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Florida Lake Management Society Annual Conference, Naples, Florida, June 4 – 7, 2007

A REASONABLE ASSURANCE PLAN FOR LAKE SEMINOLE IN PINELLAS COUNTY FLORIDA – AN ALTERNATIVE TO A TMDL

Kelli Hammer Levy Pinellas County Environmental Management Doug Robison, Dave Tomasko, and Emily Hyfield PBS&J

Lake Seminole is currently listed by the Florida Department of Environmental Protection as an impaired waterbody pursuant to Section 303(d) of the federal Clean Water Act and is scheduled for Total Maximum Daily Load (TMDL) development in 2007. The primary pollutants associated with the lake’s impairment are nutrients, which have resulted in hypereutrophic conditions.

The Clean Water Act regulations recognize that alternative pollution control requirements may obviate the need for a TMDL. Specifically, water bodies that would otherwise be listed as impaired are not required to be included on the Section 303(d) list if other pollution control mechanisms are demonstrated to be stringent enough to result in compliance with water quality standards within a reasonable period of time. These alternatives to TMDLs are referred to as Category 4b waters. Reasonable Assurance documentation is required for formal Category 4b demonstration by the U.S. Environmental Protection Agency (EPA). The EPA guidance on Category 4b demonstrations requires that the following elements be addressed:

1. The identification of the water body and a statement of problems causing the impairment;

  • 2.

    A description of pollution controls and how they will achieve water quality standards;

  • 3.

    An estimate or projection of the time when water quality standards will be met;

  • 4.

    A schedule for implementing pollution controls;

  • 5.

    A monitoring plan to track effectiveness of pollution controls; and

  • 6.

    The commitment to revise pollution controls as necessary.

In addition to addressing the six elements listed above, the Reasonable Assurance plan for Lake Seminole will establish that 1.) Implementation of the major water quality projects set forth in the Lake Seminole Watershed Plan (2001) are sufficient to meet the established restoration goals; and 2.) That the restoration goals for Lake Seminole are appropriate given the unnatural origins of the lake, as well as the significant hydrologic and biological alternations that have taken place since the lake was first constructed.

This presentation will provide an overview of the Reasonable Assurance plan process; outline the County’s progress towards developing a Reasonable Assurance plan for Lake Seminole; and will highlight key components of the Reasonable Assurance plan that will address improvements to water quality within the lake.

Session 6B – Page 2

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