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	<title>Comments for Friends of the Everglades</title>
	<atom:link href="http://www.everglades.org/comments/feed/" rel="self" type="application/rss+xml" />
	<link>http://www.everglades.org</link>
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	<lastBuildDate>Wed, 06 Feb 2013 22:42:21 +0000</lastBuildDate>
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	<item>
		<title>Comment on Science by Dean Patterson</title>
		<link>http://www.everglades.org/2012/08/science/#comment-1818</link>
		<dc:creator>Dean Patterson</dc:creator>
		<pubDate>Wed, 06 Feb 2013 22:42:21 +0000</pubDate>
		<guid isPermaLink="false">http://www.everglades.org/?p=1561#comment-1818</guid>
		<description>The tragedy happened in 1997, in Hanover, New Hampshire. The professor was a specialist in toxic metals. However, she was poisoned in her own laboratory by a few drops of the rare, extremely toxic compound dimethyl mercury. The compound is a synthetic, colorless liquid used almost exclusively as a reference standard in a particular type of specialized chemical analysis.</description>
		<content:encoded><![CDATA[<p>The tragedy happened in 1997, in Hanover, New Hampshire. The professor was a specialist in toxic metals. However, she was poisoned in her own laboratory by a few drops of the rare, extremely toxic compound dimethyl mercury. The compound is a synthetic, colorless liquid used almost exclusively as a reference standard in a particular type of specialized chemical analysis.</p>
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	</item>
	<item>
		<title>Comment on Friends Opposes Backpumping Polluted Water into Lake O. by Jean Francois</title>
		<link>http://www.everglades.org/2012/07/friends-opposes-backpumping-polluted-water-into-lake-o/#comment-1690</link>
		<dc:creator>Jean Francois</dc:creator>
		<pubDate>Fri, 23 Nov 2012 18:34:55 +0000</pubDate>
		<guid isPermaLink="false">http://www.everglades.org/?p=1540#comment-1690</guid>
		<description>They&#039;re just ruining the habitat of many animals by doing this. Hopefully it will come to an end soon.</description>
		<content:encoded><![CDATA[<p>They&#8217;re just ruining the habitat of many animals by doing this. Hopefully it will come to an end soon.</p>
]]></content:encoded>
	</item>
	<item>
		<title>Comment on How you can help by Habitats For Kids - A2Z Homeschooling</title>
		<link>http://www.everglades.org/how-you-can-help/#comment-1507</link>
		<dc:creator>Habitats For Kids - A2Z Homeschooling</dc:creator>
		<pubDate>Thu, 05 Jul 2012 19:48:15 +0000</pubDate>
		<guid isPermaLink="false">http://everglades.org/?page_id=455#comment-1507</guid>
		<description>[...] Young Friends of the Everglades At the age of 104, Marjory was clearly ecstatic about the involvement of young people with her cause to save the Everglades! &#8220;Take the children into the Everglades. Let them see it!&#8221; she stated. &#8220;The children are our future and we can&#8217;t do without that!&#8221; Gorgious photographs. [...]</description>
		<content:encoded><![CDATA[<p>[...] Young Friends of the Everglades At the age of 104, Marjory was clearly ecstatic about the involvement of young people with her cause to save the Everglades! &#8220;Take the children into the Everglades. Let them see it!&#8221; she stated. &#8220;The children are our future and we can&#8217;t do without that!&#8221; Gorgious photographs. [...]</p>
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	</item>
	<item>
		<title>Comment on Everglades Day Victory by Everglades Tours</title>
		<link>http://www.everglades.org/2012/03/everglades-day-victory/#comment-1496</link>
		<dc:creator>Everglades Tours</dc:creator>
		<pubDate>Thu, 28 Jun 2012 20:39:47 +0000</pubDate>
		<guid isPermaLink="false">http://www.everglades.org/?p=1423#comment-1496</guid>
		<description>We are a bunch of volunteers and starting a brand new scheme in our community. Your web site offered us with useful info to work on. You have performed a formidable task and our whole neighborhood will likely be thankful to you.</description>
		<content:encoded><![CDATA[<p>We are a bunch of volunteers and starting a brand new scheme in our community. Your web site offered us with useful info to work on. You have performed a formidable task and our whole neighborhood will likely be thankful to you.</p>
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	</item>
	<item>
		<title>Comment on An Everglades-Less South Florida by Wild Florida Airboats</title>
		<link>http://www.everglades.org/2012/04/an-everglades-less-south-florida/#comment-1302</link>
		<dc:creator>Wild Florida Airboats</dc:creator>
		<pubDate>Wed, 16 May 2012 03:02:59 +0000</pubDate>
		<guid isPermaLink="false">http://www.everglades.org/?p=1456#comment-1302</guid>
		<description>Not only do the Florida Everglades supply fresh water to South Florida, but also this series of eco-systems is home to more than forty species of mammals including the alligator, crocodile, egret, heron, osprey, pelican and panther.</description>
		<content:encoded><![CDATA[<p>Not only do the Florida Everglades supply fresh water to South Florida, but also this series of eco-systems is home to more than forty species of mammals including the alligator, crocodile, egret, heron, osprey, pelican and panther.</p>
]]></content:encoded>
	</item>
	<item>
