Reuse Water Usage and Permitting

The City of Marco Island received Notice in 2019 from the Florida Dept of Environmental Protection (FDEP) that some of Marco’s waterways were considered polluted above state limits, or ‘impaired’, for two consecutive years. The City contracted with Environmental Research and Design (ERD) for a study to identify the polluted waterways and the sources of the nutrients causing the problems. The long-awaited “ERD Nutrient Source Evaluation Project,” was received in August, 2021 and formally presented, after City review and editing, one month later. 

One of the ERD recommendations was to improve the quality of the 2-3 million gallons produced daily at the City’s sewage plant. Renamed as “reuse” water, the product is sold and distributed for irrigation to a number of customers. ERD traced evidence for this water’s content transferring as a pollutant into Marco’s canals.

 The City has contended it operates the treatment plant in compliance with its State permit and does not need to reduce the levels of Nitrogen and Phosphorus that the ERD report says ultimately end up polluting our waterways.

The Marco wastewater plant is classified and operated as a Reclaimed Water Production Facility (RWPF). This is not for processing water to a standard sufficient for “Discharge” into the local environment.

The current RWPF permit specifies post-treatment maximum allowable limits for typical polluting elements, except the ones polluting our waterways. The ERD report notes that the largest single source of nitrogen and phosphorus is the RWPF. We believe these constituents were overlooked when FDEP wrote these permits, focusing on RWPFs whose outputs are intended for the irrigation of inland vegetation. 

We believe Marco misuses its reclaimed water discharge system by pumping the entire daily output into irrigation. In the rainy season when routine irrigation is unnecessary, the excess product should pass into two existing deep injection wells, so the nutrients are responsibly contained and not released into the waterways. 

Marco’s reclaimed water system allows the reuse irrigation to spill onto the impervious streets nightly, which flow into the curb drain inlets onwards to the canals. In the rainy season, a further consequence of overwatering is the water’s nutrients are not absorbed by vegetation, and percolate through porous sandy soils below the vegetation’s root zone, and into the seawater/groundwater. 

The General Conditions section of the Marco Wastewater Permit, paragraph 5 states, in part, that “The permittee (Marco) shall take all reasonable steps to minimize or prevent any discharge, reuse of reclaimed water, or residuals use or disposal in violation of this permit which has a reasonable likelihood of adversely affecting human health or the environment.” We believe that Marco Island is violating this section of its permit through inappropriate dispersal of reuse water.

We are not saying that using reuse water isn’t an ecologically sound idea. Rather, Marco either has the wrong kind of permit for Marco’s sandy soil and close proximity to the 100 miles of canals or is not treating the water to a sufficient standard that is more environmentally friendly. Cleaning the water to a higher standard is also the right thing to do to protect wildlife. 

We believe FDEP should either enforce the conditions of the NPDES permit program or rewrite the permit requirements necessary for Marco Island and probably every other environmentally sensitive coastal community that uses reclaimed water for reuse irrigation.

Clean Marco Waters, LLC