January 16, 2024
Dear Commissioners:
We are Rob Robbins and Percy Angelo. We attended your water quality workshop on December 19, 2023, and are writing to provide you with some thoughts for your ongoing water quality decisions. We are both property owners in Cape Haze. Rob is a marine biologist. Percy is a retired environmental lawyer. We appreciate the attention that you are giving to water quality issues and the very informed discussion at the December 19th workshop. There is an important issue you need to address as you proceed.
In large measure the County’s nitrogen problem results from its disposal of untreated reclaimed water on properties throughout the County
The County’s sewage treatment plants (STPs) only provide secondary treatment. They do not remove nutrients. This means that the County’s reclaimed water has all the nutrients including nitrogen that were in the untreated sewage influent.
All that nitrogen is then redistributed throughout the County through its reclaimed water system to ponds and direct users located on the coasts including Cape Haze. Simple math illustrates that the County is not only failing to reduce nitrogen loading but is exacerbating the problem through new sewer connections and septic-to-sewer conversions.
The total nitrogen concentration in Charlotte County Utilities’ reclaimed water has been reported by county staff to be 34.9 mg/L[1] to as high as 92 mg/L[2]. The reported volume of reclaimed water is typically 1.3 billion gallons annually[3]. This means that the County’s reclaimed water system is discharging between 190 and 500 tons of nitrogen annually to golf courses, community and condo associations, parks, churches, and various businesses for irrigation and other purposes[4]. In fact, irrigating with the County’s reclaimed water is just like treating the property with fertilizer; yet fertilization is barred during parts of the year precisely because of the resulting nutrient pollution.
More nitrogen jeopardizes both Lemon Bay and Charlotte Harbor and contributes to their impaired status. Both are State Aquatic Preserves which FDEP has designated as Outstanding Florida Waters (OFWs).
Further, the County has a high number of sewer and reuse line breaks. These may be inevitable in a County with constant construction (reading the spill reports to FDEP it is evident that construction mishaps are a frequent causes of breaks) but because the spilled material is high in nitrogen each break is another source of nutrient pollution.
Sarasota County has already put septic system conversions on hold until Advanced Wastewater Treatment (AWT) construction is completed at its STPs[5]. Charlotte County should do likewise and minimize its ongoing discharge of nitrogen to the system.
The County’s blind eye to hundreds of tons of nitrogen discharged annually through reclaimed water is an expensive recipe for failure.
The County’s Sewer Master Plan (SMP) objective to “reduce pollution by converting septic to sewer”[6] does nothing to reduce nitrogen in the system. In fact, the County is dumping even more nitrogen into the system with every new septic-to-sewer connection and new housing development, all thanks to the nitrogen-rich reclaimed water system.
One of the means identified by Tony Janicki at your workshop to define Reasonable Assurance Plan (RAP) goals is to refer to “reference periods.” The period from 2003 to 2007 was suggested as a reference period coinciding with healthy seagrass coverages. This coincided with widespread use of septic systems suggesting that septics are not the cause of current impairments. So, what changed in 2007? What did occur in 2007 was the beginning of a 13-year expansion of the County’s reclaimed water system which introduced 24 miles of reclaimed water transmission mains throughout West County including a 16-inch reclaimed water main installed along the coast on Placida Road.[7],[8]
More nitrogen will only cause new and continued water quality impairments. This is one problem where there will necessarily be a real-world demonstration of failure. Choosing a wrong or insufficient solution (even if apparently advantageous at the time of decision) will be exposed by the required ongoing monitoring. This doesn’t have to be the case.
Charlotte County must prioritize resources toward AWT rather than septic conversions.
Charlotte County Ordinance No. 2007-041 clearly defines “reclaimed water” as wastewater having received “advanced secondary treatment.” However, none of Charlotte County’s facilities have operated with advanced treatment (AWT) since the adoption of the ordinance. Florida Statute 403.086 differentiates between “advanced waste treatment” and “secondary wastewater treatment” by defining “advanced waste treatment” as treatment which will provide a reclaimed water product with a total nitrogen concentration not exceeding 3 mg per liter. Florida statutes recognize that nitrogen in reclaimed water is significant and must be limited and the County ordinance recognizes that standard secondary treatment is not sufficient. The County’s four sewage treatment plants and the reclaim water they provide are a significant part of the nitrogen problem (3 mg/L requirement vs 34.7 to 92 mg/L County flows).
Charlotte County is at least three years away from having even one AWT capable facility and it won’t be until the next decade when all four of its facilities will finally operate at AWT standards. Until all Charlotte County facilities are converted to AWT and reclaimed water is the product of AWT processing, Charlotte County has no hope of improving its nitrogen loading to the environment and every new septic-to-sewer conversion makes the nitrogen problem even worse.
