Assessment of the Revisions to Human Health-Based Water Quality Criteria by the Florida Department of Environmental Protection (FDEP)

The document evaluates the FDEP's proposed revisions to water quality criteria for 81 harmful chemical substances. It argues that the FDEP's reliance on Monte Carlo simulations is premature and flawed, leading to criteria that are substantially less protective than U.S. EPA recommendations. The author highlights failures to protect sensitive populations, including children and subsistence fishers, and criticizes the proposed compliance monitoring plan as inadequate.

• The FDEP's proposed human health criteria (HHC) for the majority of chemical substances are less protective than the recommendations provided by the U.S. EPA. For Class I and I-T waters, 80% of the draft HHC fail to reflect national recommendations, and for Class II, III, and III-L waters, 93% of the revised criteria exceed U.S. EPA recommendations.
• The FDEP used Monte Carlo probability modeling to derive the revised criteria despite U.S. EPA advice against using it as a sole risk assessment tool due to limitations that can lead to biases and overestimates. The author asserts the model is based on sparse or non-existent data for many key parameters, making the resulting predictions of safe concentrations unreliable.
• The proposed HHC fail to adequately protect sensitive populations, including children, the elderly, and immunocompromised individuals. The analysis relied on average adult weights and ingestion rates, ignoring the fact that children have higher risk on a per-body-weight basis and are more susceptible to early life developmental effects.
• The FDEP's fish consumption rate (FCR) assumptions for subsistence fishers are underestimated and fail to account for the high proportion of imported seafood consumed by Floridians. This creates an environmental injustice, particularly for African American communities who may consume fish at subsistence rates.
• The FDEP failed to account for the cumulative or synergistic effects of chemical mixtures. While the agency considered substances separately, the author notes that many harmful chemicals co-occur in industrial effluents and can produce additive or synergistic impacts that increase overall toxicity.
• The proposed compliance assessment plan is inadequate because it requires only three water samples per year to calculate annual average concentrations. The author argues this frequency is too low to reliably detect elevated concentrations or calculate accurate averages.
• The uncertainty factors (UFs) used by FDEP to adjust reference doses (RfDs) and cancer slope factors (CSFs) were insufficient to balance the high uncertainties in the model's parameters. For 21% of the 85 substances analyzed, no UF was applied at all.
• Florida has the second highest cancer burden in the nation, with cancer being the leading cause of death for Floridians as of 2011-2012. The author links this increasing incidence to chemical contaminants in drinking water, emphasizing the need for more conservative water quality criteria.

APA

Burkholder, J. M. (n.d.). Assessment of the Revisions to Human Health-Based Water Quality Criteria by the Florida Department of Environmental Protection (FDEP). Earthjustice. https://earthjustice.org/wp-content/uploads/burkholder20assessment.pdf

Chicago

Burkholder, JoAnn M. Assessment of the Revisions to Human Health-Based Water Quality Criteria by the Florida Department of Environmental Protection (FDEP). Earthjustice, n.d. https://earthjustice.org/wp-content/uploads/burkholder20assessment.pdf.

Wikipedia

{{cite report |last1=Burkholder |first1=JoAnn M. |title=Assessment of the Revisions to Human Health-Based Water Quality Criteria by the Florida Department of Environmental Protection (FDEP) |publisher=Earthjustice |url=https://earthjustice.org/wp-content/uploads/burkholder20assessment.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@techreport{burkholderndassessment, author = {Burkholder, JoAnn M.}, title = {{Assessment of the Revisions to Human Health-Based Water Quality Criteria by the Florida Department of Environmental Protection (FDEP)}}, institution = {Earthjustice}, url = {https://earthjustice.org/wp-content/uploads/burkholder20assessment.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }