of Environmental Protection (FDEP). Undated. Seagrass and the Economy. 

Electronically available at: http://www.dep.state.fl.us/coastal/habitats/seagrass/economy.htm. 

Florida Department of Health (FDOH). 2011. Bureau of Onsite Sewage GIS Data Files. Online at 

http://www.doh.state.fl.us/Environment/programs/EhGis/EhGisDownload.htm.
January 2012 14. References

Draft for Internal Review Only-Do Not Quote or Cite

14-4

Florida Department of Health (FDOH). 2004. Wekiva Basin Onsite Sewage Treatment and Disposal 

System Study.

Florida Division of Forestry (FDOF), Department of Agriculture and Consumer Services. 2010. 

Silviculture Best Management Practices: 2009 Implementation Survey Report.

Florida Division of Forestry (FDOF), Department of Agriculture and Consumer Services. 2009. 

Silviculture Best Management Practices. 

Florida Environmental Quality Incentive Program (FL EQIP). 2009a. FY 2009 Statewide Payment 

Schedules. ftp://ftpfc.sc.egov.usda.gov/FL/eqip/EQIP_FY2009PaySched_STATEWIDE_FINAL.pdf.

Florida Environmental Quality Incentive Program (FL EQIP). 2009b. State of Florida Payment Schedule 

Cost Descriptions, FY 2009.

Florida Fish and Wildlife Commission (FWC). 2010. The Economic Impact of Saltwater Fishing in 

Florida. Electronically available at: http://myfwc.com/conservation/value/saltwater-fishing/.

Florida Geological Data Library (FGDL). 2009. GIS Data: WBIDs. 

http://www.fgdl.org/download/index.html

Florida Governmental Utility Authority (FGUA). 2009. Board Agenda Item: Thursday, February 19, 

2009: Status Update on the Lehigh Acres Utility Expansion Project – Mandatory Wastewater 

Connections. Available at: 

http://www.lehighacresweedandseedproject.info/FGUA/Lehigh%20Acres%20Mandatory%20Wastew

ater%20Connection.pdf

Freeman III, A.M. 2003. The Measurement of Environmental and Resource Values: Theory and Methods. 

Washington, DC: Resources for the Future.

Fristachi, A., J. Sinclair, S. Hall, J.H. Berkman, G. Boyer, J. Burkholder, J. Burns, W. Carmichael, A. 

DuFour, W. Frazier, S. Morton, E. O’Brien, and S. Walker. 2008. Cyanobacterial Harmful Algal 

Blooms: Chapter 3: Occurrence of Cyanobacterial Harmful Algal Blooms Workgroup Report. U.S. 

Environmental Protection Agency Papers, University of Nebraska-Lincoln. Electronically available 

at: http://digitalcommons.unl.edu/cgi/viewcontent.cgi?article=1035&context=usepapapers

Gao, X. 2009. TMDL Report: Nutrient and Dissolved Oxygen TMDLs for the Indian River Lagoon and 

Banana River Lagoon. Florida Department of Environmental Protection.

Glibert, P.M., D. Flemer, and H. Paerl. 2010. Impacts of Nutrients in Estuaries. In Glibert, P.M., C.J. 

Madden, W. Boynton, D. Flemer, C. Heil, and J. Sharp (eds.). 2010. Nutrients in Estuaries: A 

Summary Report of the National Estuarine Experts Workgroup 2005–2007. National Estuarine 

Experts Workgroup. Produced for United States Environmental Protection Agency under contracts 

68-C-02-091 and EP-C-07-025.

Glibert, P.M., C.A. Heil, D. Hollander, M. Revilla, A. Hoare, J. Alexander, and S. Murasko. 2004. 

Evidence for dissolved organic nitrogen and phosphorus uptake during a cyanobacterial bloom in 

Florida Bay. Mar. Ecol. Prog. Ser. 280: 73-83.

Greening, H. and A. Janicki. 2006. Toward Reversal of Eutrophic Conditions in a Subtropical Estuary: 

Water Quality and Seagrass: Response to Nitrogen Loading Reductions in Tampa Bay, Florida, USA. 

Environ. Mgmt. 38(2): 163-178.
January 2012 14. References

Draft for Internal Review Only-Do Not Quote or Cite

14-5

Hauxwell, J., C. Jacoby, T.K. Frazer, and J. Stevely. 2001. Nutrients and Florida's Coastal Waters: The 

Links between People, Increased Nutrients and Changes to Coastal Aquatic Systems. Florida Sea 

Grant. SGEB-55.

Hazen and Sawyer. 2008. Indian River Lagoon Economic Assessment and Analysis Update. Report to the 

Indian River Lagoon National Estuary Program, in cooperation with the St. Johns River Water 

Management District and the South Florida Water Management District. Contract No. 24706. 

Electronically available at: 

http://www.sjrwmd.com/itsyourlagoon/pdfs/IRL_Economic_Assessment_2007.pdf.

Howarth, R.W. and R. Marino. 2006. Nitrogen as the Limiting Nutrient for Eutrophication in Coastal 

Marine Ecosystems: Evolving Views over Three Decades. Limnol. Oceanogr. 51(1, pt. 2): 364-376.

Janicki, A., R. Pribble, and S. Janicki. 2001. Tampa Bay Estuary Program Model Evaluation and Update: 

Nitrogen Load - Chlorophyll-a Relationship. Prepared for the Tampa Bay Estuary Program by Janicki 

Environmental, Inc., St Petersburg, FL.

Jeyanayagam, Sam. 2005. True Confessions of the Biological Nutrient Removal Process. Florida Water 

Resources Journal: January 2005.

Johns, G.M., V.R. Leeworthy, F.W. Bell, and M.A. Bonn. 2001. Socioeconomic Study of Reefs in

Southeast Florida. Final Report by Hazen and Sawyer for Broward County, Palm Beach County, 

Miami-Dade County, Monroe County, Florida Fish and Wildlife Conservation Commission, and 

National Oceanic and Atmospheric Administration. 

Johnston, R.J., M.H. Ranson, E.Y. Besedin and E.C. Helm. 2006. “What Determines Willingness To Pay 

Per Fish? A Meta-Analysis of Recreational Fishing Values.” Marine Resource Economics 21: 1-32.

Johnston, R.J., E.Y. Besedin, R. Iovanna, C.J. Miller, R.F. Wardwell and M.H. Ranson. 2005. 

“Systematic Variation in Willingness to Pay for Aquatic Resource Improvements and Implications for 

Benefit Transfer: A Meta-Analysis.” Canadian Journal of Agricultural Economics 53(2-3): 221-248.

Kirkpatrick, B., L.E. Fleming, D. Squicciarini, L. Backer, R. Clark, W. Abraham, J. Benson, Y.S. Cheng, 

D. Johnson, R. Pierce, J. Zaias, G.D. Bossart, and D. Baden. 2002. Literature Review of Florida Red 

Tide: Implications for Human Health Effects. Florida Department of Health, Bureau of 

Environmental Public Health Medicine. Available electronically at: 

http://www.doh.state.fl.us/environment/medicine/aquatic/pdfs/RedTideLitReview_2002112502.pdf

Krause-Jensen, D., S. Sagert, H. Schubert, and C. Bostrom. 2008. Empirical relationships linking 

distribution and abundance of marine vegetation to eutrophication. Ecol. Indicators. 8: 515-529.

Krinsky, I. and A.L. Robb. 1986. “Approximating the statistical properties of elasticities.” Review of 

Economics and Statistics 68(4):715-719.

Landsberg, J.H. and S.S. Shumway. 1998. Harmful Algal Blooms and their Effects on Marine and 

Estuarine Animals. Summary of Presentation at the Third International Symposium on Aquatic 

Animal Health. Baltimore, MD, August 30-September 3, 1998. 

Lapointe, B.E., P.J. Barile, M.M. Littler, D.S. Littler, B.J. Bedford, and C. Gasque. 2005. Macroalgal 

Blooms on Southeast Florida Coral Reefs: I. Nutrient Stoichiometry of the Invasive Green Alga 

Codium isthmocladum in the Wider Caribbean Indicates Nutrient Enrichment. 
January 2012 14. References

Draft for Internal Review Only-Do Not Quote or Cite

14-6

Lapointe, B.E., P.J. Barile, and W.R. Matzie. 2004. Anthropogenic Nutrient Enrichment of Seagrass and 

Coral Reef Communities in the Lower Florida Keys: Discrimination of Local Versus Regional 

Nitrogen Sources. J. Exp. Mar. Biol. Ecol. 308: 23-58. 

Lapointe, B.E. 1997. Nutrient Thresholds for Bottom-up Control of Macroalgal Blooms on Coral Reefs in 

Jamaica and Southeast Florida. Limnol. Oceanogr. 5(part 2): 1119-1131.

Larkin, S.L. and C.M. Adams. 2006. Harmful Algal Blooms and Coastal Business: Economic 

Consequences in Florida. University of Florida. Available electronically at: 

http://crca.caloosahatchee.org/crca_docs/Larkin%20and%20Adams_SNR_1721.pdf.

Lewitus, A.J., E.T. Koepfler, and J.T. Morris. 1998. Seasonal Variation in the Regulation of 

Phytoplankton by Nitrogen and Grazing in a Salt-marsh Estuary. Limnol. Oceanogr. 43(4): 636-646.

Loomis, J., P. Kent, L. Strange, K. Fausch and A. Covich. 2000. “Measuring the total economic value of 

restoring ecosystem services in an impaired river basin: results from a contingent valuation survey.” 

Ecological Economics 33: 103-117.

Loomis, J.B. 1996. “How Large is the Extent of the Market for Public Goods: Evidence from a Nation 

Wide Contingent Valuation Survey.” Applied Economics 28(7): 779-782.

Lower St. Johns River (LSJR) TMDL Executive Committee. 2008. Exhibit 1 Basin Management Action 

Plan for the Implementation of Total Maximum Daily Loads for Nutrients Adopted by the Florida 

Department of Environmental Protection. 

http://www.dep.state.fl.us/water/watersheds/docs/bmap/adopted-lsjr-bmap.pdf

Magley, W. and D. Joyner. 2008. TMDL Report: Total Maximum Daily Load for Nutrients for the Lower 

St. Johns River. Watershed Assessment Section, Bureau of Watershed Management, Florida 

Department of Environmental Protection.

McNeer, Andy. 2009. Aquapoint Sales Representative. Personal communication. May.

Merlo, R., Wong, J., Occiano, V., Sandera, K., Pai, A., Sen, S., Jimenez, J. A., Parker, D. S., and 

Burcham, J. 2011. Analysis of Organic Nitrogen Removal in Municipal Wastewater by Reverse 

Osmosis. Preprint, Nutrient Recovery and Management 2011, January 9-12, 2011, Miami, FL.

Metcalf and Eddy. 2003. Wastewater Engineering: Treatment and Reuse. Fourth Edition. McGraw Hill: 

Boston.

Miller, M.A., R.M. Kudela, A. Mekebri, D. Crane, S.C. Oates, M.T. Tinker, M. Staedler, W.A. Miller, S. 

Toy-Choutka, C. Dominik, D. Hardin, G. Langlois, M. Murray, K. Ward, and D.A. Jessup. 2010. 

Evidence for a Novel Marine Harmful Algal Bloom: Cyanotoxin (Microcystin) Transfer from Land to 

Sea Otters. PLoS ONE 5(9): e12576.

Mitchell, R.C. and R.T. Carson. 1989. Using Surveys to Value Public Goods: The Contingent Valuation 

Method. Resources for the Future, Washington, DC.

Moeltner, K., K.J. Boyle, and R.W. Paterson. 2007. “Meta-Analysis and Benefit Transfer for Resource 

Valuation—Addressing Classical Challenges with Bayesian Modeling.” Journal of Environmental 

Economics and Management 53(2): 250-269. 

Morrison, G., A. Janicki, D. Wade, J. Martin, G. Vargo, and R. Johansson. 1996. Estimated Nitrogen 

Fluxes and Nitrogen-Chlorophyll Relationships in Tampa Bay, 1985-1994. In Treat, S.F. (ed.), 1996. 
January 2012 14. References

Draft for Internal Review Only-Do Not Quote or Cite

14-7

Proceedings of the Tampa Bay Area Scientific Information Symposium 3: Applying Our Knowledge. 

Clearwater, FL, October 21-23, 1996. 

National Ocean Economics Program (NOEP). 2006. Coastal Economy Data. Electronically available at: 

http://www.oceaneconomics.org/Market/coastal/coastalEcon.asp.

National Oceanic and Atmospheric Administration (NOAA). 2011. NOAA Fisheries: Recreational 

Fisheries Statistics Queries. Electronically available at: 

http://www.st.nmfs.noaa.gov/st1/recreational/queries/index.html

Nelson, W.G. 2009. The Interaction of Epiphytes with Seagrasses under Nutrient Enrichment. In Nelson, 

W.G. (ed.). 2009. Seagrasses and Protective Criteria: A Review and Assessment of Research Status. 

National Health and Environmental Effects Research Laboratory, United States Environmental 

Protection Agency. EPA/600/R-09/050. 

Nielsen, S.L., K. Sand-Jensen, J. Borum, and O. Geertz-Hansen. 2002. Phytoplankton, Nutrients, and 

Transparency in Danish Coastal Waters. Estuaries. 25(5): 930-937. 

Orth, R.J., T.J.B. Carruthers, W.C. Dennison, C.M. Duarte, J.W. Fourqurean, K.L. Heck, Jr., A.R. 

Hughes, G.A. Hendrick, W.J. Kenworthy, S. Olyarnik, F.T. Short, M. Waycott, and S.L. Williams. 

2006. A Global Crisis for Seagrass Ecosystems. Bioscience. 56(12): 987-996.

Paerl, H., V. Paul, J.M. O'Neil, J. Joyner, K. Arthur, A. Joyner, A. Capper, C. Ross, and C. Heil. 2009. 

Toxic Cyanobacteria Blooms Degrade Ecosystems in Coastal Florida. Based on NOAA ECOHAB 

Grant #NA05NOS4781194. University of Maryland Center for Environmental Science, Integration 

and Application Network. Newsletter, November 2009. 

Paerl, H.W., R.L. Dennis, and D.R. Whitall. 2002. Atmospheric Deposition of Nitrogen: Implications for 

Nutrient Over-enrichment of Coastal Waters. Estuaries 25(4): 677-693.

Petrus, K., and K. Laskis. 2009. TMDL Report Dissolved Oxygen and Nutrient TMDL for the Alafia 

River Above Hillsborough Bay- Tidal Segment (WBID 1621G). Division of Environmental 

Assessment and Restoration, Bureau of Watershed Management, Florida Department of 

Environmental Protection.

Petrus, K. 2003. Total Maximum Daily Load (TMDL) for the Palatlakaha River to Address Dissolved 

Oxygen Impairment, Lake County, Florida. Florida Department of Environmental Protection.

Phlips, E.J., E. Bledsoe, M. Cichra, S. Badylak, and J. Frost. 2002. The Distribution of Potentially Toxic 

Cyanobacteria in Florida. In Proceedings of Health Effects of Exposure to Cyanobacteria Toxins: 

State of the Science, Sarasota, FL, August 13-14, 2002. Electronically available at: 

http://www.doh.state.fl.us/environment/community/aquatic/pdfs/Cyanobacteria_200208.pdf

Pinckney, J.L., H.W. Paerl, P. Tester, and T.L. Richardson. 2001. The Role of Nutrient Loading and 

Eutrophication in Estuarine Ecology. Environ. Health Perspect. 109(supplement 5): 699-705.

Pollman, C.D., and S. Roy. 2003. Examination of atmospheric deposition chemistry and Its potential 

effects on the Lower St. Johns Estuary. Final Report Submitted to the St. Johns River Water 

Management District, Contract No. SE706AA. Gainesville, Florida: Tetra Tech, Inc. As cited in 

Magley, W. and D. Joyner. 2008. TMDL Report: Total Maximum Daily Load for Nutrients for the 

Lower St. Johns River. Watershed Assessment Section, Bureau of Watershed Management, Florida 

Department of Environmental Protection.
January 2012 14. References

Draft for Internal Review Only-Do Not Quote or Cite

14-8

Rosenberger, R.S. and R.J. Johnston. 2007. Selection Effects in Meta-Valuation Function Transfers. 

Meta-Analysis in Economics Conference, September 27-30, 2007, Sandbjerg Manor, Sønderborg, 

Denmark.

Rosenberger, R.S. and T.T. Phipps. 2007. “Correspondence and Convergence in Benefit Transfer 

Accuracy: Meta-Analytic Review of the Literature.” In: Navrud, S. and R. Ready (eds.), 

Environmental Value Transfer: Issues and Methods. Dordrecht, The Netherlands: Springer. pp.23-43.

Rosenberger, R.S. and T.D. Stanley. 2006. “Measurement, Generalization, and Publication: Sources of 

Error in Benefit Transfers and Their Management.” Ecological Economics 60(2): 372-378.

Schueler, T., D. Hirschman, M. Novotney, and J. Zielinski. 2007. Urban Subwatershed Restoration 

Manual No. 3: Urban Stormwater Retrofit Practices, Version 1.0. Center for Watershed Protection.

Shon, H.K., S. Vigneswaran and S.A. Snyder. 2006. Effluent organic matter (EfOM) in wastewater: 

constituents, effects, and treatment. Critical Reviews in Environmental Science and Technology, 36 

(4):327–374.

Shrestha, R., R. Rosenberger and J. Loomis. 2007. “Benefit Transfer Using Meta-Analysis in Recreation 

Economic Valuation, in Benefit Transfer Accuracy: Meta-Analytic Review of the Literature.” In: 

Navrud, S. and R. Ready (eds.). Environmental Value Transfer: Issues and Methods. Dordrecht, The 

Netherlands: Springer. pp.161-177.

Sierra Club Florida. 2011. Clean Water For Florida Nutrient Pollution Standards Campaign. 

Electronically available at: http://florida.sierraclub.org/water_quality.asp.

Smith, Stanley K and Mark House. 2006. “Snowbirds, Sunbirds, and Stayers: Seasonal Migration of 

Elderly Adults in Florida.” Journal of Gerontology 61(5) S232–S239

Smith, V.H. 2003. Eutrophication of freshwater and coastal marine ecosystem. A global problem. 

Environ. Sci. Poll. Res. 10: 1-10.

Smith, V.K., G. Van Houtven, and S.K. Pattanayak. 2002. “Benefit Transfer via Preference Calibration: 

‘Prudential Algebra’ for Policy.” Land Economics 78(1): 132-152.

Smith, V.H., Tilman, G.D. and J.C. Nekola. 1999. Eutrophication: impacts of excess nutrient inputs on 

freshwater, marine and terrestrial ecosystems. Environ. Poll. 100: 179-196.

Smith, K.N. 1993. Manatee habitat and human-related threats to seagrass in Florida: A review. 

Department of Environmental Protection, Division of Marine Resources; Tallahassee, Florida.

Electronically available at: http://myfwc.com/media/415241/Manatee_habitat_human.pdf

Soil and Water Engineering Technology (SWET). 2008. Nutrient Loading Rates, Reduction Factors and 

Implementation Costs Associated with BMPs and Technologies. Report prepared for South Florida 

Water Management District.

South Florida Water Management District (SFWMD). 2009a. Caloosahatchee River Watershed Protection 

Plan.

South Florida Water Management District (SFWMD). 2009b. St. Lucie River Watershed Protection Plan.

South Florida Water Management District (SFWMD). 2008. Lake Okeechobee Watershed Construction 

Project Phase II Technical Plan.
January 2012 14. References

Draft for Internal Review Only-Do Not Quote or Cite

14-9

South Florida Water Management District (SFWMD). 1989. Interim Lake Okeechobee Surface Water 

Improvement and Management Plan.

Spash, C.L. and A. Vatn. 2006. “Transferring Environmental Value Estimates: Issues and Alternatives.” 

Ecological Economics 60(2):379-388.

Tampa Bay Estuary Program (TBEP). 2011. Numeric Nutrient Criteria Recommendations for the Tampa 

Bay Estuary: Summary and Technical Support Documents. February.

Tampa Bay Estuary Program (TBEP). 2010. Final: 2009 Reasonable Assurance Addendum: Allocation 

and Assessment Report. January.

Tampa Bay National Estuary Program (TBNEP). 1996. Charting the Course. The Comprehensive 

Conservation and Management Plan for Tampa Bay. Electronically available at: 

http://www.tbep.org/tbep/download_charting_the_course.html

Tampa Bay Nitrogen Management Consortium (Tampa Bay NMC). 2010. Tampa Bay Nitrogen 

Management Consortium Comments and Request Regarding the Development of Protective Loads 

for the Tampa Bay Estuary as It Relates to Establishing Numeric Nutrient Criteria for Lakes, Flowing 

Waters and Estuaries in Florida. Comment on EPA Docket EPA-HQ-OW-2009-0596. March 4, 2010. 

Electronically available at: 

http://www.tbeptech.org/attachments/074_FINAL_NMC_Response_NNC_03082010.pdf

United States Census Bureau. 2010. The 2005-2009 American Community Survey 5 year estimates. 

Available at http://www.census.gov/acs/www/index.html. 

United States Department of Agriculture (USDA). 2011. Contracts and Dollars Obligated On Active 

Contracts - Contract Fiscal Year 2010. Conservation Stewardship Program, Natural Resources 

Conservation Service. Available electronically at: 

http://www.nrcs.usda.gov/wps/portal/nrcs/detailfull/national/programs/financial/csp/?&cid=stelprdb1

045143

United States Department of Agriculture (USDA). 2010. CTA Cumulative Technical Assistance Funds, 

FY 2010. Cumulative Technical Assistance Program, Natural Resources Conservation Service. 

Available electronically at: 

http://www.nrcs.usda.gov/wps/portal/nrcs/detail/national/programs/technical/cta/?&cid=stelprdb1044

456

United States Department of Agriculture (USDA). 2009. Environmental Quality Incentives Program 

Fiscal Year 2008 Payment Information. Environmental Quality Incentives Program, Natural 

Resources Conservation Service. Available electronically at: 

http://www.nrcs.usda.gov/wps/portal/nrcs/detailfull/national/programs/financial/eqip/?&cid=nrcs143

_008335

United States Department of Agriculture (USDA), National Agricultural Statistics Service (NASS). 2009. 

2007 Census of Agriculture, Florida, State and County Data. Volume 1, Geographic Area Series, Part 

9. 

http://www.agcensus.usda.gov/Publications/2007/Full_Report/Volume_1,_Chapter_2_County_Level/

Florida/flv1.pdf. 

United States Environmental Protection Agency (U.S. EPA). 2011. Permit Compliance System Database. 

http://www.epa.gov/enviro/facts/pcs/customized.html. Accessed June 2011.
January 2012 14. References

Draft for Internal Review Only-Do Not Quote or Cite

14-10

United States Environmental Protection Agency (U.S. EPA). 2010a. Guidelines for Preparing Economic 

Analyses. EPA 240-R-10-001.

United States Environmental Protection Agency (U.S. EPA). 2010b. 2008 Clean Watershed Needs 

Survey.

United States Environmental Protection Agency (U.S. EPA). 2010c. Economic Analysis of Final Water 

Quality Standards for Nutrients for Lakes and Flowing Waters in Florida November. Office of Water. 

http://water.epa.gov/lawsregs/rulesregs/upload/florida_econ.pdf.

United States Environmental Protection Agency (U.S. EPA). 2010d. 75 Federal Register 4173- 4226. 

2010. 40 CFR Part 131. Water Quality Standards for the State of Florida’s Lakes and Flowing 

Waters; Proposed Rule. Environmental Protection Agency; January 26, 2010.

United States Environmental Protection Agency (U.S. EPA). 2010e. Healthy Lakes and Higher Property 

Values. EPA-840-F-10-00. October, 2010. 

http://water.epa.gov/type/lakes/upload/healthy_lakes_and_higher_property_values.pdf 

United States Environmental Protection Agency (U.S. EPA). 2009a. Letter from Benjamin Grumbles, 

Assistant Administrator, Office of Water to Michael Sole, Secretary, Florida Department of 

Environmental Protection. January 14. http://www.epa.gov/waterscience/standards/rules/fldetermination20090114.pdf.

United States Environmental Protection Agency (U.S. EPA). 2009b. Environmental Impact and Benefits 

Assessment for Final Effluent Guidelines and Standards for the Construction and Development 

Category. November, 2009. http://www.epa.gov/guide/construction/files/environment.pdf

United States Environmental Protection Agency (U.S. EPA). 2008. Municipal Nutrient Removal 

Technologies Reference Document. Volume 1 – Technical Report. EPA 832-R-08-006.

United States Environmental Protection Agency (U.S. EPA). 2006. Voluntary Estuary Monitoring 

Manual Chapter 18: Submerged Aquatic Vegetation. EPA-842-B-06-003. Electronically available at: 

http://water.epa.gov/type/oceb/nep/monitor_index.cfm

United States Environmental Protection Agency (U.S. EPA). 2003a. ETV Joint Verification Statement: 

BioclereTM Model 16/12.

United States Environmental Protection Agency (U.S. EPA). 2003b. ETV Joint Verification Statement: 

SeptiTech® Model 400 System.

United States Environmental Protection Agency (U.S. EPA). 2002. Estimation of National Economic 

Benefits Using the National Water Pollution Control Assessment Model to Evaluate Regulatory 

Options for Concentrated Animal Feeding Operations. 

United States Environmental Protection Agency (U.S. EPA). 2001. The National Costs of the Total 

Maximum Daily Load Program (Draft Report). EPA 841-D-01-003.

United States Environmental Protection Agency (U.S. EPA). 1995. Interim Economic Guidance for Water 

Quality Standards. EPA-823-B-95-002. March.

United States Environmental Protection Agency (U.S. EPA). 1991. Technical Support Document for 

Water Quality-based Toxics Control. EPA/505/2-90-001.

United States Environmental Protection Agency (U.S. EPA) Region 4. 2007. Total Maximum Daily Load 

for Nutrients in Escambia Bay.
January 2012 14. References

Draft for Internal Review Only-Do Not Quote or Cite

14-11

United States Environmental Protection Agency (U.S. EPA) Region 4. 2005. TMDL Report: Nutrient 

TMDL for Roberts Bay (WBID 1968D). 

United States Fish and Wildlife Service (U.S. FWS). 2011. Listings and Occurrences for Florida. 

Available electronically at: 

http://ecos.fws.gov/tess_public/pub/stateListingAndOccurrenceIndividual.jsp?state=FL&s8fid=11276

1032792&s8fid=112762573902

United States Fish and Wildlife Service (U.S. FWS). 2001. Florida Manatee Recovery Plan, (Trichechus 

manatus latirostris). Third Revision. Southeast Region. Atlanta, Georgia.

United States Geological Survey (USGS). 2010. Nutrients in the Nation’s Streams and Groundwater, 

1992-2004. National Water-Quality Assessment Program, Circular 1350.

United States Government Accountability Office (U.S. GAO). 2005. Endangered Species: Fish and 

Wildlife Service Generally Focuses Recovery Funding on High-Priority Species, but Needs to 

Periodically Assess Its Funding Decisions. GAO-05-211.

Valiela, I., J. McClelland, J. Hauxwell, P.J. Behr, D. Hersh, and K. Foreman. 1997. Macroalgal Blooms in 

Shallow Estuaries: Controls and Ecophysiological and Ecosystem Consequences. 42(5): 1105-1118.

VandenBerg, T.P., G.L. Poe, and J.R. Powell. 2001. Assessing the accuracy of benefits transfers: 

Evidence from a multi-site contingent valuation study of ground water quality. In The Economic 

Value of Water Quality, J.C. Bergstrom, K.J. Boyle, and G.L. Poe (eds.). Edward Elgar Publishers, 

Northampton, MA.

van Voorthuizen, E.M., A. Zwijnenburg and M. Wessling. 2005. Nutrient removal by NF and RO 

membranes in decentralized sanitation system. Water Research, 39:3657–3667.

Vaughan, W.J. 1986. “The RFF Water Quality Ladder.” In: Mitchell, R.C. and R.T. Carson. The Use of 

Contingent Valuation Data for Benefit/Cost Analysis in Water Pollution Control, Final Report. 

Washington: Resources for the Future. Appendix B.

Viessman, W. and M. Hammer. 1998. Water Supply and Pollution Control. Sixth Edition. AddisonWesley: Menlo Park, California.

Wastewater Technologies. 2010. Personal communication. November.

Water Environment Federation (WEF) and American Society of Civil Engineers (ASCE)/Environmental 

and Water Resources Institute (EWRI). 2006. Biological Nutrient Removal (BNR) Operation in 

Wastewater Treatment Plants. McGraw Hill: New York.

Wazniak, C.E., Hall, M.R., Carruthers, T.J., Sturgis,B., Dennison, W.C. and R.J. Orth. 2007. Linking 

water quality to living resources in a mid-Atlantic lagoon system, USA. Ecological Applications 

17:S64-76.

Weaver, K. 2010. Estuary and Coastal Waters Numeric Nutrient Criteria: Workshop Introduction. Estuary 

Numeric Nutrient Criteria Public Meeting for Portions of the Florida Coast from Dixie County to 

Pasco County. Crystal River, FL, February 23, 2010. Electronically available at: 

http://publicfiles.dep.state.fl.us/dear/sas/nutrient/estuarine/crystalriver/estuary_coastal_overview.pdf

World Health Organization (WHO). 2003a. Cyanobacterial toxins: microcystin-LR in drinking-water. 