		<title>Comment on Everglades suffering from sulfate runoff and Methylmercury contamination by absolutely love</title>
		<link>http://www.everglades.org/2011/05/everglades-suffering-from-sulfate-runoff-and-methylmercury-contamination/#comment-1141</link>
		<dc:creator>absolutely love</dc:creator>
		<pubDate>Wed, 11 Apr 2012 04:59:37 +0000</pubDate>
		<guid isPermaLink="false">http://everglades.org/?p=665#comment-1141</guid>
		<description>I want to say, Everglades suffering from sulfate runoff and Methylmercury contamination &#124;  Friends of the Everglades   Everglades suffering from sulfate runoff and Methylmercury contamination &#124; is a seriously good blogging site. I might like to offer you my thanks. Heed, absolutely love</description>
		<content:encoded><![CDATA[<p>I want to say, Everglades suffering from sulfate runoff and Methylmercury contamination |  Friends of the Everglades   Everglades suffering from sulfate runoff and Methylmercury contamination | is a seriously good blogging site. I might like to offer you my thanks. Heed, absolutely love</p>
]]></content:encoded>
	</item>
	<item>
		<title>Comment on Everglades Day Victory by Robert E. Lee, Abraham Lincoln, Susan B. Anthony, Homeless Persons, and the Everglades &#124; Watery Foundation</title>
		<link>http://www.everglades.org/2012/03/everglades-day-victory/#comment-1137</link>
		<dc:creator>Robert E. Lee, Abraham Lincoln, Susan B. Anthony, Homeless Persons, and the Everglades &#124; Watery Foundation</dc:creator>
		<pubDate>Mon, 09 Apr 2012 11:29:59 +0000</pubDate>
		<guid isPermaLink="false">http://www.everglades.org/?p=1423#comment-1137</guid>
		<description>[...] just named April 7 of each year as &#8220;Everglades Day&#8221; (beginning in 2013). That is Marjory Stoneman Douglas&#8217; birthday (April 7, 1890 – May 14, 1998). In her famous book, &#8220;River of Grass,&#8221; she [...]</description>
		<content:encoded><![CDATA[<p>[...] just named April 7 of each year as &#8220;Everglades Day&#8221; (beginning in 2013). That is Marjory Stoneman Douglas&#8217; birthday (April 7, 1890 – May 14, 1998). In her famous book, &#8220;River of Grass,&#8221; she [...]</p>
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	</item>
	<item>
		<title>Comment on Write to state legislators and Gov. Scott today: fund Everglades Restoration! by Ukash</title>
		<link>http://www.everglades.org/2012/02/write-to-state-legislators-and-gov-scott-today-fund-everglades-restoration/#comment-1090</link>
		<dc:creator>Ukash</dc:creator>
		<pubDate>Tue, 27 Mar 2012 16:57:13 +0000</pubDate>
		<guid isPermaLink="false">http://www.everglades.org/?p=1347#comment-1090</guid>
		<description>You can help convince them to restore the Everglades restoration budget.</description>
		<content:encoded><![CDATA[<p>You can help convince them to restore the Everglades restoration budget.</p>
]]></content:encoded>
	</item>
	<item>
		<title>Comment on More on Mercury Pollution in the Everglades by Tim Ohr</title>
		<link>http://www.everglades.org/2011/05/mercury-pollution-in-the-everglades/#comment-861</link>
		<dc:creator>Tim Ohr</dc:creator>
		<pubDate>Sat, 18 Feb 2012 11:20:33 +0000</pubDate>
		<guid isPermaLink="false">http://everglades.org/?p=736#comment-861</guid>
		<description>This is the same sort of answer DEP has for everything: We don&#039;t know how it got there. If pressed, they will study it to see how much can be there without hurting anything. They will pay a lot of consultants to do this work and then refer it to a committee. They can they say they are working on a problem when they have merely handed it off and delayed any action. How novel it would be if our DEP took an aggressive approach to unacceptable levels of pollutants in our wetlands and rivers.</description>
		<content:encoded><![CDATA[<p>This is the same sort of answer DEP has for everything: We don&#8217;t know how it got there. If pressed, they will study it to see how much can be there without hurting anything. They will pay a lot of consultants to do this work and then refer it to a committee. They can they say they are working on a problem when they have merely handed it off and delayed any action. How novel it would be if our DEP took an aggressive approach to unacceptable levels of pollutants in our wetlands and rivers.</p>
]]></content:encoded>
	</item>
	<item>
		<title>Comment on More on Mercury Pollution in the Everglades by Chris</title>
		<link>http://www.everglades.org/2011/05/mercury-pollution-in-the-everglades/#comment-590</link>
		<dc:creator>Chris</dc:creator>
		<pubDate>Wed, 11 Jan 2012 03:21:13 +0000</pubDate>
		<guid isPermaLink="false">http://everglades.org/?p=736#comment-590</guid>
		<description>I am doing a report on the destruction of the Everglades and your website exhibits a lot of good points</description>
		<content:encoded><![CDATA[<p>I am doing a report on the destruction of the Everglades and your website exhibits a lot of good points</p>
]]></content:encoded>
	</item>
	<item>
		<title>Comment on More on Mercury Pollution in the Everglades by Larry E. Fink, M.S.</title>
		<link>http://www.everglades.org/2011/05/mercury-pollution-in-the-everglades/#comment-345</link>
		<dc:creator>Larry E. Fink, M.S.</dc:creator>
		<pubDate>Wed, 19 Oct 2011 19:41:18 +0000</pubDate>
		<guid isPermaLink="false">http://everglades.org/?p=736#comment-345</guid>
		<description>October 19, 2011

