April 28, 2010
Last week, the PURRE Water Coalition submitted these written comments to the Environmental Protection Agency in support of its proposal to assign specific numeric standards to the amount of nutrient pollution that is allowed to flow into Florida’s lakes, rivers and other flowing waters (standards for estuaries will be developed in the near future).
Florida has 7,700 lakes, 50,000 miles of rivers and streams, 4,000 square miles of estuaries, and more than 700 freshwater springs. So far, over 500 waters are identified as impaired because of phosphorus or nitrogen pollution, representing approximately 1,000 miles of rivers and streams, 350,000 acres of lakes, and 900 square miles of estuaries.
Today, only a narrative statement exists in state regulations to protect our waters. There is no specific language setting forth standards and really no way to enforce such a subjective regulation. Setting numeric criteria will provide a target and a way to enforce that target to restore waters to a healthy condition and to limit nutrient sources before problems start so currently healthy waters do not become impaired.
Below is the letter PURRE submitted in support of these proposed new regulations. We recognize that the science behind the numbers must be sound and work remains to be done, but the EPA proposal is a good start.
PURRE’s Letter to the U.S. Environmental Protection Agency:
I am submitting these comments on behalf of the PURRE Water Coalition Foundation’s 1,085 members in support of the EPA’s Proposed Numeric Nutrient Criteria (Proposed Water Quality Standards for the State of Florida’s Lakes and Flowing Waters).
PURRE (People United to Restore our Rivers and Estuaries) has members from all walks of life: business owners, workers, individuals, environmentalists, farmers, anglers, Republicans, Democrats, liberals, and conservatives. All of them are alarmed at what has happened to the water quality in South Florida and are determined to keep speaking out until we achieve the necessary change to stop the degradation of our marine environment –which inevitably destroys our quality of life in every way, economically as well as environmentally.
The narrative standards we have in place today clearly are insufficient. The proof? Water that years ago was azure and teeming with marine plant and animal life is now murky and filled with dead plant life choking for oxygen and covered with algae; we suffer regular fish kills and harmful algae blooms threatening the health and well-being not only of marine life but of human beings as well. Our economy takes a hit; our property values plummet.
It is time – long past time – to implement specific numeric standards based on sound science. We understand the development of numeric nutrient criteria is a process that will and should evolve over time and believe the EPA’s pending proposal is a good start. Of great importance is the fact that enforcement is much more difficult without numeric standards; who is to say whether someone is adhering to a narrative standard that is merely uses the word “reasonable,” a subjective term that begs for argument?
Some are complaining about the cost of complying with the new regulations, but the cost of complying is relatively small by comparison to the damage to our economy and the jobs crisis caused in great part by the effects of the deterioration to our water and our beaches. And the costs are successfully being borne elsewhere and successfully; for example, in the Chesapeake Bay area.
Cost-effective solutions exist, and where they do not, PURRE believes that these regulations will breed innovation. Those who deny it and cry, “This will put us out of business,” are simply using scare tactics to prevent the EPA from doing what it must to begin the process that will help save Florida’s invaluable lakes and waterways. What’s more, the cost of cleanup after the damage is done is incalculably higher than the cost of prevention. The sooner we act, the less expensive this vital endeavor will be for everyone.
For all these reasons, and simply because it is the right and ethical thing to do, PURRE asks the EPA, without delay, to adopt its Proposed Numeric Nutrient Criteria (Proposed Water Quality Standards for the State of Florida’s Lakes and Flowing Waters; Federal Register/Vol. 75, No. 16/Tuesday, Jan. 26, 2010, pp. 4174-226). Thank you for the opportunity to submit written comments, and for your time and attention.
Sincerely,
Michael J. Valiquette, Chairman
PURRE Water Coalition Foundation, Inc.
