Hi Juanita, EAA Strategic Plan Team, et al;  

Wayne Nelson asked me to forward to Juanita a hard copy of the Okeechobee News reporting the SFWMD recommendation that an EAA flow-way evaluation not be considered.   That is below, with annotations in [brackets].  

The good news is that the Corps appears to be moving forward anyway, in a manner TBD per Dennis Duke presentation.  It seems inappropriate that the Corps would be pursuing this, especially after the request from Senator Nelson for a cost-benefit study of Plan 6 by COE, and to have SFWMD recommending against it. 

Hence the forwarded message.    

The bad news is that Tommy Strowd reported the Okeechobee 10 County Coalition event to the Governing Board Yesterday indicating that the 10 County Coalition had adopted the SFWMD position.  Well not exactly.  Am also forwarding a copy of the 10 County Coalition  draft resolution.  There is also a statement about the WRAC position as follows:  

WHEREAS, the Lake Okeechobee Committee of the South Florida Water Management District’s Water Resources Advisory Commission has recommended, in its draft recommendations of April 25, 2007, that the need for and feasibility for additional conveyance capacity, flow ways, and reservoirs to send Lake Okeechobee water to the south be evaluated.  

Also interesting that in briefing the Gov Board, Strowd mentioned the Corps/SFWMD brief, but did not mentioned the Audubon Brief (Paul Gray) or the Marshall Foundation Brief (JAM).   So much for public comment standing and public outreach on a level playing field.  

We may have another shot at this.  Rick Smith, SFWMD WRAC facilitator, informs us that Mike Collins wants to have the WRAC hear the 10 County Coalition presentations again.   He was not aware of the Marshall Foundation Brief (attached).   The WRAC meeting is scheduled for July 5.   This would seem like a good time for EvCo to mass forces and be there, also to contact WRAC members prior to the meeting, especially we asked for a up-to-date list of WRAC Members with contacts, and were told this would be available in a week or so.   There is no contact info on line, only a list of members.  We are informed that the WRAC approach is that this information will be furnished on request, but not made pubic otherwise.  Interesting.  

A major project for our Summer Interns (last 4 entries on the CC list)  this year as last, is taking a hard look at the EAA situation and reporting findings to our elected and appointed officials.    This will make for an interesting summer.  

Reminder:  This is again consistent with our Essentials and 2007 action plan.   For those that feel that an EAA flow-way is a major issue, it is time for action prior to and during the WRAC meeting.  

Thanks for feedback, especially from EvCo members who are also WRAC members.   Out interns may be contacting you.   If anyone wants to be more involved in the Summer Project, we can arrange a conference call or a meeting in our WPB office.  

More on this as it develops.  

John Arthur Marshall, Member

EvCo EAA Strategic Plan Team

www.ArtMarshall.org

 

----------------------------------------------------Forwarded Message-----------------------------------------

  June 13, 2007

The Honorable Bill Nelson  

United States Senate  

Dear Senator Nelson;  

The ArtMarshall.org folks appreciate very much the initiative to take another look at a Plan 6 type flow-way which appeared in the Corps of Engineers 1994 Reconnaissance Study, the precursor of the Comprehensive Everglades Restoration Plan (CERP).    This flow-way was also a major segment of the Marshall Plan of the 1980's, developed by my late Uncle, Arthur R. Marshall.   It also appeared in the 1993 Science Subgroup report, and the concept has been recommended as a primary consideration by scientists, including the National Academy of Sciences peer review panel, 2004 - 2006.  

A recent Presentation by the South Florida Water Management District (SFSMD) - the Local Sponsor, recommended that a plan 6 type flow-way not be considered.   This recommendation was based on statements that are contrary to CERP Table 5-1 goals and objectives, pronouncements unsubstantiated by data-based analysis, and failure to consider costs of a highly engineered fossil-fuel approach, as well as failure to consider the ecologic and economic value of restoring sheet flow, per CERP Section 2.3.1 "Dynamic Storage and Sheet Flow", and CERP Section 7.5.3, Cost Effectiveness and Incremental Analysis of Alternatives, respectively.   

It does not appear a good thing to have the CERP Local Sponsor in such discord with the Federal Sponsor, and contrary to the CERP baseline sections, and restoration science. The purpose of this e-mail is to report the proceedings in detail, as follows.   

