EPA review of Florida proposed amendments to human health based surface water quality criteria, rules 62-302.400 and 62-302.530, F.A.C.

Earthjustice, representing St. Johns Riverkeeper and Miami Waterkeeper, urges the EPA to reject Florida's proposed water quality criteria revisions. The statement claims the Florida Department of Environmental Protection (FDEP) violated public participation laws and used an unsound probabilistic risk analysis that fails to protect sensitive populations, such as children and subsistence fishers. The document highlights drastic increases in allowable concentrations for several toxins and the failure to regulate 22 substances recommended by the EPA.

• The State of Florida failed to meet legal public participation requirements by not holding hearings in South or northeast Florida and publishing critical information on August 4, 2016, after the public participation process had ended.
• The FDEP's use of Monte Carlo probability risk analysis is deemed inappropriate for setting human health criteria because it treats uncertainty as variability and ignores correlations among exposure variables.
• The proposed revisions fail to protect vulnerable populations, including children, people aged 65 and over, and subsistence fishers, by relying on 'average adult' weights and underestimating fish consumption rates.
• The proposed rules would significantly increase the allowable maximum concentrations of several hazardous toxins, including a 1429% increase for Beryllium, a 1058% increase for Chloroform, and a 526,315% increase for 1,1-Dichloroethylene.
• Florida's proposal fails to regulate 22 substances listed on the EPA's National Recommended Water Quality Criteria – Human Health Criteria Table, including methylmercury, which is identified as a top priority for Florida's waters.
• The FDEP proposes to replace maximum concentrations with 'annual averages' for 14 dangerous toxins, including Trichloroethylene (TCE) and Carbon Tetrachloride, which the document argues provides a drastic decrease in protection.
• The proposed enforcement strategy of taking only three samples per year is considered inadequate to calculate a reliable average toxic load or detect elevated concentration events.

APA

Earthjustice (2017). EPA review of Florida proposed amendments to human health based surface water quality criteria, rules 62-302.400 and 62-302.530, F.A.C. https://earthjustice.org/wp-content/uploads/final20comments.pdf

Chicago

Earthjustice. EPA review of Florida proposed amendments to human health based surface water quality criteria, rules 62-302.400 and 62-302.530, F.A.C. 2017. https://earthjustice.org/wp-content/uploads/final20comments.pdf.

Wikipedia

{{cite press release |author=Earthjustice |title=EPA review of Florida proposed amendments to human health based surface water quality criteria, rules 62-302.400 and 62-302.530, F.A.C. |date=19 January 2017 |url=https://earthjustice.org/wp-content/uploads/final20comments.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@misc{earthjustice2017epa, author = {{Earthjustice}}, title = {{EPA review of Florida proposed amendments to human health based surface water quality criteria, rules 62-302.400 and 62-302.530, F.A.C.}}, publisher = {Earthjustice}, year = {2017}, month = jan, url = {https://earthjustice.org/wp-content/uploads/final20comments.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }