On Tuesday, we reported on overblown estimates of how much new water quality rules that limit the amount of waste allowed to be dumped in Florida waterbodies would cost Florida industry. Though the EPA has estimated costs to be around $130 million, the Florida Department of Environmental Protection has projected costs to be in the billions, and its projection has been backed up by another Florida group, the Florida Water Environment Association, a group comprised of representatives from large utilities like JEA and the Department of Environmental Protection itself.
Responding to our piece, Dee Ann Miller, deputy press secretary for the Department of Environmental Protection, writes that all estimates are hypothetical, and that the department is careful not to claim that the FWEA estimates are spot-on:
Various entities, including DEP, EPA, and the FWEA, have estimated the potential costs associated with complying with EPA’s anticipated numeric nutrient criteria for freshwater streams and lakes. Because the final criteria have not been made available, all estimates are based on a hypothetical. In addition, each estimator has used varying assumptions, including how the criteria might be implemented in a specific regulatory context. Depending on the assumptions used, cost estimates vary tremendously.
When EPA promulgates the final freshwater criteria on November 14, previous assumptions can be refined to generate better estimates of the potential impacts. Still, the estimates will involve a wide range of uncertainty. Actual costs of implementation will be facility- or entity-specific, as each will need to make choices associated with treatment upgrades, alternative disposal methods, reuse, and other considerations.
The Department of Environmental Protection has been increasingly vocal about costs associated with the nutrient criteria, but a look at internal emails shows that the department has disputed some of the math behind the high cost estimates for months.
Miller says that cost discrepancies between different agencies are due to “uncertainties” involved in the process of drafting the standards:
DEP cost estimates for domestic wastewater facilities fell between those of EPA and the FWEA because we used different assumptions. Note that FWEA estimated costs only for domestic wastewater facilities, while both DEP and EPA also estimated costs for other entities and activities than could be affected by the new criteria, such as industrial wastewater, urban stormwater runoff, agriculture, etc.