Last Thursday, South Florida Water Management District (SFWMD) provided a recommendation to the 10 County Coalition that a flow-way south through the EAA had no merit, and was not appropriate to consider.   

This is somewhat a setback in CERP implementation, as the recommendation is contrary to previous findings and what the Federal sponsor is currently considering.   The attached presentation amplifies.  

Result:   The County Coalition watered down a draft resolution implying the need for a flow-way, rather than addressing it explicitly, and voted it through 8-2, with Commissioners Ray Judah and Sarah Heard in the minority dissenting.  On second read, the Resolution may have the desired effect, but…  

The SFWMD position presented needs further consideration.  

Most of the story, fairly well reported by the Okeechobee News, is attached below with a few salient[annotations].   

Salient Points that Senator Nelson and his Staff might want to consider:

  • US Army Corps of Engineers (USACE) Summary – Next Steps:
    • Will require a re-exam of the entire flow restoration process from north to south
    • Will look at the need for additional storage and treatment south of lake as well as other alternatives for all potential flow paths needed to reconnect the system.
  • SFWMD Recommendation:   Commitment of additional resources to further investigate a southern flow-way are not warranted at this point in time.
  • The SFWMD recommendation appears to be in conflict with current Corps of Engineers approaches that have:
    • USACE (Dennis Duke) looking at flow-south options, due to the multiple needs to convey water south
    • USACE (Colonel Grosskruger) doing a Plan 6 flow-way Cost-Benefit study at the request of Senator Nelson, confirmed by a call from Senator Nelson’s office.
  • Begs a question:   How does the SFWMD local sponsor recommendation, contrary to what the federal sponsor is doing, look to federal funders?
  • The SFWMD recommendation is also contrary to the Water Resources Advisory Committee (WRAC) recommendation of April 25, 2007 which states that the need for and feasibility for additional conveyance capacity, flow-ways, and reservoirs to send Lake Okeechobee water to the south be evaluated.
  • ? Should a consideration of flow south be taken off the table before an ASR contingency plan is complete, as it would be an obvious consideration of such a plan?  The promised contingency plan has yet to appear since it was announced in January, 2001.
    • It has been repeatedly announced that the reason for its non-appearance is glitches in the modeling for the interim CERP update (ICU).
    • This begs another question, how accurate were/are the flow models in 1994, 1998, and now, regarding the decision not to put a Plan 6 like flow-way in the mix of options.
  • There were arguments presented by SFWMD against a flow-way, some of which appeared arbitrary, counter-intuitive, not consistent with previous findings, and lacking in substantiating analysis.
    • SFWMD Consultant:  a Plan 6 flow-way would not be effective or provide ecological value
    • The 1994 Recon Study states quite the opposite, specifically:  Plan 6 Maximizes achievement of planning objectives, most of which were transformed into CERP Table 5-1 goals & objectives which include:
    • Restores hydrologic function
    • Reduces fragmentation of habitats
    • Restores sheet-flow between the EAA and the WCA's
    • Increases the spatial extent of natural areas
  • The Consultant placed strong emphasis on the need for storage to solve the problem, noting that a flow-way would not provide storage.   He pushed reservoirs and ASR to provide such storage.
  • Given the current condition of the Hoover Dike and Lake Okeechobee , the Estuaries, and the drought, and an adaptive management approach, it would seem prudent to leave all options on the table, especially those that restore the natural system to any extent to improve current conditions.  CERP Table 5-1 Goals and Objectives are germane.
  • SFWMD position does not consider National Academy of Sciences peer review panel recommendation that a flow-way in the EAA be re-evaluated.

A major message, impromptu, to the audience, e-attached, was that the SFWMD consultant was proposing a water supply plan that had little to do with Everglades restoration possibilities in the EAA.  The ecologic goals which are laid out in CERP Table 5-1, are amplified in the attached.  

Board Members Bubba Wade and Charles Dauray were present.   At his request, Board Member Dauray was provided a copy of the presentation, with written material backup on the spot.  

Hopefully this will continue to get more rational consideration by the Corps of Engineers, as requested by Senator Nelson.   

