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REVIEW OF THE EPA’S ECONOMIC ANALYSIS OF
FINAL WATER QUALITY STANDARDS FOR NUTRIENTS
FOR LAKES AND FLOWING WATERS IN FLORIDA
Committee to Review EPA’s Economic Analysis of Final Water Quality
Standards for Nutrients for Lakes and Flowing Waters in Florida
Water Science and Technology Board
Division on Earth and Life Studies
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THE NATIONAL ACADEMIES PRESS 500 Fifth Street, NW Washington, DC 20001
NOTICE: The project that is the subject of this report was approved by the Govern-
ing Board of the National Research Council, whose members are drawn from the
councils of the National Academy of Sciences, the National Academy of Engineer-
ing, and the Institute of Medicine. The members of the panel responsible for the
report were chosen for their special competences and with regard for appropriate
balance.
Support for this study was provided by the U.S. Environmental Protection Agency
under grant EP-C-09-003, task order 15. Any opinions, findings, conclusions, or
recommendations expressed in this publication are those of the author(s) and do
not necessarily reflect the views of the organizations or agencies that provided sup-
port for the project.
International Standard Book Number-13: 978-0-309-25493-9
International Standard Book Number-10: 0-309-25493-0
Additional copies of this report are available from the National Academies Press,
500 5th Street, NW, Keck 360, Washington, DC 20001; (800) 624-6242 or (202)
334-3313; http://www.nap.edu.
Copyright 2012 by the National Academy of Sciences. All rights reserved.
Printed in the United States of America
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The National Academy of Sciences is a private, nonprofit, self-perpetuating society
of distinguished scholars engaged in scientific and engineering research, dedicated to
the furtherance of science and technology and to their use for the general welfare.
Upon the authority of the charter granted to it by the Congress in 1863, the Acad-
emy has a mandate that requires it to advise the federal government on scientific
and technical matters. Dr. Ralph J. Cicerone is president of the National Academy
of Sciences.
The National Academy of Engineering was established in 1964, under the charter
of the National Academy of Sciences, as a parallel organization of outstanding en-
gineers. It is autonomous in its administration and in the selection of its members,
sharing with the National Academy of Sciences the responsibility for advising the
federal government. The National Academy of Engineering also sponsors engineer-
ing programs aimed at meeting national needs, encourages education and research,
and recognizes the superior achievements of engineers. Dr. Charles M. Vest is presi-
dent of the National Academy of Engineering.
The Institute of Medicine was established in 1970 by the National Academy of
Sciences to secure the services of eminent members of appropriate professions in
the examination of policy matters pertaining to the health of the public. The Insti-
tute acts under the responsibility given to the National Academy of Sciences by its
congressional charter to be an adviser to the federal government and, upon its own
initiative, to identify issues of medical care, research, and education. Dr. Harvey V.
Fineberg is president of the Institute of Medicine.
The National Research Council was organized by the National Academy of Sci-
ences in 1916 to associate the broad community of science and technology with the
Academy’s purposes of furthering knowledge and advising the federal government.
Functioning in accordance with general policies determined by the Academy, the
Council has become the principal operating agency of both the National Academy
of Sciences and the National Academy of Engineering in providing services to
the government, the public, and the scientific and engineering communities. The
Council is administered jointly by both Academies and the Institute of Medicine.
Dr. Ralph J. Cicerone and Dr. Charles M. Vest are chair and vice chair, respectively,
of the National Research Council.
www.nationalacademies.org
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COMMITTEE TO REVIEW EPA’S ECONOMIC ANALYSIS OF
FINAL WATER QUALITY STANDARDS FOR NUTRIENTS
FOR LAKES AND FLOWING WATERS IN FLORIDA
GLEN T. DAIGGER, Chair, CH2M Hill, Englewood, Colorado
OTTO C. DOERING, Vice Chair, Purdue University, West Lafayette,
Indiana
LEONARD A. SHABMAN, Vice Chair, Resources for the Future,
Arlington, Virginia
WALTER L. BAKER, Utah Division of Water Quality, Salt Lake City
ALLEN P. DAVIS, University of Maryland, College Park
K. WILLIAM EASTER, University of Minnesota, St. Paul
WENDY D. GRAHAM, University of Florida, Gainesville
ARTURO A. KELLER, University of California, Santa Barbara
DAVID J. MULLA, University of Minnesota, St. Paul
KEVIN M. SHERMAN, Quanics, Inc., Crestwood, Kentucky
KURT STEPHENSON, Virginia Polytechnic Institute and State
University, Blacksburg
MICHAEL B. TATE, Kansas Department of Health and Environment,
Topeka
ALAN H. VICORY, Ohio River Valley Water Sanitation Commission,
Cincinnati, Ohio
LAJUANA S. WILCHER, English, Lucas, Priest, & Owsley, L.L.P.,
Bowling Green, Kentucky
NRC Staff
LAURA J. EHLERS, Study Director
JEFFREY JACOBS, Scholar
MICHAEL J. STOEVER, Research Associate
ANITA A. HALL, Senior Program Associate
v
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WATER SCIENCE AND TECHNOLOGY BOARD
DONALD I SIEGEL, Chair, Syracuse University, New York
LISA ALVAREZ-COHEN, University of California, Berkeley
EDWARD J. BOUWER, Johns Hopkins University, Baltimore, Maryland
YU-PING CHIN, Ohio State University, Columbus
OTTO C. DOERING, Purdue University, West Lafayette, Indiana
M. SIOBHAN FENNESSY, Kenyon College, Gambier, Ohio
BEN GRUMBLES, Clean Water America Alliance, Washington, D.C.
GEORGE R. HALLBERG, The Cadmus Group, Watertown,
Massachusetts
KENNETH R. HERD, Southwest Florida Water Management District,
Brooksville, Florida
GEORGE M. HORNBERGER, Vanderbilt University, Nashville,
Tennessee
KIMBERLY L. JONES, Howard University, Washington, D.C.
LARRY LARSON, Association of State Floodplain Managers, Madison,
Wisconsin
DAVID H. MOREAU, University of North Carolina, Chapel Hill
DENNIS D. MURPHY, University of Nevada, Reno
MARYLYNN V. YATES, University of California, Riverside
Staff
JEFFREY JACOBS, Director
LAURA J. EHLERS, Senior Program Officer
LAURA E. HELSABECK, Senior Program Officer
STEPHANIE E. JOHNSON, Senior Program Officer
M. JEANNE AQUILINO, Financial and Administrative Associate
ANITA A. HALL, Senior Program Associate
MICHAEL J. STOEVER, Research Associate
SARAH E. BRENNAN, Senior Program Assistant
vi
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Acknowledgment of Reviewers
T
his report has been reviewed in draft form by individuals chosen for
their diverse perspectives and technical expertise, in accordance with
procedures approved by the National Research Council’s Report
Review Committee. The purpose of this independent review is to provide
candid and critical comments that will assist the institution in making its
published report as sound as possible and to ensure that the report meets
institutional standards for objectivity, evidence, and responsiveness to the
study charge. The review comments and draft manuscript remain confiden-
tial to protect the integrity of the deliberative process. We wish to thank the
following individuals for their review of this report:
ROBERT K. DAVIS, University of Colorado, Boulder (emeritus)
PATRICK L. BREZONIK, University of Minnesota, Minneapolis (emeritus)
ROBIN K. CRAIG, Florida State University, Tallahassee
ANDREW FISK, Connecticut River Watershed Council, Greenfield,
Massachusetts
J. WALTER MILON, University of Central Florida, Orlando
PATRICIA E. NORRIS, Michigan State University, East Lansing
DAVID E. RADCLIFFE, University of Georgia, Athens
DAVID STENSEL, University of Washington, Seattle
ROBERT G. TRAVER, Villanova University, Villanova, Pennsylvania
MYRON F. UMAN, Science and Technology for Public Policy LLC,
West Palm Beach, Florida
Although the reviewers listed above have provided many constructive
comments and suggestions, they were not asked to endorse the conclusions
vii
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viii ACKNOWLEDGMENT OF REVIEWERS
or recommendations nor did they see the final draft of the report before its
release. The review of this report was overseen by Robert A. Frosch, Har-
vard University and John J. Boland, Johns Hopkins University. Appointed
by the National Research Council, they were responsible for making certain
that an independent examination of this report was carried out in accor-
dance with institutional procedures and that all review comments were
carefully considered. Responsibility for the final content of this report rests
entirely with the authoring committee and the institution.
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Contents
SUMMARY 1
1 INTRODUCTION 11
Technical Challenges of Nutrient Management in Florida, 12
Impairment of Florida’s Inland Streams, Lakes, and Springs, 18
Water Quality Standards and the TMDL Process, 19
Numeric Nutrient Criteria in Florida, 22
Request for National Research Council Study, 31
References, 33
2 ASSESSMENT AND COMMENTARY ON EPA’S ANALYSIS 35
EPA Cost Analysis Methods: Overview, 35
Sector Cost Assessments, 44
Findings and Recommendations, 78
References, 83
3 A FRAMEWORK FOR INCREMENTAL COST ANALYSIS 88
OF A RULE CHANGE
Introduction, 88
Comparing the Narrative and Numeric Nutrient Criteria Rules, 89
A Cost Analysis Framework, 98
Transparency and Dispute Resolution Under the Proposed
Framework, 112
ix
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x CONTENTS
Findings, 114
References, 115
ACRONYMS 117
APPENDIXES
A Narrative, Numeric, and Proposed Florida Nutrient Criteria
Processes Illustrated 119
B Biographical Sketches of Committee Members and Staff 127
