Miami-Dade WASD
- Enforcement driver:
- Federal Consent Decree (2013)
- Investment scale:
- $1.6B (trending $2B+)
- Key details
- 4,100 miles of sewer
- Cost overruns approaching 2.5x on completed segments
- Final milestones through 2028

Market Intelligence Report
Consent Orders, SSOs, & Where the Rehabilitation Spending Is Going
Committed and Planned Sewer Rehabilitation Spending in Florida
Miami-Dade Federal Consent Decree, with Overruns Trending toward $2B+
Hurricane Supplemental CWSRF Funding for Florida (SA-HMW, 2024)
Wastewater Spilled in Florida since 2000, per WUFT State Records
Of Gravity Mains Lined in Wilton Manors, One of Florida's Highest
DeSantis Infrastructure Awards across 37 Florida Communities, Dec. 2025
Florida's sanitary sewer collection systems are entering the most active rehabilitation cycle in the state's history. A confluence of forces has pushed cumulative committed and planned wastewater collection-system rehabilitation spending well past the $4 billion mark: a 2013 federal consent decree against Miami-Dade, a cluster of FDEP consent orders against South Florida and Tampa Bay utilities, the Clean Waterways Act of 2020, the new Rule 62-600.705(2) requiring Collection System Action Plans, and back-to-back hurricane seasons culminating in Helene and Milton in 2024.
The dominant rehabilitation methodology across this spending is trenchless: cured-in-place pipe (CIPP) lining for gravity mains and laterals, pipe bursting for upsizing, HDPE directional drilling for force-main redundancy, and manhole rehabilitation. For trenchless contractors and the engineering firms that design these programs, Florida is now the most active sewer rehabilitation market in the southeastern United States.
This report inventories every active major FDEP and federal enforcement action affecting Florida wastewater collection systems, quantifies SSO trends through the 2024 hurricane season, profiles the Clean Waterways Act compliance regime, and details the major capital programs and contractor activity driving rehabilitation work in 2025 and 2026.
The single largest active wastewater enforcement action in Florida is the 2013 federal Consent Decree against Miami-Dade County, lodged in United States, State of Florida and FDEP v. Miami-Dade County in the U.S. District Court for the Southern District of Florida.
The DOJ and EPA, joined by FDEP, authorized execution on May 21, 2013, and lodged the proposed decree with the court on June 6, 2013, after documenting at least 84 SSOs totaling more than 29 million gallons of raw sewage reaching navigable waters. The decree superseded prior 1994 and 1995 partial consent decrees. Miami-Dade agreed to rehabilitate its wastewater treatment plants and collection and transmission system within 15 years, develop and implement a CMOM-style program, pay a $978,100 civil penalty, complete a $2,047,200 Supplemental Environmental Project, and commit approximately $1.6 billion in capital investment.
Per Miami-Dade WASD's November 2025 Transparency Report, the county publishes monthly project-by-project status. Across the South District WWTP cluster, Consent Decree-budgeted spending of approximately $154 million has actually run to roughly $383 million in current cost-at-completion, more than double original estimates.
Several projects remain in construction. The Oxygenation Trains at South District WWTP are 91% complete, with portions rolled into the Ocean Outfall Legislation program. Digesters and Control Buildings are 87% complete, with a Force Majeure Notification and Time Extension request submitted October 20, 2023. Central District WWTP RS Pump Station projects are 36% to 50% complete with EPA-acknowledged delay and revised compliance dates of August 15, 2026.
Consent Decree work runs in parallel with the Ocean Outfall Legislation deadline of December 31, 2025, for elimination of normal ocean-outfall use. WASD's FY2025-26 adopted budget includes line items explicitly to design, construct, and rehabilitate collection and transmission infrastructure to comply with the federal consent decree.
For contractors, Miami-Dade's remaining work is concentrated in pump stations, large-diameter force-main rehabilitation, and final WWTP process equipment. The collection-system linear work is largely funded outside the Consent Decree but inside the WASD CIP. With cost overruns approaching 2.5x on completed segments, contractors should expect aggressive change-order activity and multiple Force Majeure-driven rebids through 2027 and 2028.