Meanwhile a major project of our Summer Intern Program is to examine the need for flow in the EAA, and report their findings to elected and appointed officials.  Save the Date:  A final report will be given at a graduation luncheon, Aug 2, 2007 in West Palm Beach.  

We hold that in lieu of no other science-based plan coming forward, a Plan 6 flow-way remains a good conceptual starting point for a data-based evaluation, just like the approach of CERP conceptual ecological models.  

Respectfully submitted,

John Arthur Marshall

www.ArtMarshall.org

-----------------------------------------------------------------------------

Group divided on flow way

By Pete Gawda, Okeechobee News, June 10, 2007

[JAMInfo notes in [brackets]]

Proponents of a southern flow way did not get the support they hoped for from an environmental group. [the 10 County Coalition]

The Coalition for Responsible Management of Lake Okeechobee, St. Lucie and Caloosahatchee Estuaries and Lake Worth Lagoon meeting in Okeehcobee on Thursday, June 7, failed to endorse Plan 6. This controversial plan would provide for excess water from Lake Okeechobee to be channeled through a flow way at the southern end of the lake where it would be cleaned up and sent on to the Everglades.

A southern flow way would lessen the amount of water that would have to be sent to estuaries during times of high water.

The coalition is made up of commissioners representing Okeechobee, St. Lucie, Martin, Lee, Palm Beach , Hendry, Glades, Highlands , Osceola and Polk counties.

Plan 6 calls for a flow way starting two miles north of the Bolles Canal . It would vary in width from 7.2 miles at the northern end to 13.1 miles at the lower end. It would be 22.5 miles long with a capacity of 6,600 cubic feet per second. The existing east levee of the Miami Canal and the west levee of the North New River Canal would serve as levees for the flow way.

After hearing several hours of expert presentations and being bombarded with technical data, commissioners adopted a resolution supporting "all means of routing excess water from Lake Okeechobee that benefits Lake Okeechobee , the estuaries and Everglades National Park ."

The resolution, as originally written, had stated support of "further investigation of routing water from Lake Okeechobee by means of a storage flow way south to one or more of the water conservation areas."

While the original resolution specifically endorsed a southern flow way, the amendment offered by commissioner Kevin McCarthy of Hendry County and approved by an 8-2 vote, voiced support for a wide range of projects and did not specifically mention a southern flow way.

Lee County Commissioners Ray Judah and Martin County Commissioner Sarah Heard voted against the resolution.

Dr. Paul Gray of the Audubon Society advocated water storage north of the lake. He noted that the conflicting information being presented on the flow shows how complicated the situation is.

Even though Lake Okeechobee is as large as the Everglades , Dr. Gray noted that not much money is spent upstream.

He also suggested what might be called a modified Plan 6 that called for widening the Miami and North New River canals because he sees a need to move more water south. He said studies would have to be conducted to see how wide the canals would need to be. They could be one-half mile wide or studies could show that 100-yard-wide canals would convey enough water south. He said the narrower canals might be better than a wider flow ways to pre-treat water.

He said that there is either too much or too little water.  Under the current water management system, high lake levels often trigger large releases to the estuaries and upset the salinity balance.  Dr. Gray noted that there is no infrastructure to move water south.

"I have backed the flow way for a long time," offered Wayne Nelson, executive director of Fisherman Against Destruction of the Environment. "We must clean up Lake Okeechobee ."

While emphases in the past were on Everglades restoration, he said he had been stressing cleaning up the lake.

" Lake water must be cleaned up before it can head south," he told the board.

He mentioned artifacts recently found on the dry lake bed to back up his claim that the lake has historically been at a lower level than it is being maintained now.

"I support sending the water south," asserted Tina Richards, an intern with the Arthur Marshall Foundation, a non-profit group dedicated to preserving the Everglades . She advocated long term viable options rather than short term solutions that are politically correct. She said she would like for her children to be able to swim in Florida water.

"Conceptually, it is very nice," said Dr. Richard Punnett who did research in the 1990s on Plan 6 for the U. S. Army Corps of Engineers. "The disagreement lies in technical details."

[info note:   In November, 1998, during modeling result deliberations, an e-mail was sent to Punnett requesting consideration of a flow-way in the EAA.  However Punnett, now a consultant to SFWMD, would not allow it, despite numerous project implementation team member requests to do so.]