The County’s decision-making, and its move toward a Reasonable Assurance Plan (RAP), which we support, must begin with a realistic calculation of nutrient loading from all sources, including spills and reclaimed water. This is simply good science. The data we provided above should be part of the analysis. The point of such analysis is to make sure that we get the most bang for our buck in nutrient control and “cleaner water faster.” Our sense is that the most cost-effective answer is AWT, which will reduce nitrogen throughout the County.
The County’s environmental assets tied to water quality are extraordinary.
At your workshop the Florida Fish and Wildlife Commission (FWC) presentation pointed out that a quarter of the County’s economy is based on natural resources and agriculture: $5.6 billion Real GDP in 2021. Recreational sport fishing is 8-9% of total economic output, 4,300 jobs. Charlotte Harbor tarpon fishing had an economic impact of over $108 million in 2010 and that number is inevitably much higher today.
Beginning with the discovery of juvenile tarpon in the ponds at Lemon Bay Conservancy’s Lemon Creek Wildflower preserve in West County experts have become aware of the crucial role that the creeks and backwaters of the area play in the tarpon life cycle. Ponds located far inland that appear to have limited access to the Harbor and Lemon Bay are in fact protective nurseries for juvenile tarpon.
FWC is currently studying the fish habitat potential of the numerous coastal ponds on Cape Haze and eastern Charlotte Harbor (“Burnt Store”). Copies of maps of the ponds identified so far are attached. It is important to recognize that many other areas of Cape Haze and Burnt Store are likely also essential habitats that will be identified as further sampling proceeds. When Placida Road was widened the workmen initially blundered right through Lemon Creek because the County was not aware of its presence under the Road on its way to Lemon Bay.
Corey Anderson, the FWC speaker at the workshop, suggested incentives for tarpon/sport fish friendly development like the Audubon golf courses. By workshop’s end, Commissioners emphasized the need for development to prioritize and actively account for environmental resource protection, especially critical sport fish nursery habitats. The FWC speaker emphasized this too. We strongly encourage these efforts and believe that your citizens will support them as well.
Thank you for your thoughtful questions about these issues. We believe the answer to restored water quality and the protection of our fragile coastal environment is AWT and future planning decisions must consider conservation of critical sport fish habitat. We look forward to contributing to your further discussions.
Very truly yours,
Robert J. Robbins, PhD (r.robbins@miami.edu)
Percy Angelo (medintzm@yahoo.com)
[1] DEPARTMENT OF ENVIRONMENTAL PROTECTION DISCHARGE MONITORING REPORT – PART A, Charlotte County Utilities Department, PERMIT NUMBER: FLA014098, FACILITY: Rotonda WRF, DESCRIPTION: R-001, including Influent, MONITORING PERIOD: From: 06/01/2023 To: 06/30/2023, Signed Daniel Atkisson, July 13, 2023
[2] DEPARTMENT OF ENVIRONMENTAL PROTECTION DISCHARGE MONITORING REPORT – PART A, Charlotte County Utilities Department, PERMIT NUMBER: FL0040291, FACILITY: Charlotte County Utilities – Eastport WWTP, DESCRIPTION: Public Access Reclaimed Water System, MONITORING PERIOD: From: 10/01/2023 To: 10/31/2023, Signed Michael Mccrumb, November 17, 2023
[3] “Reclaimed Distributed” (figure), Utilities Department Quarterly Meeting Update (presentation) Page 6, Utilities Department Quarterly Update BCC Meeting, January 9, 2024, Charlotte County Board of County Commissioners.
[4] “Reclaimed Water Distribution System”, Chapter 7, Tables 7-2 and 7-3, 2022 ANNUAL REPORT, Charlotte County Utilities Department, Jones Edmunds & Associates, Inc., March 2023.
[5] “County’s plan to eliminate septic tanks on hold Conversion to advanced wastewater treatment has top priority.”
Bob Mudge, Sun Newspapers, December 7, 2022.
[6] Charlotte County Sewer Master Plan, Charlotte County Utilities Department, Jones Edmunds & Associates, Inc., 2017.
[7] Anderson, Zac. “Toilet water keeps counties green.” Sarasota Herald-Tribune. 2007-03-18.
[8] “1.4 DEVELOPMENT OF CCU”, Chapter 1, 2022 ANNUAL REPORT, Charlotte County Utilities Department, Jones Edmunds & Associates, Inc., March 2023.
Preview attachment West County reclaimed water tons N map 1-15-2024.pdf
West County reclaimed water tons N map 1-15-2024.pdf
Preview attachment Overview_Coastal Pond PPT Universe.pdf
Toilet water keeps counties green.pdf
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Wow. Such a well written and informative letter that saves Charlotte County the expense it should have done before shotgunning the problem toward the septic system owners. Science and facts are crucial to environmental concerns and solutions not political maneuvering and good intentions.