To Whom It Should Concern:

RE:  Points of Entry into the Promulgation of the Proposed Fish Flesh-Based Mercury WQS and Related TMDLs

As the e-mail embedded below from Florida Department of Environmental Protection&#039;s Eric Shaw indicates, FDEP has no schedule for completing the process of revising the numerical mercury Water Quality Standard (WQS) for Class III Waters of 0.2 ppm wet weight in fish flesh to protect human health.  That process was begun in the last triennium in response to guidance issued by USEPA in 2000.  The promulgation of a legally defensible mercury Total Maximum Daily Load (TMDL) pursuant to Clean Water Act Section 303(d)(1)(C) for each mercury-impaired Florida water body, including the Everglades, is dependent on the adoption of the revised mercury numerical Class III WQS by Florida’s Environmental Resources Commission.  Each TMDL must then be promulgated by August 2012 pursuant to Federal court order.  Under these circumstances, it is doubtful that the court-ordered deadline will be met.

There are a number of mercury-related issues that should be of interest to Friends of the Everglades in the context of protecting endangered species such as the Florida panther, accelerating the mercury WQS promulgation process, and expediting TMDL promulgation for all South Florida mercury-impaired waters, including the Everglades, Big Cypress National Preserve, and Florida Bay.  

These issues raise questions that include:
    (1) Is methylmercury bioaccumulation in the aquatic food chain a toxicological barrier to full use of otherwise suitable critical endangered species habitat? e.g., for the Everglades mink or Florida panther?    
    (2) Is the proposed mercury human health-based Water Quality Criterion also fully protective of wildlife in general and endangered species, such as the Florida panther, in particular?
    (3) Is FDEP in effect relaxing the USEPA threshold for declaring a water body mercury-impaired/compliant by using an age-standardized mercury concentration in largemouth bass?
    (4) What is the design water temperature used to calculate the Everglades TMDL to take into account the observed divergence of the temperature-dependence of mercury methylation and demethylation with increasing temperature?
    (5) Is the approach FDEP uses to include the required margin of safety in its TMDL calculations adequate for lakes, streams, and wetlands in general and for the mercury-impaired Everglades in particular?

I would be happy to assist Friends of the Everglades in addressing these issues, because I have an abiding concern about the Everglades mercury problem and am a recognized expert in the field based on my work as the Inter-Agency Coordinator for the South Florida Mercury Science Program from 1996 to 2000 and as the South Florida Water Management District&#039;s Mercury Program Manager in the period 1993-2004.

Thank you for your consideration in this matter and looking forward to discussing this issue with appropriate staff in the very near future.

