Miami Waterkeeper Comments on BBTF Draft Report

The Biscayne Bay Task Force (BBTF) is a nine-member interdisciplinary group tasked with reviewing relevant data, prior studies, and reports related to Biscayne Bay. Their objective is to create a comprehensive report with written recommendations to the Mayor and County Commissioners regarding Biscayne Bay restoration and enhancement projects. The BBTF will be 'sunsetting' in August of 2020 -- ending their assembly and delivering the final recommendation report, "A Unified Approach for a Healthy & Resilient Biscayne Bay," to the Board of County Commissioners (BOCC). 

Biscayne Bay (Source: BBTF Draft Report)

Miami Waterkeeper has weighed in as a stakeholder since the BBTF’s inception, providing commentary, and insight regarding Biscayne Bay’s current status. Miami Waterkeeper and Executive Director, Rachel Silverstein Ph.D., delivered a presentation, “What’s Killing the Bay,” to the BBTF on October 2, 2019. View full presentation HERE.

After reviewing 35 presentations from various stakeholder groups and agencies, the BBTF created a draft recommendations report in June of 2020. The seven policy themes include Water Quality, Governance, Infrastructure, Watershed Habitat Restoration and Natural Infrastructure, Marine Debris, Education and Outreach, and Funding. 

The Task Force's overarching recommendation is to create an intergovernmental, 11-member body, called the Biscayne Bay Watershed Management Board (WMB). Members will be represented by the BOCC, League of Cities, South Florida Water Management District Governing Board, Florida Department of Environmental Protection, US Department of the Interior, Florida Fish and Wildlife Conservation Commission, and the Florida Inland Navigation District. The WMB would be supported by a new position called the Chief Bay Officer (CBO), in the County Mayor's office. The WMB and associated County staff would be responsible for collectively improving water quality in Biscayne Bay and South Florida’s watershed. 

Proposed administrative structure and relationships between entities. (Source: BBTF Draft Report).

Miami Waterkeeper supports the adoption of these recommendations. While the report was still in draft form, we made some additional suggestions to supplement the Task Force's overall goals. The following comments were made:

1. Include two additional policy themes to the existing seven: Human Health and Environmental Justice.  

2. Incorporate pollutant load standards with Total Maximum Daily Load requirements.

3. Review a 2011 report where the County committed to adopting a fertilizer ordinance by 2014 in its MS4 Clean Water Act permit.  

4. Recommend fertilizer regulation which includes 0% phosphorus and at least 50% slow-release nitrogen in fertilizer mix.  

5. Expand upon existing water quality monitoring efforts in the areas surrounding Turkey Point Power Plant. Encourage further action on the County’s resolution R-722-16 which supports seeking a commitment from FPL to discontinue the use of the cooling canal system (CSS) at Turkey Point; and more.  

6. Recommend including the National Oceanic and Atmospheric Administration (NOAA), as a member of the WMB as this federal agency has significant research interests, resources, funding, and local investment in the region. Biscayne Bay is also one of their "Habitat Focus Areas."  

7. Recommend enabling all relevant County boards to address Biscayne Bay water quality, sea level rise, resiliency, habitat protection, and environmental justice.  

8. Include environmental justice and equity in its Community Based Organization for Biscayne Bay education.  

9. Consider ‘green infrastructure’ and updating seawall guidelines to be more ecologically friendly and resilient -- consider ‘living shorelines.’   

10. Encourage projects that enable public access to waterways, including connection to the Baywalk. Facilitate access to the Bay for diverse communities, abilities, and age groups, including waiving boat ramp fees and parking fees several times per year.   

11. Recommend setting firm goals including a seagrass restoration target to restore the critical habitat.

12. Recommend a goal of eliminating conventional septic tanks in Miami-Dade County, as suggested in the 1970 Federal Water Quality Administration (DOI) report, “Pollution of the Waters of Dade County, Florida,” which led to the construction of our three waste treatment plants. The report states, “Septic tanks, widely used in Dade County, are public health hazards and contribute to overfertilization.”** 

**Over the last several years, numerous reports have explicitly identified septic system failure as a threat to our Bay. Read a 1949 article HERE, 1970 report HERE, 1984 HERE, and 1993 HERE. Even though there have been countless reports of the issue, nothing has been done to combat the problem. In contrast, more permits are continuously granted, while the County claims that more research needs to be done to evaluate the problem's severity.

On June 29, 2020, the BBTF had its final meeting to discuss and vote on the Task Force's final recommendations. This draft considered our recommendation to incorporate an Environmental Justice theme into the 'Chair’s Letter,' the 'State of the Bay' narrative, and the report’s appendix. We hope that moving forward, the WMB and CBO continue to work with relevant stakeholders and agencies to ensure stringent action plans to restore our shared and precious Bay. 

The BBTF is finalizing the report and scheduling a time to present it to the BOCC in the coming weeks. Miami Waterkeeper will keep you updated with the latest information and progress on the development. Click HERE to read more of Miami Waterkeeper's suggestions in the initial BBTF draft report with our detailed comments in red. Click HERE to read the second BBTF draft report.