Background document for development of WHO Guidelines for Drinking-water Quality. Geneva, 

Switzerland. (WHO/SDE/WSH/03.04/57).
January 2012 14. References

Draft for Internal Review Only-Do Not Quote or Cite

14-12

World Health Organization (WHO). 2003b. Guidelines for Safe Recreational Water Environments, 

Volume 1: Coastal and Fresh Waters. Electronically available at: 

http://www.who.int/water_sanitation_health/bathing/srwe1/en/index.html

Zieman, J.C. 1982. The Ecology of the Seagrasses of South Florida: A Community Profile. Prepared for 

National Coastal Ecosystems Team, Office of Biological Services, U.S. Department of the Interior. 

FWS/OBS-82/25.
January 2012 Appendix A. Proposed Numeric Nutrient Criteria

Draft for Internal Review Only-Do Not Quote or Cite

A-1

Appendix A. Proposed Numeric Nutrient Criteria

Error! Reference source not found., Error! Reference source not found., and Exhibit A-3 show the 

applicable numeric nutrient criteria for each segment or WBID.

Exhibit A-1: Proposed Chlorophyll-a Criteria for Coastal 

Waters

WBID CHLA_Criteria WBID CHLA_Criteria

8001 2.54 8092 0.27

8002 2.24 8093 0.26

8003 1.32 8094 0.23

8004 1.11 8095 0.21

8005 1.03 8096 0.20

8006 0.87 8097 0.19

8007 0.96 8098 0.18

8008 1.09 8099 0.19

8009 0.89 8100 0.24

8010 0.88 8101 0.51

8011 0.89 8102 0.89

8012 0.94 8103 1.11

8013 1.25 8104 1.51

8014 1.45 8105 1.41

8015 2.38 8106 1.38

8016 2.22 8107 1.39

8017 3.16 8108 1.30

8045C 4.87 8109 1.33

8046 4.34 8110 1.78

8047 4.15 8111 2.62

8048 4.12 8112 2.29

8049 4.48 8113 2.07

8050 3.44 8114 1.94

8051 3.12 8115 1.82

8052 2.87 8116 2.06

8053 2.81 8117 2.02

8054 2.77 8118 2.04

8055 3.09 8119 1.78

8056 4.39 8120 1.88

8057 3.96 8121 2.03

8058 3.77 8122 2.43

8059 4.19 8123 2.80

8060 5.03 8124 2.90

8061 3.97 8125 2.90

8062 3.97 8126 3.70

8063 3.88 8127 3.76

8064 4.41 8128 3.92

8091 0.64 8129 4.24
January 2012 Appendix A. Proposed Numeric Nutrient Criteria

Draft for Internal Review Only-Do Not Quote or Cite

A-2

Exhibit A-2: Proposed Nutrient Criteria for Estuaries

Estuarine Systems Segment Names Segment 

ID

TN 

(mg/L)

TP 

(mg/L)

chl_a 

(ug/L)

Perdido Bay (Includes Big 

Lagoon)

Upper Perdido Bay 0101 0.59 0.042 5.23

Big Lagoon 0102 0.26 0.019 4.85

Central Perdido Bay 0103 0.47 0.031 5.81

Lower Perdido Bay 0104 0.34 0.023 5.76

Pensacola Bay (Includes 

Escambia, Blackwater, 

East Bay and Santa Rosa 

Sound)

Blackwater Bay 0201 0.55 0.022 3.89

Upper Escambia Bay 0202 0.43 0.025 3.70

East Bay 0203 0.50 0.021 4.24

Santa Rosa Sound 0204 0.31 0.018 4.09

Lower Escambaa Bay 0205 0.42 0.024 3.93

Upper Pensacola Bay 0206 0.40 0.021 3.92

Lower Pensacola Bay 0207 0.34 0.020 3.62

Santa Rosa Sound 0208 0.33 0.020 4.08

Santa Rosa Sound 0209 0.36 0.020 5.17

Choctawhatchee Bay Eastern Choctawhatchee 

Bay 0301 0.61 0.035 4.14

Central Choctawhatchee 

Bay 0302 0.48 0.017 3.86

Western Choctawhatchee 

Bay 0303 0.41 0.015 3.49

St. Andrews Bay (includes 

West, East, and North Bay, 

and St. Andrews Sound)

East Bay 0401 0.31 0.014 4.65

St. Andrew Sound 0402 0.14 0.009 2.28

Eastern St. Andrews Bay 0403 0.24 0.021 3.93

Western St. Andrews Bay 0404 0.19 0.016 3.12

Southern St. Andrews 

Bay

0405 0.15 0.013 2.58

North Bay 1 0406 0.22 0.012 3.67

North Bay 2 0407 0.22 0.014 3.65

North Bay 3 0408 0.21 0.016 3.42

West Bay 0409 0.23 0.022 3.83

St. Joe Bay St. Josephs Bay 0501 0.43 0.020 3.00

Apalachicola Bay (includes 

St. Vincent, East Bay, St. 

George Sound)

St. George's Sound 0601 0.53 0.019 3.62

Apalachicola Bay 0602 0.51 0.019 2.66

East Bay 0603 0.76 0.034 1.65

St. Vincent Sound 0605 0.52 0.016 11.91

Apalachicola / Offshore 0606 0.30 0.008 2.32

Alligator Harbor Aligator Harbor 0701 0.36 0.011 2.79

Aligator / Offshore (WBID 

8024) 0702 0.33 0.009 3.07

Aligator / Offshore (WBID 

8023) 0703 0.33 0.009 2.86

Ochlockonee Bay St. Marks River (793A) 0828 0.55 0.030 1.19

Ochlocknee Offshore 

(8025 & 8026) 0829 0.47 0.019 1.87

Ochlocknee Bay (1248*) 0830 0.66 0.037 1.84

Econfina (3402A) 0824 0.59 0.028 4.57

Big Bend/Apalachee Bay 

(Panacea to Shired Island)

Steinhatchee Offshore 

(8035) 0818 0.39 0.032 4.78
January 2012 Appendix A. Proposed Numeric Nutrient Criteria

Draft for Internal Review Only-Do Not Quote or Cite

A-3

Exhibit A-2: Proposed Nutrient Criteria for Estuaries

Estuarine Systems Segment Names Segment 

ID

TN 

(mg/L)

TP 

(mg/L)

chl_a 

(ug/L)

Steinhatchee River 

(3573C 0819 0.67 0.077 0.97

Steinhatchee Offshore 

(8033 & 8034) 0820 0.34 0.018 3.46

SteinhatcheeFenholloway Offshore 

(8031 & 8032)

0821

0.40 0.023 4.07

Fenholloway (3473A) 0822 1.15 0.444 1.93

Fenholloway Offshore 

(8030) 0823 0.48 0.034 10.27

Econfina Offshore (8029) 0824 0.59 0.028 4.57

Ochlocknee-St. Marks 

Offshore (8028) 0825 0.79 0.033 2.72

St. Marks River Offshore 

(8027) 0827 0.51 0.022 1.66

Suwannee Sound/Cedar 

Keys

Suwannee Offshore 

(3422D) 0817 1.10 0.090 3.70

Spring Coast (Waccasassa 

to Anclote)

Anclote River (1440) 0804 0.48 0.037 4.74

Anclote Offshore (8045C) 0805 0.31 0.011 3.15

Pithlachascotee River 

(1409C) 0806 0.50 0.022 2.40

Pithlachascotee Offshore 

(8044) 0807 0.32 0.011 2.50

Weeki Wachee River 

(1382*) 0808 0.32 0.010 1.64

Weeki Wachee Offshore 

(8042 & 8043) 0809 0.30 0.010 2.06

Chassahowitzka River 

(1361) 0810 0.32 0.010 0.70

Chassahowitzka River 

Offshore (8041) 0811 0.29 0.010 1.73

Crystal River (1341) 0812 0.35 0.013 1.35

Crystal-Homosassa 

Offshore (8039 & 8040) 0813 0.36 0.013 2.10

Waccasassa River 

Offshore (8038) 0814 0.38 0.019 3.92

Waccasassa River 

Offshore (8037) 0815 0.32 0.019 4.12

Homosassa River (1345) 0833 0.47 0.032 1.89

Clearwater Harbor/St. 

Joseph Sound

Clearwater Harbor (1528 

& 1528C) 0801 0.47 0.029 5.67

St. Joseph Sound 

(8045D) 0802 0.46 0.029 5.51

Clearwater-St. Joseph 

Offshore (8046 & 8047) 0803 0.29 0.008 2.60

Tampa Bay Estuary 

Program (Boca Ciega, 

Hillsborough, Upper, Mid, 

Lower, Old, Terra Ceia, 

Manatee River)

Hillsborough Bay 0901 0.49 0.175 7.74

Old Tampa Bay 0902 0.44 0.172 12.90

Upper Tampa Bay 0903 0.44 0.152 7.85

Middle Tampa Bay 0904 0.37 0.116 6.27

Lower Tampa Bay 0905 0.31 0.074 4.91
January 2012 Appendix A. Proposed Numeric Nutrient Criteria

Draft for Internal Review Only-Do Not Quote or Cite

A-4

Exhibit A-2: Proposed Nutrient Criteria for Estuaries

Estuarine Systems Segment Names Segment 

ID

TN 

(mg/L)

TP 

(mg/L)

chl_a 

(ug/L)

Manatee River 0906 0.62 0.115 7.41

Boga Ceia 0907 0.30 0.086 5.30

Sarasota NEP (Sarasota, 

Palma Sola, Roberts, Little 

Sarasota Bay)

Sarasota Bay 1001 0.28 0.119 7.72

Palm Sola Bay 1002 0.34 0.141 7.18

Roberts Bay 1003 0.34 0.131 8.61

Little Sarasota Bay 1004 0.30 0.123 8.31

BlackBurn bay 1005 0.28 0.118 7.03

Dona Bay 1006 0.24 0.115 4.16

Charlotte Harbor NEP 

(Lemon Bay, 

Caloosahatchee, Pine 

Island Sound, San Carlos 

Bay, Estero Bay)

Upper Caloosahatchee 1101 1.11 0.110 9.88

Lower Caloosahatchee 1102 0.61 0.083 3.48

Estero Bay 1103 0.65 0.072 2.34

Matiacha Pass 1104 0.57 0.076 1.63

San Carlos Bay 1105 0.57 0.060 2.39

Peace Estuary 1106 0.79 0.303 3.52

Myakka Estuary 1107 0.71 0.176 3.79

Upper Charlotte Harbor 1108 0.71 0.177 2.88

Lower Charlotte Harbor 1109 0.61 0.105 2.11

Pine Island Sound 1110 0.56 0.062 2.05

Lake Worth 

Lagoon/Loxahatchee

North Lakeworth Lagoon 1201 0.55 0.067 4.67

Central Lakeworth 

Lagoon 1202 0.57 0.089 5.30

South Lakeworth Lagoon 1203 0.48 0.034 3.55

Lower Loxahatchee 1301 0.64 0.027 2.88

Middle Loxahatchee 1302 0.90 0.041 3.83

Upper Loxahatchee 1303 1.15 0.068 2.75

St. Lucie Lower St.Lucie 1401 0.58 0.045 5.27

Middle St.Lucie 1402 0.90 0.120 8.43

Upper St.Lucie 1403 1.22 0.197 8.94

Indian River Lagoon 

(Banana River, Mosquito 

Lagoon)

Upper Mosquito Lagoon 1501 1.10 0.050 3.60

Lower Mosquito Lagoon 1502 1.30 0.060 7.00

Banana River 1503 1.60 0.060 9.90

Upper Indian River 

Lagoon 1504 1.40 0.060 10.00

Upper Central Indian 

River Lagoon 1505 1.30 0.060 11.00

Lower Central Indian 

River Lagoon 1506 0.80 0.080 8.00

Lower Indian River 

Lagoon 1507 0.80 0.070 5.60

Halifax River (includes 

Smith Creek)

Upper Halifax River 1601 1.10 0.180 8.80

Lower Halifax River 1602 0.85 0.200 9.70

Guano, Tolomato, 

Matanzas, Pellicer

Pablo Creek 1701 0.60 0.090 6.60

Cabbage Creek 1702 0.60 0.090 6.60

Guana River 1703 0.60 0.090 6.60

Upper Tolomato River 1704 0.60 0.090 6.60

Lower Tolomato River 1705 0.60 0.090 6.60
January 2012 Appendix A. Proposed Numeric Nutrient Criteria

Draft for Internal Review Only-Do Not Quote or Cite

A-5

Exhibit A-2: Proposed Nutrient Criteria for Estuaries

Estuarine Systems Segment Names Segment 

ID

TN 

(mg/L)

TP 

(mg/L)

chl_a 

(ug/L)

Upper Matanzas River 1706 0.60 0.090 6.60

Central Matanzas River 1707 0.60 0.090 6.60

Lower Matanzas River 1708 0.60 0.090 6.60

St. Johns River Estuary Lower St. John River 1801 0.75 0.095 2.50

Trout River 1802 1.09 0.108 3.60

Trout River 1803 1.15 0.074 7.70

Nassau River/Big 

Talbot/St. Marys 

River/Amelia River

Lower Nassau 1901 0.33 0.113 3.17

Middle Nassau 1902 0.40 0.120 2.41

Upper Nassau 1903 0.75 0.125 3.45

Lower St.Mary's 2002 0.27 0.045 3.01

Middle St.Mary's 2003 0.44 0.036 2.65
January 2012 Appendix A. Proposed Numeric Nutrient Criteria

Draft for Internal Review Only-Do Not Quote or Cite

A-6

Exhibit A-3: Proposed Nutrient Criteria for South Florida Marine Waters

Waterbody Segment TN, mg/L TP, mg/L Chl-a, μg/L

Biscayne Bay CS 0.37 0.007 0.38

Biscayne Bay NCI 0.33 0.008 0.46

Biscayne Bay NNB 0.33 0.012 1.79

Biscayne Bay SCI 0.52 0.008 0.4

Biscayne Bay SCM 0.39 0.008 0.36

Biscayne Bay SCO 0.26 0.007 0.27

Biscayne Bay SNB 0.32 0.01 1.01

Florida Bay CFB 1.45 0.025 3.11

Florida Bay CL 1.59 0.049 10.06

Florida Bay ECFB 0.88 0.009 0.68

Florida Bay MBS 0.73 0.01 0.76

Florida Bay NFB 0.85 0.015 1.04

Florida Bay SFB 0.88 0.011 1.32

Florida Bay WFBC 0.63 0.02 2.01

Florida Bay WFBN 0.45 0.024 2.95

Florida Bay WFBS 0.34 0.012 1.02

Florida Keys BKB 0.28 0.009 0.38

Florida Keys BKS 0.26 0.011 0.73

Florida Keys DT 0.21 0.008 0.42

Florida Keys FKN 0.2 0.007 0.27

Florida Keys FKS 0.22 0.008 0.36

Florida Keys FKT 0.21 0.008 0.33

Florida Keys KWOS 0.21 0.008 0.38

Florida Keys MAR 0.23 0.009 0.63

Rookery Bay CI 0.3 0.033 3.56

Rookery Bay COCO 0.54 0.059 6.25

Rookery Bay EB 0.33 0.055 5.48

Rookery Bay MARC 0.36 0.048 5.86

Rookery Bay NPL 0.32 0.05 4.91

Rookery Bay PINE 0.33 0.049 4.87

Rookery Bay SCB 0.48 0.073 4.48

Gulf Shelf GS 0.39 0.021 2.84

Whitewater Bay BLK 0.46 0.056 4.24

Whitewater Bay CTHB 0.84 0.041 5.37

Whitewater Bay GI 0.54 0.041 3.69

Whitewater Bay IWW 0.76 0.037 4.98

Whitewater Bay LMB 0.89 0.027 3.98

Whitewater Bay PD 0.66 0.025 3.03

Whitewater Bay SRM 1.13 0.026 2.47

Whitewater Bay WWB 1.04 0.028 4.51
January 2012 Appendix B. Municipal WWTP Cost Estimates

Draft for Internal Review Only-Do Not Quote or Cite

B-1

Appendix B. Municipal WWTP Cost Estimates

Exhibit B-1 shows the cost estimates for municipal WWTPs discharging to affected waters in Florida.

