Meeting with Florida Local Officials Re: Proposed Numeric Nutrient
Criteria Standards

Wednesday, October 06, 2010

EPA Attendees: Sarah Hospodor-Pallone, OCIR

		  Arvin Ganesan, OCIR

		  Jack Bowles, OCIR

		  Arnita Hannon, OCIR

                          Becky Cook, OCIR

                          Denis Borum, OCIR

		  Ephraim King, OW

                          Bob Sussman, OA

                          Larry Elworth, OA

 		  Stephanie Owens, OPA

                          Allison Wise, R4

                          Jim Giattina, R4

Florida Attendees: Mayor James Tully, City of Titusville

		      Raynetta Grant, Water Resources Director, City of Titusville

 		      Mayor Daniel Raulerson, City of Plant City

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

		      Jim Davenport (Alcalde & Fay), representing Seminole County

                              Chip Merriam, Orlando Utilities Commission

		      Linda ?? (Getting her full name and title)

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

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

Mayor Raulerson: Plant City has a mostly blue-collar population of
25,000. Smithfield Meats recently left the city, causing the city to
lose $6 million in annual revenue through water utility fees, which they
depend on for the city’s operating costs. The additional cost of
implementing the proposed rule (EPA estimate) could cost each family an
additional $200/year, which these families can’t afford. The city
would have to cut its police, fire, and rescue operations. The city
hopes to attract new businesses, but fears the businesses will choose to
go elsewhere due to the proposed higher water and other environmental
standards in Florida. EPA needs to find a more cost-effective
alternative.

Mayor Tully: Titusville has a population of 44,000 and ecotourism is a
major part of the city’s economy. The city has been working with the
FL Department of Environment to develop site-specific TMDLs. The Mayor
stressed the importance of home rule in Florida, emphasizing that there
is no “one-size-fits-all” approach and that the desire is to solve
problems at the lowest level possible, beginning with the State and not
necessarily the federal level.

 City of Cocoa: The city has a population of 16,500, and its utility
supplies water to the Kennedy Space Center and other federal facilities
and military bases. The city has an unemployment rate of 16.7%, plus
upcoming NASA layoffs. The utility supplies chloraminated water through
an extensive distribution system. The federal facilities add additional
treatments to the water, resulting in nitrogen levels that are higher
than the proposed standard.  The Federal Facilities also have to do an
extensive amount of system flushing, since they are distant from the
finished water treatment facilities.

Chip Merriam, OUC: CWA and CAA (BACT, Transport, CAIR rules)
requirements are hitting small communities at the same time, resulting
in very high costs. The Commission wants an exemption for the reuse of
water; reuse of treated wastewater is a critical part of Florida’s
water conservation program along with protecting groundwater resources.
FL DEP requires that 60% of ocean outfall must be reused. The Commission
is also worried about the impact on potable water used for irrigation.

Key Issues

Reuse: the communities need clarifications (levels of treatment,
sources, destinations) on requirements and how existing reuse programs
may fit into requirements of the proposed numeric nutrients rule.

TMDLs: the officials will provide a list of the priority TMDLs impacted
by the proposed numeric nutrient criteria.

Potable water: EPA needs a better understanding of the communities’
concerns and approaches.  Florida Representatives indicated that in many
cased runoff of potable water used for irrigation would exceed the
proposed phosphorous limits.

Difference between a concentration and a load: The local officials are
seeking clarification from EPA and want further dialogue

Follow-up

FL officials will provide clarifications and list of priority TMDLs

Ephraim King (OW) will work with Jim Giattina (R4) and OIR to set up
follow-up conference calls with the Florida officials to explore the key
issues above in more detail.

