by SC Contributing Writers Jim Metzler and Jerry Smith
On September 24th and 25th, the Blue Green Algae Task Force (Task Force) held their fourth and fifth meetings. The meeting on the 24th is discussed in a companion article. At the meeting on the 25th, the Task Force worked to create a draft report that will ultimately contain the Task Force’s recommendations. This article will discuss the draft recommendations, what we like about them, and what we think needs to be changed.
The Initial Draft Set of Recommendations
Each section of the initial draft was devoted to a specific topic; e.g., public health. During the meeting Dr. Frazer read each section of the initial draft and then accepted feedback from the other members of the Task Force. At the end of the meeting, he accepted public comments.
To convey a sense of the starting point for the Task Force’s recommendations, the text below will identify one key recommendation from the sections of the initial draft that are of the most interest to the general public.
The initial draft stated that public health issues as they relate to blue-green algae blooms are an increasing concern in Florida. The Task Force recommended a greater investment in this research arena. They stated that of particular importance are studies that address acute and chronic health effects of exposure of humans and other animals to algal toxins.
Basin Management Action Plans (BMAPs)
A BMAP is a restoration road map with an identified suite of projects and/or actions to restore impaired waterbodies. However, as this article points out, the projects and actions associated with the current BMAPs are often criticized for not being effective. The Task Force recommended a more strategic approach to project selection and implementation. The initial draft stated that “Spatially focused suites of projects in areas likely to yield maximum pollutant reduction are encouraged as is the development of a purposeful sampling and monitoring program to ensure the projects (or suites of projects) are working as intended”.
Water Quality Monitoring
A widely held concern is that Florida does not have sufficient monitoring capability to evaluate the effectiveness of specific actions and projects intended to provide environmental benefit. The Task Force recommends an expanded water quality monitoring program in each of the relevant BMAP areas to identify priority areas for project implementation and for subsequent evaluation of project effectiveness in achieving nutrient load reductions.
Agricultural Best Management Practices (BMPs)
According to the Florida Department of Agriculture, “Agricultural Best Management Practices (BMPs) are practical, cost-effective action plans that agricultural producers can take to conserve water and reduce the amount of pesticides, fertilizers, animal waste and other pollutants entering our water resources.” However, similar to BMAPs, BMPs are often criticized for being ineffective. The Task Force recommends that the effectiveness of BMPs be supported by adequate data to justify the presumption of compliance granted upon enrollment and implementation [in the BMP program].
The issue here is that the estimated 2.5 million septic systems in Florida are well-known to be a substantial source of nutrients to groundwater and surface waters across the state. The Task Force recommended that the development and implementation of a septic system inspection and monitoring program with the goal of identifying improperly functioning and/or failing systems so that corrective action can be taken.
We recognize that The Task Force’s draft recommendations are just a first step. There is a lot to like with this first step, including:
- During the meeting much of the discussion focused on adding specificity to the recommendations. It is reasonable to assume the next draft will have more specific recommendations.
- We are pleased that Dr. Frazer will post a revised document with time for thoughtful review prior to a future Task Force meeting to review the revised document.
- The Florida Department of Environmental Protection (FDEP) reports to Governor DeSantis and the Task Force is part of the FDEP. As a result, FDEP-related recommendations, such as those related to BMAPs and septic systems, are likely to be adopted.
- Dr. Frazer has announced that this is not the end of the Task Force. His position is that this first set of recommendations is high level and that developing more detailed recommendations will be the focus of future meetings.
- The emphasis that is being placed on making science-based decisions.
- The Task Force appears to be very receptive to public input and comments.
Areas of Concern
A major concern that we have with the Task Force’s recommendations is the lack of economic context. What is the cost of implementing a recommendation, including the initial capital investment and the ongoing costs? What are the specific benefits? Without having this context, it is difficult for the Florida Legislature to decide to fund any or all of the recommendations. An example of how this has played out in the past is the law that Florida passed in 2010 to require septic system inspections. That law was repealed two years later because it was deemed to be too expensive. See more.
