Presentation Transcript

1. Lee County GovernmentDivision of Natural Resources TMDL/BMAP Update November 30, 2010 Roland Ottolini, Director Lee County Division of Natural Resources
2. Lee County GovernmentDivision of Natural Resources Many creeks and streams in Lee County have been designated Impaired Waters by either the FDEP or USEPA and by law will have Total Maximum Daily Loads (TMDLs) for each causative pollutant The FDEP has proceeded with adoption of TMDLs for Hendry Creek, Imperial River and the Tidal Caloosahatchee A Basin Management Action Plan (BMAP) is established for each to allocate pollutant reductions to each stakeholder and to demonstrate how compliance will be achieved Lee County is the major stakeholder as we hold the NPDES permit for stormwater discharges and WWTP. This permit will be amended to require projects and programs to fulfill these obligations, in 3 –five year cycles FDEP presented the initial allocations and pollutant reductions in a workshop held on September 21 and 22, 2010 Lee County and others have been given 60 days to review and comment
3. BMAP Process Allocation to Stakeholders Consideration of Existing Projects Development of New Projects Monitoring Plan BMAP Documentation
4. Hendry Creek Watershed
5. Hendry Creek Total Loads
6. Hendry Creek TMDL Requirements TMDL Based on Reference Site Analysis is 0.74 mg/l TMDL Load Results Load at 0.74 mg/l = 35,302 lb/yr Reduction is 34,960 lb/yr
7. Background Load Background Load = Total Load from Natural Land Uses
8. Allocation by % of Non-Background Loading Non-Background Load at TMDL = TMDL Load – Background Load = 35,302 - 31,729 = 3,573 lb/yr
9. Hendry Creek Urban Land-use 1988-2004
10. Imperial River Watershed
11. Imperial River Total Loads
12. TMDL Requirements TMDL Based on Reference Site Analysis is 0.74 mg/l Calculate Load from Target Concentration Target Load: Load at 0.74 mg/l = 137,492 lbs/yr Reduction is 122,249 lbs/yr
13. Background Load Background Load = Total Load from Natural Land Uses
14. Allocation by % of Non-Background Loading Non-Background Load at TMDL = TMDL Load – Background Load = 137,492 - 137,492 = 0
15. Imperial RiverUrban Land-use 1988-2004
16. Caloosahatchee Estuary TMDL 3240A, 3240B, 3240C TMDL for Nutrients Causative Pollutant – Total Nitrogen (TN) Target : Seagrass light requirements in San Carlos Bay TMDL= 23% Reduction in Total Nitrogen (over the entire river basin)
17. Caloosahatchee BMAP Current Total Load at the Estuary – 11,799,762 lbs/yr Current Load from Tidal Portion - 2,063,723 lbs/yr Required Reduction – 2.71 million pounds Target TN load at Estuary – 9,085,817lbs/yr
18. Summary of TMDL
19. Key Stakeholders - Tidal Caloosahatchee Basin Lee County Charlotte County City of Cape Coral City of Ft. Myers East County Water Control District Lucaya CDD FDOT FDACS
20. Background Load Background Load = Total Load from Natural Land Uses
21. Allocation by % of Non-Background Loading Non-Background Load at TMDL = TMDL Load – Background Load = 1,347,568 - 1,116,941 = 257,627
22. Areas of Urban BMPs
23. Difference in Land Uses
24. BMAP Project Credits Eligibility Dates for BMAP Load Reduction Credits are Based on the Data Period Preceding the TMDL Pounds reduced will be subtracted from the total allocation for those projects completed July 1, 2000 and later. Credit counts for treatment above and beyond permit requirements. Example 1 – BMP To Mitigate Construction Example 2 – Regional BMP Example 3 – Retrofit BMP
25. BMAP Project Credits Projects Must Be Operated and Properly Maintained as Permitted. Operation and Maintenance records may be Requested as Part of the Project Review Process. Projects Not Operated as Permitted, Including Older Projects Not Included for Specific Credit, Could Result in Additional Reduction Requirements by the Responsible Entity.
26. Potential Areas Where Projects May Be Best
27. Stakeholder Projects andManagement Activities PROJECTS Structural BMPs Quantifiable Load Reductions Reductions Not Currently Quantified Restoration and WQ Improvement Projects Basic Stormwater Management Program Implementation ACTIVITIES Regulations, Ordinances, and Guidelines Special Studies and Planning Efforts Streetsweeping Enhanced O&M Program Certain Agricultural BMPs Public Education and Outreach Efforts
28. Preliminary Projects Eligible for Credit Structural BMPs (Wet Detention, Baffle Boxes, etc.) Source Controls (Street Sweeping, Education) Special Consideration: Conservation Land Purchases If Land Use Changed After Purchase Note – May be Exchange of Loading from Original Owner to New Owner
29. Lee County GovernmentDivision of Natural Resources Cost of Compliance Removing nutrients from polluted water is proving to be especially costly in urban areas, with costs of $200-$20,000 per pound of nitrogen removed per year. Costs to meet TMDLs in Lee County will be in the multi-millions. Land availability is a major implementation constraint in urban settings. Retrofitting of older urban areas can be very expensive. Most public owned lands are road rights of way and environmental land acquisitions in the headwaters. Technology offered thus far yields very little nutrient reduction efficiency, especially TN Ten Mile Canal Filter Marsh removes an average of 4700 lbs TN/year. This project was built on 10 acres of land already owned by Lee County at a cost of $3m. This yields a cost of $638 per lb TN removed per year, not including land. At this rate, compliance with the Hendry Creek TMDL will cost $22m to meet the required 35,000 lbs/ year load reduction. For the Tidal Caloosahatchee, $98m to remove 153.877 lbs TN!
30. Lee County GovernmentDivision of Natural Resources Questions Does the Dissolved Oxygen (DO) standard apply to our estuaries? Is Total Nitrogen (TN) the causative pollutant? The State has used a reference TN concentration of 0.74 mg/l for the TMDL allocation and load reduction analysis. How can this be achieved when the Event Mean Concentrations (EMCs) for all land uses are above this rate, including wetlands?
31. Lee County GovernmentDivision of Natural Resources Questions What is the purpose of establishing a regulatory concentration that is less than natural conditions loading? Are the loading projections realistic? How do they compare to actual field data? What technologies are available to reduce TN practically and cost effectively? In retrofit scenarios? Why should local governments and other stakeholders bear the entire burden of cleaning up developments that have been permitted and presumed in compliance with current water quality standards?
32. Lee County GovernmentDivision of Natural Resources Recommendations Realistic numbers representative of real problem Give us the technology necessary to succeed State should share the burden by taking the allocation of permitted projects or providing in-kind grants to implement projects to offset their impact State should support the inclusion of new co-applicants under the County’s NPDES MS4 permit for fair and equitable distribution of allocation State needs to adopt SW rules that meet the criteria