Sincerely,
 

Larry E. Fink, M.S.
Owner and Principal
Waterwise Consulting, LLC
http://www.waterwiseconsulting.com
(954) 923-7374 (O)
(954) 226-9663 (C) 
 
Enclosures (2)

----- Forwarded Message -----
From: &quot;Shaw, Eric&quot; 
To: &#039;Larry E. Fink&#039; 
Sent: Thursday, September 22, 2011 10:53 AM
Subject: RE: Proposed Fish Flesh-Based Mercury WQS 

Larry,
 
The current Triennial Review (with proposed revisions to human health-based criteria based on a revised fisn:h consumption rate) is on hold until we finish the development of nutrient standards and revisions to the dissolved oxygen criteria.  So, there is no schedule at present.  We will need to conduct additional public workshops for Triennial Review, so there will be future opportunities to provide comment.  Please let me know if you have any questions.
 
 
Eric Shaw
Environmental Manager
Standards &amp; Assessments Section
Florida Department of Environmental Protection
2600 Blair Stone Road, MS 6511
Tallahassee, FL 32399-2400
Phone: (850) 245-8429
Email: Eric.Shaw@dep.state.fl.us
 
 

Please take a few minutes to share your comments on the service you received from the department by clicking on this link. DEP Customer Survey.


From: Larry E. Fink [mailto:larryfink@waterwiseconsulting.com] 
Sent: Wednesday, September 21, 2011 9:20 PM
To: Shaw, Eric
Subject: Proposed Fish Flesh-Based Mercury WQS 
 
Eric:
 
Hi and hope all is well.  
 
What is the status of the triennial review of the numerical Water Quality Standard (WQS) for mercury in Florida Class III surface waters? What is the schedule for the promulgation of the proposed fish flesh-based numerical WQS of 0.2 ppm on a wet weight basis for methylmercury analyzed as total mercury to protect human health in Class III surface waters?  When and where will there be additional opportunities to comment on the proposed revised mercury WQS prior to subittal for promulgation by the Environmental Regulation Commission?  Please keep me apprised of relevant developments in these regards.
 
Thank you.
 
