1

The Economic Analysis of the FDEP 

Proposed Numeric Nutrient Criteria in 

Florida

DEP Contract No: SP699

For: 

Florida Department of Environmental Protection

2600 Blair Stone Road, MS 3560

Tallahassee, FL 32399-2400

(850) 245-8420 (office)

(850) 412-0652 (fax)

Web Site: http://www.dep.state.fl.us/evergladesforever/

By:

Center for Economic Forecasting and Analysis

Florida State University

3200 Commonwealth Blvd.

Tallahassee, Fl. 32303

(850) 645-0191 phone

jharrington@cefa.fsu.edu

Web Site: http://www.cefa.fsu.edu

January 20, 2012

Center for Economic Forecasting and Analysis

Florida State University

3200 Commonwealth Blvd. Suite 153

Tallahassee, Florida 32306-2770
2

Authors

Dr. Julie Harrington

Director, Center for Economic Forecasting and Analysis, Florida State University, FSU 

Research Complex, 3200 Commonwealth Blvd. Tallahassee, Fl. 32303. Tel. (850) 644-7357. 

Email: jharrington@cefa.fsu.edu

Martijn Niekus

Sr. Researcher, Center for Economic Forecasting and Analysis, Florida State University, FSU 

Research Complex, 3200 Commonwealth Blvd. Tallahassee, Fl. 32303. Tel. (850) 645-0191. 

Email: mniekus@cefa.fsu.edu

Heejae Lee

Research Assistant, Center for Economic Forecasting and Analysis, Florida State University, 

FSU Research Complex, 3200 Commonwealth Blvd. Tallahassee, Fl. 32303. Tel. (850) 645-

0192. Email: hjlee@cefa.fsu.edu

Lilong Tao

Research Assistant, Center for Economic Forecasting and Analysis, Florida State University, 

FSU Research Complex, 3200 Commonwealth Blvd. Tallahassee, Fl. 32303. Email: 

ltao@cefa.fsu.edu
3

Acknowledgements

The Florida State University Office Center of Economic Forecasting and Analysis (FSU CEFA) 

would like to express its sincere thanks to the Florida Department of Environmental 

Protection for its timely provision of water resources research cost data, in a limited 

timeframe, for the purpose of this research project. FSU CEFA also acknowledges useful 

information provided by the Cardno ENTRIX. Other parties that FSU CEFA would like to thank 

include the University of Florida Institute for Food and Agricultural Science, Soil and Water 

Engineering Technology, Inc. and Stormwater Management Academy in University of Central 

Florida.
4

Executive Summary

This report represents the research conducted by the Center for Economic 

Forecasting and Analysis at the Florida State University on the economic analysis of 

Numeric Nutrient Criteria in Florida adopted by the Environmental Regulation 

Commission on December 8, 2011. The FSU CEFA analysis examined and integrated

some of the assumptions used in previous studies and developed some other 

assumptions based on more current cost data, and incorporated current changes in 

regulation rules. For example, the definition of “stream” in the amended rule 62-

302.200(36), does not include ditches, canals and other conveyances, or segments of 

conveyances, which are man-made, or predominantly channelized or physically 

altered. Therefore, the previous December 6, 2011 draft FSU CEFA cost estimate was

revised and re-calculated reflecting this amendment. The highlights of the FSU CEFA 

research analysis included the NNC cost estimation and economic analysis results. 

The research data for this study were provided by the Florida Department of 

Environmental Protection (FDEP). FDEP classified waterbodies into six categories. 

The Numeric Nutrient Criteria in Florida was applied to all six classified categories, 

however, the costs were primarily assigned to Category Three (Cat 3), those 

waterbodies that would be deemed impaired under FDEP’s Numeric Nutrient Criteria 

rule. As FDEP defined Category Five as “those waterbody WBIDs with insufficient 

information to determine if they fit in Category Three or Four,” this study included a 

proportion of Category Five (Cat 5), or those waterbodies with classification “Cat 5” 

with a high likelihood of being reclassified as Cat 3’s1

The economic analysis consisted of five sectors; Domestic Wastewater (DW) Sector, 

Industrial Wastewater (IW) Sector, Urban Stormwater Controls (SW) Sector, Septic 

System Sector, and the Agriculture Sector. These five sectors corresponded to sector 

groupings consistent with the previous studies; namely, the EPA study and Cardno 

Entrix studies. Each sector calculation is described in the following orders:

methodology, data and result for Cat 3, and data and result for Cat 5 to Cat 3.

. 

Although each sectors’ methodology varied, the domestic and industrial (DW and IW) 

sectors cost calculations were based on the affected facilities’ water capacity 

multiplied by capital and maintenance cost(s). The Urban Stormwater (SW) and 

Agriculture sector’s cost calculations were based on the proposed NNC rule number 

of “impacted acres” multiplied by the assumed capital and maintenance costs. The

 1 For the cost analysis conducted for this study, the probability to be reclassified from a CAT 5 to a CAT 

3 is estimated to be 17.54% based on the assessment data by WBID, provided by FDEP. Of the WBIDs 

for which there was sufficient data to assess them, 429 WBIDs were impaired out of a total of 2,446 

WBID’s (an 17.54% impairment rate).
5

Septic system cost calculations were based on the number of proposed NNC rule 

estimated septic systems multiplied by the corresponding upgrade and/or 

replacement capital and maintenance costs.

Table 1 provides a summary of the results of this study. The annual cost estimates 

were presented by sector, and included low, median and high projections. With 

regard to cost estimates pertaining only to the Cat 3 area, about $8.9 million would be 

the estimated annual median cost. With the inclusion of additional waterbodies to be 

reclassified from Cat 5 to Cat 3, the median costs were estimated to be a grand total of 

about $65.8 million. The research team estimated that that the minimum and 

maximum costs for implementation of the NNC rule would range from $50.5 million 

to $149.8 million per year.

Table 1 Summary of the Low, High and Median Costs for the NNC Rule in Florida 

Cat3 Low High Median Cost

DW $0 $0 $0 

IW $0 $0 $0 

SW $2,026,816 $7,972,144 $3,910,404 

Septic $733,203 $2,133,694 $892,628 

Agriculture $4,194,034 $4,194,034 $4,194,034 

Total $6,954,053 $14,299,871 $8,997,066 

Cat 5 to Cat 3

DW $1,838,810 $4,495,552 $2,394,744 

IW $3,355,215 $34,566,580 $9,886,313 

SW $14,365,292 $56,503,482 $27,715,437 

Septic $8,370,000 $24,357,528 $10,189,944 

Agriculture $15,624,333 $15,624,333 $15,624,333 

Total $43,553,651 $135,547,476 $65,810,772 

Grand Total

DW $1,838,810 $4,495,552 $2,394,744 

IW $3,355,215 $34,566,580 $9,886,313 

SW $16,392,108 $64,475,626 $31,625,841 

Septic $9,103,203 $26,491,222 $11,082,573 

Agriculture $19,818,367 $19,818,367 $19,818,367 

Grand Total $50,507,704 $149,847,347 $74,807,838 
6

Table of Contents

Authors................................................................................................................................ ii

Acknowledgements.......................................................................................................... iii

Executive Summary ......................................................................................................... iv

Table of Contents.............................................................................................................. vi

List of Tables ................................................................................................................... viii

Introduction ........................................................................................................................1

Background .........................................................................................................................5

Development of the Scope of Work ................................................................................9

Tasks...................................................................................................................................10

II. Description of the Rule...............................................................................................11

Proposed Rule Structure.................................................................................................11

General Discussion on Proposed Rule Structure.......................................................12

Additional Description of Hierarchical Approach.....................................................12

Discussion on Site Specific Alternative Criteria as NNC ...........................................13

Criteria Based on Cause-Effect Relationships ............................................................14

Waterbody Types and Cases with Insufficient Information....................................16

General Assumptions for Calculation: Amortizations ..............................................17

1. Methodology and Assumptions.................................................................................19

2. Data and Calculations for Cat 3 .................................................................................20

3. Data and Calculations for Estimating the Likelihood of Being Reclassified 

from a Cat 5 to Cat 3 (Impaired)....................................................................................21

3. FSU CEFA applied the probability of 17.54% to the costs for each Cat 5 

sector based on the individual sector cost methodologies......................................21

IV. Costs to Industrial Wastewater (IW) Treatment Plants.....................................23

1. Methodology and Assumptions.................................................................................23

3. FSU CEFA applied the probability of 17.54% to the costs for each Cat 5 

sector based on the individual sector cost methodologies......................................25

V. Costs for Urban Stormwater (SW) Controls............................................................27

1. Methodology and Assumptions.................................................................................27

2. Data and Calculations for Cat 3 .................................................................................28

3. Cost Results by Counties for Cat 3.............................................................................30

VI. Costs for Septic Systems ............................................................................................34

1. Method and Assumptions...........................................................................................34

2. Data and Calculation for Cat 3 ...................................................................................34
7

3. Total Costs Results by Counties for Cat 3 ................................................................36

1. Methodology and Assumptions.................................................................................40

2. Data and Calculations for Cat 3 .................................................................................40

3. Costs Results by Counties for Cat 3...........................................................................43

VII. Conclusions ................................................................................................................48

References .........................................................................................................................51

Appendix A –Acronyms and Abbreviations ................................................................53

Appendix B – Fact Sheet..................................................................................................55
8

List of Tables

Table 1 Summary of the Low, High and Median Costs for the NNC Rule in Florida ..v

Table 2 Standard for Impaired Lakes................................................................................6

Table 3 Standard for Impaired Streams............................................................................6

Table 4. The State of Florida Area and Population by Counties.....................................8

Table 5 Amortization Standard (for Private Sector)......................................................17

Table 6 Amortization Standard (for Public Sector)........................................................18

Table 7 DW Facilities with Multi-Category Entries Eliminated ...................................21

Table 8 DW Costs for Calculation....................................................................................21

Table 9 Cost Result for DW Sector (Cat 5 to Cat 3).......................................................22

Table 10 Cost Result for DW Sector by Counties (Cat 5 to Cat 3)................................22

Table 11 IW Facilities with Multi-Category Entries Eliminated ..................................25

Table 12 IW Costs for Calculation ...................................................................................26

Table 13 Cost Result for DW Sector (Cat 5 to Cat 3).....................................................26

Table 14 Cost Result for DW Sector by Counties (Cat 5 to Cat 3)................................26

Table 15 Years 1990 and 2005 Classification of Urban Stormwater WBID Acreage .28

Table 16 Years 1990 and 2005 Classification of Urban Stormwater WBID Acreage .28

Table 17 Capital Costs Per Acre.......................................................................................29

Table 18 Total Urban SW Costs (Cat 3) ..........................................................................29

Table 19 Urban SW Costs by Counties (Cat 3)...............................................................30

Table 20 SW Costs for Calculation ..................................................................................31

Table 21 Cost Result for SW Sector (Cat 5 to Cat 3)......................................................31

Table 22 Cost Result for SW Sector by Counties (Cat 5 to Cat 3) ................................32

Table 23 Number of Septic Tanks....................................................................................35

Table 24 The Capital Costs and O&M Costs to Upgrade (Per Tank) ..........................35

Table 25 Total Costs of Affected Septic Systems (Cat 3)................................................35

Table 26 Total Costs of Septic Systems, by Counties (Cat 3).........................................36

Table 27 Costs for Calculation..........................................................................................37

Table 28. Cost Results for Septic System Sector (Cat 5 to Cat 3)..................................37

Table 29 Cost Result for Septic System Sector by Counties (Cat 5 to Cat 3)...............38

Table 30. Affected Agricultural Acres .............................................................................40

Table 31 Affected Agricultural Acres by Classes(Cat 3)................................................41

Table 32 Capital Costs of Agriculture(Cat 3)..................................................................41

Table 33 Agricultural Total Costs Results (Cat 3)..........................................................42

Table 34 Agricultural Total Costs by Counties (Cat 3)..................................................43

Table 35 Costs for Calculation..........................................................................................44

Table 36 Cost Result for Agriculture Sector (Cat 5 to Cat 3)........................................45

Table 37 Cost Result for Agriculture Sector by Counties (Cat 5 to Cat 3) ..................46

Table 38 Summary of the Low, High and Median Costs for the NNC Rule in Florida

..............................................................................................................................................49

Table 39 Comparison Cost Results among FSU CEFA, EPA and Cardno ENTRIX (in 

Million Dollars per Year) ..................................................................................................50
1

Introduction

Since the inception of their water quality standards in the 1970s, Florida has used a 

narrative nutrient standard to guide the management and protection of its waters. 

Chapter 62-302.530, Florida Administrative Code (FAC), states that “in no case shall 

nutrient concentrations of body of water be altered so as to cause an imbalance in 

natural populations of flora or fauna.” The narrative criteria 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, 

FAC]. 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.”

FDEP has relied on this narrative for many years because nutrients are unlike any 

other “pollutant” regulated by the federal Clean Water Act (CWA). Most water quality 

criteria are based on a toxicity threshold, evidenced by a dose-response relationship, 

where higher concentrations can be demonstrated to be harmful, and acceptable 

concentrations can be established at a level below which adverse responses are 

elicited (usually in laboratory toxicity tests). In contrast, nutrients are not only 

present naturally in aquatic systems, they are absolutely necessary for the proper 

functioning of biological communities, and are sometimes moderated in their 

expression by many natural factors.

The FDEP has been actively working with EPA on the development of numeric 

nutrient criteria for several years. FDEP submitted its initial DRAFT Numeric Nutrient 

Criteria Development Plan to EPA Region IV in May 2002, and received mutual 

agreement on the Numeric Nutrient Criteria Development Plan from EPA on July 7, 

2004. The FDEP revised its plan in September 2007 to more accurately reflect its 

evolved strategy and technical approach, and FDEP received mutual agreement on 

the 2007 revisions from EPA on September 28, 2007. Florida has been guided in their 

development of numeric nutrient criteria by recommendations from a Technical 

Advisory Committee (TAC) composed of technical experts from throughout the state. 

