1. Lee County Government Division of Natural Resources
TMDL/BMAP Update
November 30, 2010
Roland Ottolini, Director
Lee County Division of Natural Resources

2. Lee County Government Division 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
Change in FDOT !! NEW map

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 = Total Load from Natural Land Uses

8. Allocation by % of Non-Background Loading
Non-Background Load at TMDL = TMDL Load – Background Load
= 35, ,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 = Total Load from Natural Land Uses

14. Allocation by % of Non-Background Loading
Non-Background Load at TMDL = TMDL Load – Background Load
= 137, ,492 = 0

15. Imperial River Urban 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 Target TN load at Estuary – 9,085,817 lbs/yr
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 – 9,085,817 lbs/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 = Total Load from Natural Land Uses

21. Allocation by % of Non-Background Loading
Non-Background Load at TMDL = TMDL Load – Background Load
= 1,347, ,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 and Management Activities
Regulations, Ordinances, and Guidelines
Special Studies and Planning Efforts
Streetsweeping
Enhanced O&M Program
Certain Agricultural BMPs
Public Education and Outreach Efforts
PROJECTS
Structural BMPs
Quantifiable Load Reductions
Reductions Not Currently Quantified
Restoration and WQ Improvement Projects
Basic Stormwater Management Program Implementation

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 Government Division 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 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 lbs TN!
Local Governments in Florida with an established Storm Water Utility.
Altamonte Springs, Atlantic Beach, Auburndale, Bay Harbor Island, Boca Raton, Boynton Beach, Brevard County, Cape Coral, Casselberry, Clearwater, Clermont, Cocoa, Cocoa Beach, Collier County, Coral Gables, Dade County, Daytona Beach, Deland, Delray Beach, Deltona, Dunedin, Edgewater, El Portal, Eustis, Fort Lauderdale, Fort Meade, Fort Myers, Fort Pierce, Gainesville, Golden Beach, Hallandale, Hialeah , Hialeah Gardens, Homestead, Hillsborough County, Holly Hill, Jacksonville Beach, Jupiter, Key Biscayne, Kissimmee, Lake Mary, Lake Worth, Largo, Leesburg, Leon County, Longwood, Margate, Medley, Miami, Miami Beach, Miami Shores, Miami Springs, Miami-Dade County, Miramar, Mount Dora, Naples, North Lauderdale, North Miami Beach, North Miami, Oakland Park, Ocala, Ocoee, Oldsmar, Opa-Locka, Orlando, Ormond Beach, Oviedo, Palm Bay, Plant City, Pompano Beach, Port Orange, Port St. Lucie, Safety Harbor, Sanford, Sarasota County, Satellite Beach, South Daytona, South Miami, St. Augustine, St. Petersburg, Sunrise, Surfside, Sweetwater, Tallahassee, Tamarac, Tampa, Tavares, Titusville, Venice, Volusia County, West Miami, West Palm Beach, Wilton Manors, Winter Garden, Winter Park, Winter Springs

31. Lee County Government Division 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?

32. Lee County Government Division 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?

33. Lee County Government Division 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