Meeting with Florida Local Officials Re: Proposed Numeric Nutrient Criteria 

Standards

Wednesday, October 06, 2010

EPA Attendees: Sarah Hospodor-Pallone, OCIR

 Arvin Ganesan, OCIR

 Jack Bowles, OCIR

 Arnita Hannon, OCIR

 Becky Cook, OCIR

 Denis Borum, OCIR

 Ephraim King, OW

 Bob Sussman, OA

 Larry Elworth, OA

 Stephanie Owens, OPA

 Allison Wise, R4

 Jim Giattina, R4

Florida Attendees: Mayor James Tully, City of Titusville

 Raynetta Grant, Water Resources Director, City of Titusville

 Mayor Daniel Raulerson, City of Plant City

 Jeffrey Thompson, P.E., Deputy Director of Operations/Utilities, City 

 of Cocoa

 Jim Davenport (Alcalde & Fay), representing Seminole County

 Chip Merriam, Orlando Utilities Commission

 Linda ?? (Getting her full name and title)

 Edward P. de la Parte, Jr., representing various Florida communities

 Overriding concern: is the impact of numeric nutrient criteria on small 

communities

 Mayor Raulerson: Plant City has a mostly blue-collar population of 25,000. 

Smithfield Meats recently left the city, causing the city to lose $6 million in 

annual revenue through water utility fees, which they depend on for the city’s 

operating costs. The additional cost of implementing the proposed rule (EPA 

estimate) could cost each family an additional $200/year, which these families

can’t afford. The city would have to cut its police, fire, and rescue operations. The 

city hopes to attract new businesses, but fears the businesses will choose to go 

elsewhere due to the proposed higher water and other environmental standards in 

Florida. EPA needs to find a more cost-effective alternative.

 Mayor Tully: Titusville has a population of 44,000 and ecotourism is a major 

part of the city’s economy. The city has been working with the FL Department of 

Environment to develop site-specific TMDLs. The Mayor stressed the importance 

of home rule in Florida, emphasizing that there is no “one-size-fits-all” approach 

and that the desire is to solve problems at the lowest level possible, beginning 

with the State and not necessarily the federal level.

 City of Cocoa: The city has a population of 16,500, and its utility supplies water 

to the Kennedy Space Center and other federal facilities and military bases. The 
city has an unemployment rate of 16.7%, plus upcoming NASA layoffs. The 

utility supplies chloraminated water through an extensive distribution system. The 

federal facilities add additional treatments to the water, resulting in nitrogen levels 

that are higher than the proposed standard. The Federal Facilities also have to do 

an extensive amount of system flushing, since they are distant from the finished 

water treatment facilities.

 Chip Merriam, OUC: CWA and CAA (BACT, Transport, CAIR rules)

requirements are hitting small communities at the same time, resulting in very

high costs. The Commission wants an exemption for the reuse of water; reuse of 

treated wastewater is a critical part of Florida’s water conservation program along 

with protecting groundwater resources. FL DEP requires that 60% of ocean 

outfall must be reused. The Commission is also worried about the impact on 

potable water used for irrigation.

Key Issues

 Reuse: the communities need clarifications (levels of treatment, sources, 

destinations) on requirements and how existing reuse programs may fit into 

requirements of the proposed numeric nutrients rule.

 TMDLs: the officials will provide a list of the priority TMDLs impacted by the 

proposed numeric nutrient criteria.

 Potable water: EPA needs a better understanding of the communities’ concerns 

and approaches. Florida Representatives indicated that in many cased runoff of 

potable water used for irrigation would exceed the proposed phosphorous limits.

 Difference between a concentration and a load: The local officials are seeking 

clarification from EPA and want further dialogue

Follow-up

 FL officials will provide clarifications and list of priority TMDLs

 Ephraim King (OW) will work with Jim Giattina (R4) and OIR to set up followup conference calls with the Florida officials to explore the key issues above in 

more detail.