Comments on scope of economic impact review of nutrient criteria august 11, 2011

1,000 Friends of Florida * Arthur R. Marshall Foundation * Audubon of Southwest Florida Clean Water Action * Conservancy of Southwest Florida * Everglades FoundationFlorida Billfish, Inc. * Friends of the Arthur R. Marshall Loxahatchee National Wildlife RefugeFlorida Oceanographic Society * Friends of the Everglades * Sierra Club Loxahatchee Group Sierra Club * Snook and Gamefish Foundation * South Florida Audubon Society South Florida Wildlands Association * Urban Environment League August 11, 2011 Dr. Laura Ehlers, Senior Staff Officer Water Science and Technology Board 500 Fifth Street, NW, Keck 607 Washington, D.C. 20001 Senator Bill Nelson United States Senate 716 Senate Hart Office Building Washington, D.C. 20510 Lisa Jackson, Administrator U.S. Environmental Protection Agency 61 Forsyth Street, South West Atlanta, GA 30303 Re: Scope of Charge to the National Academies in Reviewing EPA’s Economic Analysis of Final Water Quality Standards for Nutrients for Lakes and Flowing Waters in Florida Dear Dr. Elhers, Senator Nelson and Administrator Jackson: We the undersigned organizations are writing to comment on the scope of review for the ongoing National Academies assessment of EPA’s economic analysis of numeric nutrient water quality standards for Florida’s lakes and flowing waters. We understand the specific charge to the National Academies Water Science and Technology Board is to evaluate the EPA’s analysis based exclusively on cost of implementation. We believe this narrow scope is biased, and will not yield accurate results as to the net economic impacts of the proposed regulation. Only by considering the cost of polluted waters to other leading industries in Florida if these criteria are not implemented, as well as the benefits that will be yielded from their implementation, can the National Academies produce a correct assessment of its impacts to Florida’s economy. While we fully understand the charge given to the Water Science and Technology Board with regard to this ongoing assessment and the limitations that accompany such a narrow scope, we feel strongly that these imposed limitations will prevent the assessment from fulfilling its intended role. Certain information – such as revenue and jobs lost in the commercial and recreational fishing industries due to fish kills and

harmful algae outbreaks resulting from nitrogen and phosphorous overloads – is criticalto a thorough understanding of the impacts that nutrient pollutants have on Florida’seconomy and the effect that established and enforceable numeric water qualitystandards will subsequently have.Additionally, it is important to understand that whether Florida maintains its existingregulatory system, adopts the EPA’s proposed numeric nutrient criteria, or adoptsDEP’s proposed nutrient criteria, there will be costs incurred. The question remainsas to who will bear the burden of these costs; industries that cause the pollution, orthose whose livelihoods depend on the availability of unpolluted water? While the costof pollution cleanup may be substantial, the implementation policies that are knownand outlined in Florida’s Impaired Waters Rule and other state regulations ensure thatthey will be implemented in a way that is both reasonable and cost feasible. Moreover,without these criteria, the financial burden caused by nutrient pollution can represent amuch greater cost to impacted industries and the numerous residents who rely on thesuccess of these businesses to support their families and bolster Florida’s economy.We urge the EPA and National Academies to re-evaluate the scope of this chargeto ensure that an accurate assessment will be done to determine the true net economicimpact of EPA’s numeric nutrient criteria for freshwater lakes and flowing waters outsideSouth Florida. We look forward to providing you additional comments and data to offerinsight as to the costs associated with polluted waterways on Florida’s economy andthe economic returns that investments in clean water can provide.Sincerely,Charles Pattison John Arthur MarshallPresident Chairman of the Board1,000 Friends of Florida Arthur R. Marshall FoundationSarah Larsen Kathleen E. AternoPresident Florida DirectorAudubon of Southwest Florida Clean Water ActionJennifer Hecker Kirk FordhamDirector of Natural Resource Policy Chief Executive OfficerConservancy of Southwest Florida Everglades FoundationDan Kipnis Stephen E. Horowitz, PresidentCaptain Friends of the Arthur R. MarshallFlorida Billfish, Inc Loxahatchee National Wildlife RefugeMark D. Perry Alan FaragoExecutive Director PresidentFlorida Oceanographic Society Friends of the Everglades

Frank Jackalone Drew MartinSenior Organizing Manager Conservation ChairSierra Club Sierra Club Loxahatchee GroupRick Roberts Grant CampbellExecutive Director Director of Wildlife PolicySnook and Gamefish Foundation South Florida Audubon SocietyMatt Schwartz Barbara FalseyExecutive Director PresidentSouth Florida Wildlands Association Urban Environment LeagueCC:Dr. Glen T. Daiger, Chair Dr. Otto C. Doering, Vice-ChairNational Academies National AcademiesWater Science and Technology Board Water Science and Technology BoardDr. Leonard Shabman, Vice-Chair Mr. Walter BakerNational Academies National AcademiesWater Science and Technology Board Water Science and Technology BoardDr. Allen Davis Dr. Wendy GrahamNational Academies National AcademiesWater Science and Technology Board Water Science and Technology BoardDr. Arturo Keller Dr. David MullaNational Academies National AcademiesWater Science and Technology Board Water Science and Technology BoardDr. Kevin Sherman Dr. Kurt StephensonNational Academies National AcademiesWater Science and Technology Board Water Science and Technology BoardMr. Michael Tate Mr. Alan VicoryNational Academies National AcademiesWater Science and Technology Board Water Science and Technology BoardMs. LaJuana WilcherNational AcademiesWater Science and Technology Board

Comments on scope of economic impact review of nutrient criteria august 11, 2011

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