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USEPA's Proposed Numeric Nutrient Criteria for Florida: Not Ready for Prime Time

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On January 26, 2010, the United State Environmental Protection Agency (USEPA) published proposed numeric nutrient criteria for flowing waters of the State of Florida including lakes, streams and springs. We believe this proposed rule is neither necessary, nor based on sound scientific relationships between nutrients and observed water quality impacts. We conclude that the proposed rule is scientifically flawed to the extent that it is not workable and should be abandoned.

The USEPA has used methods that do not demonstrate a cause and effect relationship between nutrients and impairment, a key criticism of USEPA's own SAB committee charged with review of the Agency's methods. The USEPA continues to utilize methods that are not based in sound scientific principles and have not produced statistically defensible cause and effect relationship between stressor and response.

The USEPA continues to ignore the fact that the eutrophication response in many systems is not simply dependent on nutrient concentrations. In fact, nutrients are rarely the stressors, but rather the eutrophication process is initiated by nutrients, which may result in stressed conditions, typically because of low dissolved oxygen. Numerous multivariate factors contribute to the ultimate expression of a nutrient impact, and simple nutrient criteria, based on empirical univariate relationships for large groups of waterbodies, particularly streams, is simply not possible.

The methods used by the USEPA to derive its proposed criteria were not based on scientifically justifiable assumptions, do not result in scientifically defensible endpoints, and, therefore, represent a flawed, non-scientific approach. The USEPA should work with the FDEP in improving its current TMDL and BMAP programs, which provide sufficient mechanisms to regulate nutrients within the State of Florida.
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Keywords: Eutrophication; Florida Surface Waters; Numeric Nutrient Criteria

Document Type: Research Article

Publication date: 2011-01-01

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