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Fifth, your letter confuses regulatory standards with basic research. The letter cites an NPDES permit and monthly county
sampling as if they are the scientific gold standards of water quality management. They are not. They are simply legal
constructs that allow industries, cities and other polluters to dispose of waste water and contaminants typically at some
monthly or annual mean level intended to balance economic costs against ecological ones. State water quality standards
have been repeatedly challenged in court or questioned by scientists because the old adage that "dilution is the solution to
pollution" has not always proven true. The city is surely aware, for instance, that the state of Florida has ordered the
shutdown of ocean outfall sewage pipes because of mounting evidence of reef damage from long-term nutrient loading.
The repeated dismissal of Briceno's work as "foundation-less" shows misunderstanding of the research process. This is
actually the definition of foundation work, the establishment of baseline information that can help scientists, regulators
and civic and political leaders to understand what is coming out of the pipe before it is diluted. That is a fundamental first
step to both understanding long-term impacts and setting effective water quality standards.
Lastly, the letter suggests that Dr. Briceno and by extension Florida International University, the University of Miami
and National Oceanic and Atmospheric Administration researchers who worked with him to compile and analyze the data
are somehow exaggerating research to extract a contract from the city. If that is the citys contention, we expect to see
proof. Well be submitting a request for these records.
Again, the city has done commendable work to tackle the challenges of climate change. As pioneers of a major
engineering endeavor, you must expect to encounter technical challenges and we of course welcome any discussions on
how you will tackle this one and others that will inevitably arise.
Sincerely,