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Turbidity, Coral Reef, Cyanotoxin, and Numeric Nutrient Criteria –Waterkeepers Florida to Florida Triennial Review 2019-11-22

Florida provides Get Out of Jail Free cards for fertilizer, sewage, and manure (FSM), wrote Waterkeepers Florida in this letter sent Friday to the Florida Department of Environmental Protection (FDEP) in its Triennial Review of Water Quality Standards:

If actual substantial harm is eventually found, the only result is a planning processes that lead to Basin Management Action Plans (BMAPs). BMAPs are largely collaborations of the operators of FSM pollution sources, and the only consequence of the failure of the plan to actually curb FSM pollution is a requirement to report the failure. Where BMAPs were hoped to be practical mechanisms to reduce FSM pollution, they have in fact functioned as a “Get Out of Jail Free” card for agriculture industries and other sources of as FSM pollution, while our waters continue to be degraded. The FSM rules have been implemented over the past seven years, during which time, widespread massive algae outbreaks have taken place on the St. Johns River, and in other rivers and lakes throughout Florida.

[Turbidity Criteria]

Much of this letter from most of the members of Waterkeepers Florida, including Suwannee Riverkeeper, is about cyanotoxins, which fortunately we do not yet have in the Suwannee River Basin, and coral reefs, which are a southern Florida regional matter. Yet every regional matter affects the whole state of Florida, the southeast, the nation, and the world. For example, about II. Routes of Ingestion:

This calculation only takes ingestion while swimming into account. Exposure to cyanotoxins can also occur dermally and through inhalation of aerosolized particles. These routes are not taken into consideration, as EPA states, because adequate effects data are not available. The relative source contribution that was a part of the 2016 recommendations has been removed, to focus on the ingestion.

Plus people all over Florida and beyond eat fish caught in the red tide areas: how much exposure to ingested cyanotoxins do we all have?

WKFL Letter

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