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Dear Reef Relief Member:

The recent closing of many of Key West’s beaches as a result of contamination from fecal coliform bacteria from sewage has raised alarm throughout the Keys. National media attention has been focussed on Key West’s beaches and on dirty canals as far north as Key Largo. Never have the environmental and economic costs of failing to properly treat wastewater been made more obvious or ominous.

Yet at the very time the Florida Keys are faced with this sewage management crisis, the United States Environmental Protection Agency (EPA) is proposing to relax an important standard governing injection wells that receive wastewater from municipal sewage treatment plants. The change will allow common wastewater contaminants—nutrients that feed the algal blooms smothering our reef tracts, bacteria, viruses, heavy metals and other toxins—to migrate underground toward and into sources of drinking water supplies and our oceans.

US Geologic Survey studies conducted on shallow Class V wells in the Upper Keys have proven conclusively that septic contaminants migrate underground from land to nearshore waters in a matter of hours. In theory, deeper Class I wells that receive more hazardous fluids supposedly confine injected contaminants, but in practice that has not proven to be the case.

As the federal law presently stands, Class I municipal wells that inject waste beneath Florida’s drinking water aquifers must insure that the hazardous injected fluid be confined and not move off site. Unfortunately, in a state whose geology has been described as "swiss cheese," many Class I wells, including 13 in South Florida discharging 208 million gallons of waste daily, are leaking badly. Evidence of drinking water degradation in Miami Dade already exists and coral reef scientists suspect that unprecedented algal blooms smothering Palm Beach’s coral reefs may be caused by inadequately-treated sewage flowing from septic systems and injection wells. Other areas of South Florida, including Broward and Pinellas Counties, are the subject of state review for lack of confinement of injected waste.

Under the Safe Drinking Water Act, the State of Florida Department of Environmental Protection (FDEP) is allowed to administer its own injection well program, which includes enforcing the confinement rule that applies to Class I wells. Under the Clean Water Act, the EPA must make sure that states that oversee their own water programs enforce the laws designed to protect both human and environmental health.

The EPA is considering relaxing the containment rule for "certain portions of Florida." This would essentially legalize the leaking wells, with the requirement that the movement of injected fluids be monitored.

Reef Relief is strongly opposed to this rule relaxation for many reasons, two in particular: Once injected, the underground migration of wastewater can be monitored, but not controlled. Or removed. The integrity of our drinking water sources, and the health of our beaches, marine environment and the economy they support are too valuable to put at risk, especially when additional treatment, known as Advanced Wastewater Treatment (AWT) exists. AWT strips out harmful nutrients, toxins and bacteria from the wastewater; the end result is freshwater that can either be safely injected or reused for irrigation.

Secondly, if EPA allows an exception to the confinement rule in the case of a few Florida wells, it will set a legal precedent for all facilities using Class 1 wells to request exceptions. This in turn could ease permitting requirements for new Class I wells and encourage their proliferation.

This issue is especially relevant in Key West, where a Class I well will soon be installed to eliminate the ocean outfall from the city’s wastewater facility. The City of Key West has understood the need to treat wastewater to AWT standards to protect our marine environment and has voluntarily committed to pursuing that course of action. Reef Relief believes that this standard is the only long-term solution to the Key’s and Florida’s wastewater dilemma and that it should be the rule statewide. We urge you to call or write the EPA and voice your objection to this proposed change and encourage them to pursue AWT as a standard for Florida. Each and every voice or letter counts. Thank you for your time and effort on behalf of wild critters clean water and coral polyps everywhere!

WHAT YOU CAN DO TO IMPROVE WATER QUALITY

(1) Call the EPA’s to receive materials on EPA’s proposal. Simply calling will let EPA know that you are monitoring their actions: 800-426-4791 .

(2) For more information and to leave messages, contact Nancy Marsh at (404) 562-9450 or email to marsh.nancy@epa.gov and Howard Beard at (202) 260-8796 or email to beard.howard@epa.gov

(3) Write to: John Hankinson, U.S. EPA Region 4, Atlanta Federal Center, 61 Forsyth Street, Atlanta, GA 30303-8960

Let them know that you support efforts to improve water quality for ourselves and our coral reefs; and you encourage the EPA to require Advanced Wastewater Treatment for all sewage injected into shallow or deep wells in South Florida based on the record documenting lack of confinement in existing wells as a result of the porous geology of the area.

Stand up for clean water now and for our future. Write today. Thank you.

For more information, contact Reef Relief (305) 294-3100 or e-mail us.