Exhibit B-1: Potential Costs to Municipal WWTPs for Compliance with Numeric 

Nutrient Criteria

NPDES 

No. Discharger Name Flow (mgd)

Reductions 

Needed

Total 

Capital 

Costs 

(millions 

2010$)

Annual 

O&M 

Costs 

(millions 

2010$) TN TP

Majors

FL0000922 USN MAYPORT NAVAL 

STATION WWTF 2 No Yes $1.4 $0.2

FL0000957 USN NAS JACKSONVILLE 

STP 3 No Yes $2.2 $0.3

FL0002631 BAY COUNTY WASTE 

TRTMNT-PANAMA 37 Yes Yes $50.6 $5.5

FL0020206 PORT ST. JOE 3.1 No Yes $2.2 $0.3

FL0020231 JAX BEACH STP 4.5 No Yes $3.2 $0.4

FL0020401 PALMETTO STP 2.4 No No $0.0 $0.0

FL0020427 NEPTUNE BEACH WWTP 1.5 No Yes $1.1 $0.1

FL0020451 ST ANDREWS WWTF 5 No Yes $3.6 $0.5

FL0020532 ORMOND BEACH STP 6 No No $0.0 $0.0

FL0020541 CAPE CANAVERAL 1.8 No No $0.0 $0.0

FL0020940 HOWARD F CURREN AWTP 96 No No $0.0 $0.0

FL0021105 COCOA BEACH WRF 6 No No $0.0 $0.0

FL0021261 FT MYERS-CENTRAL STP 11 No Yes $7.9 $1.0

FL0021270 FT MYERS-SOUTH STP 12 No Yes $8.6 $1.1

FL0021326 DUNEDIN-MAINLAND STP 6 No Yes $4.3 $0.6

FL0021440 MAIN STREET WWTP 20 No No $0.0 $0.0

FL0021512 PANAMA CITY BEACH STP 7 Yes Yes $9.6 $1.0

FL0021661 VERO BEACH WWTPINDIAN RIVER 4.5 No No $0.0 $0.0

FL0021857 CLEARWATER-MARSHALL 

ST STP 10 Yes Yes $13.7 $1.5

FL0021865 CLEARWATER-EAST WWTF 4.3 No Yes $3.1 $0.4

FL0021938 ST AUGUSTINE STP NO 1 4.5 Yes Yes $6.2 $0.7

FL0023248 ATLANTIC BEACH -

BUCCANEER STP 1.3 No Yes $0.9 $0.1

FL0023604 JEA - MONTEREY WWTF 3.6 No Yes $2.6 $0.3

FL0023663 SAN JOSE WWTF 2.25 No Yes $1.6 $0.2

FL0023671 JEA - JACKSONVILLE 

HEIGHTS WWT 2.5 No Yes $1.8 $0.2

FL0024007 SANTA ROSA ISL-PENSCLA 

BCH STP 2.4 No No $0.0 $0.0

FL0024805 MIAMI-VIRGINIA KEY WTP 121 No No $0.0 $0.0
January 2012 Appendix B. Municipal WWTP Cost Estimates

Draft for Internal Review Only-Do Not Quote or Cite

B-2

Exhibit B-1: Potential Costs to Municipal WWTPs for Compliance with Numeric 

Nutrient Criteria

NPDES 

No. Discharger Name Flow (mgd)

Reductions 

Needed

Total 

Capital 

Costs 

(millions 

2010$)

Annual 

O&M 

Costs 

(millions 

2010$) TN TP

FL0025755 SIESTA KEY UTILITIES 

AUTHORITY 2.7 No Yes $1.9 $0.3

FL0025984 DAYTONA BCH/BETHUNE 

PT WWTF 10 No No $0.0 $0.0

FL0026000 JEA - BUCKMAN WWTF 52.5 No Yes $37.8 $4.9

FL0026255 HOLLYWOOD WTP 42 No No $0.0 $0.0

FL0026271 NAPLES-MUNICIPAL PLANT 10 No Yes $7.2 $0.9

FL0026344 BOCA RATON WPC FAC 20 No No $0.0 $0.0

FL0026441 JEA - ARLINGTON WWTF 15 No Yes $10.8 $1.4

FL0026450 JEA - NORTHEAST WWTF 

(FKA DIST 10 No Yes $7.2 $0.9

FL0026468 JEA - SOUTHWEST WWTF 10 No Yes $7.2 $0.9

FL0026603 LARGO CITY OF 15 No Yes $10.8 $1.4

FL0026611 FLAGLER BEACH WTP 1 Yes Yes $1.4 $0.1

FL0026751 JEA - ROYAL LAKES WWTF 3.25 No Yes $2.3 $0.3

FL0026778 BEACON HILLS 

SUBDIVISION WWTF 1.3 No Yes $0.9 $0.1

FL0027260 FERNANDINA BEACHMUNICIPAL STP 3.5 Yes Yes $4.8 $0.5

FL0027278 FT PIERCE UTIL 

AUTHORITY-WTP 9 No No $0.0 $0.0

FL0027651 CITY OF OLDSMAR 2.25 No Yes $1.6 $0.2

FL0027677 HOLLY HILL ADVANCED 

WWTF 2.4 No No $0.0 $0.0

FL0030007 CITY OF CAPE CORAL 15.1 No No $0.0 $0.0

FL0030325 FL CITIES WATERWATERWAY EST 1.25 No Yes $0.9 $0.1

FL0030406 TARPON SPRINGS STP 4 No No $0.0 $0.0

FL0031771 BROWARD CO NORTH 

REGIONAL WWTP 80 No No $0.0 $0.0

FL0031801 ESCAMBIA CTY - BAYOU 

MARCUS 8.2 No Yes $5.9 $0.8

FL0032182 MIAMI-DADE NO DIST WTF 112.5 No No $0.0 $0.0

FL0034649 LOXAHATCHEE RV REG 

WWTP&RECL 11 No No $0.0 $0.0

FL0035980 SO. CENTRAL -WW DISP. 

BD. 24 No No $0.0 $0.0

FL0038776 ATLANTIC BEACH WWTP 3 No Yes $2.2 $0.3

FL0038831 ANASTASIA ISLAND WWTP 4 Yes Yes $5.5 $0.6

FL0039829 LEE COUNTY UTIL-FIESTA 

VILLAGE 5 No No $0.0 $0.0

FL0040398 COOPER CITY UTILITY 2.5 No No $0.0 $0.0
January 2012 Appendix B. Municipal WWTP Cost Estimates

Draft for Internal Review Only-Do Not Quote or Cite

B-3

Exhibit B-1: Potential Costs to Municipal WWTPs for Compliance with Numeric 

Nutrient Criteria

NPDES 

No. Discharger Name Flow (mgd)

Reductions 

Needed

Total 

Capital 

Costs 

(millions 

2010$)

Annual 

O&M 

Costs 

(millions 

2010$) TN TP

DEPT

FL0040541 DAVIE STP 3 No No $0.0 $0.0

FL0040614 HILLSBORO CO -

FALKENBURG RD A 6 No Yes $4.3 $0.6

FL0040665 CLEWISTON CITY OF 

WWTP 1.5 No No $0.0 $0.0

FL0040771 SARASOTA CITY OF WWTP 10 No No $0.0 $0.0

FL0041122 MELBOURNE CTY OF 

GRANT ST WWTP 5.5 No No $0.0 $0.0

FL0041360 EAST CENTRAL REGIONAL 

WWTP 64 Yes Yes $87.6 $9.5

FL0041637 INDIAN RIV CTY-WEST 

REGIONAL 4 No No $0.0 $0.0

FL0041670 NORTHWEST REGIONAL 

WRF 5 No Yes $3.6 $0.5

FL0139475 SLCU SOUTH HUTCHINSON 

ISLAND 1.6 No No $0.0 $0.0

FL0167959 MILITARY PT REGIONAL 

WWTF 7 No No $0.0 $0.0

FL0169978 CITY OF LYNN HAVEN 2.5 No Yes $1.8 $0.2

FL0170909 MILLVILLE WWT FACILITY 5 Yes Yes $6.8 $0.7

FL0173371 SPENCER WWTF 0.499 No Yes $0.4 $0.0

Minors

FL0003174 HURLBURT FIELD AIR 

FORCE BASE 1 No No $0.0 $0.0

FL0020559 PORT ORANGE WWTP 12 No No $0.0 $0.0

FL0021431 EDGEWATER CITY OF 0.83 No No $0.0 $0.0

FL0021521 COCOA WATER 

RECLAMATION FACILI 4.5 No No $0.0 $0.0

FL0021571 ROCKLEDGE WWTP 0 No No $0.0 $0.0

FL0023396 WELLINGTON ARMS 

CONDO WWTP 0.015 Yes Yes $0.0 $0.0

FL0023981 SANTA ROSA ISL-NAVARRE 

BCH STP 0.9 No No $0.0 $0.0

FL0027618 EVERGLADES CITY STP 0.115 Yes Yes $0.2 $0.0

FL0028380 OCEAN MAISONETTES 0.01 Yes Yes $0.0 $0.0

FL0031216 CEDAR KEY SEWER & 

WATER DIST 0.166 Yes Yes $0.2 $0.0

FL0032468 CENTURY TOWN OF 0.45 No No $0.0 $0.0

FL0032654 MARSH COVE WWTF 0.05 Yes Yes $0.1 $0.0

FL0036862 POINCIANA UTILKISSIMMEE 0.35 Yes Yes $0.5 $0.1
January 2012 Appendix B. Municipal WWTP Cost Estimates

Draft for Internal Review Only-Do Not Quote or Cite

B-4

Exhibit B-1: Potential Costs to Municipal WWTPs for Compliance with Numeric 

Nutrient Criteria

NPDES 

No. Discharger Name Flow (mgd)

Reductions 

Needed

Total 

Capital 

Costs 

(millions 

2010$)

Annual 

O&M 

Costs 

(millions 

2010$) TN TP

FL0038768 SEACOAST UTIL-PGA 

WWTP 12 Yes Yes $16.4 $1.8

FL0039756 BEVERLY BEACH 

SURFSIDE UTILITY 0.099 Yes Yes $0.1 $0.0

FL0040592 ATLANTIC DRY DOCK CORP 

STP 0.06 Yes Yes $0.1 $0.0

FL0040622 BREVARD COUNTY - S. 

BEACHES 0.017 No No $0.0 $0.0

FL0041424 PALM BCH CTY - REGIONAL 

PLANT 30 Yes Yes $41.0 $4.4

FL0042242 WALDO WWTP CITY OF 0.085 Yes Yes $0.1 $0.0

FL0042293 BAREFOOT BAY 0.9 No No $0.0 $0.0

FL0044237 INNLET BEACH WWTF 0.5 Yes Yes $0.7 $0.1

FL0044245 PLAYERS CLUB SOUTH 

WWTF 0.5 Yes Yes $0.7 $0.1

FL0044253 MARSH LANDING WWTF 0.6 Yes Yes $0.8 $0.1

FL0102482 SOUTH WALTON UTILITY 

COMPANY 2.5 No Yes $1.8 $0.2

FL0102920 CCAFS/REGIONAL (DW) 0.8 Yes Yes $1.1 $0.1

FL0103268 TITUSVILLE NORTH -

OSPREY 0.54 No No $0.0 $0.0

FL0116009 PALM COAST UTILITY 

CORPORATION 3.35 Yes Yes $4.6 $0.5

FL0116793 NASSAU REGIONAL WWTF 2 Yes Yes $2.7 $0.3

FL0116921 NASSAU HOST INC. 0.03 Yes Yes $0.0 $0.0

FL0117897 SAWGRASS STP 0.8 Yes Yes $1.1 $0.1

FL0128775 WILLIAM E DUNN WRF 9 No No $0.0 $0.0

FL0141356 COLLIER CO S REGIONAL 8 Yes Yes $10.9 $1.2

FL0141399 COLLIER COUNTY NORTH 

REGIONAL 13.5 Yes Yes $18.5 $2.0

FL0141704 PORT OF THE ISLANDS 

SOUTH WWTP 0.2 Yes No $0.1 $0.0

FL0147141 FLAMINGO SEWAGE 

TREATMENT PLAN 0.09 Yes No $0.1 $0.0

FL0170224 SEMINOLE IMPROVEMENT 

DISTRICT 0.06 Yes Yes $0.1 $0.0

FL0174441 BLACKS FORD WRF 0.49 Yes Yes $0.7 $0.1

FL0177008 SARASOTA COUNTY 

UTILITIES - NO 5.937 Yes Yes $8.1 $0.9
January 2012 Appendix C. Sample Industrial Discharger Analyses

Draft for Internal Review Only-Do Not Quote or Cite

C-1

Appendix C. Sample Industrial Discharger Analyses

Kinder Morgan Tampaplex Bulk Terminal

NPDES permit number: FL0321486

Major/minor: Minor

SIC code: 5169 (Chemicals and Allied Products, Not Elsewhere Classified)

Industrial Category: Chemicals and Allied Products

Design Flow: Not reported

Average Flow: Intermittent (range: 0.23 mgd to 2.88 mgd from 2006 through 2010).

Receiving Water: Port Sutton Channel (WBID 1637)

Description

The facility consists of bulk material handling, warehousing, and a shipping terminal. The company 

transports aggregates, fertilizer products, and other dry bulk materials to and from the facility via ship, 

truck, or rail. These materials are temporarily stored at the facility in enclosed structures and outdoors. 

The facility collects contact storm water runoff from the product unloading, storage, and loading areas in 

the Western and Central detention ponds where it is pumped through a series of treatment ponds prior to 

overflowing into the Eastern detention pond. The facility routes contact and noncontact storm water from 

the eastern outdoor storage areas and scrubber underflow water to two dust suppression ponds. In the 

event of excess accumulation of wastewater and storm water, the facility may discharge via Outfalls 001 

and 004 to Port Sutton Channel.

Summary of Effluent Data and Limits

The facility does not discharge every month. In fact, effluent concentration data for TN and TP are only 

available for 5 months and effluent load data are only available for 10 months from 2006 through 2010, as 

shown in Exhibit C-1.

Exhibit C-1: Effluent Data Summary, Kinder Morgan Tampaplex Bulk Terminal1

Pollutant

Concentration Data Load Data

Observations Avg. Effluent 

(mg/L)

Permit Limit 

(mg/L) Observations Avg. Effluent (lb/day)

Permit Limit 

(lb/day)

TN 5 27.1 None 10 50.4 None

TP 5 41.6 None 10 96.8 None

Source: EPA (2011)

1. TN and TP effluent data from 2006 through 2010. Concentration data represent average of maximum monthly 

values; Load data represent average of maximum monthly values.

The permit specifies a 5-year rolling annual average TP target of 4.1 tons per year for both the Kinder 

Morgan Tampaplex Terminal and Ammonia Terminal (FL0000264), and a cumulative 5-year average of 

monthly TN loads target of 75 tons per year for 4 facilities total (FL0321486, FL0000264, FL0001643, 

and FL0122904). Thus, compliance with these limits depends on nutrient loads at other facilities.

Incremental Controls 

The facility discharges to the Hillsborough Bay segment (Segment ID 0901) of the Tampa Bay estuary

with annual geometric mean criteria for TN and TP of 0.49 mg/L and 0.175 mg/L, respectively. The 

discharger is currently covered under the Tampa Bay Reasonable Assurance Plan, and has a TN effluent 

loading limit reflecting the target levels for the bay. However, the plan does not include targets for TP. 

Thus, given current effluent TP concentrations, and the uncertainty as to whether dilution would be 
January 2012 Appendix C. Sample Industrial Discharger Analyses

Draft for Internal Review Only-Do Not Quote or Cite

C-2

considered in the calculations of potential effluent limits, this facility may need to implement a level of 

incremental control to reduce TP concentrations under the proposed rule. 

Effluent monitoring data indicate that the facility discharges intermittently (there are only 5 monthly 

maximum/average flow values reported in PCS over 5 years of data) with extremely variable flows 

(ranging an order of magnitude). Without site-specific facility information or knowledge of how FDEP 

would permit such a discharge, the compliance mechanisms that would be necessary under the proposed 

rule are uncertain. For example, the discharger may be able to implement pollution prevention or waste 

minimization measures to reduce stormwater contact with materials or reduce wastewater volume. The 

discharger could also expand or construct new detention ponds to reduce or eliminate the discharge. 

However, due to the uncertainty related to the likely compliance mechanism, EPA conservatively (i.e., 

erring on the side of higher costs) assumed that the discharger would need to meet effluent limits based on 

criteria end-of-pipe. 

To meet the potential TP levels, EPA estimated costs based on chemical precipitation followed by 

filtration. Capital and O&M unit costs could be $0.32/gpd and $238/MG, respectively. Based on a design 

flow of 2.88 mgd, total capital costs could be approximately $0.93 million. During the last 5 years, the 

facility has only discharged 2 consecutive months. Thus, to estimate O&M costs, EPA assumed that the 

facility would operate the treatment units for 60 days per year at a flow of 2.88 mgd for a cost of $0.041

million. Total annual costs would be $0.13 million based on annualizing capital costs at 7% over 20 years 

and adding annual O&M. Exhibit C-2 summarizes these costs.

Exhibit C-2: Potential Incremental Costs, Kinder Morgan Tampaplex Bulk Terminal

Treatment Controls Capital Costs 

($ million)1

O&M Cost 

($ million/year)2

Annual Costs 

($ million/year)3

Chemical precipitation 

with filtration $0.93 $0.041 $0.13

1. Design flow multiplied by unit cost of $0.32/gpd for chemical precipitation with filtration.

2. Average flow multiplied by unit cost of $238/MG for chemical precipitation with filtration and the number of 

operating days per year (60 days).

3. Capital costs annualized at 7% over 20 years plus annual O&M.
January 2012 Appendix C. Sample Industrial Discharger Analyses

Draft for Internal Review Only-Do Not Quote or Cite

C-3

Mosaic Fertilizer – Riverview Chemical Complex

NPDES permit number: FL0000761

Major/minor: Major

SIC code: 2874 (Phosphatic Fertilizers)

Industrial Category: Chemicals and Allied Products

Design Flow: Not reported

Average Flow: 0.79 mgd for Outfall 005B and 0.33 mgd for Outfall 021 (2006 - 2010)

Receiving Water: Alafia River (Outfall 001, 005A, 005B, 021); Hillsborough Bay (Outfall 

022); Archie Creek (Outfall 025)

Description

The facility manufactures sulfuric acid, phosphoric acid, fluoride products, ammoniated phosphates and 

micronutrient added fertilizers, and animal feed phosphates. At full capacity, the facility produces 

approximately 1,500,000 tons of phosphoric acid per year (with 7,500,000 tons per year of 

phosphogypsum as a byproduct of the manufacturing process). Other operations at the site include electric 

cogeneration, phosphogypsum storage, raw material storage and handling, wastewater storage and 

handling, process material handling, product shipping facilities, and a 0.0175 mgd domestic wastewater 

treatment plant. 

The facility discharges nonprocess wastewater, treated process wastewater, and storm water through 

Outfalls 001 and 005A to the Alafia River and through Outfall 005B to a barge basin off the Alafia River. 

In its 2005 permit, the facility proposed to change its operations to reduce the discharge from Outfall 001 

and redirect the discharge to Outfall 005B. The facility sends storm water runoff from nonprocess area to 

detention ponds where filtration and nutrient removal take place prior to discharging through Outfalls 021 

and 022. The north storm water management system for Outfall 025 is designed to contain a storm event 

resulting in 7 inches of rain within a 24-hour period. Effluent from the wastewater plant is routed to the 

process cooling pond water system. 

Summary of Effluent Data and Limits

Exhibit C-3 summarizes average monthly effluent data for TN and TP for Outfall 005B and TP data for 

Outfall 021 from 2006 through 2010; there are no data for the other outfalls.

Exhibit C-3: Effluent Data Summary, Mosaic Fertilizer – Riverview Chemical Complex1

Pollutant

Concentration Data Load Data

Observations Avg. Effluent 

(mg/L)

Permit Limit 

(mg/L) Observations Avg. Effluent (lb/day)

Permit Limit 

(lb/day)2

Outfall 005B

TN 60 8.5 None 59 8.8 55

TP 5 41.6 None 59 23.8 55

Outfall 021

TN 57 1.8 None 0 -- None

Source: EPA (2011)

1. TN and TP effluent data from 2006 through 2010. Concentration data represent average of maximum monthly 

values; Load data represent average of average monthly values (which were consistently higher than the maximum 

monthly values reported).

2. Represents average monthly loading limits. The maximum daily load limit is 100 lbs/day for TN and 120 lbs/day for 

TP. The facility also has cumulative target values for Outfalls 001, 005A, and 005B of 1,452,331 lb/yr for TN and 

2,358,657 lb/yr for TP. 
January 2012 Appendix C. Sample Industrial Discharger Analyses

Draft for Internal Review Only-Do Not Quote or Cite

C-4

Incremental Controls 

The facility discharges to the estuarine portion of the Alafia River (Segment ID 0901) of the Tampa Bay 

estuary with annual geometric mean criteria for TN and TP of 0.49 mg/L and 0.175 mg/L, respectively. 

The facility is already covered under the Alafia River Nutrient TMDL. FDEP considers the discharger an 

insignificant source of nutrients (Petrus and Laskis, 2009): 

“The one point source with outfalls discharging to the Alafia River, the Mosaic Fertilizer, L.L.C. 

Riverview Chemical Complex, NPDES No. FL0000761, was considered not to be a significant 

load to the lower Alafia River relative to the total nonpoint source load, as the current TN load 

being discharged is less than one percent of the total load entering the lower Alafia River. The 

facility’s current load to the river, for the 2001-2007 period, was applied as the WLA. Since the 

facility load is small relative to the total load entering the estuary, the reductions will be focused 

on MS4 facilities and nonpoint sources.”

However, because FDEP determined TN to be the limiting pollutant in the receiving water, it established 

a TMDL for TN only. Thus, under the rule the discharger may need to implement controls to reduce TP 

concentrations. Given the lack of site-specific facility treatment or process information and the 

uncertainty regarding how FDEP will establish effluent limits for the facility, the compliance mechanisms 

the facility would implement under the rule are uncertain. For example, the permit indicates that the 

discharge has filtration and nutrient removal prior to discharge through Outfall 021. However, it does not 

specify the type of nutrient removal processes to give indication as to whether modifications could be 

made to the existing treatment to enhance TP removal. It is also not clear whether FDEP would treat TP 

similar to how it treats TN under the Alafia River TMDL and set effluent limits based on existing loads 

because the discharger accounts for such a small percentage of the load. Due to these uncertainties, EPA 

conservatively (i.e., erring on the side of higher costs) assumed that the discharger would need to meet 

effluent limits based on criteria end-of-pipe. 

To meet the potential TP levels, EPA estimated costs based on chemical precipitation followed by 

filtration. Capital and O&M unit costs could be $0.32/gpd and $238/MG, respectively. The facility’s 

permit does not report design flows from which to estimate total capital costs. Therefore, to estimate 

capital costs, we used the 90th percentile maximum monthly flow from 2006 through 2010 to approximate 

the necessary design flow (1.7 mgd for Outfall 005B and 0.8 mgd for Outfall 021). Based on these flows, 

total capital costs could be approximately $0.80 million. During the last 5 years, average maximum 

monthly flows for Outfall 005B and Outfall 021 have been 0.79 mgd and 0.33 mgd, respectively. Thus, to 

estimate O&M costs we used these average flows assuming operation of the treatment units 365 days per 

year at a cost of $0.097 million. Total annual costs would be $0.17 million based on annualizing capital 

costs at 7% over 20 years and adding annual O&M. Exhibit C-4 summarizes these costs.

Exhibit C-4: Potential Incremental Costs, Mosaic Fertilizer – Riverview Chemical 

Complex

Treatment Controls Capital Costs 

($ million)1

O&M Cost 

($ million/year)2

Annual Costs 

($ million/year)3

Chemical precipitation 

with filtration $0.80 $0.097 $0.17

1. Design flow multiplied by unit cost of $0.32/gpd for chemical precipitation with filtration.

2. Average flow multiplied by unit cost of $238/MG for chemical precipitation with filtration and the number of 

operating days per year (365 days).

3. Capital costs annualized at 7% over 20 years plus annual O&M.
January 2012 Appendix C. Sample Industrial Discharger Analyses

Draft for Internal Review Only-Do Not Quote or Cite

C-5

Trademark Nitrogen Corporation

NPDES permit number: FL0000647

Major/minor: Minor

SIC code: 2873 (Nitrogenous Fertilizers)

Industrial Category: Chemicals and Allied Products

Design Flow: 25 mgd

Average Flow: 0.11 mgd (average of monthly maximum flows)

Receiving Water: Unnamed ditch to Palm River to McKay Bay

Description

The facility is a fertilizer production plant, consisting of a 125 ton per day nitric acid plant, a 150 ton per 

day ammonium nitrate plant, a fertilizer solution plant, a magnesium nitrate plant, a nitrogen-phosphoruspotassium blend plant (liquid fertilizer), and a small boiler plant. Wastewater consists of boiler 

blowdown, boiler water softener backwash, cooling tower blowdown, once-through noncontact cooling 

water, and storm water runoff. All wastewater except the cooling water is treated in an unlined, hyacinths 

vegetated detention ditch. The ditch system provides for uptake of nutrients and settling of solids. 

Noncontact cooling water is piped directly to a basin downstream of the vegetated ditch.

Summary of Effluent Data and Limits

Exhibit C-5 summarizes average monthly effluent data for TN and TP from 2005 to 2010.

Exhibit C-5: Effluent Data Summary, Trademark Nitrogen Corporation

Pollutant Number of 

Observations

Average Effluent 

(mg/L)1 Permit Limit2

Total nitrogen 60 0.76 3.0

Total phosphorus 1 0.048 None

Source: EPA (2011) for nitrogen data; 2008 Effluent Quality Assessment Report for phosphorus.

1. TN effluent data from 2006 through 2010. Represents average of maximum monthly values. TP effluent data from 

March 2008.

2. Represents monthly average limit; permit also contains a daily maximum limit of 5.0 mg/L. In addition, the 5-year 

rolling average for TN may not exceed 200 lbs/yr.

Incremental Controls 

The facility discharges to McKay Bay (Segment ID 0901) of the Tampa Bay estuary with annual 

geometric mean criteria for TN and TP of 0.49 mg/L and 0.175 mg/L, respectively. However, the facility 

is already covered under the McKay Bay TMDL and has a WLA for TN of 3.0 mg/L, which it is currently 

meeting. Therefore, EPA assumed that the TMDL TN targets would be adopted as SSAC and the facility 

would not incur incremental costs associated with TN reductions. 

The only TP observation indicates that the discharger is likely discharging below the applicable TP 

criterion. Thus, EPA assumed that an incremental level of control would not be necessary for compliance 

with effluent limits under the proposed rule and costs would be zero.
January 2012 Appendix C. Sample Industrial Discharger Analyses

Draft for Internal Review Only-Do Not Quote or Cite

C-6

Anheuser Busch Inc., Main Street Sod Farm

NPDES permit number: FL0041530

Major/minor: Minor

SIC code: 2082 (Malt Beverages)

Industrial Category: Food

Design Flow: 2.4 mgd

Average Flow: 1.02 mgd (average of annual average values from 2006 through 2010)

Receiving Water: Little Cedar Creek to Broward River

Description

Anheuser Busch operates a land application system that receives untreated and/or pretreated brewery 

liquor as a nutrient enrichment to grow turf and forage crops on a 320-acre site. The land application site 

drains to an interconnected pond system comprised of two ponds: North Borrow Pit (NBP) and South 

Borrow Pit (SBP). NBP drains to SBP which discharges via Outfall 001 to Little Cedar Creek.

Summary of Effluent Data and Limits

Exhibit C-6 summarizes average monthly effluent data for TN and TP from 2005 to 2010.

Exhibit C-6: Effluent Data Summary, Anheuser Busch Inc., Main Street Sod Farm

Pollutant Number of 

Observations

Average Effluent 

(mg/L)1 Permit Limit2

Total nitrogen 55 3.0 None

Total phosphorus 20 1.3 None

Source: EPA (2011)

1. TN and TP effluent data from 2006 through 2010. Represents average of maximum monthly values.

2. Permit contains an annual loading limit for TN of 27,000 lbs/year.

Incremental Controls 

The facility discharges to the Saint Johns River estuary (Segment ID 1802) with draft annual average 

criteria for TN and TP of 1.09 mg/L and 0.108 mg/L, respectively. However, for TN the discharger is 

covered under the Lower Saint Johns River TMDL and BMAP. FDEP gave the discharger a TN WLA 

that represented a 49% decrease in TN. To reduce effluent nutrient loads, in 2006, Anheuser Busch 

improved/modified the site nutrient management plan and increased the crop area to which they land 

applied a portion of the wastewater to reduce the nutrient load per acre (Busby, 2009). Thus, EPA 

assumed that the discharger would not be required to implement additional controls for compliance with 

TN limits under the proposed rule. 

However, for TP the discharger may need to reduce effluent levels under the proposed rule. Due to a lack 

of site-specific facility operations and treatment data, it is uncertain whether additional improvements or 

modifications similar to those made to reduce TN concentrations could be made to reduce TP 

concentrations. It is also uncertain how FDEP would permit the facility under the proposed rule (e.g., 

limits based on criteria end-of-pipe, existing loads, or factoring in some degree of available dilution). As 

such, EPA conservatively (i.e., erring on the side of higher costs) assumed that the discharger would need 

to meet effluent limits based on criteria end-of-pipe for TP. 
January 2012 Appendix C. Sample Industrial Discharger Analyses

Draft for Internal Review Only-Do Not Quote or Cite

C-7

To meet the potential TP levels, EPA assumed that the facility would likely install chemical precipitation 

followed by filtration. Capital and O&M unit costs could be $0.32/gpd and $238/MG, respectively. Based 

on a design flow of 2.4 mgd, total capital costs could be approximately $0.77 million. During the last 5 

years, average maximum monthly flows have been approximately 1.02 mgd. Thus, assuming operation of 

the treatment units 365 days per year, O&M costs could be approximately $0.089 million. Total annual 

costs would be $0.16 million based on annualizing capital costs at 7% over 20 years and adding annual 

O&M. Exhibit C-7 summarizes these costs.

Exhibit C-7: Potential Incremental Costs, Anheuser Busch – Main Street Sod Farm

Treatment Controls Capital Costs 

($ million)1

O&M Cost 

($ million/year)2

Annual Costs 

($ million/year)3

Chemical precipitation 

with filtration $0.77 $0.089 $0.16

1. Design flow multiplied by unit cost of $0.32/gpd for chemical precipitation with filtration.

2. Average flow multiplied by unit cost of $238/MG for chemical precipitation with filtration and the number of 

operating days per year (365 days).

3. Capital costs annualized at 7% over 20 years plus annual O&M.
January 2012 Appendix C. Sample Industrial Discharger Analyses

Draft for Internal Review Only-Do Not Quote or Cite

C-8

Coca-Cola North America, Dunedin

NPDES permit number: FL0000477

Major/minor: Major

SIC code: 2033 (Canned Fruits, Vegetables, Preserves, Jams, and Jellies)

Industrial Category: Food

Design Flow: 0.45 mgd

Average Flow: 0.22 mgd (average monthly maximum values from 2006 through 2010)

Receiving Water: Saint Joseph’s Sound

Description

Coca-Cola North America operates a fruit juice blending, packaging, and shipping operation for various 

fruit juice based concentrates for sale to food service organizations. The facility has an activated sludge 

industrial wastewater treatment system designed to collect and treat industrial process wastewater through 

flow equalization, aeration, clarification, and filtration. The process wastewater consists of process 

blending, tank cleaning, boiler blowdown, cleaning from truck unloading area, noncontact defrost water, 

storm water runoff from parking lots and paved areas, well water used for cleaning and maintenance of 

the activated sludge treatment plant, and reverse osmosis concentrated from the water treatment plant 

onsite (the facility uses drinking water as an ingredient in its products).

Summary of Effluent Data and Limits

Exhibit C-8 summarizes average monthly effluent data for TN and TP from 2005 to 2010.

Exhibit C-8: Effluent Data Summary, Coca-Cola North America, Dunedin

Pollutant Number of 

Observations

Average Effluent 

(mg/L)1 Permit Limit (mg/L)2

Total nitrogen 60 1.4 3.0

Total phosphorus 20 0.53 1.0

Source: EPA (2011)

1. TN and TP effluent data from 2006 through 2010. Represents average of maximum monthly values.

2. Permit contains an annual loading limit for TN of 27,000 lbs/year.

Incremental Controls 

The facility discharges to the Saint Joseph’s Sound (Segment ID 0802) with annual geometric mean 

criteria for TN and TP of 0.46 mg/L and 0.029 mg/L, respectively. The facility is currently discharging 

above the applicable criteria, and because water quality data indicate that the segment could be impaired 

for nutrients, it is not likely to receive dilution in the calculations of effluent limits. Thus, EPA assumed 

that potential effluent limits for TN and TP would reflect criteria end-of-pipe. 

However, due to the extremely low TN and TP levels, there is significant uncertainty as to whether the 

projected effluent limits are technologically or economically feasible to attain. Thus, EPA assumed that 

the facility would likely pursue a variance from meeting effluent limits based on criteria end-of-pipe. 

While existing TN concentrations are already relatively low, additional reductions in TP could be 

achieved through cost-effective treatment controls. Thus, EPA estimated incremental compliance costs 

based on installation of chemical precipitation (the facility already has filtration) as a condition of the 

variance (e.g., lowest levels feasible).

Capital and O&M unit costs could be $0.03/gpd and $101/MG, respectively. Based on a design flow of 

0.45 mgd, total capital costs could be approximately $0.015 million. During the last 5 years, average 
January 2012 Appendix C. Sample Industrial Discharger Analyses

Draft for Internal Review Only-Do Not Quote or Cite

C-9

maximum monthly flows have been approximately 0.22 mgd. Thus, assuming operation of the treatment 

units 365 days per year, O&M costs could be approximately $0.008 million. Total annual costs would be 

$0.01 million based on annualizing capital costs at 7% over 20 years and adding annual O&M. Exhibit 

C-9 summarizes these costs.

Exhibit C-9: Potential Incremental Costs, Coca Cola North America - Dunedin 

Treatment Controls Capital Costs 

($ million)1

O&M Cost 

($ million/year)2

Annual Costs 

($ million/year)3

Chemical precipitation $0.015 $0.008 $0.01

1. Design flow multiplied by unit cost of $0.03/gpd for chemical precipitation.

2. Average flow multiplied by unit cost of $101/MG for chemical precipitation and the number of operating days per 

year (365 days).

3. Capital costs annualized at 7% over 20 years plus annual O&M.
January 2012 Appendix C. Sample Industrial Discharger Analyses

Draft for Internal Review Only-Do Not Quote or Cite

C-10

Tropicana Manufacturing Company, Inc.

NPDES permit number: FL0000043

Major/minor: Major

SIC code: 0174 (Citrus Fruits)

Industrial Category: Food

Design Flow: 2.26 mgd

Average Flow: No discharge since 2003

Receiving Water: Manatee River

Description

The facility operates a citrus juice processing plant with processes fresh fruit during the harvesting season 

(November through June) and packages the juice on a year-round basis. The process wastewater from the 

production facility is treated in an onsite, multi-stage wastewater treatment plant which consists of 

equalization, dissolved air flotation, anaerobic bioreactors, pH adjustment, and 2nd stage activated sludge 

(aeration and secondary clarification), and tertiary dissolved air flotation. Treated effluent is stored or 

discharged to to an underground injection well or Manatee River.

Summary of Effluent Data and Limits

The facility has not discharged in the last five years; thus, there are no effluent data for TN and TP.

However, the discharge has an annual loading limit for TN of 9.125 tons/year based on a 5-year rolling 

average with a 1-year maximum load not to exceed 13.6875 tons.

Incremental Controls 

The Manatee River (Segment ID 0906) has TN and TP criteria of 0.62 mg/L and 0.115 mg/L, 

respectively. However, because the facility has not discharged within the last five years, EPA assumes 

that it would not incur incremental control costs under the proposed rule.
January 2012 Appendix C. Sample Industrial Discharger Analyses

Draft for Internal Review Only-Do Not Quote or Cite

C-11

Tampa Phosphate Terminal and Warehouse

NPDES permit number: FL0166057

Major/minor: Minor

SIC code: 1475 (Phosphate Rock)

Industrial Category: Mining

Design Flow: Not reported

Average Flow: 0.018 mgd Outfall D-SW1; 0.31 mgd Outfall D-SW3 (average of 

average monthly values for 2006 through 2010)

Receiving Water: East Bay (sub-bay of Hillsborough Bay)

Description

Facility operations consist of bulk fertilizer storage and material transfer for the shipping terminal at the 

Port of Tampa. The facility is permitted to discharge contact and noncontact stormwater via Outfall DSW1 and D-SW3 directly into East Bay, a sub-bay of Tampa Bay. During normal rainfall events, Outfall 

D-SW1 does not discharge, and the sump pump transfers all storm water to the onsite storm water 

retention pond which is designed to store a 25-year, 24-hour rainfall event of 8 inches. Storm water enters 

the retention pond where solids settle out and then flows over a berm to the secondary area containing 

hyacinths with uptake nutrients. Outfall D-SW3 is located at the stormwater retention pond. Fertilizer 

products are the only significant materials handled at the facility that have potential for stormwater 

exposure.

Summary of Effluent Data and Limits

Exhibit C-10 summarizes TN and TP effluent data from 2006 through 2010 for Outfalls D-SW1 and DSW3.

Exhibit C-10: Effluent Data Summary, Tampa Phosphate Terminal and Warehouse

Pollutant Number of 

Observations

Average Effluent (mg/L) 1 Permit Limit2

Outfall D-SW1

Total nitrogen 13 19.1 None

Total phosphorus 13 22.6 None

Outfall D-SW3

Total nitrogen 5 17.4 None

Total phosphorus 5 32.1 None

Source: EPA (2011)

1. TN and TP effluent data from 2006 through 2010 representing average of maximum monthly values.

2. Permit contains 5-year rolling average annual maximum target values for TN and TP of 1,104 lbs/year and 986 

lbs/year, respectively.

Incremental Controls 

The facility discharges to Hillsborough Bay (Segment ID 0901) in the Tampa Bay estuary with annual 

geometric mean criteria for TN and TP of 0.49 mg/L and 0.175 mg/L, respectively. The discharger is 

currently covered under the Tampa Bay Reasonable Assurance Plan, and has a TN effluent loading limit 

reflecting the target levels for the bay. However, the plan does not include targets for TP. Thus, given 

current effluent TP concentrations, and the uncertainty as to whether the discharger would receive 

dilution in the calculations of potential effluent limits, this facility may need to implement a level of 

incremental control to reduce TP concentrations under the proposed rule. 
January 2012 Appendix C. Sample Industrial Discharger Analyses

Draft for Internal Review Only-Do Not Quote or Cite

C-12

Effluent monitoring data indicate that the facility discharges intermittently (there are only 13 monthly 

maximum/average flow values reported in PCS over 5 years of data for Outfall D-SW1 and 5 for Outfall 

D-SW3) with extremely variable flows (ranging 2 orders of magnitude). Without site-specific facility 

information or knowledge of how FDEP would permit such a discharge, the compliance mechanisms that 

would be necessary under the proposed rule are uncertain. For example, the discharger may be able to 

implement pollution prevention or waste minimization measures to reduce stormwater contact with 

materials or reduce wastewater volume. The discharge could also expand or construct new stormwater 

detention ponds to reduce or eliminate the discharge. However, due to the uncertainty related to the likely 

compliance mechanism, EPA conservatively (i.e., erring on the side of higher costs) assumed that the 

discharger would need to install additional end-of-pipe treatment controls to meet effluent limits based on

the criteria at the point of discharge (i.e., no dilution).

To meet the potential TP levels, EPA estimated costs based on chemical precipitation followed by 

filtration. Capital and O&M unit costs could be $0.32/gpd and $238/MG, respectively. The facility’s 

permit does not report design flows from which to estimate total capital costs. Therefore, to estimate 

capital costs, we used the 90th percentile maximum monthly flow for both outfalls from 2006 through 

2010 to approximate the necessary design flow (0.29 mgd for Outfall SW1 and 0.76 mgd for Outfall 

SW3). Based on these flows, total capital costs could be approximately $0.34 million. During the last 5 

years, average maximum monthly flows for Outfall SW1 and Outfall SW3 have been 0.018 mgd and 0.31

mgd, respectively. Thus, to estimate O&M costs we used these average flows assuming operation of the 

treatment units 79 days per year (13 months of discharge over 5 years = 79 discharge days per year) at a 

cost of $0.006 million. Total annual costs would be $0.038 million based on annualizing capital costs at 

7% over 20 years and adding annual O&M. Exhibit C-11 summarizes these costs.

Exhibit C-11: Potential Incremental Costs, Tampa Phosphate Terminal and Warehouse

Treatment Controls Capital Costs 

($ million)1

O&M Cost 

($ million/year)2

Annual Costs 

($ million/year)3

Chemical precipitation 

with filtration $0.34 $0.006 $0.038

1. 90th percentile flow multiplied by unit cost of $0.32/gpd for chemical precipitation with filtration.

2. Average flow multiplied by unit cost of $238/MG for chemical precipitation with filtration and the number of 

operating days per year (79 days).

3. Capital costs annualized at 7% over 20 years plus annual O&M.
January 2012 Appendix C. Sample Industrial Discharger Analyses

Draft for Internal Review Only-Do Not Quote or Cite

C-13

YARA North America, Inc.

NPDES permit number: FL0038652

Major/minor: Major

SIC code: 1475 (Phosphate Rock)

Industrial Category: Mining

Design Flow: 2 mgd

Average Flow: 1.8 mgd (average of maximum monthly values from 2006 through 2010)

Receiving Water: Port Sutton Channel

Description

The facility is a bulk anhydrous ammonia storage and transfer facility that encompasses approximately 

3.65 acres. The anhydrous ammonia arrives via ship and is stored in two onsite storage tanks where it is 

distributed by commercial pipeline and tanker trucks. The facility intakes seawater from the Tampa Bay 

Electric discharge, and pumps the warmed water through two parallel shell and tube type heat exchangers. 

The facility has a 15,000 gallon holding tank to store contaminated seawater in case of an upset and to 

contain noncontact cooling water from the condensers prior to discharge. The condensers use potable 

municipal water with addition of antiscalant, corrosion inhibitors, and biocides. The wastewater treatment 

system has a fully automatic differential pH detection and control system. The facility also collects storm 

water in a 50,000 gallon detention pond where it monitors and controls the water level using a sump 

pump system. Any pumped storm water mixes with the seawater cooling water upstream of Outfall D-001 

prior to discharging to the Port Sutton Channel.

Summary of Effluent Data and Limits

Exhibit C-12 summarizes average monthly effluent data for TN and TP from 2005 to 2010.

Exhibit C-12: Effluent Data Summary, YARA North America, Inc.

Pollutant Number of 

Observations

Average Effluent 

(mg/L)1 Permit Limit (mg/L)2

Total nitrogen 59 1.1 3.0

Total phosphorus 53 0.23 None

Source: EPA (2011)

1. TN and TP effluent data from 2006 through 2010. Represents average of maximum monthly values.

2. Permit also contains an annual loading target value for TN of 7,951 lbs/year representing only the load 

contributed by the facility (excludes any TN in the initial intake water).

Incremental Controls 

The facility discharges to Port Sutton Channel (Segment ID 0901) in the Tampa Bay estuary with annual 

geometric mean criteria for TN and TP of 0.49 mg/L and 0.175 mg/L, respectively. The discharger is 

currently covered under the Black Point Channel TN TMDL and the Tampa Bay Reasonable Assurance 

Plan, and has a TN effluent loading limit reflecting the target levels for the bay. Thus, EPA assumed the 

discharger would not incur incremental control costs associated with TN reductions.

The plan does not include targets for TP. Current average effluent TP concentrations indicate that the 

facility is likely discharging below the TP criterion. Thus, EPA assumed that the facility would not incur 

incremental costs associated with TP reductions.
January 2012 Appendix C. Sample Industrial Discharger Analyses

Draft for Internal Review Only-Do Not Quote or Cite

C-14

Coastal Terminals LLC - Fisher Island Terminal

NPDES permit number: FL0036064

Major/minor: Minor

SIC code: 5171 (Petroleum Bulk Stations and Terminals)

Industrial Category: Other

Design Flow: 0.5 mgd

Average Flow: 0.42 mgd (only one maximum monthly value from 2006 through 2010)

Receiving Water: Biscayne Bay

Description

The facility is a bulk petroleum products storage and distribution facility with a total of 17 aboveground 

storage tanks at the terminal site that store petroleum products including No. 6 fuel oil and diesel fuel. 

There is no dedicated "off-spec" tank as all petroleum contact water (PCW), including tank bottom water 

and contaminated stormwater are diverted to any one of the No. 6 fuel oil storage tanks for assimilation. 

Secondary containment for the tank farm is provided by earthen dikes that surround an unlined 

containment basin area of about 150,000 square feet. This facility may discharge up to 0.5 MGD of 

hydrostatic tank test water through Outfall D-002, using either ambient sea water or municipal fresh water 

as the test water source. Hydrostatic test water is not normally treated before disposal, but it must first be 

analyzed and shown to meet the effluent limitations specified in the permit before its release. If necessary, 

portable water treatment equipment (e.g., diatomaceous earth filter) may be utilized to reduce the

particular pollutant(s) of concern. In the event municipal potable water is used as the source water, 

effluent total residual chlorine (TRC) level is typically reduced by exposure to atmosphere, during 

overland flow in transit to Outfall D-002. Tank bottom water, loading rack runoff and other miscellaneous 

PCW’s, are returned to any one of the No. 6 fuel oil storage tanks for assimilation.

Summary of Effluent Data and Limits

There are no effluent TN and TP data available in EPA’s PCS database for this discharger.

Incremental Controls 

The facility discharges wastewater to the Southern North Bay (Segment ID SNB) of the Biscayne Bay 

estuary with annual geometric mean criteria for TN and TP of 0.32 mg/L and 0.010 mg/L, respectively. 

The facility does not have existing effluent limits or monitoring requirements for TN or TP. Given the 

lack of existing permit requirements, the nature of the wastewater (e.g., petroleum contact water and 

hydrostatic test water made up of ambient sea water or municipal potable water), and the frequency of 

discharge (once in five years), it is unlikely that the facility would have reasonable potential under the 

proposed rule. Thus, incremental compliance costs are likely zero.
January 2012 Appendix C. Sample Industrial Discharger Analyses

Draft for Internal Review Only-Do Not Quote or Cite

C-15

Florida Atlantic University Sea Tech Facility

NPDES permit number: FL0178870

Major/minor: Minor

SIC code: 8733 (Noncommercial Research Organizations)

Industrial Category: Other

Design Flow: 0.062 mgd

Average Flow: 0.054 mgd (average of maximum monthly values from 2006 through 

2010)

Receiving Water: Whiskey Creek or New River Sound

Description

The facility is a university research institute that engages in various aspects of ocean engineering research 

activities. Part of the operation carried out at the facility involves the study of marine materials and 

corrosion effect as relating to offshore structures using natural sea water in holding tanks. Inside the 

tanks, sea water comes into contact with a variety of coupon-sized test samples of metal (steel and 

aluminum), reinforced concrete, and carbon fiber composites structural materials that are in suspension 

and submerged under water. Researches renew the test water in the tanks is periodically with new sea 

water to maintain general freshness and to prevent bio-growth inside the tanks. The facility periodically

discharges "spent" test sea water through Outfall D-001 to the south end of the Whiskey Creek or New 

River Sound. Note that only 5% to 10% of the total sea water withdrawn is actually routed into the two 

test tanks. The majority of the inflow bypasses the tanks entirely, and flows directly to the outfall. The 

facility does not treat the spent sea water before discharge due to the historic low level of pollutants being 

introduced into the waste stream from the test processes, absence of foreign chemical additives used in 

the study, high proportion of noncontact direct bypass flow, and the very well controlled environment of 

the laboratory. The test tanks are manually scrubbed down periodically to remove any larger settled and 

floating debris or excess bio-growth.

Summary of Effluent Data and Limits

There are no effluent TN and TP data available in EPA’s PCS database for this discharger.

Incremental Controls 

The facility discharges coastal waters, for which EPA has proposed only chlorophyll-a criteria. However, 

the facility does not have existing effluent limits or monitoring requirements for TN or TP. Given the lack 

of existing permit requirements and the nature of the wastewater (e.g., spent and noncontact sea water), it 

is unlikely that the facility would have reasonable potential under the proposed rule. Thus, incremental 

compliance costs are likely zero. 
January 2012 Appendix C. Sample Industrial Discharger Analyses

Draft for Internal Review Only-Do Not Quote or Cite

C-16

Miami Seaquarium Tank Flow-Through Water Discharge Facility

NPDES permit number: FL0169129

Major/minor: Minor

SIC code: 7996 (Amusement Parks)

Industrial Category: Other

Design Flow: 18.72 mgd

Average Flow: Outfall D-001 = 2.88 mgd; Outfall D-003 = 3.024 mgd; Outfall D-004 = 

1.44 mgd; Outfall D-005 = 1.44 mgd (average of average monthly values 

from 2006 through 2010)

Receiving Water: Biscayne Bay

Description

Miami Seaquarium is a major marine life exhibition facility that presents a variety of marine wildlife 

exhibits, animal shows, and other marine ecosystem theme attractions. The facility discharges continuous, 

once-through, tank flow through waters from the various marine life habitats and tanks at the seaquarium 

facility. Intake water for the seaquarium is from Biscayne Bay continuously flows through the habitats 

and tanks in various sequences, before being returned to the Biscayne Bay through one of the seven ocean 

outfalls. Treatment of the raw supply water is minimal and limited to filtration at the intake to improve 

the purity of the water, and chlorination prior to the entrances to most of the tanks to control bacteria and 

algae growth. There is also localized further conditioning of the supply water (e.g. chilling, aeration and 

additional filtration, etc.) at various tanks to accommodate the unique habitat environment required of 

different animals.

Tank flow-through water normally only contains relatively low level of waste loads, that consist of 

mostly animal waste and by-product, and other natural foreign matters including animal feed residue and 

decayed vegetation. As a result, treatment or reduction of waste loads is normally adequately achieved by 

the natural dilution, mixing and breakdown effects, associated with the continuous high volume flowthrough renewal process; and from nature degradation by exposure to atmosphere. The facility discharges 

through Outfalls D-001 through D-007 to Biscayne Bay.

Summary of Effluent Data and Limits

There are no effluent TN and TP data available in EPA’s PCS database for this discharger.

Incremental Controls 

The facility discharges wastewater from all of its outfalls to the Southern North Bay (Segment ID SNB) 

of the Biscayne Bay estuary with annual geometric mean criteria for TN and TP of 0.32 mg/L and 0.010 

mg/L, respectively. However, there are no effluent data from which to assess compliance and the facility 

does not have existing effluent limits or monitoring requirements for TN or TP. Given the lack of existing 

permit requirements and the nature of the wastewater (e.g., spent and noncontact sea water), it is unlikely 

that the facility would have reasonable potential under the proposed rule. Thus, incremental compliance 

costs are likely zero. 
January 2012 Appendix C. Sample Industrial Discharger Analyses

Draft for Internal Review Only-Do Not Quote or Cite

C-17

Motiva Enterprises LLC, Port Tampa Terminal

NPDES permit number: FL0000591

Major/minor: Minor

SIC code: 5171 (Petroleum Bulk Stations and Terminals)

Industrial Category: Other

Design Flow: Not reported

Average Flow: Outfall D-001 = 0.15 mgd; Outfall D-002 = 0.08 mgd; (average of 

maximum monthly values from 2006 through 2010)

Receiving Water: Tampa Bay

Description

The facility is a bulk petroleum storage facility that receives refined petroleum products from marine 

vessels and tank trucks. The facility stores the products in above ground storage tanks and distributes 

them to transport trucks and/or pipelines. The wastewater generated from the facility consists of 

hydrostatic test tank water and stormwater. The hydrostatic test water is potable city water that is used to 

fill a storage tank after completion of modifications or repairs to the tank. Tank drawdown will be 

collected and hauled offsite for treatment and disposal by a registered contractor in accordance with 

relevant regulations.

Summary of Effluent Data and Limits

There are no effluent TN and TP data available in EPA’s PCS database for this discharger.

Incremental Controls 

The facility discharges in the Upper Tampa Bay (Segment ID 0903) in the Tampa Bay estuary with 

annual geometric mean criteria for TN and TP of 0.44 mg/L and 0.152 mg/L, respectively. However, 

there are no effluent data from which to assess compliance and the facility does not have existing effluent 

limits or monitoring requirements for TN or TP. Given the lack of existing permit requirements and the 

nature of the wastewater (e.g., potable, hydrostatic test water, and stormwater), it is unlikely that the 

facility would have reasonable potential under the proposed rule. Thus, incremental compliance costs are 

likely zero. 
January 2012 Appendix C. Sample Industrial Discharger Analyses

Draft for Internal Review Only-Do Not Quote or Cite

C-18

Smurfit Stone, Fernandina Beach Containerboard Mill 

NPDES permit number: FL0001104

Major/minor: Major

SIC code: 2631 (Paperboard Mills)

Industrial Category: Pulp and Paper

Design Flow: 37.5 mgd

Average Flow: 17.1 mgd (average of maximum monthly values from 2006 through 

2010)

Receiving Water: Lower Amelia River

Description

The facility produces unbleached kraft linerboard through the following processes: wood preparation, 

pulping, pulp processing and chemical recovery, and paper and paperboard manufacturing, all of which 

contribute to production of wastewater. Wastewater treatment consists of a grit chamber, bar screen, 

primary clarifier, heat exchanger, cooling tower (for noncontact cooling water), UNOX pure oxygen 

activated sludge treatment system, and dual secondary clarifiers. The facility dewaters primary and 

secondary solids using screw presses and belt presses. The facility discharges to Amelia River.

Summary of Effluent Data and Limits

Exhibit C-13 summarizes average monthly effluent data for TP from 2006 to 2010.

Exhibit C-13: Effluent Data Summary, Smurfit Stone - Fernandina Beach Mill

Pollutant Number of 

Observations

Average Effluent 

(mg/L)1 Permit Limit (mg/L)2

Total phosphorus 19 0.47 None

Source: EPA (2011)

1. TP effluent data from 2006 through 2010. Represents average of maximum monthly values.

TN data are not available from EPA’s PCS database, however, the average total Kjeldahl nitrogen 

concentration from 2006 to 2010 is approximately 3.8 mg/L (based on 19 observations of the maximum 

monthly value). Total Kjeldahl nitrogen is the sum of organic nitrogen, ammonia, and ammonium, and 

can be used to estimate TN by adding the concentrations of nitrate-N and nitrite-N. Lab reports for this 

facility indicate that nitrate and nitrite concentrations are extremely low. Thus, total Kjeldahl nitrogen 

levels can be used as a proxy for TN for this analysis.

Incremental Controls 

The facility discharges to the Lower Amelia River (Segment ID 2002) in the St. Mary’s estuary with 

annual geometric mean criteria for TN and TP 0.27 mg/L and 0.045 mg/L, respectively. The discharger 

has a mixing zone for the calculation of effluent limits for dissolved oxygen, copper, nickel, and 

temperature. The dilution ratio is 32:1 and because the existing water quality data (see discussion in 

Section 4) indicate that the segment is not likely to be impaired under the proposed rule, EPA assumed 

the discharger would have a mixing zone for TN and TP under the proposed rule. Potential effluent limits 

could be 8.6 mg/L for TN and 1.4 mg/L for TP. Existing effluent data indicate that the facility would 

likely be in compliance with projected TN and TP effluent limits. Thus, incremental costs would be zero.
January 2012 Appendix C. Sample Industrial Discharger Analyses

Draft for Internal Review Only-Do Not Quote or Cite

C-19

Rayonier Performance Fibers, LLC 

NPDES permit number: FL0000701

Major/minor: Major

SIC code: 2611 (Pulp Mills)

Industrial Category: Pulp and Paper

Design Flow: 26.31 mgd

Average Flow: 16.8 mgd (average of maximum monthly values from 2006 through 

2010)

Receiving Water: Amelia River

Description

The facility is a chemical cellulose pulp mill using the sulfite process. Wastewater treatment consists of a 

grit chamber, neutralization, primary clarifier, and a 34-acre mechanical aeration lagoon. The facility

discharges treated process wastewater, treated stormwater, rinse water, and regenerate water from the 

water treatment plant zeolite softening units to Amelia River only during outgoing tides.

Summary of Effluent Data and Limits

TN and TP data are not available from EPA’s PCS database, however, a laboratory report indicates that in 

2009 TN concentrations were approximately 42.2 mg/L and TP concentrations were approximately 1.6 

mg/L. There are no effluent limits for TN and TP in the current permit.

Incremental Controls 

The facility discharges to the Lower Amelia River (Segment ID 2002) in the St. Mary’s estuary with 

annual geometric mean criteria for TN and TP of 0.27 mg/L and 0.045 mg/L, respectively. The discharger 

has a mixing zone for the calculation of effluent limits for dissolved oxygen, copper, nickel, aluminum, 

iron, lead, and zinc. The dilution ratios range from 2:1 to 8:1 depending on the pollutant. 