The TAC reviewed all available technical information to ensure that the resulting 

criteria reflect the characteristics and aquatic life use of Florida’s diverse 

waterbodies.

In 2008, Earth Justice filed a lawsuit against the EPA on behalf of five environmental 

groups2

 2 Namely, the Florida Wildlife Federation, the Conservancy of Southwest Florida, the Environmental 

Confederation of Southwest Florida, St. John's Riverkeeper, and the Sierra Club

. The suit alleged that: 1) the EPA had previously determined that NNC is 

necessary as described in the Federal Clean Water Act; and that: 2) the EPA was 

obligated to promulgate numeric nutrient criteria for Florida. In January 2009, EPA 

formally determined that numeric nutrient criteria were necessary for Florida’s 

waters and subsequently entered into a consent decree with the environmental 

groups in August 2009. EPA finalized its rules for inland lakes and flowing waters on 

Nov 14, 2010. That rule faces at least eight legal and/or scientific challenges, 
2

including those from the State Attorney General, State Commissioner of Agriculture, 

and a lawsuit filed by the Florida League of Cities and the Florida Stormwater 

Association.

In the meantime, FDEP formally initiated rulemaking on numeric nutrient criteria in 

January, 2009, following receipt of EPA’s determination letter. Since then, FDEP has 

held four publically noticed TAC meetings and three additional public rulemaking 

workshops. Issues and concerns rose by stakeholders, both verbally and in writing, 

were carefully considered, and modifications in the rules reflect the input. 

EPA Numeric. On Nov 3, 2011, the EPA gave a tentative approval for a state 

alternative to its NNC rule, the FDEP NNC proposal that was adopted by the state 

Environmental Regulation Commission on December 8, 2011. The rule has 

subsequently been submitted to the Florida legislature for ratification.

Florida modified the rule in order to be tailored and as specific to, Florida, and for the

purpose of clarification or simplification of the rule language. For example, FCG EC 

and FWEA Utility Council introduced an amendment to the FDEP proposed Section 

62-302.200, F.A.C. to specifically3

 

3 From:

exclude ditches, canals and other conveyances, or 

segments of conveyances, which are man-made, or predominantly channelized or 

(36) “Stream” shall mean, for purposes of interpreting the narrative nutrient criterion in paragraph 62-

302.530(47)(b), F.A.C., a predominantly fresh surface waterbody with perennial flow in a defined 

channel with banks during typical climatic and hydrologic conditions for its region within the state. 

During periods of drought, portions of a stream channel may exhibit a dry bed, but wetted pools are 

typically still present during these conditions. Streams do not include non-perennial water segments, 

wetlands, or portions of streams that exhibit lake characteristics (e.g., long water residence time, 

increased width, or predominance of biological taxa typically found in non-flowing conditions).

To: 

(36) “Stream” shall mean, for purposes of interpreting the narrative nutrient criterion in paragraph 62-

302.530(47)(b), F.A.C., under paragraph 62-302.531(2)(c), F.A.C., a predominantly fresh surface 

waterbody with perennial flow in a defined channel with banks during typical climatic and hydrologic 

conditions for its region within the state. During periods of drought, portions of a stream channel may 

exhibit a dry bed, but wetted pools are typically still present during these conditions. Streams do not 

include:

(a) non-perennial water segments where fluctuating hydrologic conditions, including periods of 

desiccation, typically result in the dominance of wetland and/or terrestrial taxa (and corresponding 

reduction in obligate fluvial or lotic taxa), wetlands, portions of streams that exhibit lake 

characteristics (e.g., long water residence time, increased width, or predominance of biological taxa 

typically found in non-flowing conditions) or tidally influenced segments that fluctuate between 

predominantly marine and predominantly fresh waters during typical climatic and hydrologic 

conditions; or

(b) ditches, canals and other conveyances, or segments of conveyances, that are man-made, or 

predominantly channelized or physically altered and;

1. are primarily used for water management purposes, such as flood protection, stormwater 

management, irrigation, or water supply; and

2. have marginal or poor stream habitat or habitat components, such as a lack of habitat or substrate 

that is biologically limited, because the conveyance has cross sections that are predominantly 

trapezoidal, has armored banks, or is maintained primarily for water conveyance.
3

physically altered from the definition for streams. Therefore, the previous December 

6, 2011 FSU CEFA cost estimate was revised and re-calculated reflecting this new 

amendment. 

While many states have adopted some version of numeric nutrient criteria to parts of 

their water bodies4, Florida NNC rule would be the first one that is applied on a state 

wide basis. Noticeably, this new numeric nutrient criteria would likely result in 

greater regulatory costs in terms of its design, implementation, and monitoring. The 

Florida Department of Environmental Protection (FDEP) acknowledges that “the 

derivation of specific numeric nutrient criteria to complement the narrative is very 

complex”, since each waterbody can have very different and unique nutrient 

requirements”5. In October, 2011, FDEP contracted with the Florida State University 

Center for Economic Forecasting Analysis (FSU CEFA) to conduct the cost and 

economic analysis associated with implementation of FDEP’s proposed NNC rule.

Waterbodies were assessed in segments (termed Waterbody IDs or WBIDs) for the 

purpose of developing cost estimates for the implementation of the Department’s 

Numeric Nutrient Criteria Rule. WBIDs were apportioned into the following six 

categories for cost assessment purposes:

Category One – WBIDs that are impaired for nutrients or dissolved oxygen with 

nutrients as the causative parameter on Florida’s 303(d) list under categories 4a, 4b, 

4e, or 5 and for which a TMDL has been established for either nitrogen or phosphorus 

or both. For this category, the load reductions being required under these TMDLs will 

be compiled and the distribution of the data will be used to derive cost estimates.

Category Two - WBIDs that are impaired for nutrients or dissolved oxygen with 

nutrients as the causative parameter on Florida’s 303(d) list under categories 4a, 4b, 

4e, or 5 and for which a TMDL has not yet been established for either nitrogen or 

phosphorus are included. There are 720 such WBIDs based on our current 

assessment. Therefore, it will be assumed that the expected load reductions for these 

WBIDs will be similar to those in category one and the costs can be estimated using 

the distribution of those load reductions.

Category Three – WBIDs that would be deemed impaired under the Department’s 

Numeric Nutrient Criteria rule. This category will include lakes, streams, and 

estuaries which will be calculated as follows:

Lakes – Lake WBIDs will be deemed impaired if they exceed either the 

applicable annual chlorophyll a criterion, the applicable maximum annual total 

nitrogen, or total phosphorus value in the Department’s rule.

Streams – stream WBIDs will be deemed impaired if they exceed the 

applicable stream thresholds and the biology is deemed impaired under the 

Department’s rule.

 4http://water.epa.gov/scitech/swguidance/standards/criteria/nutrients/ . 5 http://www.dep.state.fl.us/water/wqssp/nutrients/faq.htm
4

Estuaries – estuarine WBIDs will be deemed impaired if they exceed the 

applicable criteria established for that estuary under the Department’s rule

Category Four – WBIDs that would be deemed unimpaired under the Department’s 

Numeric Nutrient Criteria rule. This category will also include lakes, streams, and 

estuaries which will be calculated as follows:

Lakes – Lake WBIDs will be deemed impaired if they achieve the applicable 

annual chlorophyll a criterion

Streams – stream WBIDs will be deemed unimpaired if the achieve either the 

applicable stream threshold or the biology is deemed unimpaired under the 

Department’s rule

Estuaries – estuarine WBIDs will be deemed unimpaired if the achieve the 

applicable criteria established for that estuary under the Department’s rule.

Category Five – WBIDs for which there is insufficient information to determine if they 

fit in category three or four.

Category Six – WBIDs for which there is insufficient information are placed on the

study list.
5

Background

The Florida Department of Environmental Protection (FDEP), recognizing the role of 

site-specific factors that affect numeric responses, proposes to base new standards on 

establishing a systematic numeric interpretation of the existing narrative criteria.

As was also the case for the Environmental Protection Agency’s rule at 40 CFR 

131.43(e) [Federal Register, Volume 75, Number 233, Page 75762], this concept is 

intended to implement Rule 62-302.530 (47) (b), FAC, which 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 aquatic flora or fauna.” 

1. What is the standard for impaired water?

In a nutshell, an impaired waterbody is one that does not meet water quality

standards. These standards can be either numeric or narrative. The most current 

version of FDEP’s numeric interpretation of the above mentioned narrative standard 

states: 

For lakes, the applicable numeric interpretations of the narrative nutrient criterion 

in paragraph 62-302.530(47) (b), F.A.C., for chlorophyll a are shown in the table 

below. The applicable interpretations for TN and TP will vary on an annual basis, 

depending on the availability of chlorophyll a data and the concentrations of 

nutrients and chlorophyll a in the lake as described below. The applicable numeric 

interpretations for TN, TP, and chlorophyll a shall not be exceeded more than once in 

any consecutive three year period.

a. If there is sufficient data to calculate the annual geometric mean 

chlorophyll a and the mean does not exceed the chlorophyll a value for the 

lake type in the table below, then the TN and TP numeric interpretations 

for that calendar year shall be the annual geometric means of lake TN and 

TP samples, subject to the minimum and maximum limits in the table 

below. However, for lakes with color > 40 PCU in the West Central 

Nutrient Watershed Region, the maximum TP limit shall be the 0.49 mg/L 

TP streams threshold for the region; or 

b. If there are insufficient data to calculate the annual geometric mean 

chlorophyll a for a given year or the annual geometric mean chlorophyll a 

exceeds the values in the table below for the lake type, then the applicable 

numeric interpretations for TN and TP shall be the minimum values in the 

table below.
6

Table 2 Standard for Impaired Lakes

Long Term 

Geometric 

Mean Lake 

Color and 

Alkalinity

Annual 

Geometric 

Mean 

Chlorophyll a

Minimum calculated 

numeric interpretation

Maximum calculated 

numeric interpretation

Annual 

Geometric 

Mean Total

Phosphorus

Annual 

Geometric 

Mean Total

Nitrogen

Annual 

Geometric 

Mean Total

Phosphorus

Annual 

Geometric 

Mean Total

Nitrogen

> 40 Platinum 

Cobalt Units 20 μg/L 0.05 mg/L 1.27 mg/L 0.16 mg/L1 2.23 mg/L

≤ 40 Platinum 

Cobalt Units 

and > 20 mg/L 

CaCO3

20 μg/L 0.03 mg/L 1.05 mg/L 0.09 mg/L1 1.91 mg/L

≤ 40 Platinum 

Cobalt Units 

and ≤ 20 mg/L 

CaCO3

6 μg/L 0.01 mg/L 0.51 mg/L 0.03 mg/L1 0.93 mg/L

1 For lakes with color > 40 PCU in the West Central Nutrient Watershed Region, the 

maximum TP limit shall be the 0.49 mg/L TP streams threshold for the region.

For streams, if a site specific interpretation pursuant to paragraph 62-302.531(2) (a) 

or (2) (b), F.A.C., has not been established, biological information shall be used to 

interpret the narrative nutrient criterion in combination with nutrient thresholds. 

The narrative nutrient criterion in paragraph 62-302.530(47)(b), F.A.C., shall be 

interpreted as being achieved in a stream segment where information on chlorophyll 

a levels, algal mats or blooms, nuisance macrophyte growth, and changes in algal

species composition indicates there are no imbalances in flora or fauna, and either: 

1. The average score of at least two temporally independent SCIs performed at 

representative locations and times is 40 or higher, with neither of the two most 

recent SCI scores less than 35, or 

2. The nutrient thresholds set forth in the table below are achieved.

Table 3 Standard for Impaired Streams

Nutrient 

Watershed Region

Total Phosphorus Nutrient 

Threshold1

Total Nitrogen Nutrient 

Threshold1

Panhandle West 0.06 mg/L 0.67 mg/L

Panhandle East 0.18 mg/L 1.03 mg/L

North Central 0.30 mg/L 1.87 mg/L

Peninsular 0.12 mg/L 1.54 mg/L

West Central 0.49 mg/L 1.65 mg/L

South Florida

No numeric nutrient 

threshold. The narrative 

criterion in paragraph 62-

302.530(47) (b), F.A.C., 

applies.

No numeric nutrient 

threshold. The narrative 

criterion in paragraph 62-

302.530(47) (b), F.A.C., 

applies.
7

For spring vents, the applicable numeric interpretation of the narrative nutrient 

criterion is 0.35 mg/L of nitrate-nitrite (NO3 + NO2) as an annual geometric mean, 

not to be exceeded more than once in any three calendar year period.

For Estuary, (1) Estuary-specific numeric interpretations of the narrative nutrient 

criterion in paragraph 62-302.530(47)(b), F.A.C., are in the table in Page 9- 11, NPR 

62-302 11-1-11 FINAL. The concentration-based estuary interpretations are open 

water, area-wide averages. The interpretations expressed as load per million cubic 

meters of freshwater inflow are the total load of that nutrient to the estuary divided 

by the total volume of freshwater inflow to that estuary.

(2) Estuarine and marine areas are delineated in the map of the Florida Marine 

Nutrient Regions that may be obtained from the Department’s internet site at 

http://www.dep.state.fl.us/water/wqssp/swq-docs or by writing to the Florida 

Department of Environmental Protection, Standards and Assessment Section, 2600 

Blair Stone Road, MS 6511, Tallahassee, FL 32399-2400.

(3) The Department shall establish by rule or final order an estuary specific 

numeric interpretation of the narrative nutrient criteria for TN and TP for Perdido 

Bay, Pensacola Bay (including Escambia Bay), St. Andrews Bay, Choctawhatchee Bay, 

and Apalachicola Bay by June 30, 2013, subject to the provisions of Chapter 120, F.S. 