Larry E. Fink, M.S.
Owner and Principal
Waterwise Consulting, LLC</description>
		<content:encoded><![CDATA[<p>October 19, 2011</p>
<p>To Whom It Should Concern:</p>
<p>RE:  Points of Entry into the Promulgation of the Proposed Fish Flesh-Based Mercury WQS and Related TMDLs</p>
<p>As the e-mail embedded below from Florida Department of Environmental Protection&#8217;s Eric Shaw indicates, FDEP has no schedule for completing the process of revising the numerical mercury Water Quality Standard (WQS) for Class III Waters of 0.2 ppm wet weight in fish flesh to protect human health.  That process was begun in the last triennium in response to guidance issued by USEPA in 2000.  The promulgation of a legally defensible mercury Total Maximum Daily Load (TMDL) pursuant to Clean Water Act Section 303(d)(1)(C) for each mercury-impaired Florida water body, including the Everglades, is dependent on the adoption of the revised mercury numerical Class III WQS by Florida’s Environmental Resources Commission.  Each TMDL must then be promulgated by August 2012 pursuant to Federal court order.  Under these circumstances, it is doubtful that the court-ordered deadline will be met.</p>
<p>There are a number of mercury-related issues that should be of interest to Friends of the Everglades in the context of protecting endangered species such as the Florida panther, accelerating the mercury WQS promulgation process, and expediting TMDL promulgation for all South Florida mercury-impaired waters, including the Everglades, Big Cypress National Preserve, and Florida Bay.  </p>
<p>These issues raise questions that include:<br />
    (1) Is methylmercury bioaccumulation in the aquatic food chain a toxicological barrier to full use of otherwise suitable critical endangered species habitat? e.g., for the Everglades mink or Florida panther?<br />
    (2) Is the proposed mercury human health-based Water Quality Criterion also fully protective of wildlife in general and endangered species, such as the Florida panther, in particular?<br />
    (3) Is FDEP in effect relaxing the USEPA threshold for declaring a water body mercury-impaired/compliant by using an age-standardized mercury concentration in largemouth bass?<br />
    (4) What is the design water temperature used to calculate the Everglades TMDL to take into account the observed divergence of the temperature-dependence of mercury methylation and demethylation with increasing temperature?<br />
    (5) Is the approach FDEP uses to include the required margin of safety in its TMDL calculations adequate for lakes, streams, and wetlands in general and for the mercury-impaired Everglades in particular?</p>
<p>I would be happy to assist Friends of the Everglades in addressing these issues, because I have an abiding concern about the Everglades mercury problem and am a recognized expert in the field based on my work as the Inter-Agency Coordinator for the South Florida Mercury Science Program from 1996 to 2000 and as the South Florida Water Management District&#8217;s Mercury Program Manager in the period 1993-2004.</p>
<p>Thank you for your consideration in this matter and looking forward to discussing this issue with appropriate staff in the very near future.</p>
<p>Sincerely,</p>
<p>Larry E. Fink, M.S.<br />
Owner and Principal<br />
Waterwise Consulting, LLC<br />
<a href="http://www.waterwiseconsulting.com" rel="nofollow">http://www.waterwiseconsulting.com</a><br />
(954) 923-7374 (O)<br />
(954) 226-9663 (C) </p>
<p>Enclosures (2)</p>
<p>&#8212;&#8211; Forwarded Message &#8212;&#8211;<br />
From: &#8220;Shaw, Eric&#8221;<br />
To: &#8216;Larry E. Fink&#8217;<br />
Sent: Thursday, September 22, 2011 10:53 AM<br />
Subject: RE: Proposed Fish Flesh-Based Mercury WQS </p>
<p>Larry,</p>
<p>The current Triennial Review (with proposed revisions to human health-based criteria based on a revised fisn:h consumption rate) is on hold until we finish the development of nutrient standards and revisions to the dissolved oxygen criteria.  So, there is no schedule at present.  We will need to conduct additional public workshops for Triennial Review, so there will be future opportunities to provide comment.  Please let me know if you have any questions.</p>
<p>Eric Shaw<br />
Environmental Manager<br />
Standards &amp; Assessments Section<br />
Florida Department of Environmental Protection<br />
2600 Blair Stone Road, MS 6511<br />
Tallahassee, FL 32399-2400<br />
Phone: (850) 245-8429<br />
Email: <a href="mailto:Eric.Shaw@dep.state.fl.us">Eric.Shaw@dep.state.fl.us</a></p>
<p>Please take a few minutes to share your comments on the service you received from the department by clicking on this link. DEP Customer Survey.</p>
<p>From: Larry E. Fink [mailto:larryfink@waterwiseconsulting.com]<br />
Sent: Wednesday, September 21, 2011 9:20 PM<br />
To: Shaw, Eric<br />
Subject: Proposed Fish Flesh-Based Mercury WQS </p>
<p>Eric:</p>
<p>Hi and hope all is well.  </p>
<p>What is the status of the triennial review of the numerical Water Quality Standard (WQS) for mercury in Florida Class III surface waters? What is the schedule for the promulgation of the proposed fish flesh-based numerical WQS of 0.2 ppm on a wet weight basis for methylmercury analyzed as total mercury to protect human health in Class III surface waters?  When and where will there be additional opportunities to comment on the proposed revised mercury WQS prior to subittal for promulgation by the Environmental Regulation Commission?  Please keep me apprised of relevant developments in these regards.</p>
<p>Thank you.</p>
<p>Larry E. Fink, M.S.<br />
Owner and Principal<br />
Waterwise Consulting, LLC</p>
]]></content:encoded>
	</item>
	<item>
		<title>Comment on More on Mercury Pollution in the Everglades by Larry E. Fink, M.S.</title>
		<link>http://www.everglades.org/2011/05/mercury-pollution-in-the-everglades/#comment-344</link>
		<dc:creator>Larry E. Fink, M.S.</dc:creator>
		<pubDate>Wed, 19 Oct 2011 19:40:29 +0000</pubDate>
		<guid isPermaLink="false">http://everglades.org/?p=736#comment-344</guid>
		<description>October 19, 2011

To Whom It Should Concern:
RE:  Points of Entry into the Promulgation of the Proposed Fish Flesh-Based Mercury WQS and Related TMDLs

As the e-mail embedded below from Florida Department of Environmental Protection&#039;s Eric Shaw indicates, FDEP has no schedule for completing the process of revising the numerical mercury Water Quality Standard (WQS) for Class III Waters of 0.2 ppm wet weight in fish flesh to protect human health.  That process was begun in the last triennium in response to guidance issued by USEPA in 2000.  The promulgation of a legally defensible mercury Total Maximum Daily Load (TMDL) pursuant to Clean Water Act Section 303(d)(1)(C) for each mercury-impaired Florida water body, including the Everglades, is dependent on the adoption of the revised mercury numerical Class III WQS by Florida’s Environmental Resources Commission.  Each TMDL must then be promulgated by August 2012 pursuant to Federal court order.  Under these circumstances, it is doubtful that the court-ordered deadline will be met.

