EPA Wastewater Letter

Henry Kelley will be reading this into record at the EPA Wastewater hearing in Tallahassee on Feb. 16th. There is an effort to coordinate Patriot rallies at the meetings in Tally, Orlando and West Palm Beach next week.

Fort Walton Beach Florida is the home of the newest wastewater plant in the United States. On behalf of the Fort Walton Beach Tea Party, we would like to register our objection to these proposed regulations.

The litigation that was filed to create this issue does not in our opinion, have any basis in supportable science, and we question the EPA’s right to adjudicate this matter based on the 10th amendment. The Fort Walton Beach Tea Party supports responsible means to protect our environment, and our tax dollars going to build a new $60 million dollar waste water plant is tangible proof of our commitment. The EPA was not needed to approve this new facility, so we question how it can now inject itself into a state and local matter.

We protest the following:

1. The proposed rules only apply to the State of Florida, they do not apply to any of the other 49 states. We believe that this may be a violation of the equal protection clause of the US Constitution.

2. There is no clear science behind the rules. The numeric criteria provide for Maximum Contaminant Levels (MCL) are ridiculously low and there is no scientific data to back up the extremely low MCLs for nitrates. There is also no data to support the idea that wastewater treatment plants are a significant source of nitrate contamination in surface water bodies. We believe that agricultural runoff, residential lawn fertilizers and runoff from golf courses are probably all contributing a higher percentage of the nitrate contamination of Florida surface waters and wastewater treatment facilities are way down on the list.

3. In the panhandle, we are being punished for doing a good job of protecting our surface waters by having extremely strict NNC MCLs. Under the rules, Florida is divided into five sub-regions. There are different NNCs depending upon the zone. The more existing impairment, the less strict the NNCs. Our region has much higher surface water quality compared to the other sub-regions. Our NNC MCLs are significantly lower, which makes them even harder to meet.

4. There is not a single wastewater treatment facility in Florida that can currently meet the new limits.

5. The cost for retrofitting every plant in Florida is estimated to be in the tens of billions of dollars. In order to pay for the enormous costs to come into compliance, catastrophic double digit rate increases for all wastewater utility customers in Florida will be required. Meanwhile, the EPA has estimated that it will cost $4 million to retrofit all of Florida’s plants to come into compliance with the new rules. This is another ridiculous number that has no scientific data behind it.

In this economy, we cannot continue to pretend that taxpayers can afford every environmental whim that comes down the pike. We have seen agencies like NOAA threaten the entire Florida Charter Fishing fleet based on limited data, and are very concerned about the hard dollar cost to us as taxpayers. As I stated, Okaloosa counted invested in $60 million barely 60 days ago to have state of the art plant, and based on flawed science we will be asked to pay millions more. We cannot afford anymore, and request that you stop this action.

Meeting locations.

* February 16, 2010 at the Holiday Inn Capitol East
1355 Apalachee Parkway, Tallahassee, FL 32301
o 10:00 a.m. to 12:00 noon (new session)
o 1:00 p.m. to 5:00 p.m.
o 7:00 p.m. to 10:00 p.m.
* February 17, 2010 at the Crowne Plaza Orlando Universal
7800 Universal Boulevard, Orlando, FL 32819
o 1:00 p.m. to 6:30 p.m. (this session has been extended 1.5 hours)
o 7:30 p.m. to 10:00 p.m. (this session will begin 30 minutes later than originally planned)
* February 18, 2010 at the Holiday Inn Palm Beach Airport
1301 Belvedere Road, West Palm Beach, FL 33405
o 12:00 noon to 5:00 p.m. (this session will begin 1 hour earlier than originally planned)
o 6:00 p.m. to 10:00 p.m. (this session will begin 1 hour earlier than originally planned)


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