The Department shall establish by rule or final order the estuary specific numeric 

interpretation of the narrative nutrient criteria for TN and TP for the remaining 

estuaries by June 30, 2015, subject to the provisions of Chapter 120, F.S. This 

subsection shall not be implemented until Rule 62-302.531, F.A.C., is approved in its 

entirety pursuant to 40 C.F.R. § 131.21 and 33 U.S.C. § 1313(c). If any provision of 

Rule 62-302.531, F.A.C., is later determined invalid, then this subsection shall not be 

implemented.

2. Current status in Florida

Table 3 provides a summary of recent state of Florida area and population by 

counties in 2010. Florida consists of 67 counties which contains 31 small counties6. 

 6 According to 210.52(19), FS, small county is defined as population of county is below 75,000. Folloiwng 

counties in Florida are small counties; Baker, Bradford, Calhoun, Columbia, Desoto, Dixie, Franklin, 

Gadsden, Gilchrist, Glades, Gulf, Hamilton, Hardee, Hendry, Holmes, Jackson, Jefferson, Lafayette, Levy, 

Liberty, Madison, Monroe, Nassau, Okeechobee, Putnam, Suwannee, Taylor, Union, Wakulla, Walton, 

Washington
8

Table 4 The State of Florida Area and Population by Counties

County Area Population (2010) County Area Population,(2010)

Alachua 969.2 217,955 Lake 1,156.5 210,528

Baker 589 22,259 Lee 1,212 440,888

Bay 1,033.3 148,217 Leon 701.8 239,452

Bradford 300.1 26,088 Levy 1,412.4 34,450

Brevard 1,557.3 476,230 Liberty 843.2 7,021

Broward 1,319.8 1,623,018 Madison 715.9 18,733

Calhoun 574.4 13,017 Manatee 892.8 264,002

Charlotte 859.3 141,627 Marion 1,663.1 258,916

Citrus 773.5 118,085 Martin 752.9 126,731

Clay 643.7 140,814 Miami-Dade 2,429.6 2,253,362

Collier 2,305.1 251,377 Monroe 3,737.5 79,589

Columbia 801.2 56,513 Nassau 725.9 57,663

DeSoto 639.5 32,209 Okaloosa 1,082.1 170,498

Dixie 863.8 13,827 Okeechobee 892 35,910

Duval 918.3 778,879 Orange 1,004.3 896,344

Escambia 893.9 294,410 Osceola 1,506.5 172,493

Flagler 570.8 49,832 Palm Beach 2,386.5 1,131,184

Franklin 1,026.5 11,057 Pasco 868 344,765

Gadsden 528.6 45,087 Pinellas 535.8 921,482

Gilchrist 355.5 14,437 Polk 2,010.2 483,924

Glades 986.2 10,576 Putnam 827.3 70,423

Gulf 755.8 13,332 Santa Rosa 1,155.3 123,135

Hamilton 519.4 13,327 Sarasota 725.3 192,695

Hardee 638.4 26,938 Seminole 344.9 117,743

Hendry 1,189.9 36,210 St. Johns 821.4 325,957

Hernando 589.1 130,802 St. Lucie 688.1 365,196

Highlands 1,106.4 87,366 Sumter 580.4 53,345

Hillsborough 1,266.3 998,948 Suwannee 692 34,844

Holmes 488.8 18,564 Taylor 1,232.1 19,256

Indian River 617 112,947 Union 249.7 13,442

Jackson 954.7 46,755 Volusia 1,432.5 443,343

Jefferson 636.7 12,902 Wakulla 735.8 22,863

Lafayette 547.9 7,022 Walton 1,238.2 40,601

Washington 615.9 20,973

Source: US Census Bureau 2010, and State Library of Florida
9

Development of the Scope of Work 

In order to fully assess the scope of work involved with the FDEP draft rule and 

economic and cost analyses, four documents were provided as background 

informational materials. The documents included “FDEP Review of the EPA’s 

Preliminary Estimate of Potential Compliance Costs and Benefits Associated with 

EPA’s Proposed Numeric Nutrient Criteria for Florida”, draft Chapter(s) 62-302 and 

62-303, “EPA’s Economic Analysis of Final Water Quality Standards for Nutrients for 

Lakes and Flowing Waters in Florida”, and “Economic Analysis of the Proposed 

Federal Numeric Nutrient Criteria for Florida” by Cardno ENTRIX. 

The documents provided two cost estimates for the proposed rule from the EPA and 

Cardno ENTRIX. In summary, the cost estimates of the Cardno ENTRIX study are far 

greater than the EPA estimates. Depending on the level of enforcement by the EPA, 

the Cardno ENTRIX cost estimates range from $3.4 to $4.7 billion for the “end of pipe” 

criteria, and for the less strict “Best Management Practices” (BMP’s) and “Limit of 

Technology” (LOT), the costs could range from $298 - $533 million. These ranges 

were within a 95% confidence interval that represented operating, maintenance, and 

capital costs annualized over a 20-year period. 
10

Tasks

The tasks associated with the following project are outlined below.

FDEP Rule Analysis

• Literature Review

• Data collection 

o CEFA will base the initial cost estimates on the Cardno ENTRIX most 

recent/updated cost analyses (by county). If it’s determined additional 

cost data is needed to perform the FDEP draft rule analysis (per 

county), CEFA proposes to work with FDEP staff, and other data 

sources in order to obtain pertinent cost data.

o Data validation/cleaning if needed. 

o Conduct data and statistical analyses.

• Draft Chapter/Report on FDEP Rule Analysis Cost Estimation

• Draft report of Economic analyses

• Final report

FSU CEFA will provide the final report to the FDEP no later than 5:00 p.m. on March 

15, 2012, and supply any needed clarifications or revisions by March 31, 2012.
11

II. Description of the Rule

Proposed Rule Structure 

The narrative nutrient criteria would continue to apply to all bodies of water, and 

numeric interpretations would be applied based on the scientific information 

available. The narrative would be implemented using a systematic structure that 

numerically interprets the narrative nutrient criteria for each body of water in the 

following hierarchical manner: 

1. Established site specific numeric interpretations of the narrative criteria 

(including TMDLs, SSACs, and other interpretations embodied in an official 

Department action) would be the primary interpretation of the narrative 

nutrient criteria. 

2. If “1” (above) is not available for a body of water, the interpretation of the 

narrative criteria for a specific one would be based on established, quantifiable 

nutrient cause and effect relationships where the nutrient concentrations 

responsible for causing an imbalance of natural populations of aquatic flora or 

fauna is understood (currently, this is limited to fresh water springs and 

lakes). 

3. If “1” and “2” (above) are not available, a combination of reference-based 

nutrient thresholds and biological information will be used (currently, this is 

limited to fresh flowing bodies of water excluding largely intermittent 

streams): 

a. Waters achieving the nutrient thresholds that are also biological healthy 

(e.g., using SCI and measures of floral health) are deemed to meet the narrative 

criteria. 

b. Waters that exceed the nutrient thresholds but also reflect balanced flora 

and fauna (e.g., using SCI and measures of floral health) are deemed to meet 

the narrative nutrient criteria. 

c. Waters that meet the nutrient thresholds, but are not biologically healthy 

are deemed to not attain Aquatic Life Use Support goals. FDEP would target 

these waters for a stressor identification study to determine the causative 

factor(s).

These waters are initially deemed to attain the narrative nutrient criteria 

unless the stressor identification study links the adverse biological effects to 

nutrients. 

d. Waters that exceed the nutrient thresholds that are not biologically healthy 

would be deemed to not attain the narrative nutrient criteria unless a stressor 

identification study determines that nutrients are not the causative pollutant. 

For “c” and “d”, if nutrients are identified as a causative pollutant, the Department will 

develop a TMDL or SSAC, at which point the numeric interpretation would default to 

the provisions of “1” after Department action. During these studies, confounding 

factors (those other than nutrient effects) will be considered. 
12

General Discussion on Proposed Rule Structure 

• Attainment of the narrative criterion is assessed as a spatial average for the body of 

water. If interpreted based on a TMDL or SSAC, the spatial component is as defined in 

the TMDL or SSAC document. If based on a generally applicable dose-response 

relationship, it will be as stated in a manner consistent with the derivation of the 

criterion. For reference-based thresholds, the spatial extent will be determined by 

site-specific considerations, such as relative system homogeneity, system 

classification, biological expectations, or empirically measured responses. Waterbody

segments or aggregations of segments from a waterbody may be appropriate in 

many, but not all cases. 

• If there are both a TMDL and a SSAC for a given waterbody, the most recently 

adopted TMDL or SSAC would take precedence. 

• Protection of downstream waters will be provided using a narrative, rather than 

“downstream protection values”. In no case shall the loading of nitrogen or 

phosphorus from a Class I or III fresh water stream or lake cause or contribute to an 

exceedance of water quality standards in a downstream waterbody. Upstream actions 

taken by the Department would consider downstream standards pursuant to this

narrative. 

Additional Description of Hierarchical Approach 

Discussion on TMDLs as NNC 

• Only State adopted nutrient related TMDLs would be eligible as site-specific 

interpretations of the narrative nutrient criteria. 

• To be eligible, the nutrient TMDLs should be based upon prevention of imbalances 

of flora or fauna [Rule 62-302.530 (47) (b), FAC], but TMDLs for dissolved oxygen 

(DO) (Rule 62-302.530 (47) (a), FAC) would also be eligible if nutrients were 

identified as a causative pollutant and the TMDL demonstrated that it would also 

prevent an imbalance of natural populations of flora and fauna. As an example, 

surplus anthropogenic nutrients could be shown to generate excess plant biomass 

(periphyton, phytoplankton, or vascular plants), which could by themselves 

constitute an imbalance in flora or result in habitat smothering (e.g., excess 

periphyton accumulation), food web alteration (e.g., dominance of taxa that thrive in 

nutrient enriched conditions), or low DO (from decomposition or respiration of 

excess plant biomass), etc., that results in imbalances in fauna, as reflected by failing 

SCI scores or other meaningful biological endpoint (e.g., sea grass and transparency, 

etc.). If the TMDL is written to prevent this cycle and then achieve DO, it could be 

eligible as the numeric interpretation of Rule 62-302.530 (47) (b), FAC. 

• Many TMDLs are expressed as loads instead of concentrations, but the loads do not 

have to be translated into concentrations to be deemed the numeric interpretation of 

the narrative nutrient criteria. 
13

• TMDLs may be modified based on new data, new science, or different targeted 

endpoints (such as DO). When TMDLs are modified and readopted, they become the 

new interpretation of the narrative. 

• Future TMDL rules may include a response target (chlorophyll a, for example) 

designed to implement the narrative nutrient criterion. Scientific information relating 

to the response target and the bases for existing TMDLs is presented in the TMDL 

reports, and this information can be used to establish a site-specific listing threshold 

for nutrient impairment pursuant to Rule 62-303.450, F.A.C. 

• TMDLs may be written to achieve numeric nutrient values established in Chapter 

62-303 (lakes or springs), or alternatively, be written to achieve conditions necessary 

to protect specific thresholds used for the TMDL would become the numeric 

interpretation of the narrative pursuant to “1” of the hierarchy. 

Discussion on Site Specific Alternative Criteria as NNC 

• The current restriction on establishing a SSAC for nutrients pursuant to Rule 62-

303.800(2), F.A.C., would be eliminated. 

• A structure to allow a predictable approach to developing nutrient SSACs (such as 

the previously proposed Type III SSAC) would be included as part of the rulemaking. 

The rule language will provide clear expectations on the water quality and biological 

data needed to characterize existing nutrient concentrations and aquatic health, but 

the specific number of stations required for assessment will be determined on a site 

specific basis. 

• Since numeric nutrient criteria are intended to protect healthy, well-balanced 

natural populations of flora and fauna, and if the biology is found to be healthy, then 

the existing nutrient concentrations are deemed protective. The nutrient SSAC will 

need to address the natural variability in nutrient concentrations. Any SSAC must 

demonstrate that the designated use is being protected. 

• As part of Type III SSAC development, aquatic life use support must be 

demonstrated. Waterbodies where the average of two temporally independent 

Stream Condition Index (SCI) results is greater than 40 and that do not exhibit excess 

algal growth or nuisance aquatic plants are biologically healthy. 

• FDEP will consider phytoplankton, periphyton, and vascular plant community 

responses as additional evidence to demonstrate systems are meeting their 

designated use. Impaired Waters Rule- chlorophyll a metrics may also be used for this 

demonstration. 
14

Criteria Based on Cause-Effect Relationships 

Scope of Approach 

For springs and lakes, quantifiable nutrient cause and effect relationships provide the 

basis for the numeric interpretation of the narrative nutrient criteria: 

Springs: Nitrate criterion of 0.35 mg/L as an annual average. 

Lakes: Use the existing chlorophyll/nutrient regression equations, acknowledging the 

uncertainty in the equations by allowing for “modified” criteria when chlorophyll 

targets are achieved. 

Discussion of Numeric Interpretations Based on Cause and Effect 

• The scientific bases for the spring and lake criteria have been previously presented 

in FDEP 2009 document, “Development of Numeric Nutrient Criteria for Florida 

Lakes and Streams”. In highly colored lakes (long term average >140 PCU) where 

there is no longer a cause and effect relationship, the narrative nutrient criteria 

should continue to apply. 

• FDEP is re-examining regionalization and morphoedapthic factors (color, alkalinity) 

to establish more appropriate lake criteria for some situations. 

• Paleoliminological evidence may provide the basis for alternate natural chlorophyll 

targets in many Florida lakes, which could allow adjustment in the acceptable TP and 

TN using the regression equations. 

Flowing Waters (Streams) 

The FCG EC and FWEA Utility Council suggested a more specific and clear definition 

of the rule amendment regarding streams. 