While Miami-Dade dominates by dollar value, FDEP has issued and continues to enforce a series of state-level Consent Orders against municipal collection-system operators for SSOs, I&I, and capacity-related Clean Water Act violations.
The Fort Lauderdale Consent Order, signed September 29, 2017, is the largest state CO in Florida by committed capital. After the catastrophic December 2019 through February 2020 force-main breaks released more than 200 million gallons of raw sewage, FDEP increased the penalty to $2.1 million, the largest sewage-spill fine in Florida history at the time, with an in-kind option to spend $3.1 million on local environmental restoration. Hazen and Sawyer serves as Consent Order Program Manager.
The total Fort Lauderdale sewer rehabilitation effort is now estimated at $800 million to $1 billion over an 8 to 10 year horizon. Funding includes a $200 million bond issuance in 2018. The redundant 7.5-mile, $65 million HDPE force main from the G.T. Lohmeyer Wastewater Treatment Plant to the Coral Ridge Country Club lift station, installed via horizontal directional drilling by David Mancini and Sons and Murphy Pipeline Contractors, was activated in April 2021 and won Trenchless Technology's 2021 Project of the Year, Honorable Mention, New Installation.
Active 2025 and 2026 rehabilitation includes CIPP work across multiple Victoria Park, Lake Ridge, Beverly Heights, Harbordale, Rio Vista, and Sunrise Intracoastal segments. Through earlier phases, the City rehabilitated 41 miles of public sanitary sewer main and approximately 4,300 lateral connections in high-priority areas.
Wilton Manors signed a Consent Order with FDEP in 2021 covering 32 corrective actions following 10 sewage release events. As of the City's most recent public update, 25 of 32 required actions are complete with 7 remaining. The CO is on schedule. As of December 2024, the City had lined approximately 91% of its gravity wastewater mains, one of the highest CIPP penetrations of any Florida collection system. This makes Wilton Manors an effective benchmark for what near-completion of an FDEP-driven CIPP program looks like.
Hollywood entered FDEP Consent Order 21-0392, with required I&I Reduction and Asset Management/CMOM programs. By Resolution R-2025-034, the City Commission authorized Hazen and Sawyer as engineering services provider. Hollywood's collection system is notable in that approximately 50% of the city remains unsewered, and the City Commission reviewed a multi-phase $1.3 billion sanitary sewer expansion program in October 2025. The CDM Smith Comprehensive Citywide Stormwater Master Plan runs in parallel.
After the 2015 through 2016 sewage crisis, in which the City discharged approximately 1 billion gallons, St. Petersburg entered an FDEP Consent Order and committed more than $400 million in rehabilitation spending since 2016.
The Private Lateral Rehabilitation Rebate Program launched Phase 1 on June 30, 2025 and is the most significant lateral rehabilitation initiative recently launched in Florida. Phase 1 offers 100% reimbursement for inspection and rehabilitation in identified high-I&I areas, backed by a $500,000 initial allocation. Approximately 32,000 properties are potentially eligible. Phase 2, anticipated October 2026, would expand citywide with reimbursement capped at $5,000 per home. A 2019 pilot study with approximately 300 participants demonstrated a 34% I&I reduction from private lateral repairs alone.
The Sarasota Consent Order drives both treatment-plant conversion to Advanced Wastewater Treatment and collection-system rehabilitation. The Bee Ridge WRF AWT conversion was completed by December 31, 2025, with Notice of Completion submitted to FDEP December 10, 2025. A CMOM Program was required by December 31, 2025.
Sarasota County adopted Ordinance 2022-061, which gives the Public Utilities Director authority to require inspection, repair, and rehabilitation of privately owned sewer systems and laterals contributing extraneous flow, with enforcement remedies including I/I fees. The county works off stipulated penalties through quarterly in-kind projects including manhole coatings, lift-station rehabilitations, and gravity main CIPP, including the Bell Meade development project.
Lakeland reported a notable April 2024 force-main break in a 12-inch industrial wastewater main and documented at least eight Helene/Milton-related discharges across multiple lakes. Tampa, Clearwater, and Pinellas County all sustained large 2024 hurricane-related events. Tampa's 8.5 million gallons of Helene spills did not produce a new CO but accelerated CIP and federal mitigation funding.