Economic analysis is not part of the Task Force’s charter, nor are they qualified to do that. In the short term, we recommend that the Task Force commission an appropriate party to gather and summarize the existing data on the economics of water in Florida and to include this summary with their report. We would also like the Task Force to include in their report a recommendation that the State of Florida commission a detailed study of the economics of water in Florida.
We believe strongly in the goal of the Task Force – making science-based recommendations. However, we feel that the creation and use of the economic study we are recommending will enable the appropriate parties in Florida to make decisions that are made on a combination of science and a set of economic data that has been vetted and agreed to.
Specificity of Recommendations
As mentioned, the Task Force is part of the FDEP. In addition, senior members of the FDEP have been participating in each of the Task Force’s meetings. As such, the recommendations that are calling for the FDEP to take action, don’t need to be unduly detailed. In contrast, the members of the Florida Legislature have not been participating in the Task Force’s meetings. As such, the recommendations that are calling for the Florida Legislature to take action need to have as much detail as possible.
Sense of Urgency
In their first four meetings the Task Force analyzed several topics that are critical to the restoration of Florida’s waterbodies. However, they didn’t have time to analyze topics, such as land use planning, land conservation, biosolids and the use of fertilizer, that are also critical to the restoration of Florida’s waterbodies. We understand that the Task Force will cover those topics some time in the future. However, given the ongoing threats to Florida’s environment, we are recommending that the Task Force meet more frequently.
Florida’s environment is changing quickly due to factors such as growth in population, changes in land use and impacts of climate change such as wetter wet seasons and drier dry seasons. We believe that the Task Force needs to recommend that the processes that are intended to improve water quality need to be constructed in a way so that they are able to adapt at least as fast as the rate of change in the environment. Otherwise we are always trying to solve yesterday’s problem.
Focus on Prevention
In a previous article we stated: Our hope for the Task Force is that in their report to the Governor and Legislature that they clearly identify the prevention of nutrients flowing into Lake Okeechobee, the estuaries and the Everglades, as a critical requirement.
During their four meetings, the Task Force often talked about the need for preventive measures. However, the word prevention appears just once in the initial draft document. We are recommending that the Task Force write their recommendations in a way that is forward-looking and which focuses on how the recommendations can be used by the FDEP, the Florida Department of Agriculture, the Florida Department of Health and the Florida Legislature in a preventative approach to solving the problems with Florida’s waterbodies.
We are also recommending that the Task Force make some recommendations that are both strategic and preventative, such as recommending that the Florida Legislature fund Florida Forever at the historic level of $300 million per year.
Educate and Communicate
The Task Force is encouraging Florida Department of Health (FDOH) and the FDEP to develop a more robust education and communication plan with easy to consume information, consistent messaging and consistent implementation of advisories when harmful algal blooms are present. We are recommending that the Task Force take a similar approach and develop a robust education and communications plan for their recommendations. The plan must be structured and written to appeal to the general public as well as to key players such as the Florida Legislature. One possible component of the plan is to have Dr. Frazer conduct workshops with the Florida Legislature.
Step Outside of Your Comfort Zone
This recommendation is not about the report the Task Force is writing, but about the overall approach the Task Force is taking.
The Task Force members are renowned researchers and scientists. Throughout the process of conducting meetings, they have methodically worked through several blue-green algae issues with a focus on identifying where there is enough science so that they feel comfortable making a science-based recommendation.
However, the ecological and public health impacts of harmful algal blooms are very detrimental to people, animals and wildlife and are not going away any time soon. As a result, the public needs recommendations that are actionable immediately. We are recommending that the Task Force step out of their comfort zone and make science-based recommendations based on the data we have at hand, recognizing that there are gaps in the data and likely always will be.
We are also recommending that the Task Force step out of its comfort zone and not only make science-based recommendations but also look at how to market those recommendations. We have already given a few examples of what we mean by that. One is to include in the discussion the economics of water, another is to craft the recommendations in a way that they are useful to the Florida Legislature, a third is to proactively educate the Florida Legislature on the recommendations.
We provided our concerns to the Task Force at the meeting on the 25th during the public comment period. If you would like to provide input to the Task Force, go here.