Thus, because the existing water quality data (see discussion in Section 4) indicate that the segment is not 

likely to be impaired under the proposed rule, EPA assumed the discharger would have a mixing zone for 

TN and TP under the proposed rule. Potential effluent limits could be 2.2 mg/L for TN and 0.36 mg/L for 

TP. Existing effluent data indicate that the facility would likely need to implement controls for 

compliance with such limits. 

However, due to the low TN, there is significant uncertainty as to whether the projected effluent limits are 

feasible to attain. Thus, EPA assumed that the discharger would likely pursue a variance from meeting the 

projected effluent limits. Because existing TN and TP concentrations are relatively high compared to 

levels that can be achieved with cost-effective treatment controls such as advanced BNR, EPA assumed 

that the facility would need to reduce TN and TP as a condition of the variance (e.g., lowest levels 

feasible). Thus, EPA estimated incremental compliance costs based on installation of advanced BNR.

Capital and O&M unit costs could be $1.30/gpd and $385/MG, respectively. Based on a design flow of 

26.31 mgd, total capital costs could be approximately $36.0 million. During the last 5 years, average 

maximum monthly flows have been 16.8 mgd. Thus, to estimate O&M costs we used these average flows 

assuming operation of the treatment units 365 days per year at a cost of $2.5 million. Total annual costs 

would be $5.9 million based on annualizing capital costs at 7% over 20 years and adding annual O&M.

Exhibit C-14 summarizes these costs.
January 2012 Appendix C. Sample Industrial Discharger Analyses

Draft for Internal Review Only-Do Not Quote or Cite

C-20

Exhibit C-14: Potential Incremental Costs, Rayonier Performance Fibers, LLC

Treatment Controls Capital Costs 

($ million)1

O&M Cost 

($ million/year)2

Annual Costs 

($ million/year)3

Advanced BNR $36.0 $2.5 $5.9

1. Design flow multiplied by unit cost of $1.30/gpd for advanced BNR.

2. Average flow multiplied by unit cost of $385/MG for advanced BNR and the number of operating days per year 

(365 days).

3. Capital costs annualized at 7% over 20 years plus annual O&M.
January 2012 Appendix C. Sample Industrial Discharger Analyses

Draft for Internal Review Only-Do Not Quote or Cite

C-21

Smurfit Stone, Seminole Mill 

NPDES permit number: FL0000400

Major/minor: Major

SIC code: 2611 (Pulp Mills)

Industrial Category: Pulp and Paper

Design Flow: 20 mgd

Average Flow: 7.4 mgd (average of maximum monthly values from 2006 through 2010)

Receiving Water: Saint Johns River

Description

The facility generates pulp with an onsite OCC recycling pulp operation or the purchase of bleached pulp. 

The Saint John’s River BMAP indicates that the facility changed from a pulp and paper mill to a 

recycling mill in the 1990s, reducing the volume of effluent. Wastewater treatment consists of grit 

removal, primary clarification, and aeration in two unlined holding ponds and an unlined aeration 

stabilization basin. The facility also includes an onsite landfill and sludge drying beds which process 

nonhazardous solid waste material from onsite operations and activities. The facility discharges treated 

process wastewater and sanitary wastewater to the Saint John’s River.

Summary of Effluent Data and Limits

Exhibit C-15 summarizes average monthly effluent data for TN and TP from 2006 to 2010.

Exhibit C-15: Effluent Data Summary, Smurfit Stone - Seminole Mill

Pollutant Number of 

Observations

Average Effluent 

(mg/L)1 Permit Limit (mg/L)2

Total nitrogen 31 4.8 None

Total phosphorus 14 0.41 None

Source: EPA (2011)

1. TN and TP effluent data from 2006 through 2010. Represents average of maximum monthly values.

2. Permit contains an annual load based limit for TN of 74,305 kg/year.

Incremental Controls 

The facility discharges to the Saint John’s River (Segment ID 1802) with annual geometric mean criteria 

for TN and TP of 1.09 mg/L and 0.108 mg/L, respectively. The Saint John’s River BMAP indicates that 

no additional reductions are needed for compliance with the facility’s WLA (it has already achieved twice 

as many reductions as needed for the TMDL). Thus, assuming the existing TN TMDL target is adopted as 

SSAC, there would be no incremental costs associated with TN reductions under the proposed rule. 

However, for TP the discharger may need to reduce effluent levels under the proposed rule. Due to a lack 

of site-specific facility operations and treatment data, it is uncertain whether additional improvements or 

modifications could be made to reduce TP concentrations. It is also uncertain how FDEP would permit 

the facility under the proposed rule (e.g., limits based on criteria end-of-pipe, existing loads, or factoring 

in some degree of available dilution). As such, EPA conservatively (i.e., erring on the side of higher 

costs) assumed that the discharger would need to meet effluent limits based on criteria end-of-pipe. To

meet the potential TP levels, the facility would likely need to install chemical precipitation followed by 

filtration. 

Capital and O&M unit costs could be $0.32/gpd and $238/MG, respectively. Based on a design flow of 

20 mgd, total capital costs could be approximately $6.4 million. During the last 5 years, average 
January 2012 Appendix C. Sample Industrial Discharger Analyses

Draft for Internal Review Only-Do Not Quote or Cite

C-22

maximum monthly flows have been approximately 7.4 mgd. Thus, assuming operation of the treatment 

units 365 days per year, O&M costs could be approximately $0.64 million. Total annual costs would be 

$1.3 million based on annualizing capital costs at 7% over 20 years and adding annual O&M. Exhibit 

C-16 summarizes these costs.

Exhibit C-16: Potential Incremental Costs, Smurfit Stone – Seminole Mill

Treatment Controls Capital Costs 

($ million)1

O&M Cost 

($ million/year)2

Annual Costs 

($ million/year)3

Chemical precipitation 

with filtration $6.4 $0.64 $1.3

1. Design flow multiplied by unit cost of $0.32/gpd for chemical precipitation with filtration.

2. Average flow multiplied by unit cost of $238/MG for chemical precipitation with filtration and the number of 

operating days per year (365 days).

3. Capital costs annualized at 7% over 20 years plus annual O&M.
January 2012 Appendix C. Sample Industrial Discharger Analyses

Draft for Internal Review Only-Do Not Quote or Cite

C-23

Florida Power and Light, Cutler Plant

NPDES permit number: FL0001481

Major/minor: Major

SIC code: 4911 (Electric Services)

Industrial Category: Electric Services

Design Flow: 313 mgd

Average Flow: 134.7 mgd; (average of maximum monthly values from 2006 through 

2010)

Receiving Water: Biscayne Bay

Description

The facility consists of two gas fired units (Units 5 & 6) with rated capacities 85 megawatts and 160 

megawatts, respectively. The units are normally used only during periods of peak power demand. Oncethrough condenser cooling water is withdrawn from Biscayne Bay through a common intake canal for the 

purpose of cooling the steam condensers. The facility does not add chemicals or provide treatment for the 

once-through condenser cooling water, auxiliary cooling water and intake screen wash water. Other 

wastewater streams generated at the plant including air heater wash, stack wash, dust collector wash, ash 

sluice, boiler chemical cleaning wastewater, boiler fireside wash, water treatment system wastewater, and 

boiler blowdown are treated and discharge to the evaporation/percolation pond. Treatment consists of 

solids settling, neutralization, and chemical precipitation. The facility also treats wastewater from plant 

and equipment area floor drains by oil separation prior to discharge to the evaporation/percolation pond.

The facility discharges the effluent from this system to the common cooling water discharge canal. The 

facility discharges intake screen backwash water and non-equipment area uncontaminated stormwater to 

Biscayne Bay via a discharge canal; other wastewater streams generated at the plant are treated and 

discharged to an onsite evaporation/percolation pond.

Summary of Effluent Data and Limits

There are no effluent TN and TP data available in EPA’s PCS database for this discharger.

Incremental Controls 

The facility discharges to the Northern Central Inshore (Segment ID NCI) of Biscayne Bay with TN and 

TP annual geometric mean criteria of 0.33 mg/L and 0.008 mg/L, respectively. However, there are no 

effluent data from which to assess compliance and the facility does not have existing effluent limits or 

monitoring requirements for TN or TP. Given the lack of existing permit requirements and the nature of 

the wastewater (e.g., mainly once-through cooling water), it is unlikely that the facility would have 

reasonable potential under the proposed rule. Thus, incremental compliance costs are likely zero. 
January 2012 Appendix C. Sample Industrial Discharger Analyses

Draft for Internal Review Only-Do Not Quote or Cite

C-24

Progress Energy, Bartow Power Plant

NPDES permit number: FL0000132

Major/minor: Major

SIC code: 4911 (Electric Services)

Industrial Category: Electric Services

Design Flow: Not reported

Average Flow: 524 mgd; (average of maximum monthly values from 2006 through 

2010)

Receiving Water: Old Tampa Bay

Description

This facility is a steam electric generating facility consisting of three units with a net rated capacity of 495 

MW and uses natural gas and oil for plant fuel. The plant has a once-through condenser cooling water 

system that uses water from Tampa Bay. Cooling water is intermittently chlorinated for biofouling 

control. Wastewater from the facility consists of once-through cooling water, intake screen washwater, 

metal cleaning wastes, and low volume wastes which include boiler blowdown, surface and equipment 

wash down waste, demineralizer regeneration waste, and reverse osmosis reject. The facility dischargers 

stormwater from plant areas and diked petroleum storage areas; once-through cooling water, intake screen 

washwater, and stormwater to Tampa Bay; and metal cleaning wastes and low volume wastes to ground 

water via the onsite evaporation/percolation pond system.

Summary of Effluent Data and Limits

There are no effluent TN and TP data available in EPA’s PCS database for this discharger.

Incremental Controls 

The facility discharges to Old Tampa Bay (Segment ID 0902) in the Tampa Bay estuary with annual 

geometric mean criteria for TN and TP of 0.44 mg/L and 0.172 mg/L, respectively. However, there are no 

effluent data from which to assess compliance and the facility does not have existing effluent limits or 

monitoring requirements for TN or TP. Given the lack of existing permit requirements and the nature of 

the wastewater (e.g., mainly once-through cooling water), it is unlikely that the facility would have 

reasonable potential under the proposed rule. Thus, incremental compliance costs are likely zero.
January 2012 Appendix D. Analysis of Downstream Protection Values

Draft for Internal Review Only-Do Not Quote or Cite

D-1

Appendix D. Analysis of Downstream Protection Values

As part of the proposed rule, EPA is establishing numeric nutrient criteria for specific locations that flow 

into estuary segments or coastal waters, referred to as pour points. However, EPA is not proposing 

implementation procedures associated with these pour points. In addition, FDEP has not proposed similar 

criteria under its current (2011) proposed numeric nutrient criteria rule. Thus, it is uncertain how such 

criteria would be implemented in terms of listing impaired waters, TMDL development, and requirements 

on point and nonpoint sources.

This appendix provides an analysis of whether the applicable numeric nutrient criteria are being attained 

at the pour points and the potential implications associated with nonattainment.

D.1. Estimating Attainment of Criteria for Pour Points

Using the same minimum data requirements (e.g., four data points in one year with at least one data point 

in summer and winter seasons) and attainment criteria (no more than one exceedance in a three year 

period), EPA estimated whether the numeric nutrient criteria would be attained at each pour point. 

For estuary pour points not in South Florida, EPA used data from any station within 0.5 miles of and 

within the same WBID as the pour point. Of the 402 individual estuary pour points, EPA estimated that 

criterion for at least one pollutant is being exceeded at 50 points. However, the downstream estuary 

segment for only 16 of these 50 pour points is also exceeding the proposed criteria.

For South Florida pour points, EPA used data from the WBID in which the pour point is located because 

it did not have specific location data for the points. This analysis suggests that 12 out of 23 pour points 

are potentially exceeding the criterion for at least one pollutant. Of these 12, only 4 are associated with 

marine segments that are not also exceeding the proposed criteria.

D.2. Potential Implementation Actions

EPA proposed criteria for pour points to protect the estuary and coastal waters downstream of these 

points. However, the actions that the state would take in cases where the criteria are exceeded at the pour 

point and not the downstream estuary are uncertain. For example, the state could use data from the pour 

point analysis to require additional monitoring or investigation of the downstream estuary. The state could 

also decide to include any WBID containing a pour point exceeding the criteria on its 303(d) list of 

impaired waters and develop a TMDL to prevent future degradation of the downstream water.

Scenario 1: Pour Point Exceedance Trigger Additional Monitoring

Under a scenario in which an exceedance of the criteria at a pour point results in the state requiring 

additional monitoring and studies for an estuary, incremental costs are likely minimal. Currently, FDEP

maintains a database of ambient water quality monitoring data for waters across the state, segregating 

water quality monitoring into three tiers:

 Tier 1 includes regular monitoring, using a probabilistic monitoring design to estimate water quality 

across the state on the basis of a representative subsample of waterbodies.

 Tier 2 provides more intensive monitoring of waterbodies identified as impaired or at risk; FDEP 

implements it through strategic monitoring plans (SMPs) at the state water management district level.

 Tier 3 monitoring is intensive monitoring for the development of TMDLs or the investigation of 

variances or site specific alternative criteria (SSAC).
January 2012 Appendix D. Analysis of Downstream Protection Values

Draft for Internal Review Only-Do Not Quote or Cite

D-2

Thus, based on the outcome of the pour point attainment analyses, FDEP can shift water quality 

monitoring locations and resources to areas it deems most necessary or relevant.

Scenario 2: Pour Point Exceedance Result in Impairment Listing

Under a scenario in which exceedances of criteria at the pour points results in FDEP listing the entire 

WBID in which the pour point is located as impaired, incremental costs would be based on the extent of 

existing source controls. For example, none of the estuary pour points are in WBIDs located in 

watersheds for which EPA has not already estimated control costs either under this proposed rule or as 

part of its inland numeric nutrient criteria rule. For the South Florida pour points, only one WBID is in a 

watershed for which EPA has not already estimated control costs. If incremental controls on urban, 

agriculture, and septic systems are needed in this watershed total annual costs could be approximately 

$81,000 (based on the methods for estimating costs described in the report). Exhibit D-1 summarizes 

these costs.

Exhibit D-1: Summary of Potential Incremental Costs Associated with DPVs

Source Category Units in 

Watershed Annual Unit Cost Total Potential Incremental Annual Cost ($/year)

Urban 57.7 acres $9901 $76,100

Agriculture 0 acres1 NA $0

Septic Systems 3 systems $1,3003 $4,700

Total NA NA $80,800

1. Based on capital cost of $6,800 annualized at 7% over 20 years plus O&M equal to 5% of capital.

2. Land use data for the watershed indicate that there are no agriculture acres.

3. Based on capital cost of $6,500 annualized at 7% over 20 years plus O&M equal to $650 per year.