Miami Waterkeeper Provides Supplemental Comments to FDEP Turkey Point NPDES Permit

Miami Waterkeeper and the National Parks Conservation Association (NPCA) jointly provided supplemental technical comments on the Florida Department of Environmental Protection’s (FDEP) Draft National Pollutant Discharge Elimination System (NPDES) Permit for Turkey Point. These comments were submitted in addition to the comments made in May 2019.

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Turkey Point Point Power Plant - Photo Credit: Sun-Sentinel

Earlier this year, FDEP issued a draft permit that raised serious concerns about whether or not the pollution coming from the Cooling Canal system at Turkey Point would be authorized. Miami Waterkeeper and NPCA submitted technical comments on the draft permit which focused on impacts to national parks and protected areas -- specifically highlighting ambiguities in permit scope, monitoring requirements, and definitions of permitted activities. 

Supplemental comments were submitted in an effort to draw attention to Biscayne Bay's rigorous antidegradation standard. As a designated Outstanding Natural Resource Water, Biscayne Bay has a special water quality standard, which states that no reduction of water quality beyond temporary and short-term changes is allowed. The cooling canal system is hydrologically connected to Biscayne Bay, therefore, changes to the permit that would alter water quality would be in violation of this standard.

The supplemental comments also focused on issues of regulatory backsliding -- the idea that new permits cannot reflect less stringent standards than previous permits. Any discharge released to the Bay may be considered “backsliding,” or “a relaxation of effluent limitations” as such discharges represent less rigorous standards. In the draft permit, there is no discussion of the response that would occur in the event that discharge is found to be released to the Bay.

Issues of property ownership, possible discharges into the Everglades Mitigation Bank and publicly-owned lands were also addressed, as these represent possible violations of surface water and groundwater quality.

To read the full supplemental comments, click HERE

Learn more about our campaign to address ongoing pollution at Turkey Point HERE


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Miami Waterkeeper Provides Supplemental Comments to FDEP Turkey Point NPDES Permit
Miami Waterkeeper Provides Supplemental Comments to FDEP Turkey Point NPDES Permit
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