There are a number of mercury-related issues that should be of interest to Friends of the Everglades in the context of protecting endangered species such as the Florida panther, accelerating the mercury WQS promulgation process, and expediting TMDL promulgation for all South Florida mercury-impaired waters, including the Everglades, Big Cypress National Preserve, and Florida Bay.  

These issues raise questions that include:
    (1) Is methylmercury bioaccumulation in the aquatic food chain a toxicological barrier to full use of otherwise suitable critical endangered species habitat? e.g., for the Everglades mink or Florida panther?    
    (2) Is the proposed mercury human health-based Water Quality Criterion also fully protective of wildlife in general and endangered species, such as the Florida panther, in particular?
    (3) Is FDEP in effect relaxing the USEPA threshold for declaring a water body mercury-impaired/compliant by using an age-standardized mercury concentration in largemouth bass?
    (4) What is the design water temperature used to calculate the Everglades TMDL to take into account the observed divergence of the temperature-dependence of mercury methylation and demethylation with increasing temperature?
    (5) Is the approach FDEP uses to include the required margin of safety in its TMDL calculations adequate for lakes, streams, and wetlands in general and for the mercury-impaired Everglades in particular?

I would be happy to assist Friends of the Everglades in addressing these issues, because I have an abiding concern about the Everglades mercury problem and am a recognized expert in the field based on my work as the Inter-Agency Coordinator for the South Florida Mercury Science Program from 1996 to 2000 and as the South Florida Water Management District&#039;s Mercury Program Manager in the period 1993-2004.

Thank you for your consideration in this matter and looking forward to discussing this issue with appropriate staff in the very near future.

Sincerely,
 

Larry E. Fink, M.S.
Owner and Principal
Waterwise Consulting, LLC
http://www.waterwiseconsulting.com
(954) 923-7374 (O)
(954) 226-9663 (C) 
 
Enclosures (2)

----- Forwarded Message -----
From: &quot;Shaw, Eric&quot; 
To: &#039;Larry E. Fink&#039; 
Sent: Thursday, September 22, 2011 10:53 AM
Subject: RE: Proposed Fish Flesh-Based Mercury WQS 

Larry,
 
The current Triennial Review (with proposed revisions to human health-based criteria based on a revised fisn:h consumption rate) is on hold until we finish the development of nutrient standards and revisions to the dissolved oxygen criteria.  So, there is no schedule at present.  We will need to conduct additional public workshops for Triennial Review, so there will be future opportunities to provide comment.  Please let me know if you have any questions.
 
 
Eric Shaw
Environmental Manager
Standards &amp; Assessments Section
Florida Department of Environmental Protection
2600 Blair Stone Road, MS 6511
Tallahassee, FL 32399-2400
Phone: (850) 245-8429
Email: Eric.Shaw@dep.state.fl.us
 
 

Please take a few minutes to share your comments on the service you received from the department by clicking on this link. DEP Customer Survey.


From: Larry E. Fink [mailto:larryfink@waterwiseconsulting.com] 
Sent: Wednesday, September 21, 2011 9:20 PM
To: Shaw, Eric
Subject: Proposed Fish Flesh-Based Mercury WQS 
 
Eric:
 
Hi and hope all is well.  
 
What is the status of the triennial review of the numerical Water Quality Standard (WQS) for mercury in Florida Class III surface waters? What is the schedule for the promulgation of the proposed fish flesh-based numerical WQS of 0.2 ppm on a wet weight basis for methylmercury analyzed as total mercury to protect human health in Class III surface waters?  When and where will there be additional opportunities to comment on the proposed revised mercury WQS prior to subittal for promulgation by the Environmental Regulation Commission?  Please keep me apprised of relevant developments in these regards.
 
Thank you.
 