JEA's Buckman WWTP Consent Order, effective September 15, 2025, cited multiple effluent exceedances with a $24,750 settlement. While not a collection-system enforcement action, JEA's collection-system pressure is visible through its Septic Tank Phase Out Program, with completed neighborhoods including Biltmore C, Beverly Hills West, and Beverly Hills East, and active Christobel and Riverview phases.
Public records and utility disclosures show active or recently completed consent-order or stipulated-penalty activity involving the City of West Palm Beach, ECUA Pensacola, and several smaller utilities. FDEP's standard stipulated-penalty regime in collection-system COs runs roughly $200 per day per violation, with in-kind project options at approximately 1.5x the cash-penalty value.
Florida's SSO reporting regime is governed by Section 403.077, F.S., Rule 62-604.550, F.A.C., and FDEP's Sanitary Sewer Spill or Overflow electronic reporting tool. Spills greater than 1,000 gallons or that may threaten public health or the environment must be reported to the State Watch Office within 24 hours, with written reports due within 5 days. Less than 20% of reported spills reach surface water in normal conditions; that ratio inverts during hurricanes.
Independent journalism has provided the most comprehensive longitudinal data. Since 2000, more than 2.4 billion gallons of wastewater have spilled in Florida, per state records compiled by WUFT. A separate GateHouse Media analysis covering 2009 through 2018 documented approximately 1.6 billion gallons across nearly 23,000 reported spills, more than six per day on average.
Florida lacks a single FDEP-published statewide annual SSO report for the 2019 through 2024 period with comprehensive utility rankings. The Clean Waterways Act mandated annual reports to the Governor and Legislature, but the most navigable public dataset remains the FDEP Notice of Pollution portal and the 2017 RS&H/FDEP Hurricane Hermine evaluation report, which profiled St. Petersburg, Largo, Gulfport, Clearwater, and Pinellas County Utilities.
Hurricane-related SSOs now dominate the high-volume tail of Florida's spill record.
Hurricane Debby in August 2024 pushed the South County Regional Advanced WWTP in Hillsborough to peak influent flows of 25.0 MGD against 10.0 MGD design capacity. Tampa reported 270,000 gallons from West Coachman/Alline manholes to Hillsborough Bay and approximately 30,000 gallons from Perry Avenue/Charter Street manholes to the Hillsborough River. Pinellas Park reported 30,000 gallons into Cross Bayou canal.
Hurricane Helene in September 2024 caused 8.5 million gallons of spills across 10 Tampa overflows along the Hillsborough River and south Tampa coastline. St. Petersburg reported approximately 1.5 million gallons untreated, with two-thirds from the Northeast Water Reclamation Facility. St. Pete Beach saw storm surge damage to control panels at 8 of 21 lift stations.
Hurricane Milton in October 2024 produced the single largest documented Florida SSO event of the cycle: the Clearwater Marshall Street WRF discharged approximately 25.4 million gallons of partially treated wastewater into Stevenson Creek over October 15 through 18, caused by debris-blocked bar screens. Leesburg reported approximately 2 million gallons of untreated sewage into streets. The Seminole/South Cross Bayou WRF discharged 102,000 gallons and then 400,320 gallons into Lake Seminole.
The modal SSO cause during the 2024 hurricane season shifted from pipe failures to lift-station inundation and power-outage-driven backups, particularly at coastal lift stations vulnerable to storm surge. Wet-weather I&I-driven surcharge events are increasingly tied to private-side lateral defects, which is why utilities including St. Petersburg, Pinellas County, Sarasota County, and ECUA are pivoting to lateral programs.
