TMDL OverviewTMDL Overview

Kurt Spitzerwww.florida-stormwater.org

kurtspitzer@ksanet.net850/561-0904

Estimates of Cost of ComplianceFlorida Consumer Fertilizer Task Force

What is a TMDL?

The maximum amount of a pollutant that a water body or water segment can assimilate without exceeding water quality standards.

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.

Problem Statement

Unlike most point source discharges, urban stormwater is characterized as:

1. 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

Problem Statement

Unlike most point source discharges, urban stormwater is characterized as:

2. From uncontrollable sources and in sometimes untreatable volumes

• it ain’t going into or coming out of “a pipe”

Problem Statement

Unlike point source discharge programs, urban stormwater has not had the benefit of federal funding to assist in implementation

Clean Water Act – 1972Principal federal program to aid WWT plant

construction. 1972-1984 = $41 billion

The WWT grant program was the largestnon-military public works program since theInterstate Highway System

- Congressional Research Service

Problem Statement

TMDLs:

“…..the largest unfunded environmental mandate in history”

- Jimmy Palmer, EPA Administrator

Region IV

Estimating Costs of Compliance

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

Projected Costs

City of Tallahassee 2001 Case Study

1. Developed Area = 23,607 acres

2. Percentage of area meeting state standards = 6,989 acres (30%)

3. 45% - 30% = additional 3,634 acres to be retrofitted

4. Retrofit costs = $7,500 per acre

• 45% threshold = $27.3 million

• 90% threshold = $100+ million

• Unit cost of $180 per capita

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

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

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

#3. 2004 Clean Watersheds “Needs Survey”Report to Congress

Category of Need Needs ($000)

Category I – Secondary Treatment $ 33,611

Category II – Advanced Treatment $ 4,595,918

Category III-A – Inflow/Infiltration Correction $ 310,526

Category III-B – Major Sewer Rehabilitation $ 960,088

Category IV-A – New Collector Sewers $ 1,752,257

Category IV-B – New Transmission Facilities $ 1,392,458

Category V – Combined Sewer Overflow Correction 0

Category VI – Municipal Separate Storm Sewer System (MS4) Permitted Stormwater Management

$ 2,182,750

Category VII – Nonpoint Source BMPs $ 9,285,007

Category VIII – Confined Animals Point Source 0

Category IX – Mining Point Source 0

Category X – Recycled Reclaimed Water Distribution $ 1,672,115

Category XI – Estuary Management $ 63,073

Florida’s Total Projected Needs for Next 10 Years $22,247,803

(+$2.2 billion/year)

+50% NPS needs

Source: 2006 305(b)/303(d) Integrated Report to EPA

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

Projecting Costs

10.4 million acres draining to Impaired Waters

but…• Some undeveloped

• Some agricultural

• Everglades

• Lake Okeechobee

#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

Too Many Dollars / Lb.

Too Many Dollars / Lb.

SUMMARY

1. Costs are overwhelming.

2. There is a grossly insufficient amount of state and/or federal assistance available.

3. It is infinitely more efficient and effective to keep pollutants out of waterbodies than it is to remove pollutants later.

Questions?Questions?

Kurt Spitzerkurtspitzer@ksanet.net

850/561-0904