Update 2024-05-25: The Santa Fe River BMAP session was no more informative.

If my car has an oil leak and I take it to the dealer, I want to know has it stopped leaking, or at least when will it be fixed so it doesn’t leak, and how far along is it to being fixed. I don’t want to hear a precise torque wrench reading, which nut the wrench turned, etc., at least not until after I’ve heard the progress report.

But FDEP tells us about all the nuts and bolts, makes and models, projects and documents, without ever telling us what have the BMAPs accomplished, compared to their stated goals of reducing nitrogen loadings in springs.

Suwannee BMAP meeting, what progress? 2024-05-24, vs. 2017-04-13 BMAPs and FDEP 2022 Statewide Annual Report

I don’t doubt that it’s a great tool and those using it are qualified and hardworking, the Nitrogen Source Inventory Loading Tool (NSILT) and other tools used in the BMAPs. But they are tools, not the goal. I first want to know progress towards the goal.

After an hour of today’s online public meeting about the Suwannee River Basin Management Action Plan (BMAP), I asked via the questions option:

11:16 AM Me to Staff

Is there a summary document that shows how much nitrate loading has been reduced as a percentage, compared to the goal reduction, then per each major BMAP area, then per spring, with sources? Plus a list of enforcement orders.

11:18 AM Staff to Me

John—all project information (inlcuding reductions) can be found in the Statewide Annual Report https://experience.arcgis.com/experience/f8ac2fddcad44921a8d86340107163bb/?draft=true

Answered JQ

FDEP Statewide Annual Report (STAR) 2022 BMAPs

OK, I went there and that led to a followup question.

11:20 AM Me to Staff

Following the link to the Statewide Annual Report, it says: “As of Dec. 31, 2022, verified projects in the BMAP have reduced 693,972 lbs/yr of total nitrogen towards the 4,075,935 lbs/yr modeled load target.” Is that 4 million number the total intended load? If so, what is the intended reduction amount?

Sent JQ

11:20 AM Me to Staff

Also, why 2022? Are there no data from 2023?

11:22 AM Me to Staff

Why are you not telling the other participants about these qauestions?

Instead of answering my second and third questions, FDEP staff told the attendees there were no more questions about the Suwannee River Basin BMAPs and ended the webinar.

The report they directed me to was for 2022. Maybe this is what they plan to update in July 2024. If so, why did they direct me to the 2022 report?

Meanwhile, I tried examining what those web pages for 2022 say.

Middle and Lower Suwannee River Basin Management Action Plan

Waters in the Middle and Lower Suwannee River Basin Management Action Plan (BMAP) are impaired for Nitrate (NO3). Progress is primarily assessed by project implementation to reduce sources of the impairment parameter(s). ¯The BMAP restoration targets are estimated to be achieved by 2033.

As of Dec. 31, 2022, verified projects in the BMAP have reduced 693,972 lbs/yr of total nitrogen towards the 4,075,935 lbs/yr modeled load target. Additionally, projects currently planned or underway are not included in the above reduction figure, but are viewable in the appended project table. BMAP milestones, if applicable, are detailed in the BMAP StoryMaps.

In order to advance progress on the BMAP, DEP recommends the following actions:

• Implement source reduction and best management practices for existing and new urban development and agricultural sources to prevent excess nutrient input into impaired waters. 
• Promote onsite sewage treatment and disposal systems (OSTDS) enhanced nitrogen treatment or sewer connections.
• Expand wastewater treatment facility upgrades and funding opportunities.
• Maintain existing project infrastructure to continue treatment benefits.
• Review water quality for improvement.

For additional information about this BMAP, please contact Lauren Campbell at (850) 245-8083 or Lauren.Campbell@FloridaDEP.gov. ¯

If the modelled load target is the intended reduction, that’s 17% reduction for the Suwannee BMAP.

That makes this assertion a bit dubious: “Waters in the Middle and Lower Suwannee River Basin Management Action Plan (BMAP) are impaired for Nitrate (NO3). Progress is primarily assessed by project implementation to reduce sources of the impairment parameter(s). The BMAP restoration targets are estimated to be achieved by 2033.”

It’s been seven years since FDEP revealed the Suwannee River Basin BMAP, April 13, 2017. https://wwals.net/?p=32478

Title slide

Let’s call it six years.
17% / 6 = 2.83% per year.

Another nine years at that rate would get 25.5% reduction. Added to the apparent 17% reduction would be about 43% reduction. Not 100%.

Now I don’t know whether the reductions are linear. Maybe they are increasing over time. You’d think FDEP would tell us that.

Withlacoochee River Nitrogen Loading to Groundwater

This arithmetic is assuming the “modeled load target” is the intended reduction, i.e., the “Estimated Load Reduction (lbs-N/yr)” from the April 2017 slides.

Withlacoochee River Nitrogen Reductions by Source

But it doesn’t matter much whether it is actually the “Estimated Total Nitrogen Load to Groundwater (pounds of Nitrogen per year [lbs-N/yr])”, since the estimated load reduction was more than 80% of the estimated total load in the April 2017 tables for the Withlacoochee River, Middle Suwannee River, and Lower Suwannee River.