Florida Administrative Code Rule 62-600.705(2), effective June 28, 2023, requires every domestic wastewater facility permittee to develop a Collection System Action Plan, or CSAP. A summary must be submitted with the next new permit, renewal, or substantial revision. Annual reports on implementation must be submitted by June 30 each year. The plan must cover at least a 5-year planning horizon, set annual goals to assess the system with a minimum of 25% of the collection system evaluated over the 5-year horizon, use one or more investigative techniques such as CCTV, smoke testing, data analytics, flow isolation, focused electrode leak location, and direct observation, include a GIS map and electronic inventory mandatory for facilities at or above 1 MGD, include an adaptive maintenance and repair plan, address resiliency for sea-level rise and flood mitigation, and after December 21, 2025, identify all satellite collection systems connected to the facility.
Annual reports must include the percentage of system assessed, results, significant repairs and replacements and expansions, identification of new satellite systems after December 2025, annual expenditures on I&I studies and CSAP implementation, FOG/roots/wipes measures, and facility revenues and expenditures related to the collection system.
FDEP has not yet published a public compliance roster or enforcement-action list specifically tied to the December 21, 2025 satellite-system-identification deadline. The structure of the rule, with annual reporting tied to permit renewals, implies enforcement will be visible primarily through 2026 permit-renewal cycles and through SSO-driven secondary enforcement, with FDEP citing CSAP non-compliance as an aggravating factor in stipulated penalties for SSO events.
For municipal utility benchmarking, the implication is that any utility above 1 MGD that has not GIS-mapped its system, committed to an annual 5%+ assessment rate via CCTV or smoke testing, and identified all satellite systems by December 21, 2025, is at elevated FDEP enforcement risk.
Florida's Clean Water State Revolving Fund, administered by FDEP under Chapters 62-503 and 62-552, F.A.C., funds planning, design, and construction of wastewater, stormwater, and nonpoint-source projects through a quarterly priority-list process. Loan terms are 20-year amortization, with rates averaging less than 50% of market. Disadvantaged-community grant subsidies can substantially offset principal.
On December 21, 2024, the President signed P.L. 118-158, the American Relief Act, 2025, including $3 billion in disaster-relief supplemental SRF funding for EPA Regions 3, 4, and 9 to address facilities impacted by Hurricanes Helene, Milton, and the Hawaii Wildfires.
Florida received the largest CWSRF SA-HMW capitalization grant of any state: $806,392,000 with at least 50% subsidy for all communities and 100% subsidization for disadvantaged communities, with no state match required. An additional $35,950,000 in decentralized capitalization provides 100% subsidy for septic-to-centralized-sewer connections. This is the largest single federal injection of wastewater capital into Florida in a generation.
On December 18, 2025, Governor DeSantis announced $311 million in awards across 37 Florida communities. Key wastewater-related awards include the JEA Normandy Village Wastewater System rebuild at $20 million, where JEA was court-appointed receiver in September 2025 for approximately 1,350 to 1,400 customers with failing gravity mains and a non-rehabilitatable WWTF. Citrus County received $16,435,400 for sanitary sewer system replacement following storm-driven intrusion, and the Peace River Watershed Project received $70 million. The 2023/2024 storms allocation includes a separate $50 million HUD allotment to impacted counties.
FDEP's Resilient Florida Program funds vulnerability assessments and adaptation projects. Pinellas County's WWCSMP benefited from a $25 million Florida Resilient Fund grant plus American Rescue Plan Act funding for private-lateral and septic-to-sewer programs. The Water Quality Improvement Grant Program and Springs Restoration Grant Program also fund wastewater upgrades, including $2.9 million for Newberry's septic-to-sewer project on the Santa Fe River.
Beyond the Consent Decree, WASD's FY2025-26 Adopted Multi-Year Capital Plan funds the South Dade 54-inch PCCP force main rehabilitation, 48-inch force main installation from Kendall Drive to PS 0536, North Miami/Aventura/Snake Creek/Lehman Causeway force-main projects, switchgear replacements, SCADA RTU upgrades, the Connect 2 Protect septic-to-sewer program for Biscayne Bay-adjacent properties, and AWT and PFAS-related upgrades.
