Chapter 1 Minimum Flows and Levels - Southwest Florida Water ...

Preventing Significant Harm – 15% Change n Habitat Availability
6) The authors of the peer review report state that the 15% habitat loss
criterion remains one of the most subjective aspects of the District's
approach. They do, however, note that staff correctly points out that
there are few thresholds or "bright lines" which can be identified for
establishing MFLs, and that previous peer review panels found the
criterion to be "reasonable and prudent." The panel acknowledges
that the use of the criterion is rational and pragmatic, but claims that
the specific value of 15% is subjective.
Staff agrees that the use of the15% habitat loss criterion for establishing MFLs
may be considered subjective. The criterion was, however, developed based on
review of threshold values used for other minimum flow determinations reported
in the literature and a previous peer review recommendation. Staff acknowledges
that additional documentation could be gathered and reviewed to support or
potentially refine use of a percentage-based habitat-loss criterion for MFLs
development, and plans to hire a consultant to complete this effort. Staff has
also engaged the peer review panel in discussions concerning a potential study
for validating and refining the assumptions associated with use of the 15%
habitat-loss criterion.
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