Larry E. Fink, M.S.
Owner and Principal
Waterwise Consulting, LLC</description>
		<content:encoded><![CDATA[<p>October 19, 2011</p>
<p>To Whom It Should Concern:<br />
RE:  Points of Entry into the Promulgation of the Proposed Fish Flesh-Based Mercury WQS and Related TMDLs</p>
<p>As the e-mail embedded below from Florida Department of Environmental Protection&#8217;s Eric Shaw indicates, FDEP has no schedule for completing the process of revising the numerical mercury Water Quality Standard (WQS) for Class III Waters of 0.2 ppm wet weight in fish flesh to protect human health.  That process was begun in the last triennium in response to guidance issued by USEPA in 2000.  The promulgation of a legally defensible mercury Total Maximum Daily Load (TMDL) pursuant to Clean Water Act Section 303(d)(1)(C) for each mercury-impaired Florida water body, including the Everglades, is dependent on the adoption of the revised mercury numerical Class III WQS by Florida’s Environmental Resources Commission.  Each TMDL must then be promulgated by August 2012 pursuant to Federal court order.  Under these circumstances, it is doubtful that the court-ordered deadline will be met.</p>
<p>There are a number of mercury-related issues that should be of interest to Friends of the Everglades in the context of protecting endangered species such as the Florida panther, accelerating the mercury WQS promulgation process, and expediting TMDL promulgation for all South Florida mercury-impaired waters, including the Everglades, Big Cypress National Preserve, and Florida Bay.  </p>
<p>These issues raise questions that include:<br />
    (1) Is methylmercury bioaccumulation in the aquatic food chain a toxicological barrier to full use of otherwise suitable critical endangered species habitat? e.g., for the Everglades mink or Florida panther?<br />
    (2) Is the proposed mercury human health-based Water Quality Criterion also fully protective of wildlife in general and endangered species, such as the Florida panther, in particular?<br />
    (3) Is FDEP in effect relaxing the USEPA threshold for declaring a water body mercury-impaired/compliant by using an age-standardized mercury concentration in largemouth bass?<br />
    (4) What is the design water temperature used to calculate the Everglades TMDL to take into account the observed divergence of the temperature-dependence of mercury methylation and demethylation with increasing temperature?<br />
    (5) Is the approach FDEP uses to include the required margin of safety in its TMDL calculations adequate for lakes, streams, and wetlands in general and for the mercury-impaired Everglades in particular?</p>
<p>I would be happy to assist Friends of the Everglades in addressing these issues, because I have an abiding concern about the Everglades mercury problem and am a recognized expert in the field based on my work as the Inter-Agency Coordinator for the South Florida Mercury Science Program from 1996 to 2000 and as the South Florida Water Management District&#8217;s Mercury Program Manager in the period 1993-2004.</p>
<p>Thank you for your consideration in this matter and looking forward to discussing this issue with appropriate staff in the very near future.</p>
<p>Sincerely,</p>
<p>Larry E. Fink, M.S.<br />
Owner and Principal<br />
Waterwise Consulting, LLC<br />
<a href="http://www.waterwiseconsulting.com" rel="nofollow">http://www.waterwiseconsulting.com</a><br />
(954) 923-7374 (O)<br />
(954) 226-9663 (C) </p>
<p>Enclosures (2)</p>
<p>&#8212;&#8211; Forwarded Message &#8212;&#8211;<br />
From: &#8220;Shaw, Eric&#8221;<br />
To: &#8216;Larry E. Fink&#8217;<br />
Sent: Thursday, September 22, 2011 10:53 AM<br />
Subject: RE: Proposed Fish Flesh-Based Mercury WQS </p>
<p>Larry,</p>
<p>The current Triennial Review (with proposed revisions to human health-based criteria based on a revised fisn:h consumption rate) is on hold until we finish the development of nutrient standards and revisions to the dissolved oxygen criteria.  So, there is no schedule at present.  We will need to conduct additional public workshops for Triennial Review, so there will be future opportunities to provide comment.  Please let me know if you have any questions.</p>
<p>Eric Shaw<br />
Environmental Manager<br />
Standards &amp; Assessments Section<br />
Florida Department of Environmental Protection<br />
2600 Blair Stone Road, MS 6511<br />
Tallahassee, FL 32399-2400<br />
Phone: (850) 245-8429<br />
Email: <a href="mailto:Eric.Shaw@dep.state.fl.us">Eric.Shaw@dep.state.fl.us</a></p>
<p>Please take a few minutes to share your comments on the service you received from the department by clicking on this link. DEP Customer Survey.</p>
<p>From: Larry E. Fink [mailto:larryfink@waterwiseconsulting.com]<br />
