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TMDL Overview

TMDL Overview. Estimates of Cost of Compliance Florida Consumer Fertilizer Task Force. Kurt Spitzer www.florida-stormwater.org kurtspitzer @ksanet.net 850/561-0904. What is a TMDL ?.

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TMDL Overview

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  1. TMDL Overview Estimates of Cost of Compliance Florida Consumer Fertilizer Task Force Kurt Spitzer www.florida-stormwater.org kurtspitzer@ksanet.net 850/561-0904

  2. What is a TMDL? The maximum amount of a pollutant that a water body or water segment can assimilate without exceeding water quality standards.

  3. What is a TMDL? Last component of 1972 CWA to be implemented. Result of numerous lawsuits throughout country seeking to enforce CWA. 1999 - Consent Decree between EPA and EarthJustice in Florida. Legislature passes 403.067, FS, concerning listings. 2005 – Legislature amends 403.067, FS, concerning implementation. Adopts $100M trust fund for water quality and alternative water supply funding.

  4. Problem Statement Unlike most point source discharges, urban stormwater is characterized as: • An unpredictable, episodic discharge • it doesn’t rain every day - we don’t know when its going to rain, for how long, or by how much

  5. Problem Statement Unlike most point source discharges, urban stormwater is characterized as: • From uncontrollable sources and in sometimes untreatable volumes • it ain’t going into or coming out of “a pipe”

  6. Problem Statement Unlike point source discharge programs, urban stormwater has not had the benefit of federal funding to assist in implementation Clean Water Act – 1972 Principal federal program to aid WWT plant construction. 1972-1984 = $41 billion The WWT grant program was the largest non-military public works program since the Interstate Highway System - Congressional Research Service

  7. Problem Statement TMDLs: “…..the largest unfunded environmental mandate in history” - Jimmy Palmer, EPA Administrator Region IV

  8. Estimating Costs of Compliance

  9. Projecting Costs FDEP Allocation Technical Advisory Committee: “Report to the Legislature and Governor on the Allocation of TMDLs in Florida” • Calculate pollutant reductions if 45% of urban areas met stormwater requirements for new construction • Calculate pollutant reductions of 90% of urban areas met stormwater requirements for new construction

  10. Projected Costs City of Tallahassee 2001 Case Study • Developed Area = 23,607 acres • Percentage of area meeting state standards = 6,989 acres (30%) • 45% - 30% = additional 3,634 acres to be retrofitted • Retrofit costs = $7,500 per acre • 45% threshold = $27.3 million • 90% threshold = $100+ million • Unit cost of $180 per capita

  11. Projected Costs #1. FSA 2001 White Paper Estimates • Method One: 33% of State • Impacted Population of 5,274,200 • Unit Cost of $180 Per Capita • Estimated Statewide Cost: $0.950 Billion • Method Two : Municipal Population • Impacted Population of 8,000,000 • Unit Cost of $180 Per Capita • Estimated Statewide Cost: $1.44 Billion

  12. Projected Costs #2. FSA TMDL 2002 Survey Estimates • Method 1-A: Step 1 Compliance • Impacted Population of 5,274,200 • Unit Cost of $279-$559 Per Capita • Statewide Cost: $1.474/$2.947 Billion • Method 1-B : Step 1 Compliance • Impacted Population of 8,000,000 • Unit Cost of $279-$559 Per Capita • Statewide Cost: $2.235/$4.470 Billion

  13. Projected Costs #2. FSA TMDL 2002 Survey Estimates • Method 2-A: Step 2 Compliance • Impacted Population of 5,274,200 • Unit Cost of $796/$1,592 Per Capita • Statewide Cost: $4.198/$8.396 Billion • Method 2-B : Step 2 Compliance • Impacted Population of 8,000,000 • Unit Cost of $796/$1,592 Per Capita • Statewide Cost: $6.368/$12.736 Billion

  14. #3. 2004 Clean Watersheds “Needs Survey”Report to Congress +50% NPS needs (+$2.2 billion/year) Source: 2006 305(b)/303(d) Integrated Report to EPA

  15. Projecting Costs Area of Watersheds Draining to Impaired Waters • Groups 1-4 = 7.1M acres, 650 segments • Group 5 = 3.3M acres, 180 segments • Total = 10.4 million acres

  16. Projecting Costs 10.4 million acres draining to Impaired Waters but… • Some undeveloped • Some agricultural • Everglades • Lake Okeechobee

  17. #4. Projected Costs Total = 10.4 million acres Assume 33% developed 3.48 million x $7,500 = $26.1B 3.48 million x $15,500 = $52.2B

  18. Too Many Dollars / Lb.

  19. Too Many Dollars / Lb.

  20. SUMMARY • Costs are overwhelming. • There is a grossly insufficient amount of state and/or federal assistance available. • It is infinitely more efficient and effective to keep pollutants out of waterbodies than it is to remove pollutants later.

  21. Questions? Kurt Spitzer kurtspitzer@ksanet.net 850/561-0904

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