Flagler Estates Concerned Citizens, Inc.
Hastings, FL 32145
Administ
Over that past few years, we, the people of Flagler Estates, have been told repeatedly that DEP (Department of Environmental Protection) was preparing to pass regulations regarding TMDLs. TMDLs are Total Maximum Daily Loads for certain indicators of pollutants. Once in place, we were led to believe that failure to meet the new requirements could result in fines of as much as $10,000 per day.
The TMDL requirements were the major justification for the Water Treatment Facility. As is often the case in Flagler Estates, the reality seems to be quite different than what was presented. In an effort to gather more accurate information, two Flagler Estates concerned residents attended the DEP meeting for extra perspective.
The first half of the meeting addressed fecal coliform and lead in Mill Creek, Little Black Creek, Grog Branch, Peters Creek and Greene Creek. Many of these bodies of water are located in Clay County.
The meeting was attended by very few people (Approximately 10 people - 3 District representatives, 2 Flagler Estates residents). Aside from the District Board member, no other elected officials were in attendance.
FDEP must pass TMDL regulations quickly because of the deadline imposed by EPA related to the Federal Government Consent Decree.
It was made clear that involved parties would be required to pay their share and not more.
Jan Mandrup-Paulsen stressed that it is not advisable to ‘over-commit” when considering avenues to address TMDLs.
The case of 16-Mile Creek and dissolved oxygen levels was considered for about 15 minutes.
The likely cause of the problem in 16-Mile Creek was algae.
The seasonal relationship to low oxygen levels in our creek was noted and Mr. Mandrup-Paulsen noted that seasonal problems can be addressed as such.
He said that, in 16-Mile Creek, the problem was not so much the low dissolved oxygen levels but the range of values that are the problem. (See research bullets below.)
He stated that 16-Mile Creek is a Class 3 water body and that the only way to even consider re-evaluating the classification was if there was NO water body present before the creation of the canal/creek. He stressed that there are many legal precedents.
Natural sources for the dissolved oxygen indicator are NOT addressed by DEP.
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On behalf of the Flagler Estates community, research was undertaken in order to gain a better understanding of our situation and the best ways to manage the issue. The information comes from very qualified sources.
On the 1998 303(d) list, 16-Mile Creek was considered a low priority. Compared to the other water bodies discussed, 16-Mile Creek is in comparatively better shape.
There are serious problems with interpreting DO(Dissolved Oxygen) Data. It is not a good indicator of a potential problem.
The biggest condition contributing to the DO readings is the shallowness of the creek.
The way the tests are done give only a snapshot which is inaccurate. This will still be the case when the District is testing. Continuous data collection is more accurate.
DO fluctuations are normal. With ‘5‘ as the DEP acceptable level, it is not unusual to see levels form 1 to 9 in the same body of water - in the same day!
The saturation percentage is actually a more telling of a potential issue than the DO number. 100% saturation is 100% saturation, regardless of the DO number. High temperatures mean saturation occurs at lower levels..
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What can WE realistically do to address the issue?
Decomposing vegetation adds to the problem. Bacteria uses up the oxygen. Ours is a summertime problem. SOOO… spraying should not be done in the summer. It is a balancing act.
When mowing, care should be taken to keep debris out of the canal.
Encourage aeration of the water. This is best done by appropriate, native vegetation. (Not hydrilla or cattails)
Aeration can be aided by vegetation on the banks. As water runs over the vegetation, it is dispersed and picks up air. Bank growth should be encouraged.
Dog poop! (This was a BIG topic. My sources include it in their educational programs, also, so - Here it is!) Animal waste should be kept out of the ditches as much as possible.
Fountains or anything that agitates the water is a good thing. Think about an aerator in a fish tank.
Fish can stir up turbidity (cloudiness). Cloudiness blocks light leading to reduced photosynthesis. A by-product of photosynthesis is oxygen.
Large rain events can lead to the low DO water rising to the top. It can stir up the bottom so the bottom water rises and the oxygenated water sinks to the bottom. This can lead to fish kills because the fish stay toward the top. Fish kills are indicative of oxygen problems. In my 10 years here, I do not recall a fish kill.
DEP issuing $10,000 per day fines -”Not likely!” A timeline and a plan as illustrated above should address the situation.
Palm Coast mechanically removes excess vegetation. This is a good idea because then decomposition does not take place in the water..
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Opinion Time!
A District Staff member was quite argumentative and condescending at this meeting. I cannot help but wonder if it is in the community’s best interest to antagonize DEP.
There may still be some benefit to the District undertaking its own DO testing, despite the fact that it is an unreliable indicator. It will demonstrate good will on our part. While this information will likely be as flawed as what has been collected by DEP and SJRWMD, it is the criteria they are using.
$5,000 worth of good will by purchasing testing equipment seems WAY MORE SENSIBLE than a $20,000,000 Water Treatment Facility. (Yes! I said 20 million) that would be pretty much a very expensive good will gesture. (See FAQs).
Upstream of Flagler Estates at the start of the creek, there is little human activity that can cause pollution. The area is swamp and silviculture (tree farms). After the water leaves Flagler Estates, it is outside of our area of responsibility, control and jurisdiction. . I am uncertain why we must worry about elements and neighbors who are beyond our control. It seems reasonable to let DEP police our neighbors. IT IS NOT OUR JOB.
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Links of Interest
http://edis.ifas.ufl.edu/topic_book_beginners_guide_to_water_management
Class I waters are for POTABLE
WATER SUPPLIES;
Class II waters are for SHELLFISH
PROPAGATION OR HARVESTING;
Class III waters are for RECREATION,
PROPAGATION AND MAINTENANCE
OF A HEALTHY, WELL-BALANCED
POPULATION OF FISH AND WILDLIFE;
Class IV waters are for AGRICULTURAL
WATER SUPPLIES; and
Class V waters are for NAVIGATION,
UTILITY AND INDUSTRIAL USE.
All Florida waterbodies are designated as
Class III unless they have been specifically
classified otherwise (refer to Chapter 62-302.400,
Florida Administrative Code for a list of waterbodies
that are not Class III ).
This information explains WHY 16 -Mile Creek is considered a Class III Waterway. http://edis.ifas.ufl.edu/pdffiles/FA/FA07900.pdf
http://edis.ifas.ufl.edu/pdffiles/FA/FA10600.pdf
http://www.dep.state.fl.us/water/tmdl/index.htm
Flagler Estates Concerned Citizens, Inc.
Hastings, FL 32145
Administ