Middle Suwannee River Nitrogen Loading to Groundwater

The totals from 2017 were, Withlacoochee + Middle Suwannee + Lower Suwannee:

Middle Suwannee River Nitrogen Reductions by Source

Total load: 452,424 + 4,212,493 + 2,332,703 = 6,997,620

Load reduction: 374,069 + 3,518,830 + 2,170,983 = 6,063,882

So that’s 86.7% Load reduction / Total load from April 2017.

Lower Suwannee River Nitrogen Loading to Groundwater

Also, the 2022 figure doesn’t match any of the figures from the individual 2017 tables, and much lower than either of the sums of total load or load reduction from 2017.

Lower Suwannee River Nitrogen Reductions by Source (Fanning/Manatee)

So what is this 4,075,935 lbs/yr modeled load target?

Why is it so different from the April 2017 figures? Is it because it is only about projects completed, as in: “Additionally, projects currently planned or underway are not included in the above reduction figure, but are viewable in the appended project table.”?

If so, what percentage of the overall reduction goal do these reductions represent?

Under BMAP Projects, there is a pie chart for “All Basins TN Reductions Achieved by Completed and Ongoing Projects as of Dec. 31, 2022”.

All Basins TN Reductions Achieved by Completed and Ongoing Projects as of Dec. 31, 2022

So that chart includes projects underway, while the other figures do not.

That chart claims (you can only see these numbers by mousing over the pie chart) 97.157% (674,242) reduction from agriculture, 2.348% (16,296) from stormwater, and 0.495% (3,434) from wastewater. Those total to 100% (693,972).

And that 693,972 is the same as the number in “As of Dec. 31, 2022, verified projects in the BMAP have reduced 693,972 lbs/yr of total nitrogen towards the 4,075,935 lbs/yr modeled load target.”

Yet the pie chart says it includes ongoing projects while the other text says projects underway are not included.

In this context, is there some different between “ongoing” and “underway” of which I am unaware?

With such contradictory and partial information, why should we believe ¯”The BMAP restoration targets are estimated to be achieved by 2033″?

Following the link on “For More Info, See Our StoryMap”, that leads you to another page that requires logging in with an organizational account.

Sign in for Suwannee BMAP StoryMap

Some BMAPs actually do have StoryMaps, such as Upper Wakulla River and Wakulla Spring Basin Management Action Plan. But that one does not seem to say how much nitrogen or phosphate loading has been reduced, much less as a percentage of the total goal.

Maybe it’s in there somewhere.

But why should we have to mouse around to find it?

Since such reductions are the alleged purpose of the BMAPs, why don’t we see progress indicators front and center?

This is all tax-paid information. Why is it not public?

Digging around there is an FDEP page on “July 1, 2025 BMAP Update Progress”.
https://fdep.maps.arcgis.com/apps/dashboards/d889715f3baa479b9d5371d9faf35cb0

Selecting Outstanding Florida Springs BMAPs, that includes 14 BMAPs. It has a table of percentages for various tasks, all of them various projects.

If you select “Nitrogen Source Inventory Loading Tool (NSILT) Updates”, it has a percentage for Stakeholder Meetings. So by attending today’s BMAP meeting, you contributed to FDEP claiming they’re farther along towards completing the BMAPs.

Nitrogen Source Inventory Loading Tool (NSILT) Updates

None of those tasks or their subtasks say anything about how much has nitrogen loading been reduced.

There is a Reductions Summary for all 33 BMAPs as of Dec. 31, 2022.

Reductions Summary for all 33 BMAPs as of Dec. 31, 2022.

It does not have a total for cost estimates for completed, ongoing, planned, or underway projects, but they add up to $19,417,772,250.

For more than $19 billion dollars, don’t the taxpayers deserve to know what are the results compared to what was promised?

Without wading through bits and pieces here and there?

The BMAP meeting for the Santa Fe River Basin started at 1:30 PM today. Maybe it will be more informative.

Update 2024-05-25: No, it wasn’t. My questions and staff’s non-answers:

02:05 PM Me to Staff

Is there a summary document that shows how much nitrate loading has been reduced as a percentage, compared to the goal reduction, then per each major BMAP area, then per spring, with sources? Plus a list of enforcement orders. This information is not in STAR 2022.

02:07 PM Staff to Me

John, if you could please share your email information with us, we will follow up with you regarding your question.

Answered JQ

02:12 PM Me to Staff

Or you could tell the attendees the answers. But you know my email: wwalswatershed@gmail.com

02:12 PM Staff to Me

Thank you.

Many other people also report asking questions that were not relayed to the other attendees, and were not answered by staff.

 -jsq, John S. Quarterman, Suwannee RIVERKEEPER®

You can help with clean, swimmable, fishable, drinkable, water in the 10,000-square-mile Suwannee River Basin in Florida and Georgia by becoming a WWALS member today!
https://wwals.net/donations/

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