According to the amended Rule 62-302.200, F.A.C. (36), “Stream” shall mean, for 

purposes of interpreting the narrative nutrient criterion in paragraph 62-

302.530(47)(b), F.A.C., under paragraph 62-302.531(2)(c), F.A.C., a predominantly 

fresh surface waterbody with perennial flow in a defined channel with banks during 

typical climatic and hydrologic conditions for its region within the state. During 

periods of drought, portions of a stream channel may exhibit a dry bed, but wetted

pools are typically still present during these conditions. Streams do not include:

(a) non-perennial water segments where fluctuating hydrologic conditions, including 

periods of desiccation, typically result in the dominance of wetland and/or terrestrial 

taxa (and corresponding reduction in obligate fluvial or lotic taxa), wetlands, portions 

of streams that exhibit lake characteristics (e.g., long water residence time, increased 

width, or predominance of biological taxa typically found in non-flowing conditions) 

or tidally influenced segments that fluctuate between predominantly marine and 

predominantly fresh waters during typical climatic and hydrologic conditions; or

(b) ditches, canals and other conveyances, or segments of conveyances, that are manmade, or predominantly channelized or physically altered and;

1. are primarily used for water management purposes, such as flood protection,

stormwater management, irrigation, or water supply; and
15

2. have marginal or poor stream habitat or habitat components, such as a lack of

habitat or substrate that is biologically limited, because the conveyance has cross 

sections that are predominantly trapezoidal, has armored banks, or is maintained 

primarily for water conveyance.

Discussion of NNC Process for Streams 

• FDEP plans to use referenced-based stream nutrient values, such as the EPA’s 

promulgated criteria, as thresholds during the process for numerically interpreting 

the narrative criteria described in this document. 

• Note that the reference-based nutrient values were derived as waterbody geometric 

means. Spatial application of these values to streams is determined by site-specific 

considerations, such as relative system homogeneity, system classification, biological 

expectations, or empirically measured responses. WBIDs or aggregations of WBIDs 

may be appropriate in many, but not all cases. 

• Reference based nutrient values were derived in perennial streams, generally. 

Application of these values to intermittent streams is not appropriate given their 

derivation and expression. 

• Following amended rule 62-302.200, F.A.C., streams do not include ditches, canals 

and other conveyances, or segments of conveyances, which are man-made, or 

predominantly channelized or physically altered. 
16

Waterbody Types and Cases with Insufficient Information 

In aquatic systems where insufficient information currently exists to accurately 

interpret the narrative nutrient criteria, such as Class III wetlands, Class III flowing 

waters in South Florida, and Class III intermittent streams, the narrative will continue 

to apply, and the Department will numerically interpret the narrative criteria as the 

information is developed. 

Implementation Considerations 

Permitting 

• Nutrient effluent limits for facilities discharging to surface waters will be developed 

through the Water Quality-Based Effluent Limitations (WQBEL) process pursuant to 

Chapter 62-650, F.A.C. Nutrient WQBELs developed to date were developed to attain 

the narrative nutrient criteria, and these WQBELs will remain in effect unless a more 

recent waste load allocation (WLA) is developed for the facility, the WQBEL is revised 

pursuant to the WQBEL rule, or the WQBEL is superseded by an agency action. For 

new or revised WQBELs, the WQBEL process will determine the approach that best 

interprets the narrative nutrient criteria as outlined in the hierarchical structure. The 

site specific analysis performed as part of the WQBEL process can be written to 

achieve “1”, “2” or “3” of the structure, depending on the available information or 

result in a new interpretation of the narrative that could be considered a Department 

action relevant to “1”. 

Assessment 

• FDEP will revise the IWR to be consistent with the revisions to Chapter 62-302, 

F.A.C., including provisions to directly implement the NNC for lakes and springs and 

to directly assess TMDLs. 

• For waters with nutrient TMDLs expressed as a load, attainment of the allowable 

loads will be evaluated as part of the BMAP reporting process, and nonattainment will 

be assumed until information is provided to prove attainment (a combination of 

model estimated loads of nonpoint sources and measured loads from point sources). 

Waters should only be deemed to be in attainment if they meet the loads (or 

concentrations) and targets (e.g., chlorophyll) and a demonstration that nutrients are 

no longer causing biological imbalances. If the waterbody attains the allowable 

loading but there is site-specific information indicating an imbalance in flora or fauna, 

the TMDL would be revisited and revised as needed. 

• As part of these revisions, the Department is contemplating the creation of the study 

list (in addition to the planning list and verified list) for waters that do not attain 

water quality standards based on the evidence, but appropriate actions have yet to be 

identified to rectify the situation. This is common for dissolved oxygen 

nonattainment, biological nonattainment, and is anticipated for nutrient criteria 

nonattainment. For example, waters that exceed reference-based nutrient thresholds 

will be placed on a “study list” unless there are bio-assessment data indicating the 

stream is healthy. Waters on the study list will receive a site-specific physical, 

chemical, and biological investigation to determine if aquatic life use support goals 
17

are attained (if there were no bio-assessment data available), and if aquatic life use 

support is not attained, to then determine the causative pollutant(s). This process 

constitutes a “stressor identification” study. If the stream is determined to be 

impaired due to nutrients (at least in part), the water will be listed on the verified list 

for TMDL development, which will determine the reductions needed. This approach 

places waters on the study list if there is a nonattainment condition based on the 

current numeric interpretation of the narrative criteria outlined above, and also

places waters on the IWR verified list for nutrients if they need a reduction in 

nutrient loading to attain the narrative nutrient criteria or otherwise restore the 

waterbody’s designated use. 

General Assumptions for Calculation: Amortizations

1. Amortization

Previous studies use various amortization methodologies. FSU CEFA included two 

separate amortization methodologies, with regard to private and public sectors as 

because the timeframe and the rate of time preference are different between private 

and public sectors. Basically, for the Industrial Wastewater, Septic System, and 

Agriculture Sector FSU CEFA used private sector amortization. For the Domestic 

Wastewater and Stormwater sectors, FSU CEFA used public sector amortization. 

1) Private sectors

CEFA calculated the amortization year and rate for private sectors based on the board 

of governors of Federal Reserve System data7. For example, CEFA will use 20 years 

and 6.40 %. 

Table 5 Amortization Standard (for Private Sector)

Period 10 year 15 year 20 year 25 year 30 year

Interest rate 6.10% 6.25% 6.40% 6.55% 6.70%

Source: HSHAssociates.com, adjusted by CEFA staff.

 7 Sources 

- Date, 15-Year FRM, 30-Year FRM, 1-Year ARM retrieved from 

http://www.federalreserve.gov/releases/h15/data/Annual/H15_TCMNOM_Y10.txt

- Instrument,"U.S. government securities/Treasury constant maturities/Nominal"

- Maturity,"10-year"

- Frequency,"Annual"

- Description,"Market yield on U.S. Treasury securities at 10-year constant maturity, quoted on 

investment basis"

- Note,"Yields on actively traded non-inflation-indexed issues adjusted to constant maturities. The 30-

year Treasury constant maturity series was discontinued on February 18, 2002, and reintroduced on 

February 9, 2006. From February 18, 2002, to February 9, 2006, the U.S. Treasury published a 

factor for adjusting the daily nominal 20-year constant maturity in order to estimate a 30-year 

nominal rate. The historical adjustment factor can be found at www.treasury.gov/resourcecenter/data-chart-center/interest-rates/. Source: U.S. Treasury."
18

2) Public sectors

FSU CEFA calculated the amortization methodology for public sectors based on: the

Florida municipal bond rates (on water, sewerage and power sector).8 FSU CEFA staff 

used 10 years and 15 year moving averages of the bond rates projected 20 and 30 

years from Year 2011. For example, for 20 years, FSU CEFA used 4.90%. 

Table 6 Amortization Standard (for Public Sector)

Period 20 year 30 year

Interest rate 4.90% 4.70%

Source: Florida municipal bond rates, adjusted by FSU CEFA staff.

2. Classification Categories for Analysis

As previously mentioned, FDEP classified Florida’s waterbodies into six categories. 

Within the six categories, the primary category of NNC Rule costs was Category Three; 

Cat 3. In addition, Category Five was: “WBIDs for which there is insufficient 

information to determine if they fit in Category three or four”; the economic analysis 

also focused on the costs associated with the probability, or likelihood, of the Cat 5’s 

being reclassified in the near future, to Cat 3’s. Similar to previous studies, the 

economic analysis consisted of five sectors: the Domestic Wastewater (DW),

Industrial Wastewater (IW), Urban Stormwater (SW), Septic System, and Agriculture 

Sectors. The following report framework was applied to the description of each sector: 

the Cat 3 and (Cat 5 to Cat 3) economic analysis data and methodology, and 

associated results.

 8 Sources from http://florida.municipalbonds.com/bonds/search/wtr%20swr%20pwr/s_type:desc/category:1/
19

III. Costs to Domestic Wastewater (DW) Treatment Plants

1. Methodology and Assumptions

(1) Domestic wastewater facilities with NPDES permits discharging to surface 

waters were included in the estimate. The list of domestic wastewater 

facilities for which costs were estimated was provided by FDEP staff.

(2) Costs for facilities discharging to a WBID, which is currently impaired and for 

which there currently exists (Cat 1) or will in the future (Cat 2) be a TMDL,

were attributable to the current rule. Costs for facilities discharging to a WBID,

which will become impaired (Cat 3) under the FDEP Numeric Nutrient Criteria,

were attributed to the new rule. 

(3) No costs were calculated for facilities discharging to a wetland or to a stream 

in the South Nutrient Watershed Region. No costs were calculated for facilities 

discharging to an estuary for which criteria are not proposed in the 

Department’s rule. In addition, no costs were calculated for facilities 

discharging to an estuary for which criteria are proposed since those criteria 

are being established to maintain existing nutrient conditions in those 

estuaries; therefore, it is not believed that further nutrient reductions are 

required.

(4) For intermittent discharges for Mechanical Integrity Testing9, discharges 

under Florida’s Apricot Act10 (Section Section 403.086(7), Florida Statutes 

(F.S.), intermittent discharges from golf course ponds11, and for intermittent 

wet weather discharges from reuse facilities under certain conditions12

 9 Mechanical Integrity Testing discharges are for facilities using deep well injection. Such facilities 

require a Mechanical Integrity Test once every five years. Since the testing is for a very brief duration 

once every five years and is required to be conducted under circumstances where the nutrients won’t 

harm the receiving water, it was not deemed practical or necessary to require additional treatment.

, it was 

10 The Florida Apricot Act of 1994 states that backup discharges for reuse facilities that are at AWT and 

provide high-level disinfection may discharge up to less than 30% of their permitted capacity annually. 

Since these discharges are statutorily authorized, it was not deemed necessary to require additional 

treatment.

11 Reclaimed water is often stored in golf course ponds (or other lakes ponds or lakes) which are not 

waters of the State. Reclaimed water is only discharged to such ponds when the lake level is below the 

level needed to ensure adequate stormwater storage and treatment volume requirements. As a result, 

discharges from such ponds to water of the State are intermittent and consist primarily of stormwater 

in response to storm events. Since such discharges are intermittent and only occur during times when 

there is significant dilution available in the ponds and receiving waters it was not deemed necessary to 

require additional treatment for such discharges.

12Review of data for intermittent wet weather discharges from reuse facilities indicates that many of 

those facilities generally discharge less than 15% of their total volumes. Since such discharges occur 

only intermittently, involve relatively small volumes of effluent, and occur when there is significant 

dilution available in the receiving waters, it was not deemed necessary to require additional treatment 

for such discharges.
20

assumed that no further improvements would be necessary in their level of 

treatment unless an increase in their discharge was being requested. 

Therefore, no cost was assumed for such discharges. 

(5) For facilities with multiple discharge locations, costs were calculated based on 

the permitted facility flow and the primary discharge location.

(6) For facilities already at or better than advanced wastewater treatment (AWT), 

no further treatment was assumed to be necessary to provide reasonable 

assurance for permitting discharge to surface waters. AWT is defined by 

Section 403.086, Florida Statutes, as containing not more, on a permitted 

annual average basis, than CBOD5 of 5mg/L, suspended solids of 5mg/L, total 

nitrogen of 3 mg/L, total phosphorus of 1 mg/L and has received high level 

disinfection. Therefore, no cost was assumed for such discharges. 

(7) Unit capital costs to upgrade were based on “AWT-upgrades cost data” from 

FDEP: The data was made more consistent since some had lacked an 

“engineering cost” component. The relative engineering cost part was 

assumed to be 25%. The unit capital costs were calculated relative to the MGD 

capacities of the various facilities. The range of the unit capital cost data 

(n=19) was subjected to a distribution analyses using @RISK software, and a 

fit was established with a Lognormal distribution. Given the distribution, a 

lower tail at 10% was established at $0.90, the medium at $3.30, and the upper 

90% tail at $12.36.

(8) The unit Operation & Maintenance costs were estimated to be $0.56 per gallon 

per year based on Cardno ENTRIX cost data.

(9) The amortization was for 20 years at a 4.9% interest rate, as described in the 

general assumptions.

2. Data and Calculations for Cat 3

1) Affected Facilities and Capacities

Costs for facilities discharging to a WBID that will become impaired (Cat 3 and a 

proportion of Cat 5) under the FDEP Numeric Nutrient Criteria were attributed to the 

new rule. FDEP provided a domestic wastewater dataset which contained 

information concerning a total of 341 outfalls on 203 facilities in Florida. After 

assigning the 341 outfalls to the six categories and eliminating facilities for which no 

costs would be anticipated as described in the Methods and Assumptions section, 

there were zero facilities associated with only category 3 costs.
21

Table 7 DW Facilities with Multi-Category Entries Eliminated

Total 

Outfalls in 

Facilities

Outfalls with 

Categorized Cat 1 Cat 2 Cat 3 Cat 4 Cat 5 Cat 6 MGD in Cat 3

341 58 16 14 0 19 8 1 0

3. Data and Calculations for Estimating the Likelihood of Being 

Reclassified from a Cat 5 to Cat 3 (Impaired)

Baseline Assumptions

1. Using a data assessment performed by FDEP, facilities in Cat 5 will be 

reclassified by FDEP as a Cat 3 or Cat 4

2. The probability to be reclassified from a Cat 5 to a Cat 3 is estimated to be 

17.54% based on the assessment data by WBID, provided by FDEP. Of the 

WBIDs for which there was sufficient data to assess them 429 WBIDs were 

impaired out of a total of 2446 WBID (17.54% impairment rate).

3. FSU CEFA applied the probability of 17.54% to the costs for each Cat 5 

sector based on the individual sector cost methodologies. 

DW Cat 5 to Cat 3 Cost Calculations

1. Cat 5 Data

After removing facilities for which no costs would be incurred (consistent 

with the Methods and Assumptions), there are five facilities which would 

incur costs in Cat 5.

The facility capacity total for the 5 facilities is 16.605 MGD.

By applying the probabilities of 17.54% to the facility’s total capacity, a 

facility capacity of 2.91 will be obtained.

2. DW Cost Data 

Table 8 DW Costs for Calculation

Capital Cost O&M Cost

Minimum : $0.90/ gallon 

Median: $3.30 /gallon

Maximum: $12.36 /gallon

$ 0.56/ gallon/year

3. The Capital Cost and O&M cost are multiplied by the (facility capacity * 

MGD). Amortization is 4.9% for 20 years.
22

4. Cost Results 

Table 9 Cost Result for DW Sector (Cat 5 to Cat 3)

Capital Cost Annual Cost O&M Cost Total Annual Cost

Median $ 9,599,036.50 $763,734.07 $1,631,009.52 $2,394,743.59 

Low $ 2,611,756.02 $207,800.76 $1,631,009.52 $1,838,810.28 

High $ 36,003,166.60 $2,864,542.18 $1,631,009.52 $4,495,551.70 

5. Cost Results for Cat 5 to Cat 3 by Counties

Table 10 Cost Result for DW Sector by Counties (Cat 5 to Cat 3)

County Minimum Annual cost Maximum Annual cost Median Annual cost

Clay $99,665 $243,661 $129,796 

Duval $1,705,371 $4,169,316 $2,220,961 

Flagler $33,222 $81,220 $43,265 

Nassau $554 $1,354 $721 

Total $1,838,810 $4,495,552 $2,394,744 
23

IV. Costs to Industrial Wastewater (IW) Treatment Plants

1. Methodology and Assumptions 

(1)Industrial wastewater facilities with NPDES permits discharging to surface 

waters were included in the estimate. The list of industrial wastewater 

facilities for which costs were estimated were provided by FDEP staff.

(2) The list of facilities was restricted to:

a. Facilities that have numeric discharge limitations for any form of 

nitrogen and/or phosphorus in their NPDES IW permits,

b. Facilities that are required to report the concentration of any form of 

nitrogen and/or phosphorus in their NPDES IW permits, and

c. Other NPDES permitted IW facilities that are not currently required to 

monitor nutrients, but are in the SIC categories for a and b, above.

(3) The following were specifically excluded from the cost analysis:

a. Stormwater Treatment Areas (STAs) (SIC 3822) developed for 

Everglades restoration efforts within the Everglades Protection Area have 

separate criteria and are not included.

b. Facilities discharging to a wetland or to a stream in the South Nutrient 

Watershed Region.

c. Facilities discharging to a WBID which is currently impaired and for 

which there currently exists or will in the future be a TMDL and therefore have 

costs attributable to FDEP’s current rule.

d. NPDES permitted facilities in various SIC categories that meet the 

criteria in items 1 and 2, above, but which discharged during 10% or fewer 

months within the past five years, based on U.S. Environmental Protection 

Agency’s (EPA) Permit Compliance System (PCS) database, were not included 

in cost calculations. It was assumed that no further improvements would be 

necessary in their level of treatment due to the infrequent nature of their 

discharge.

(4) Costs for facilities discharging to a WBID, which is currently impaired and for 

which there currently exists (Cat 1) or will in the future (Cat 2) be a TMDL,

were attributable to the current rule. Costs for facilities discharging to a WBID 

which will become impaired (Cat 3) under the FDEP Numeric Nutrient Criteria 

were attributed to the new rule. 

(5) Discharge estimation assumptions are as follows:

a. The discharge flows were based on data obtained from the FDEP 

Permit Compliance System, as reported on Discharge Monitoring Reports from 

permitted facilities for the five year period from January 1, 2005 through 

December 31, 2009. 
24

b. For facilities with multiple discharge points (outfalls), flows from all 

outfalls that potentially may discharge nutrients were used.

c. Estimated annual discharges were assumed for 340 days/year of 

discharge, except for facilities that are known to have intermittent discharges, 

in which case the number of months per year during which discharge occurred 

were identified from PCS13

d. Monthly average flows were used as the flow basis in estimating annual 

operation and maintenance (O&M) costs.

.

e. Daily maximum flow data were used as an approximation of maximum 

design capacity for estimating capital costs.

(6) Estimated discharges for phosphogypsum processing facilities with associated 

gypsum stacks (SIC 2874) were obtained from the Bureau of Mine 

Reclamation. Gypsum stacks discharge treated industrial wastewater during a 

five year closure period, followed by post-closure treatment and discharge 

over periods up to 50 years. 

(7) Capital and operating costs for phosphogypsum processing facilities with 

associated gypsum stacks (SIC 2874) were also obtained from the Bureau of 

Mine Reclamation.

(8) Unit capital costs to upgrade were based on “AWT-upgrades cost data” from 

FDEP: The data was made more consistent since some lacked an “engineering 

cost” component. The relative engineering cost part was assumed to be 25%. 

Unit Capital Costs were calculated as to the MGD capacities of the various 

facilities. The range of unit capital cost data (n=19) was subjected to a 

distribution analyses with the @RISK software package, and a fit was 

established with a Risk Lognormal distribution. Given the distribution, a lower 

tail at 10% was established at $0.90, the medium at $3.30, and the upper 90% 

tail at $12.36.

(9) Total capital cost is calculated by Affected Daily Maximum Flow * Capital Cost 

in assumption (8).

(10) Unit Operation & Maintenance costs were $0.56 per gallon per year based on

Cardno ENTRIX cost data.

(11)Total O&M cost per year is calculated by Affected Monthly Average Flow * 

O&M Cost in assumption (10).

 13 The estimate of 340days/year of discharge for continuously discharging IW facilities is 

conservatively high to avoid under estimating costs. This approach seems appropriate because it 

provides an estimate of the potential cost and operational burden for facilities operating at full 

capacity Personal Communication, Allen Hubbard, Industrial Waste, FDEP.
25

(12)As mentioned earlier in the general assumptions, FSU CEFA will assume a rate 

of 6.7% amortized over 30 years for the private sector and 4.7% amortized 

over 30 years for the public sector.

2. Data and Calculations for Cat 3

1) Affected Facilities and Capacities

The FDEP NPDES IW database was used which contained 158 data points with 

variable outfalls. 118 outfalls in 87 IW facilities were classified into 6 categories by 

FDEP staff. Excluding facilities which fell under either category 1 or 2, only 3 outfalls 

in 3 facilities are classified in category 3. However, one facility was “intermittent” and 

based on the current IW assumptions, FSU CEFA didn’t include this facility in the cost 

analysis. The other two facilities are categories that were removed because these 

facilities discharge to wetlands and FDEP have not established criteria for wetlands in 

NNC rule. Therefore, there is no affected facility by NNC rule.

Table 11 IW Facilities with Multi-Category Entries Eliminated

Total 

outfalls Categorized 

Outfalls 

Cat1 Cat2 Cat3 Cat4 Cat5 Cat6 MGD in Cat3

203 118 19 40

0

(3=> 2 go for 

wetland and 1 is 

intermittent)

21 26 9 22.659(aver.)

/62.83(max.)

3. IW Data and Calculations for Cat 5 to Cat 3

Baseline Assumptions

1. Using a data assessment performed by FDEP, facilities in Cat 5 will be 

reclassified by FDEP as a Cat 3 or Cat 4.

2. The probability to be reclassified from a Cat 5 to a Cat 3 is estimated to be 

17.54% based on the assessment data by WBID, provided by FDEP. Of the 

WBIDs for which there was sufficient data to assess them, 429 WBIDs 

were impaired, out of a total of 2,446 WBID (17.54% impairment rate).

3. FSU CEFA applied the probability of 17.54% to the costs for each Cat 5 

sector based on the individual sector cost methodologies. 
26

IW Cat 5 to Cat 3 Cost Calculations

1. Cat 5 Data

After removing facilities for which no costs would be incurred (consistent 

with the Methods and Assumptions), there are five outfalls which would 

incur costs in Cat 5.

Average flows total 9.305 MGD and maximum flows total 198.55 MGD for 

those 5 outfalls.

By applying the probabilities of 17.54%, the average flow and maximum 

flow of 1.632 MGD, and 34.83 MGD will be obtained.

2. IW Cost Data 

Table 12 IW Costs for Calculation

Capital Cost O&M Cost

Minimum : $0.90/ gallon 

Medium: $3.30 /gallon

Maximum: $12.36 /gallon

$ 0.56/ gallon/year

3. Capital cost is multiplied by (maximum flow * MGD), and O&M cost is 

multiplied by (average flow * MGD). Amortization is 6.7% for 30 years.

4. IW Cost Results

Table 13 Cost Result for DW Sector (Cat 5 to Cat 3)

Capital Cost Annual Cost O&M Cost Total Annual Cost

Median $ 114,777,422 $ 8,972,338 $ 913,974 $ 9,886,313

Low $ 31,229,241 $ 2,441,241 $ 913,974 $ 3,355,215

High $ 430,496,400 $ 33,652,606 $ 913,974 $ 34,566,580

5. Cost Results for Cat 5 to Cat 3 by counties

Table 14 Cost Result for DW Sector by Counties (Cat 5 to Cat 3)

County Minimum Annual cost Maximum Annual Cost Median Annual Cost

Santa Rosa $7,957 $19,276 $10,326 

Polk $3,347,258 $34,547,305 $9,875,987 

Total $3,355,215 $34,566,580 $9,886,313 
27

V. Costs for Urban Stormwater (SW) Controls

1. Methodology and Assumptions 

(1) Florida was the first state in the nation to implement comprehensive 

stormwater treatment programs in 1981 for all new urban development and 

re-development. This program specifies the BMPs to be used to treat 

stormwater to specific performance standards (minimum level of treatment) 

for all stormwater discharges during and after construction. Therefore, for the 

purpose of this estimate, it was assumed that implementation of urban 

stormwater measures subsequent to the 1981 stormwater program would 

achieve the proposed criteria, but that pre-1982 urban areas without such 

measures would not.

(2) For calculating the costs associated with the NNC, FDEP staff performed GIS 

analysis to find the urban area-specific included within the target waterbody 

IDs WBIDs for years 1990 and 2005. In 1990, the urban area that was included 

in the target WBIDs was 2,575,895 acres, and the urban area was 3,562,468

acres, in 2005. FDEP staff classified the urban areas in 1990 and 2005 by six 

categories. 

(3) FDEP has undertaken numerous retrofit projects to address pollutant loading 

from municipal stormwater runoff, many of which required monitoring in 

order to show the effectiveness of the retrofit. The data from these projects 

have been compiled into a database by FDEP, which include information on 

the acreage of the area which was retrofitted. This information was used to 

derive a cost per unit acre to retrofit urban areas for nutrient removal. 

Utilizing the bootstrap analysis performed by Cardno-ENTRIX on FDEP’s data, 

the mean cost per acre for such retrofit projects was $2,800 per acre, with a 

range around that mean of $1,500 per acre to $5,900 per acre, ranging from 

the 10th to the 90th percentile.

(4) The operation and maintenance costs were estimated based on existing 

literature14. Although actual costs can often exceed this rate, a conservative 

estimate of 5% of the capital outlay was chosen for this estimate. 

(5) A 30-year annualized cost was calculated using an amortization rate of 4.7%. 

 14 The Use of Best Management Practices (BMPs) in Urban Watersheds – U.S. EPA, 2004; Stormwater: 

The Journal for Surface Water Quality Professionals, Nov.-Dec., 2008.
28

2. Data and Calculations for Cat 3

1) Affected Urban Stormwater Acres

Concerning the NNC cost calculations, the category 3’s were the primary focus. About 

51,717 acres were classified as category 3’s according to year 2005 data, and about 

67,667 acres were classified based on the year 1990 data. Ruling out multiple 

category acres, the remaining representative acres (designated as category 3) were

20,141 and 27,734, for years 1990 and 2005, respectively. The category 3 acres 

decreased about 27.4% from years 2005 to 1990. Annually, there have been 

decreases of about 2.11%. Extrapolated to year 1982, the category 3’s acreage would 

be 16,982 acres, representing a 38.8% decrease from 2005. According to the 

assumption (1), it is estimated that about 16,982 acres would be affected by 

implementation of the NNC rule.

Table 15 Years 1990 and 2005 Classification of Urban Stormwater WBID Acreage

#_WBID Acres* Cat 1

Acres

Cat 2

Acres

Cat 3

Acres**

Cat 4

Acres

Cat 5

Acres

Cat 6

Acres

1990 5,231 2,575,895 111,524 422,313 20,141 626,401 839,491 123,558

2005 5,833 3,562,468 195,794 524,781 27,734 914,350 1,225,045 155,812

Source: FDEP staff

*Acreage based on the WBIDs – some WBIDs fell in multiple categories

**Excluding WBIDs which also fell in Categories 1 or 2

Table 16 Years 1990 and 2005 Classification of Urban Stormwater WBID Acreage

# WBID Acres Cat 3 Only Acreage Cat 5 to Cat 3 Acreage*

1990 5,231 2,575,895 20,141 147,247

2005 5,833 3,562,468 27,734 214,873

Source: FDEP staff

*Costs for Cat 5 to Cat 3 Acreage were based on 17.54% assumption of total Cat 5 

acreage.