Sent: Wednesday, September 21, 2011 9:20 PM<br />
To: Shaw, Eric<br />
Subject: Proposed Fish Flesh-Based Mercury WQS </p>
<p>Eric:</p>
<p>Hi and hope all is well.  </p>
<p>What is the status of the triennial review of the numerical Water Quality Standard (WQS) for mercury in Florida Class III surface waters? What is the schedule for the promulgation of the proposed fish flesh-based numerical WQS of 0.2 ppm on a wet weight basis for methylmercury analyzed as total mercury to protect human health in Class III surface waters?  When and where will there be additional opportunities to comment on the proposed revised mercury WQS prior to subittal for promulgation by the Environmental Regulation Commission?  Please keep me apprised of relevant developments in these regards.</p>
<p>Thank you.</p>
<p>Larry E. Fink, M.S.<br />
Owner and Principal<br />
Waterwise Consulting, LLC</p>
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		<title>Comment on Everglades suffering from sulfate runoff and Methylmercury contamination by Tracy</title>
		<link>http://www.everglades.org/2011/05/everglades-suffering-from-sulfate-runoff-and-methylmercury-contamination/#comment-327</link>
		<dc:creator>Tracy</dc:creator>
		<pubDate>Mon, 08 Aug 2011 02:48:15 +0000</pubDate>
		<guid isPermaLink="false">http://everglades.org/?p=665#comment-327</guid>
		<description>Being a South Florida resident I have a keen interest in seeing the Everglades thrive. But, of course, I do use sugar and I myself live in an area that was once wetland. I think the key is to use common sense and find the best balance between the needs of people and the environment.
Anyway, your readers may like our latest blog:  http://homepageheroes.com/shopforcharity-everglades-park-saving-florida-animals
It speaks about a couple of charities that are doing a lot to preserve Everglades National Park and how we can all help (for free).
Best regards, Tracy</description>
		<content:encoded><![CDATA[<p>Being a South Florida resident I have a keen interest in seeing the Everglades thrive. But, of course, I do use sugar and I myself live in an area that was once wetland. I think the key is to use common sense and find the best balance between the needs of people and the environment.<br />
Anyway, your readers may like our latest blog:  <a href="http://homepageheroes.com/shopforcharity-everglades-park-saving-florida-animals" rel="nofollow">http://homepageheroes.com/shopforcharity-everglades-park-saving-florida-animals</a><br />
It speaks about a couple of charities that are doing a lot to preserve Everglades National Park and how we can all help (for free).<br />
Best regards, Tracy</p>
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		<title>Comment on Take Action: Write EPA to Fortify Clean Water in Florida by Florida and the EPA Slammed with Failure to Preserve the Everglades - SEOLawFirm.com</title>
		<link>http://www.everglades.org/2011/05/take-action-write-epa-to-fortify-clean-water-in-florida/#comment-44</link>
		<dc:creator>Florida and the EPA Slammed with Failure to Preserve the Everglades - SEOLawFirm.com</dc:creator>
		<pubDate>Tue, 31 May 2011 16:42:35 +0000</pubDate>
		<guid isPermaLink="false">http://everglades.org/?p=691#comment-44</guid>
		<description>[...] [6] http://everglades.org/2011/05/take-action-write-epa-to-fortify-clean-water-in-florida/ [...]</description>
		<content:encoded><![CDATA[<p>[...] [6] <a href="http://everglades.org/2011/05/take-action-write-epa-to-fortify-clean-water-in-florida/" rel="nofollow">http://everglades.org/2011/05/take-action-write-epa-to-fortify-clean-water-in-florida/</a> [...]</p>
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		<title>Comment on Everglades suffering from sulfate runoff and Methylmercury contamination by Florida and the EPA Slammed with Failure to Preserve the Everglades - SEOLawFirm.com</title>
		<link>http://www.everglades.org/2011/05/everglades-suffering-from-sulfate-runoff-and-methylmercury-contamination/#comment-42</link>
		<dc:creator>Florida and the EPA Slammed with Failure to Preserve the Everglades - SEOLawFirm.com</dc:creator>
		<pubDate>Tue, 24 May 2011 16:31:13 +0000</pubDate>
		<guid isPermaLink="false">http://everglades.org/?p=665#comment-42</guid>
		<description>[...] [2] http://everglades.org/2011/05/everglades-suffering-from-sulfate-runoff-and-methylmercury-contaminati... [...]</description>
		<content:encoded><![CDATA[<p>[...] [2] <a href="http://everglades.org/2011/05/everglades-suffering-from-sulfate-runoff-and-methylmercury-contaminati" rel="nofollow">http://everglades.org/2011/05/everglades-suffering-from-sulfate-runoff-and-methylmercury-contaminati</a>&#8230; [...]</p>
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