The Florida Legislature
OPPAGA script logo
Office of Program Policy Analysis and Government Accountability

Cumulative Impact Consideration in Environmental Resource Permitting, Report No. 01-40, September 2001
Full report in PDF format

Florida law requires that the Department of Environmental Protection and water management districts consider cumulative impacts to surface waters and wetlands within a drainage basin in deciding whether to grant an Environmental Resource Permit.

The 2000 Legislature directed OPPAGA to study the cumulative impact consideration within the Environmental Resource Permitting Program. Our review addressed the justification for the consideration; whether changes would provide greater clarity and certainty in the consideration, and whether a practicable, consistent, and equitable methodology for considering cumulative impacts could be developed. We concluded that

  • the cumulative impact consideration is conceptually justified because despite regulatory efforts, surface waters and wetlands continue to be degraded or lost;
  • however, weaknesses in design and implementation limit the cumulative impact consideration’s effectiveness;
  • a consistent, equitable, and practical methodology for considering cumulative impacts at the individual project level is not available; and
  • changes to the process would add clarity and certainty in applying the consideration, but would not address fundamental problems.
Given the weaknesses of the cumulative impact consideration in current environmental permitting, we recommend that the Legislature, regulatory agencies, and local governments adopt an integrated planning approach for proactively addressing cumulative impacts to surface waters and wetlands.

Which Government Program Summaries contain related information?

Department of Environmental Protection
Water Management Districts

What other OPPAGA-related materials are available?

  • Report No. 99-40 Policy Review: Wetland Mitigation,  published in March 2000.
  • Report No. 12211 A Review of the Management and Storage of Surface Waters Program Administered by the Water Management Districts Under the General Supervision of the Department of Environmental Protection, published in December 1993.

Copies of this report in print or alternate accessible format may be obtained by telephone (850/488-0021), by FAX (850/487-9213), in person, or by mail (OPPAGA Report Production, Claude Pepper Building, Room 312, 111 W. Madison St., Tallahassee, FL 32399-1475).
e-mail address:

Reports  |  Home