2) Capital Costs Per Acre
29

Table 17 Capital Costs Per Acre

Min Max Most likely

$ 1,500 $5,900 $ 2,894

Source: Cardno ENTRIX (2011)

3) Total Costs

We assumed an interest rate of 4.9% over 30 years15. The total capital cost was 

calculated by 1) Affected urban acres * 2) Capital costs per Acre. The total O&M cost 

per year was calculated by deriving 5% of the total cost. 

Table 18 Total Urban SW Costs (Cat 3)

Treatment Acres Cost per Acre O&M Cost

(5%) Annual Cost

Min 16,982.14 $1,500 $75 $2,026,816

Max 16,982.14 $5,900 $295 $7,972,144

Most likely 16,982.14 $2,894 $145 $3,910,404

 15 Based on FDEP methodology (2010).
30

3. Cost Results by Counties for Cat 3

The following Table depicts the cost results by counties. 

Table 19 Urban SW Costs by Counties (Cat 3)

County 1990 Cat 3 Acreage Ratio Minimum Cost Maximum Cost

Alachua 2.84 0% $286 $1,126

Calhoun 145.73 1% $14,665 $57,683

Citrus 3.62 0% $364 $1,433

Desoto 1394.99 7% $140,379 $552,156

Dixie .22 0% $22 $86

Escambia 4484.11 22% $451,238 $1,774,869

Franklin 76.87 0% $7,735 $30,425

Glades 4.57 0% $460 $1,808

Hardee 92.73 0% $9,332 $36,706

Hendry .84 0% $85 $333

Hernando 4044.63 20% $407,013 $1,600,917

Highlands 2.53 0% $254 $1,001

Hillsborough 8.51 0% $856 $3,369

Indian River 1528.05 8% $153,769 $604,823

Lake 1.60 0% $161 $632

Lee 1291.72 6% $129,986 $511,279

Leon 76.28 0% $7,676 $30,192

Manatee 1.02 0% $103 $405

Okeechobee 432.71 2% $43,544 $171,273

Orange 31.01 0% $3,120 $12,273

Pasco 3055.87 15% $307,513 $1,209,553

Pinellas 3035.87 15% $305,501 $1,201,638

Polk 181.53 1% $18,268 $71,852

Seminole 23.77 0% $2,392 $9,410

Taylor 208.38 1% $20,970 $82,482

Volusia 11.17 0% $1,124 $4,421

Total 20141.17 100% $2,026,816 $7,972,144
31

4. Data and Calculations for Cat 5 to Cat 3

1. Cat 5 data

In 2005, the Cat 5-only acres totaled 1,225,045. Based on our SW 

assumption whereby there will be an annual 2.49% decrease for 23 years, 

the base 1982 Cat 5 acres were extrapolated to total 686,241.

By assuming an estimated likelihood of 17.54%, the affected area is 

120,366.72 acres. 

2. Stormwater Cost Data 

Table 20 SW Costs for Calculation

Capital Cost O&M Cost (5% per year)

Most likely: $2,894 

Minimum: $1,500

Maximum: $5,900

Most likely: $144.7 

Minimum: $75

Maximum: $295

3. The Capital cost is multiplied by 17.54% of the Cat 5 acres, and the O&M 

cost is estimated at 5% of annual capital costs. The amortization is 4.9% 

for 20 years.

4. SW Cost Results

Table 21 Cost Result for SW Sector (Cat 5 to Cat 3)

Treatment Acres Cost per Acre O&M Cost (5%) Annual Cost

Most 

Likely 120,366.72 $2,894.00 $144.70 $27,715,436.87

Min 120,366.72 $1,500.00 $75.00 $14,365,292.09

Max 120,366.72 $5,900.00 $295.00 $56,503,482.22
32

5. Cost Results for Cat 5 to Cat 3 by Counties

Table 22 Cost Result for SW Sector by Counties (Cat 5 to Cat 3)

County 1990 Cat 5 to Cat 3 Ratio Minimum Annual 

Cost

Maximum Annual 

Cost

Alachua 4766.57 3% $465,023 $1,829,092

Baker 1355.21 1% $132,213 $520,039

Bay 2231.23 2% $217,677 $856,198

Bradford 344.94 0% $33,652 $132,365

Brevard 3516.16 2% $343,034 $1,349,269

Broward 5.20 0% $508 $1,997

Calhoun 358.07 0% $34,934 $137,405

Charlotte 244.04 0% $23,809 $93,647

Citrus 866.95 1% $84,579 $332,677

Clay 4038.97 3% $394,040 $1,549,890

Columbia 1538.51 1% $150,096 $590,379

Dade 1.46 0% $143 $561

Desoto 453.61 0% $44,254 $174,064

Dixie 359.95 0% $35,117 $138,126

Duval 3518.49 2% $343,262 $1,350,164

Escambia 1764.96 1% $172,189 $677,275

Flagler 775.96 1% $75,702 $297,761

Franklin 43.97 0% $4,290 $16,872

Gadsden 2391.01 2% $233,265 $917,509

Gilchrist 22.36 0% $2,182 $8,581

Glades 5.74 0% $560 $2,202

Gulf 469.97 0% $45,850 $180,344

Hamilton 228.37 0% $22,280 $87,635

Hardee 282.54 0% $27,565 $108,421

Hernando 4629.85 3% $451,685 $1,776,628

Highlands 2725.98 2% $265,945 $1,046,052

Hillsborough 2738.91 2% $267,207 $1,051,013

Holmes 929.03 1% $90,636 $356,500

Indian River 1016.89 1% $99,207 $390,214

Jackson 2459.83 2% $239,979 $943,919

Jefferson 218.09 0% $21,277 $83,688

Lake 6390.62 4% $623,465 $2,452,295

Lee 440.76 0% $43,000 $169,135

Leon 2432.75 2% $237,337 $933,526

Levy 2316.26 2% $225,973 $888,825

Liberty 430.17 0% $41,967 $165,071
33

Madison 224.46 0% $21,898 $86,133

Manatee 926.29 1% $90,368 $355,449

Marion 16699.88 11% $1,629,229 $6,408,301

Martin 423.38 0% $41,304 $162,464

Nassau 1944.47 1% $189,701 $746,158

Okaloosa 5462.08 4% $532,877 $2,095,982

Okeechobee 91.90 0% $8,966 $35,265

Orange 12396.18 8% $1,209,363 $4,756,829

Osceola 2468.86 2% $240,860 $947,384

Pasco 9076.18 6% $885,466 $3,482,833

Pinellas 2487.44 2% $242,673 $954,515

Polk 9378.36 6% $914,947 $3,598,790

Putnam 4196.46 3% $409,404 $1,610,321

Santa Rosa 2888.82 2% $281,832 $1,108,539

Sarasota 1887.48 1% $184,141 $724,290

Seminole 1626.54 1% $158,684 $624,157

St. Johns 1145.12 1% $111,717 $439,421

St. Lucie 200.28 0% $19,539 $76,854

Sumter 2292.68 2% $223,672 $879,777

Suwannee 809.65 1% $78,988 $310,688

Taylor 108.29 0% $10,565 $41,554

Union 228.48 0% $22,291 $87,677

Volusia 8136.13 6% $793,756 $3,122,107

Wakulla 308.32 0% $30,079 $118,311

Walton 4445.18 3% $433,669 $1,705,764

Washington 1080.39 1% $105,402 $414,582

Total 147,246.70 100% $14,365,292 $56,503,482
34

VI. Costs for Septic Systems

1. Method and Assumptions 

(1) FDEP staff provided the number of septic tanks , derived from the FDEP GIS 

analysis results. The locations of the septic tanks were provided by the Florida 

Department of Health. Only those tanks with STATUS = ACTIVE were part of 

the cost analysis. Using the 100K National Hydrography Dataset (NHD), a GIS 

layer representing streams, and lakes larger than two acres, was created. This 

layer was then buffered by 500 feet (153 meters). FDEP staff calculated the 

number of septic tanks that fell inside the buffer. 

(2) Estimated construction costs were taken from an interim report prepared for 

the FDEP entitled “Onsite Sewage Treatment and Disposal Systems Evaluation 

for Nutrient Removal”, January 7, 2010, Stormwater Management Academy, 

University of Central Florida. It compared different advanced septic systems 

with conventional systems.16 The septic systems costs with higher levels of 

nutrient removal (e.g., advanced or performance based systems) ranged from 

$9,320 to $18,200 per unit. The operation and maintenance costs were also 

estimated from this report, which indicated values ranging from $200 - $1,800 

per year.

(3) Regarding financing a septic system, FSU CEFA staff assumed a shorter 

financing stream; as 20 years was viewed as not realistic, given 20 years is the 

average life span of a septic system. FSU CEFA decided that anywhere from 5-

10 years would be representative of a higher level septic system, e.g., 

advanced or performance based system. FSU CEFA staff assumed an interest 

rate of 6.1% (see aforementioned assumption related to financing public and 

private projects) over ten years. The O & M costs were not tied to inflation.

2. Data and Calculation for Cat 3

1) The Number of Septic Tanks

The total number of septic tanks which would potentially be affected by 

implementation of the NNC rule was 76,994. The number of septic tanks in category 3 

is 1,201 (this total includes septic tanks in category 3 which also are listed in category 

1 or 2). The number of septic tanks with costs that could be incurred under the NNC 

rule is 498 (septic tanks which are listed in category 3 only). 

 16 Stormwater Management Academy (2010). UCF. Onsite Sewage Treatment and Disposal Systems 

Evaluation for Nutrient Removal, p.3
35

Table 23 Number of Septic Tanks

Total Cat 1 Cat 2 Cat 3 Cat 4 Cat 5 Cat 6

76,994 3,266 9,451 498 19,372 32,413 3,909

2) Costs to Upgrade Per Tank

Table 24 The Capital Costs and O&M Costs to Upgrade (Per Tank)

Low High

Capital Costs To Upgrade Per Tank $9,320 $18,200

O & M per Septic System $200 $1,800

3) Total Costs

We assumed an interest rate of 6.1% over ten years (based on aforementioned 

assumptions). The total cost of replacement was calculated by 1) Number of septic 

tanks * 2) Capital costs to upgrade per tank. The total O&M cost per year was 

calculated by 1) Number of septic tanks * 2) O & M cost per septic system. 

Table 25 Total Costs of Affected Septic Systems (Cat 3)

Low High

Replacement Total Cost $4,641,360 $9,063,600 

Total O & M cost per year $99,600 $896,400 

Capital Investment Amortization 6.1% over 10 years

Replacement Annual Costs $733,203 $2,133,694 
36

3. Total Costs Results by Counties for Cat 3

The following Table reports the cost results by counties. 

Table 26 Total Costs of Septic Systems, by Counties (Cat 3)

County #of Septic Systems Cat 3 

Only Low High

Calhoun 1 $1,472 $4,285

Desoto 42 $61,836 $179,950

Dixie 1 $1,472 $4,285

Escambia 170 $250,290 $728,369

Franklin 4 $5,889 $17,138

Hardee 4 $5,889 $17,138

Hernando 101 $148,702 $432,737

Hillsborough 3 $4,417 $12,854

Indian River 36 $53,003 $154,243

Lee 2 $2,945 $8,569

Okeechobee 37 $54,475 $158,527

Pasco 24 $35,335 $102,829

Pinellas 48 $70,670 $205,657

Polk 2 $2,945 $8,569

Taylor 23 $33,863 $98,544

Total 498 $733,203 $2,133,694
37

4. Data and Calculations for Cat 5 to Cat 3

1. Cat 5 Data

There are a total of 32,413 septic systems listed in Cat 5.

Similar to the previous methodology regarding a probability of 17.54% in 

being reclassified from a Cat 5 to a Cat 3, it was estimated that there were 

5,685 septic systems which might be reclassified to a Cat 3.

2. Cost Data

Table 27 Costs for Calculation

Capital Cost O&M Cost

Low: $9,320 

High: $18,200

Median: $10,200

Low: $200 

High: $1,800

Median: $400

3. The capital cost and O&M costs were multiplied by the number of septic 

systems likely to be reclassified from a Cat 5 to a Cat 3. Amortization is 

6.1% for ten years.

4. Septic System Cost Results

Table 28. Cost Results for Septic System Sector (Cat 5 to Cat 3)

Total Number of Septic Systems 

to be Upgraded 5,685

Low High Median

Capital Costs To Upgrade Per Tank $9,320 $18,200 $10,200

O & M per Septic System $200 $1,800 $400

Total Annualized Cost $1,472.30 $4,284.53 $1,792.43

Instant Replacement Total Cost $52,984,200 $103,467,000 $57,987,000 

Total O & M Cost per Year $1,137,000 $10,233,000 $2,274,000 

Capital Investment Amortization 6.1% over 10 years

Instant Replacement Annual Costs $8,370,000 $24,357,528 $10,189,944 
38

5. Cost Results for Cat 5 to Cat 3 by Counties

Table 29 Cost Result for Septic System Sector by Counties (Cat 5 to Cat 3)

County Cat 5 to Cat 3 Ratio Low Annual Cost High Annual Cost

Alachua 56 1% $82,892 $241,223

Baker 19 0% $28,663 $83,414

Bay 68 1% $99,935 $290,820

Bradford 15 0% $21,691 $63,124

Brevard 20 0% $29,696 $86,420

Calhoun 12 0% $17,818 $51,852

Charlotte 10 0% $14,203 $41,331

Citrus 32 1% $47,514 $138,271

Clay 317 6% $466,363 $1,357,162

Columbia 38 1% $55,261 $160,815

Desoto 27 0% $39,767 $115,727

Dixie 13 0% $19,625 $57,112

Duval 120 2% $176,629 $514,008

Escambia 63 1% $92,704 $269,779

Flagler 3 0% $3,873 $11,272

Franklin 1 0% $1,291 $3,757

Gadsden 109 2% $160,361 $466,665

Gilchrist 1 0% $1,549 $4,509

Gulf 14 0% $20,917 $60,869

Hamilton 14 0% $19,884 $57,864

Hardee 15 0% $22,724 $66,130

Hernando 121 2% $178,695 $520,020

Highlands 206 4% $303,936 $884,485

Hillsborough 142 2% $209,166 $608,694

Holmes 52 1% $75,920 $220,933

Indian River 180 3% $264,685 $770,261

Jackson 122 2% $179,986 $523,777

Jefferson 20 0% $29,955 $87,171

Lafayette 1 0% $775 $2,254

Lake 473 8% $696,187 $2,025,974

Leon 104 2% $152,614 $444,121

Levy 14 0% $20,142 $58,615

Liberty 9 0% $13,428 $39,077

Madison 4 0% $5,165 $15,029

Manatee 60 1% $88,573 $257,756

Marion 43 1% $63,525 $184,863

Martin 19 0% $27,631 $80,408
39

Nassau 50 1% $74,112 $215,673

Okaloosa 163 3% $239,379 $696,616

Okeechobee 18 0% $25,823 $75,147

Orange 793 14% $1,167,973 $3,398,917

Osceola 115 2% $169,140 $492,215

Pasco 341 6% $501,482 $1,459,363

Pinellas 27 0% $39,767 $115,727

Polk 457 8% $672,172 $1,956,087

Putnam 153 3% $225,176 $655,285

Santa Rosa 142 3% $209,424 $609,445

Sarasota 36 1% $52,421 $152,549

Seminole 123 2% $181,277 $527,535

St. Johns 116 2% $171,465 $498,979

St. Lucie 6 0% $8,522 $24,799

Sumter 61 1% $89,606 $260,761

Suwannee 13 0% $19,109 $55,609

Taylor 18 0% $26,081 $75,899

Union 10 0% $14,719 $42,834

Volusia 302 5% $445,188 $1,295,541

Wakulla 2 0% $2,582 $7,515

Walton 148 3% $218,204 $634,996

Washington 56 1% $82,634 $240,472

Total 5685 100% $8,370,000 $24,357,528
40

VII. Agriculture Costs

1. Methodology and Assumptions 

FSU CEFA adhered to the majority of assumptions developed by an earlier study 

conducted by FDACS, UF & SWET (2010).

(1) FDEP staff provided FSU CEFA with WBID acreages relating to agriculture.

(2) The estimated per-acre costs for agricultural producers to implement BMPs 

were taken from a report prepared for the South Florida Water Management 

District17. The BMPs included the full range of typical owner-implemented 

practices, such as fertilizer management, grazing management, and livestock 

exclusion from waterways.

(3) The initial capital cost estimates included materials, labor and engineering.

(4) The total annual costs included O&M (estimated at 20% of the capital costs) 

and amortization of the capital investment at 6.4% interest over 20 years.18

2. Data and Calculations for Cat 3

1) Affected Acreages

The following Table portrays the agricultural WBID acreages (by six categories) 

totaling 5,092,884. Using 5.09 million acres as a baseline, implementation of the NNC 

rule will affect approximately 187,659 (category 3) acres. Therefore, FSU CEFA 

examined about 188,000 acres relating to costs. 

Table 30. Affected Agricultural Acres

Total Cat 1 Cat 2 Cat 3 Cat 4 Cat 5 Cat 6

5,092,884 276,259 847,423 97,056 1,231,307 2,277,952 300,282

Ruling out the acres with costs associated across agricultural WBIDs which are also 

listed under category 1 or 2, FSU CEFA estimated that about 97,056 acres would be 

 17 Soil & Water Engineering Technologies, Inc. (SWET), 2008. Nutrient Loading Rates, Reduction 

Factors and Implementation Costs Associated with BMPs and Technologies, Appendix A. 18Based on FSU CEFA methodology.
41

affected by implementation of the NNC rule (category 3 only). The affected areas 

were divided by 25 counties and 9 agricultural classes (FDACS). The following Tables 

depict affected acres by agricultural class.

Table 31 Affected Agricultural Acres by Classes (Cat 3)

FDACS Classification Acre(s)

Aquaculture 1 

Beef Cattle Ranching & Farming 44,845 

Citrus 1,194 

Dairy Cattle & Milk Production 870 

Hay Farming 4,558 

Horse & Other Equine Production 628 

Non-citrus Fruit & Berry Farming 6,093 

Ornamentals 600 

Row Crops 38,268 

Total 97,056 

Source: GIS estimation performed by FDEP staff.

2) Capital Costs

Table 32 Capital Costs of Agriculture (Cat 3)

FDACS Per Acre Cost Acre Capital Cost

Aquaculture $58 1 $76.56

Beef Cattle Ranching & 

Farming $25 44,845 $1,134,571.71

Citrus $490 1,194 $584,876.21

Dairy Cattle & Milk Production $1,045 870 $908,974.02

Hay Farming $58 4,558 $264,352.46

Horse & Other Equine 

Production $50 628 $31,074.90

Non-Citrus Fruit & Berry 

Farming $490 6,093 $2,985,411.23

Ornamentals $220 600 $132,088.81

Row Crops $220 38,268 $8,418,925.50

Total 97,056 $14,460,351.41

Source: FDACS, UF & SWET (2010)
42

3) Total Costs of Agriculture

FDACS, UF & SWET (2010) used an amortization rate of 10% over 20 years. 

According to the aforementioned methodology, FSU CEFA assumed 6.4% over 20

years. The O & M cost was estimated based on 20 percent of the capital costs.

Table 33 Agricultural Total Costs Results (Cat 3)

FDACS Capital Cost Annual Cost Total Annual Cost

Aquaculture $76.56 $6.89 $22.21

Beef Cattle Ranching & 

Farming $1,134,571.71 $102,153.20 $329,067.54

Citrus $584,876.21 $52,660.38 $169,635.62

Dairy Cattle & Milk 

Production $908,974.02 $81,841.10 $263,635.91

Hay Farming $264,352.46 $23,801.45 $76,671.94

Horse & Other Equine 

Production $31,074.90 $2,797.88 $9,012.86

Non-Citrus Fruit & Berry 

Farming $2,985,411.23 $268,796.84 $865,879.09

Ornamentals $132,088.81 $11,892.85 $38,310.62

Row Crops $8,418,925.50 $758,013.03 $2,441,798.13

Total $14,460,351.41 $1,301,963.63 $4,194,033.91
43

3. Costs Results by Counties for Cat 3

The following Table shows the total costs results by counties. 

Table 34 Agricultural Total Costs by Counties (Cat 3)

County Acres Capital Cost Annual Cost (incl. 20% O&M)

Alachua .0 $0 $0

Calhoun 844.6 $125,834 $36,497

Citrus .0 $3 $1

Desoto 10,627.5 $1,583,392 $459,242

Dixie 215.1 $32,050 $9,296

Escambia 1,473.5 $219,538 $63,674

Glades 3,139.4 $467,746 $135,663

Hardee 10,599.6 $1,579,232 $458,035

Hendry 128.0 $19,069 $5,531

Hernando 11,046.8 $1,645,864 $477,361

Highlands 260.3 $38,784 $11,249

Hillsborough 2,319.7 $345,615 $100,241

Indian River 1,745.7 $260,090 $75,436

Lake .2 $37 $11

Lee 1,473.0 $219,467 $63,654

Leon 24.7 $3,682 $1,068

Okeechobee 41,044.1 $6,115,148 $1,773,618

Orange 9.2 $1,374 $398

Pasco 11,464.5 $1,708,088 $495,408

Pinellas 9.6 $1,426 $414

Polk 493.6 $73,538 $21,329

Seminole 3.8 $570 $165

Sumter 120.0 $17,873 $5,184

Taylor 6.5 $973 $282

Volusia 6.4 $957 $278

Total 97,056.0 $14,460,351 $4,194,034
44

4. Data and Calculations for Cat 5 to Cat 3

1. Cat 5 Data

There are a total of 2,277,952 Cat 5 acres in agriculture.

FSU CEFA calculated the “Cat5 to Cat 3” cost by assuming a probability of 

17.54% of Cat 5 acres.

2. Cost Data

Table 35 Costs for Calculation

DACS Cost

Aquaculture $ 58.00

Beef Cattle Ranching $ 25.30

Citrus $ 490.00

Dairy Cattle and Milk Production $ 1,045.00

Hay $ 58.00

Horse and Equine Production $ 49.50

Non Citrus fruit and berry farming $ 490.00

Ornamentals $ 220.00

Poultry and Egg Production $ 58.00

Row Crops $ 220.00

Silviculture and Tree Plantation $ 22.00

Sod Production $ 110.00

Sugarcane $ 110.80

3. The capital cost is multiplied by the Cat 5 acres and the O&M cost is 

assumed to be approximately 20% of the capital cost. Amortization is 6.4% 

for 20 years.
45

4. Agriculture Cost Results

Table 36 Cost Result for Agriculture Sector (Cat 5 to Cat 3)

DACS Cat 5 Cost Capital Cost Total Annual Cost

Aquaculture 1,843 $58.0 $106,903.13 $31,005.84

Beef Cattle 

Ranching & 

Farming

 938,234 $25.3 $23,737,315.21 $6,884,694.71

Citrus 61,972 $490.0 $30,366,313.35 $8,807,348.06

Dairy Cattle & Milk 

Production 1,589 $1,045.0 $1,660,196.89 $481,518.18

Hay Farming 329,765 $58.0 $19,126,376.28 $5,547,352.79

Horse & Other 

Equine Production 86,187 $49.5 $4,266,243.15 $1,237,367.47

Non-citrus Fruit & 

Berry Farming 150,009 $490.0 $73,504,187.79 $21,318,918.70

Ornamentals 27,329 $220.0 $6,012,466.52 $1,743,836.49

Poultry & Egg 

Production 2,241 $58.0 $129,982.00 $37,699.56

Row Crops 668,649 $220.0 $147,102,818.91 $42,665,229.44

Sod Production 10,134 $110.0 $1,114,776.73 $323,326.27

Total 2,277,952 $307,127,579.98 $89,078,297.51

Probability of Cat 5 

to Cat 3 Cost* 399,553 $53,870,177.53 $15,624,333.38

*FSU CEFA calculated the costs based on the probability of 17.54% to be reclassified 

from a “Cat 5 to a Cat 3”.
46

5. Agriculture Costs by Counties (For Cat 5 to Cat 3)

Table 37 Cost Result for Agriculture Sector by Counties (Cat 5 to Cat 3)

County Cat 5 to Cat 3 Ratio Capital Cost Total Annual Cost

Alachua 14,225 4% $1,917,919 $556,267

Baker 2,121 1% $285,942 $82,934

Bay 951 0% $128,198 $37,182

Bradford 2,588 1% $348,973 $101,215

Brevard 4,563 1% $615,257 $178,447

Calhoun 3,281 1% $442,326 $128,291

Charlotte 1,507 0% $203,246 $58,949

Citrus 876 0% $118,163 $34,272

Clay 1,304 0% $175,767 $50,979

Columbia 6,083 2% $820,107 $237,861

Desoto 9,725 2% $1,311,213 $380,300

Dixie 1,498 0% $202,036 $58,598

Duval 1,148 0% $154,840 $44,909

Escambia 4,109 1% $553,991 $160,678

Flagler 2,749 1% $370,659 $107,505

Franklin 14 0% $1,925 $558

Gadsden 4,440 1% $598,569 $173,607

Gilchrist 2,557 1% $344,791 $100,002

Glades 3,602 1% $485,698 $140,870

Gulf 364 0% $49,130 $14,249

Hamilton 2,986 1% $402,623 $116,776

Hardee 16,640 4% $2,243,567 $650,717

Hernando 2,589 1% $349,098 $101,251

Highlands 6,527 2% $880,013 $255,236

Hillsborough 2,905 1% $391,606 $113,580

Holmes 8,149 2% $1,098,654 $318,650

Indian River 6,949 2% $936,872 $271,727

Jackson 22,331 6% $3,010,867 $873,262

Jefferson 5,414 1% $729,959 $211,715

Lafayette 2,232 1% $300,880 $87,266

Lake 17,232 4% $2,323,331 $673,851

Lee 25 0% $3,425 $993

Leon 1,740 0% $234,589 $68,040

Levy 14,985 4% $2,020,346 $585,975

Liberty 406 0% $54,793 $15,892

Madison 6,971 2% $939,852 $272,592
47

Manatee 11,866 3% $1,599,901 $464,030

Marion 34,879 9% $4,702,661 $1,363,945

Martin 193 0% $25,998 $7,540

Nassau 2,305 1% $310,737 $90,125

Okaloosa 4,997 1% $673,711 $195,401

Okeechobee 6,743 2% $909,121 $263,679

Orange 9,370 2% $1,263,328 $366,412

Osceola 44,121 11% $5,948,636 $1,725,323

Pasco 10,304 3% $1,389,304 $402,949

Pinellas 53 0% $7,188 $2,085

Polk 31,698 8% $4,273,761 $1,239,548

Putnam 2,739 1% $369,351 $107,125

Santa Rosa 6,175 2% $832,522 $241,462

Sarasota 3,477 1% $468,791 $135,967

Seminole 746 0% $100,545 $29,162

St. Johns 624 0% $84,120 $24,398

St. Lucie 65 0% $8,746 $2,537

Sumter 16,734 4% $2,256,133 $654,362

Suwannee 7,856 2% $1,059,138 $307,189

Taylor 735 0% $99,111 $28,746

Union 1,665 0% $224,552 $65,128

Volusia 5,280 1% $711,886 $206,473

Wakulla 123 0% $16,581 $4,809

Walton 7,165 2% $966,069 $280,196

Washington 3,850 1% $519,062 $150,547

Total 399,553 100% $53,870,178 $15,624,333
48

VII. Conclusions

Florida has adopted quantitative nutrient water quality standards to facilitate the 

assessment of attainment of water quality standards and to protect state waters from 

the adverse effects of nutrient over enrichment. The addition of excess nutrients not 

only have a negative effect on Florida’s environment and public health, but can also 

negatively affect Florida’s economy as explained more fully below. The FDEP Numeric 

Nutrient Criteria rule (NNC rule) in Florida is an important component of Florida’s 

efforts in decreasing these negative impacts. 

This report represents the research conducted by FSU CEFA concerning the economic 

analysis of the FDEP Numeric Nutrient Criteria adopted for Florida. The FSU CEFA 

analysis examined and integrated some of the assumptions used in previous studies

and developed some other assumptions based on more current cost data, and 

incorporated current changes in regulation rules. The highlights of the FSU CEFA 

research analysis included the NNC cost estimation and economic analysis results. 

The research data for this study were provided by the Florida Department of 

Environmental Protection (FDEP). FDEP classified waterbodies into six categories. 

The Numeric Nutrient Criteria in Florida was applied to all six classified categories, 

however, the costs were primarily assigned to Category Three (Cat 3), those 

waterbodies that would be deemed impaired under FDEP’s Numeric Nutrient Criteria 

rule. As FDEP defined Category Five as “those waterbody WBIDs with insufficient 

information to determine if they fit in Category Three or Four,” this study included a 

proportion of Category Five (Cat 5), or those waterbodies with classification “Cat 5” 

with a high likelihood of being reclassified as Cat 3’s19

The economic analysis consisted of five sectors; Domestic Wastewater (DW) Sector, 

Industrial Wastewater (IW) Sector, Urban Stormwater Controls (SW) Sector, Septic 

System Sector, and the Agriculture Sector. These five sectors corresponded to sector 

groupings consistent with the previous studies; namely, the EPA study and Cardno 

Entrix studies. Each sector calculation described following orders; methodology, data 

and result for Cat 3, and data and result for Cat 5 to Cat 3.

. 

Although each sectors’ methodology varied, the domestic and industrial (DW and IW) 

sectors cost calculations were based on the affected facilities’ water capacity 

multiplied by capital and maintenance cost(s). The Urban Stormwater (SW) and 

 19 For the cost analysis conducted for this study, the probability to be reclassified from a CAT 5 to a 

CAT 3 is estimated to be 17.54% based on the assessment data by WBID, provided by FDEP. Of the 

WBIDs for which there was sufficient data to assess them, 429 WBIDs were impaired out of a total of 

2,446 WBID’s (an 17.54% impairment rate).
49

Agriculture sector’s cost calculations were based on the proposed NNC rule number 

of “impacted acres” multiplied by the assumed capital and maintenance costs. The

Septic system cost calculations were based on the number of proposed NNC rule 

estimated septic systems multiplied by the corresponding upgrade and/or 

replacement capital and maintenance costs.

The following Table provides a summary of the results of this study. The annual cost

estimates were presented by sector, and included low, median and high projections. 

With regard to cost estimates pertaining only to the Cat 3 area, about $8.9 million 

would be the estimated annual median cost. With the inclusion of additional 

waterbodies to be reclassified from Cat 5 to Cat 3, the median costs were estimated to 

be a grand total of about $65.8 million. The research team estimated that that the 

minimum and maximum costs for implementation of the NNC rule would range from 

$50.5 million to $149.8 million per year.

Table 38 Summary of the Low, High and Median Costs for the NNC Rule in Florida 

Cat3 Low High Median Cost

DW $0 $0 $0 

IW $0 $0 $0 

SW $2,026,816 $7,972,144 $3,910,404 

Septic $733,203 $2,133,694 $892,628 

Agriculture $4,194,034 $4,194,034 $4,194,034 

Total $6,954,053 $14,299,871 $8,997,066 

Cat 5 to Cat 3

DW $1,838,810 $4,495,552 $2,394,744 

IW $3,355,215 $34,566,580 $9,886,313 

SW $14,365,292 $56,503,482 $27,715,437 

Septic $8,370,000 $24,357,528 $10,189,944 

Agriculture $15,624,333 $15,624,333 $15,624,333 

Total $43,553,651 $135,547,476 $65,810,772 

Grand Total

DW $1,838,810 $4,495,552 $2,394,744 

IW $3,355,215 $34,566,580 $9,886,313 

SW $16,392,108 $64,475,626 $31,625,841 

Septic $9,103,203 $26,491,222 $11,082,573 

Agriculture $19,818,367 $19,818,367 $19,818,367 

Grand Total $50,507,704 $149,847,347 $74,807,838 
50

Table 39 Comparison Cost Results among FSU CEFA, EPA and Cardno ENTRIX (in Million 

Dollars per Year)

Sector Low High Median Cost

CEFA(2012)

DW $2 $4 $2 

IW $3 $35 $10 

SW $16 $64 $32 

Septic $9 $26 $11

Agriculture $20 $20 $20

Total $50 $150 $75

EPA(2010)

DW $22 $38 

IW $25 $25 

SW $61 $108 

Septic $7 $11 

Agriculture $20 $23 

Total $135 $206 

Cardno 

ENTRIX(2011)

DW $17 $66 $41 

IW $164 $372 $270 

SW $25 $115 $61 

Septic $2 $18 $8 

Agriculture $24 $42 $33 

Total $298 $533 $415 
51

References

Associated Industries of Florida, CF Industries Holdings, Inc., Florida Farm Bureau, Florida 

Water Quality Coalition (Jan. 6, 2011). Retrieved from “EPA Nutrient Rulemaking 

Poised to Stymie Job Growth in Florida

Budell, R., Stone, H., Clements, J., Hodges, A., Stevens, T., Rahmani, M., Borisova, T., and 

Bottcher. D. (2010). "Economic Impacts and Compliance Costs of Proposed EPA 

Numeric Nutrient Criteria for Florida Agriculture." from http://www.flcounties.com/Docs/Legislative%20Division/Environmental/Economic%20impa

cts%20of%20EPA%20Numeric%20Criteria.pdf. (AKA. FDACS, UF & SWET 

(2010))

Carollo Engineers (2010). “Technologies to Meet Numeric Nutrient Criteria at Florida’s 

Domestic Wastewater Reclamation Facilities.” for Florida Water Environment 

Association Utilities Council. Retrieved from 

http://www.fweauc.org/PDFs/FWEAUC%20letter%20to%20Crist%20re%20N

NC%20Cost%20Implications%20for%20Fla%20POTWs%20with%20attachmen

t.pdf (AKA. “FWEA Report”)

Cardno ENTRIX (2010). “Economic Analysis of the Proposed Federal Numeric Nutrient 

Criteria for Florida” 

EPA (1997). "Guiding Principles for Monte Carlo Analysis." Retrieved EPA/630/R-97/001, 

2010, from http://www.epa.gov/ncea/pdfs/montcarl.pdf.

EPA (1998) "National Strategy for the Development of Regional Nutrient Criteria".

EPA (2010). Preliminary estimate of Potential Compliance Costs and Benefits Associated with 

EPA's Proposed Numeric Nutrient Criteria for Florida.

FDEP(2010). FDEP Review of EPA’s “Preliminary Estimate of Potential Compliance Costs and 

Benefits Associated with EPA’s Proposed Numeric Nutrient Criteria for Florida”

FDEP(2010b). Sustaining Our Water Resources. Annual Report on Regional Water Supply 

Planning.

FDEP(2010c). TMDL Water Quality Restoration Grants. Online at 

http://www.dep.state.fl.us/water/watersheds/docs/tmdl-grant-nutrient-costs0210.pdf.

Fed. Reg. 75 (Dec. 6, 2010) 771 

Grumbles, B. Letter to M. Sole, Florida Department of Environmental Protection, 8 (Jan. 14, 

2009).
52

Harrington, J., T. Taylor, S. Lewers, Y. Liu, H.J. Lee, Z. Siddiqui, D. Duch, and R. Markell. Final 

Report: Assistance Project for Wakulla County OSTDS Program, Florida 

Department of Environmental Protection, Oct. 2011.

Harrington, J., and J. Guo, “OSTDS and Decentralized Systems Wastewater Treatment 

Program: Phase I and Phase II,” Final Report to the Florida Department of 

Environmental Protection, Nov. 2006.

Obreza, T., Clark, M., Boman, B., Borisova, T., Cohen, M., Dukes, M., Frazer, T., Hanlon, E., 

Havens, K., Martinez, C., Migliaccio, K., Shukla, S., and Wright, A., (2010) “A Guide 

to EPA's Numeric Nutrient Water Quality Criteria for Florida”. Retrived March 

2011 revised version from http://edis.ifas.ufl.edu/pdffiles/SS/SS52800.pdf

Salomaa, E. and Watkins G. (2011) Environmental Performance and Compliance Costs for 

Industrial Wastewater Treatment – an International Comparison. Sustainable 

Development Vol. 19. pp. 325-336

Soil & Water Engineering Technologies, Inc., (2008). Nutrient Loading Rates, Reduction 

Factors and Implementation Costs Associated with BMPs and Technologies for 

South Florida Water Management District. Retrieved from 

http://www.sccf.org/files/content/docs/Preliminary%20Report%20rev2_sfwm

d.pdf (AKA. SWET(2010))

Spechler, R. (1994) “Saltwater Intrusion and Quality of Water in the Floridan Aquifer System, 

Northeastern Florida” for U.S. GEOLOGICAL SURVEY Water-Resources 

Investigations Report 92-4174

Stanley Consultants (2007) Wastewater Rate Study for City of East Moline

St. Petersburg Times (Nov. 4 2011), editorial.

Stormwater Management Academy (2010) Onsite Sewage Treatment and Disposal Systems 

Evaluation for Nutrient Removal, Interim Report for FDEP

Tuckfield Associates (2009) Report on Water and Wastewater Rate Study for Heritage Ranch 

Community Service District.

University of Florida Institute of Food and Agricultural Sciences (UF/IFAS). 2009. Review of 

Nutrient Management Systems for Florida Vegetable Producers: A White Paper 

from the UF/IFAS Vegetable Fertilizer Task Force. Publication #HS1156. 

http://edis.ifas.ufl.edu/HS1156.
53

Appendix A –Acronyms and Abbreviations

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 

DACS Department of Agriculture and Consumer Services 

DOH Department of Health 

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 

MIB 2-methylisborneol 

MLE Modified Ludzack-Ettinger 

MS4 Municipal separate storm sewer system

NO2 Nitrate 

NO3 Nitrite 
54

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, Inc. 

SWIM Surface Water Improvement and Management 

SWMP Stormwater management program 

TMDL Total maximum daily load 

TN Total nitrogen 

TP Total phosphorus 

TSD Technical Support Document for Water Quality-Based Toxics Control 

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
55

Appendix B – Fact Sheet

Economic Analysis for FDEP Numeric Nutrient Criteria

The FSU Center for Economic Forecasting and Analysis (CEFA) performed an initial 

economic analysis of FDEP’s Numeric Nutrient Standards approved by the Environmental 

Regulation Commission on December 8, 2011. Estimates of the costs potentially 

associated with the FDEP proposed rule were provided to FSU CEFA by FDEP, and cost 

analysis was performed by FSU CEFA for five industry sectors that may incur costs to 

reduce nutrients sufficiently for Florida’s waters to be in compliance with the proposed 

rule. It was assumed that such costs would potentially be incurred by entities in 

waterbodies which do not appear to achieve the standards, based on an assessment by 

FDEP. Costs for domestic and industrial wastewater facilities were estimated based on 

the cost associated with upgrading those facilities to advanced wastewater treatment. 

Costs for agricultural and urban stormwater were based on the acreage and cost associated 

with BMP implementation for those waterbodies20. Costs for septic tanks were based on 

the number of affected systems and costs associated with their upgrade. The initial 

estimate21

Sector

was revised to reflect the rule adopted on December 8th, 2011. The revised 

estimate is:

Low Cost High Cost Median Cost

Industrial Wastewater $3,355,215 $34,566,580 $9,886,313 

Domestic Wastewater $1,838,810 $4,495,552 $2,394,744 

Urban Stormwater $16,392,108 $64,475,626 $31,625,841 

Agricultural Stormwater $19,818,367 $19,818,367 $19,818,367 

Septic Tanks $9,103,203 $26,491,222 $11,082,573 

Total $50,507,704 $149,847,347 $74,807,838 

The Department’s rule represents a significant cost saving in comparison to the recentlyadopted U.S. EPA rule. Estimates of those costs were performed by Cardno ENTRIX22

Sector

with assumptions similar to those assumed for the Department’s rule. The Cardno 

ENTRIX estimated costs were:

Estimated Annual Costs (Million $)

Low Cost High Cost Median Cost

Industrial Wastewater $164 $372 $270 

Domestic Wastewater $17 $66 $41 

Urban Stormwater $25 $115 $61 

Agricultural Stormwater $24 $42 $33 

Septic Tanks $2 $18 $8

Total $298 $533 $415 

 20 Based on FDEP definition of Waterbody Identification (WBID)

21 Based on removal of the costs of associated canals from the total cost analyses.

22 Addendum to the Economic Analysis of the Federal Numeric Nutrient Criteria for Florida. Prepared for 

the Florida Water Quality Coalition by Cardno ENTRIX. July 2011