Middle St. Johns - Florida Department of Environmental Protection

Water Quality Assessment Report: Middle St. Johns
185
Recent EPA guidance requires states to include as point sources those
stormwater systems that are covered by a National Pollutant Discharge
Elimination System (NPDES) stormwater permit. However, NPDESpermitted
stormwater discharges are not subject to the same types of effluent
limitations, cannot be centrally collected and treated, and typically have
not invested in treatment controls to the same degree as traditional point
sources. Nonpoint sources include intermittent, rainfall-driven, diffuse
sources of pollutants associated with everyday human activities, including
runoff from urban land uses, agriculture, silviculture, and mining; discharges
from failing septic systems; and atmospheric deposition.
These point and nonpoint definitions do not directly relate to whether
a source is regulated. Some nonpoint sources such as stormwater systems
are permitted under the regulatory programs of the Department or water
management districts, while others, such as agricultural stormwater discharges,
are not. This distinction is important because the implementation
of the allocations to nonpoint sources outside the authority of regulatory
programs will require cooperation from dischargers to implement best management
practices (BMP) voluntarily.
While a “detailed allocation” will ultimately be necessary to implement
a TMDL fully, a key goal of the initial allocation is to assign responsibility
for pollutant load reductions between point and nonpoint sources. For
point sources, allocations will be implemented through the Department’s
NPDES wastewater and stormwater permitting programs. The implementation
of nonpoint source load reductions will be done through a combination
of regulatory and nonregulatory processes.
Initial allocations of pollutant loadings will also be made to historical
sources (e.g., the phosphorus-laden sediments at the bottom of a lake) and
upstream sources (those entering into an impaired waterbody). Upstream
sources include sources outside Florida, and these sources will receive
reduced allocations similar to in-state sources.
The FWRA provided direction for the allocation of TMDLs and
directed the Department to provide guidance on the allocation process
by establishing an Allocation Technical Advisory Committee (ATAC),
consisting of representatives of key stakeholder groups. The committee’s
report recommended a three-step process for developing initial allocations
and addressed detailed allocations for nonpoint sources, stakeholder
involvement, the use of BMPs, and other TMDL implementation issues
(Department, 2001). A copy of the ATAC report can be found at http:
//www.dep.state.fl.us/water/tmdl/docs/Allocation.pdf.
Implementation Programs and Approaches
The FWRA designates the Department as the lead agency in coordinating
the implementation of TMDLs. Existing programs and approaches
through which TMDLs may be carried out include the following:
1. Permitting and other existing regulatory programs, such as NPDES
permits, domestic and industrial wastewater permits, and stormwater/environmental
resource permits. The municipal NPDES
stormwater permittees and copermittees in the Middle St. Johns