Be Careful what you ask for… A Florida Example of TMDL Development and Implementation

This paper presents a case study of the development of a total maximum daily load (TMDL) for nutrients in a unique lake system where water detention times are small and available nutrients are elevated. It describes the TMDL development process driven by litigation-based deadlines by which field studies were conducted by a local wastewater utility and incorporated into an analytical model in order to revise the TMDL. The utility's efforts resulted in a revised TMDL with a 20,000 lb/yr increase in allowable loading; however, the costs for TMDL implementation for the utility will likely exceed 40 Million without measurable impact to the lake system if there are not significant load reductions from non-point sources. A history of the utility's efforts through the stakeholder process to revise the TMDL and to voice concerns over the uncertain outcomes of implementing a TMDL based on a limited understanding of the complexities of the lake system is presented. The utility's alternatives for meeting the TMDL will remove or divert flow away from the waterbody during critical drought conditions, which will likely have a detrimental impact on the ecology of the waterbody. Developing and implementing TMDL are meant to restore impaired waterbodies; however, the framework and process under which TMDL are being developed may force stakeholder to take actions that detrimentally alter or ultimately remove the waterbody from existence.