Tampa funds collection-system rehabilitation primarily through its PIPES program, the Progressive Infrastructure Plan to Ensure Sustainability, with rate increases effective October 1, 2024. The wastewater system includes approximately 1,800 miles of gravity and force main, approximately 30,000 manholes, and approximately 50 MGD daily flow into the Howard F. Curren Advanced WWTP. Active projects include Downtown Phase II Collection System Rehabilitation by CIPP, numerous pump-station rehabilitations, and the Live Oak Square HMGP project strengthening gravity collection-system pipelines via CIPP and rehabilitating 315 manholes. A CDBG-MIT application covers up to approximately 60 miles of gravity sewer and approximately 1,300 manholes across 8 to 9 areas, primarily CIPP.
Pinellas County's Wastewater Collection System Master Plan, developed with Wade Trim, is the most data-driven I&I program in the state. The North County system alone comprises 340 miles of gravity main, 85 miles of force main, and 152 pump stations at approximately 6.5 MGD daily flow. The Asset Management Program has inventoried and scored more than 135,000 wastewater assets. The Septic-to-Sewer Program has inventoried more than 8,900 septic systems for phased conversion. McKim and Creed conducted the North County Flow Monitoring Study using 40 open-channel meters plus smoke testing. The four-part Private Sewer Lateral Policy is the first of its kind in Florida.
ECUA operates approximately 1,225 miles of sewer for more than 70,000 customers, with some lines exceeding 100 years of age. The proactive neighborhood-by-neighborhood lateral inspection program uses CCTV plus smoke testing, with mandatory 6-month repair windows enforced by a $50 per month service surcharge and ultimately service termination. The Central Water Reclamation Facility, commissioned in 2010 at a cost of $316 million, is the receiving AWT plant.
JEA's collection system includes approximately 3,700 miles of collection lines, approximately 1,200 pumping stations, and 14 sewer treatment plants at approximately 70 MGD daily flow. CIP areas include the Septic Tank Phase Out Program with five active neighborhoods, a $17 to $20 million pipe-bursting trenchless rehabilitation continuing-services contract in procurement, and the $20 million CDBG-DR-funded Normandy Village system rebuild.
Beyond CO obligations, Sarasota's multi-year CIP funds continuing in-kind projects on lift stations and gravity main lining through quarterly compliance cycles, plus the completed AWT conversion at Bee Ridge.
Hollywood's Consent Order work, designed by Hazen and Sawyer, is paired with the CDM Smith Comprehensive Citywide Stormwater Master Plan rebuild and an active CDBG-funded sewer-connection program. The October 2025 City Commission workshop identified a $1.3 billion sanitary sewer expansion program across multiple phases.
West Palm Beach has been an early Insituform CIPP customer and continues active force-main and gravity-main rehabilitation.
Active rehabilitation programs and near-term CIP cycles documented in public records include Citrus County, Cape Coral, Lakeland, Clearwater, Newberry, and Seminole County, Toho Water Authority, OUC, Tallahassee, FKAA, and GRU, all of which operate active CIPs and are subject to the Rule 62-600.705(2) CSAP regime.
Azuria Water Solutions acquired BLD Services on June 16, 2025, its fourth acquisition that year. The combined entity is now the dominant CIPP main-and-lateral player in Florida. BLD has been ECUA's principal lateral CIPP contractor since 2014 and is positioned for the St. Petersburg Phase 1 lateral rebate work and Pinellas County Find and Fix work.
LMK Pipe Renewal is active in Jacksonville, including the Jacksonville Golf and Country Club neighborhood lateral lining program rehabilitating sanitary sewer mains and lateral connections by trenchless lining.
Lanzo Construction Co. is the dominant Fort Lauderdale CIPP contractor, with simultaneous work in Victoria Park, Lake Ridge, Beverly Heights, Harbordale, Rio Vista, and Sunrise Intracoastal segments throughout 2025 and 2026 under the Consent Order program.
David Mancini and Sons and Murphy Pipeline Contractors installed the 7.5-mile $65 million Fort Lauderdale redundant HDPE force main via HDD.
Hazen and Sawyer serves as Fort Lauderdale CO Program Manager and Hollywood CO 21-0392 engineer of record. Wade Trim leads the Pinellas County WWCSMP. McKim and Creed conducted the Pinellas North County Flow Monitoring Study. CDM Smith prepared Hollywood's Comprehensive Citywide Stormwater Master Plan. RS&H authored the 2017 FDEP Hurricane Hermine SSO evaluation that remains the methodological benchmark.
