1. A coalition of 18 environmental and conservation organizations wrote a letter to express concern about the narrow scope of the National Academies' review of EPA's economic analysis of water quality standards in Florida. 2. The letter argues that only considering implementation costs, and not costs of pollution or economic benefits of clean water, will result in an inaccurate assessment. Certain information about jobs and revenue lost in industries like fishing due to pollution is important. 3. The coalition urges expanding the review's scope to provide a true assessment of the standards' net economic impact, and offered to provide additional comments and data on costs of polluted waterways.

1. 1,000 Friends of Florida * Arthur R. Marshall Foundation * Audubon of Southwest Florida
Clean Water Action * Conservancy of Southwest Florida * Everglades Foundation
Florida Billfish, Inc. * Friends of the Arthur R. Marshall Loxahatchee National Wildlife Refuge
Florida 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

2. harmful algae outbreaks resulting from nitrogen and phosphorous overloads – is critical
to a thorough understanding of the impacts that nutrient pollutants have on Florida’s
economy and the effect that established and enforceable numeric water quality
standards will subsequently have.
Additionally, it is important to understand that whether Florida maintains its existing
regulatory system, adopts the EPA’s proposed numeric nutrient criteria, or adopts
DEP’s proposed nutrient criteria, there will be costs incurred. The question remains
as to who will bear the burden of these costs; industries that cause the pollution, or
those whose livelihoods depend on the availability of unpolluted water? While the cost
of pollution cleanup may be substantial, the implementation policies that are known
and outlined in Florida’s Impaired Waters Rule and other state regulations ensure that
they 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 a
much greater cost to impacted industries and the numerous residents who rely on the
success 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 charge
to ensure that an accurate assessment will be done to determine the true net economic
impact of EPA’s numeric nutrient criteria for freshwater lakes and flowing waters outside
South Florida. We look forward to providing you additional comments and data to offer
insight as to the costs associated with polluted waterways on Florida’s economy and
the economic returns that investments in clean water can provide.
Sincerely,
Charles Pattison John Arthur Marshall
President Chairman of the Board
1,000 Friends of Florida Arthur R. Marshall Foundation
Sarah Larsen Kathleen E. Aterno
President Florida Director
Audubon of Southwest Florida Clean Water Action
Jennifer Hecker Kirk Fordham
Director of Natural Resource Policy Chief Executive Officer
Conservancy of Southwest Florida Everglades Foundation
Dan Kipnis Stephen E. Horowitz, President
Captain Friends of the Arthur R. Marshall
Florida Billfish, Inc Loxahatchee National Wildlife Refuge
Mark D. Perry Alan Farago
Executive Director President
Florida Oceanographic Society Friends of the Everglades

3. Frank Jackalone Drew Martin
Senior Organizing Manager Conservation Chair
Sierra Club Sierra Club Loxahatchee Group
Rick Roberts Grant Campbell
Executive Director Director of Wildlife Policy
Snook and Gamefish Foundation South Florida Audubon Society
Matt Schwartz Barbara Falsey
Executive Director President
South Florida Wildlands Association Urban Environment League
CC:
Dr. Glen T. Daiger, Chair Dr. Otto C. Doering, Vice-Chair
National Academies National Academies
Water Science and Technology Board Water Science and Technology Board
Dr. Leonard Shabman, Vice-Chair Mr. Walter Baker
National Academies National Academies
Water Science and Technology Board Water Science and Technology Board
Dr. Allen Davis Dr. Wendy Graham
National Academies National Academies
Water Science and Technology Board Water Science and Technology Board
Dr. Arturo Keller Dr. David Mulla
National Academies National Academies
Water Science and Technology Board Water Science and Technology Board
Dr. Kevin Sherman Dr. Kurt Stephenson
National Academies National Academies
Water Science and Technology Board Water Science and Technology Board
Mr. Michael Tate Mr. Alan Vicory
National Academies National Academies
Water Science and Technology Board Water Science and Technology Board
Ms. LaJuana Wilcher
National Academies
Water Science and Technology Board