He contended that a flow way would not flow at the correct times without proper management.   He said the flow way was not the most efficient plan proposed and that a flow way does not act as a wetland.

[info note:   This is in direct conflict with what the 1994 restudy shows; it also conflicts with National Academy of Science peer review recommendations.]

A 1999 feasibility study concluded a flow way creates a water supply burden on the system without clear hydrological benefits.

[Info note:  From the standpoint of an eye witness, there was never visible modeling or a cost analysis of alternatives as required by CERP Section 7.5.3, to support this; the statement was made without visible analytic justification]

Soil subsistence and evaporation would be determents to a southern flow way, according to Dr. Punnett.

[Info note:  Subsidence is a problem to be solved; evaporation is a solution, not a problem.]

He contended that delivery of water to a flow way would be a problem.  By storing excess water in the lake, Dr. Punnett said "you can meet more of the needs of users."He stated that at times when it would be desirable to discharge water south from the lake, the water conservation areas would be full and could not take any more water.  Dr. Punnett presented charts to show that when the lake level was high, the water level in the water control areas was also high.

"It isn't a simple matter of redirecting the water," he said.   He claimed that today the extremes of water level fluctuations are greater than they were before the lake was managed for flood control and water supplies. Because of that he feels more storage is needed.

"Managed storage is what we really need," he said. "A flow way will not provide storage."  

[Info note:  BIG push was for ASR and Reservoirs; this is about a water supply plan, not CERP.  This is contrary to the CERP "baseline" described in CERP Section 2.3.1 - Dynamic Storage and Sheet Flow.  Sheet flow as dynamic storage has been acknowledged as the primary characteristic of the Everglades by virtually all scientists, including National Academy of Science Peer Review Panel Members in a series of written reports that began with Everglades scientists. ]

The southern flow way cause was advocated by John Marshall of the Arthur Marshall Foundation.

He claimed that earlier models used by Dr. Punnett were based on faulty topological data.

[Question that needs to be answered:   Just how accurate were/are the models in 1994, 1998, 2007 regarding flow, and related ecological value called for in CERP Table 5-1 "enhance ecological values" objectives?]

To counter claims that there is not enough water for a flow way, Mr. Marshall stated that over 50 percent of the Everglades are lost, yet nearly 100 percent of the rainfall remains. He said a flow way would use less than 20 percent of the original flow plain.

He claimed that a flow way is a better functional alternative than deep reservoirs with low or no water treatment value.

Mr. Marshall claimed a flow way would mimic the historic lake spill-over through the original pond apple forest and saw grass plains.

As to the assertion that evaporation would negate any benefits of a flow way, Mr. Marshall claims that rainfall always exceeds evaporation. If that were not true, Florida would be a desert.

As for water quality, Mr. Marshall contended that a flow way would more than double the treatment area provided by current storm water treatment areas.  He claims Plan 6 provides the most ecological benefit and reconnects the entire Everglades ecosystem.

"Plan 6 looked to be a good fix back in 1981, and earlier, and still looks that way," Mr. Marshall said.

"If we have a flow way to take water from the lake we would have something meaningful," said Mr. Judah . "Most of water from EAA does not come from the lake."

"The system today is not what it was and it would be very difficult to get it that way," offered SFWMD's Tommy Strowd.   He claimed that evaporation in a flow way would be a problem. He mentioned the man-made structures that would have to be removed to accommodate a flow way. He claimed that storm water treatment areas are more effective than shallow flow ways.  "Commitment of additional resources to further investigate a southern flow way are not warranted at this time," he said.

Commissioner Joe Smith of St. Lucie County suggested a full cost analysis of Plan 6.  At least one commissioner was sold on Plan 6.

"This is a good time to reconsider Plan 6 as a method to get clean water to the park," was the opinion of Mrs. Heard.

An opposing view was expressed by Mr. McCarthy. "This is the answer to the estuaries," he said.  But he went on to say that it is not the whole answer. He advocated looking at all means of routing excess water south and not limiting the study to Plan 6.

"We have heard a lot of evidence that says a flow-ways will not work," he said.  He suggested multiple flow ways or perhaps a small flow way and lot more reservoirs.

Mr. Judah contended that SFWMDs way of looking at water storage is not in the best interest of the estuaries.