Highest-confidence prospecting targets through 2026 and 2027: the Florida SA-HMW CWSRF Priority Lists, particularly Hillsborough, Pinellas, Manatee, Sarasota, Pasco, Lee, and Citrus counties. The St. Petersburg Phase 2 Private Lateral Rebate Program launching citywide in October 2026. Fort Lauderdale's continuing CIPP and force-main program. Miami-Dade WASD Consent Decree force-main, pump station, and OOL-related projects continuing through 2026 and 2028. Sarasota County in-kind project pipeline. JEA pipe-bursting and septic-to-sewer programs. Tampa PIPES plus HMGP and CDBG-MIT-funded CIPP packages. Citrus County's $16.4 million sewer-system replacement.
Cost overruns are systemic. Miami-Dade WASD's published Consent Decree report shows multiple completed projects running well over 2x original estimates. This pattern is not unique to Miami-Dade and should be assumed in budgeting for any large CO program.
FDEP's annual SSO statewide compilation is uneven. While the State Watch Office and DEP Business Portal capture all reportable spills, FDEP has not published a single comprehensive 2024 statewide annual SSO report comparable to the 2017 RS&H/Hermine evaluation. For statewide totals, journalist data sets and individual utility advisories remain the most navigable sources.
Force majeure delays are routine. Both Miami-Dade and Sarasota County have invoked force majeure provisions repeatedly across the 2018 through 2024 hurricane seasons. Contractors should expect schedule slippage and serial CO modification orders.
The December 21, 2025 satellite-system-identification deadline under Rule 62-600.705(2) is ongoing. While no enforcement actions specifically tied to that deadline were public at the time of this report, expect non-compliance to be cited as an aggravating factor in 2026 SSO-driven enforcement.
The "$4 billion" headline figure aggregates Miami-Dade's $1.6 billion Consent Decree commitment with overruns trending toward $2 billion, Fort Lauderdale's $800 million to $1 billion program, Tampa's $2.9 billion PIPES portfolio, the Pinellas WWCSMP and lateral programs, the SA-HMW $806 million Florida CWSRF capitalization, the December 2025 $311 million CDBG-DR award round and prior rounds, Hollywood's $1.3 billion sewer expansion, plus Wilton Manors, Sarasota County, ECUA, JEA, and dozens of smaller utility CIPs. The actual figure is likely closer to $5 to $6 billion. The $4 billion is a conservative floor.
Use Wilton Manors (gravity main lining percentage), St. Petersburg and Pinellas County (lateral programs and WWCSMP asset management), and ECUA Pensacola (long-tenured CCTV-driven lateral inspection and smoke testing) as the three primary peer benchmarks for collection-system rehabilitation maturity.
Use Sarasota Ordinance 2022-061 as the model ordinance for private-lateral and private-sewer-system extraneous-flow enforcement.
Treat the December 21, 2025 satellite-system identification deadline as an immediate enforcement risk, not a soft deadline.
Explore pairing CWSRF (low-interest 20-year loans with 50%+ subsidy under SA-HMW, 100% subsidy for disadvantaged communities) with CDBG-DR for hurricane-impacted projects and Resilient Florida funding for vulnerability-assessment-driven implementation.
The single highest-leverage prospecting list for the next 24 months is the FDEP CWSRF SA-HMW Priority List, particularly Hillsborough, Pinellas, Manatee, Sarasota, Pasco, Lee, and Citrus counties.
The St. Petersburg Phase 2 (October 2026) and Pinellas County Find and Fix programs together represent the largest single private-lateral CIPP opportunity in the U.S. southeast through 2027.
Wilton Manors (91% lined) is a lookahead model: Florida utilities at 50 to 70% gravity main lining penetration represent the largest mid-cycle opportunity.
Force-main HDD work is increasingly preferred where redundancy is required (Fort Lauderdale, West Palm Beach corridor); contractors with HDPE HDD capability and large-diameter CIPP experience have a clear advantage.
30 sources cited in this report
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