The EAA poses a great risk to CERP implementation... A suggested sample of what needs to be sent as part of the solution in a mass-media campaign is the letter sent to the Governor, Sole and Pelham, cc to our legislative representatives, state and federal, below.

JAM
JamInfo@aol.com

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

March 6, 2007

The Honorable Charlie Crist
Governor, Great State of Florida
The Capitol, Tallahassee , FL 32399-0001

Dear Governor Crist,

We are requesting that the Everglades Agricultural Area (EAA) immediately be declared a State region of Critical Concern, and that a strategic plan for the future of EAA be pursued to avoid a significant compromise of Comprehensive Everglades Restoration Plan (CERP) implementation.

The Governor's telephonic speech to the Everglades Coalition on January 20, 2007, and presentations and interactions with Mike Sole and Tom Pelham at the Coalition Conference, and the recent press conference in Stuart, have given the conservation community much optimism about moving CERP forward. However there is no time to waste on pressing for an EAA strategic plan, in the most unplanned region of CERP.

The results of lack of such a plan include a number of proposed and approved development projects in the EAA or vicinity, mostly in Palm Beach County . This includes two land fills, one adjacent to the Arthur R. Marshall Loxahatchee National Wildlife Refuge, two power plants, one coal-fired, and an agriculture chemical warehouse at the entrance to the Refuge, all of which may adversely affect CERP implementation. The attached needs and gaps assessment amplifies.

There is a significant need for conveyance of water south through the EAA, to provide citizens protection in the form of a spill-way for the Herbert Hoover Dike. This would also provide a major relief for the Caloosahatchee and St. Lucie estuaries.

The lack of a contingency plan that includes these options and numerous development and infrastructure projects in the EAA that may impede CERP implementation begs a question: Is this a reason for withholding promised federal dollars? Some of us think the answer is yes, and are willing to ask our Congressional representatives to continue to withhold federal funding, given continued inaction to address the issues outlined above, and in the attached, including the Everglades Coalition "Essentials and 2007 Action Plan, published at the Coalition Conference.

Thanks for immediate consideration here, especially designation of the EAA as a region of State Critical Concern, and being the catalyst for successful restoration of the Everglades for the future of Florida . It's the honorable thing to do.

Revise for EvCo Sign on as appropriate.

Attachment as noted.

Copy to:
Secretary, FDEP
Secretary, FDCA
Executive Director, SFWMD

 

Attachment:

Northern Everglades Watershed Region (EAA Region): CERP Needs and Gaps Assessment

There is significant proposed and approved development and infrastructure in the Everglades Agricultural Area (EAA) and vicinity that has the potential to preclude Comprehensive Everglades Restoration Plan (CERP) implementation. Related to this, the Arthur R. Marshall Loxahatchee National Wildlife Refuge, located immediately to the east of the EAA, is being threatened by some of the aforementioned proposed development and infrastructure. This includes:

A Solid Waste Authority (SWA) landfill a few hundred yards west, 1600 acres and 200+ feet high when completed: Many trucks per day dumping, air/ground water pollution (approval pending)

A gas-fired power plant to the Northeast a few miles – a big water user (approval moving ahead)

A coal fired power plant near the west side of Lake Okeechobee , with mercury and sulfate emissions that the Everglades National Park manager and others is publicly protesting. (pending)

An agricultural chemical warehouse and sales building at the front entrance to the Refuge (proposed; search for an alternate site pending)

A 2500 unit development to the south of the Refuge where a reservoir was proposed. (pending?)

A golf course at the south end of the Refuge, another potential Refuge water user (Pending)

The EAA, formerly the Northern Everglades Watershed (~700,000 acres of pond apple forest/sawgrass plains) to the west and northwest of the Refuge, was the historic connecting link between the north and south part of the Everglades ecosystem. There are few plans to restore much here, especially the essential link. Absent a plan, the following development and infrastructure currently is being considered:

Approved rock mining operations on ~5000 acres, and likely more requests for rock mining coming, since Miami-Dade rock mining has been curtailed due to pollution of the local aquifer.

Boat Locks proposal to support an inland port, with associated infrastructure, including a commercial airport, and rail connections

An approved land fill for ash from sugarcane bagase.

Rooftops, some potentially within the floodzone of a breach in the Herbert Hoover dike; FEMA maps do not recognize this as a flood zone, which is convenient to development

Another landfill on the western shore of Lake Okeechobee

Major future road corridors proposed to go through the Everglades (Century Commission report)

Needed: A strategic plan for the future of the EAA as repeatedly requested by the Everglades Coalition and 10 County Coalition (Counties surrounding Lake Okeechobee and Caloosahatchee-St, Lucie estuaries), to ensure proposed development and infrastructure does not impede CERP implementation, and adversely effect the Refuge, last remnant of the Northern Everglades; also a need for more ecosystem ecology applied science.

The Palm Beach County Commission continues to promote development by approving development requests, granting variations, or changing the code, with no consideration of collective impacts of all these projects. One or two commissioners have called for the EAA Strategic Plan, driven by the need to assess the rock mining situation; only that situation is being assessed at the present time in a study.

The South Florida Ecosystem Restoration Task Force (TF) has the WRDA 96 Section 528 Charter to take t on strategic planning, and to ensure compatibility with the built and natural system per goal 3 of 3 goals. A TF premise, following the legacy of the Marshall Plan, is that the Ecosystem should be managed as a whole . That is not happening here, and the TF has politely refused to take anything but a passive role in managing the ecosystem as a whole, in the case of the Northern Everglades Watershed region (Now the EAA).

The State complains that the feds are way behind on funding CERP implementation, which is true.

This begs a question: Would a federal funder, observing a FWS managed Refuge under attack, as well as CERP itself, by a collection of development approvals, be inclined to fund a potential CERP failure?

Big Picture Regional Needs and Gaps assessment summary, not necessarily limited to the following :

• Need for a strategic plan for the future of the EAA, as expressed by the Nine County Coalition, the Everglades Coalition, and a minority of the Palm Beach County Commissioners.

• Need for a northern Everglades watershed conceptual ecological model (CEM) to support the production of a strategic plan. All CERP regions are covered by a CEM except for the EAA region. This was the region of the forested wetlands and sawgrass plains. Lack of a CEM for this region, has had the effect of exempting this region from the CERP footprint and allowing non-agricultural use (aka development) to prevail, with virtually no consideration of the historical ecological values of the region, and near total lack of any attempt to restore same, as the Marshall Plan, Recon Study (1994), etc, have called for.

• Need for a flow way south to relieve the estuaries, provide a spillway given the current condition of the Hoover Dike; and increase spatial extent of natural area, restore habitat and functional quality and native species, per CERP ecological goals outlined in CERP Table 5-1 of the yellow book.

The consistent approach to meet the need for restoring dynamic storage and sheet flow, per CERP Section 2.1, has been outlined in the Marshall Plan, the Science Subgroup Report (1993) and in the Corps of Engineers Recon Study Plan 6 (1994), and more recently by the Rivers Coalition revisiting the need for a Recon Study Plan 6 flow way. The 10 County Coalition is currently considering endorsing a re-evaluation of Plan 6, pending a briefs at the April meeting.

• Need for an ASR Contingency Plan. Aquifer Storage and recovery have been touted as a major component of CERP; an ASR contingency plan has been “promised” since 2002.

Per CERP Section 7.5.3 - Cost-effective analysis of alternatives - there is a need to evaluate the trade-offs between ASR and restoring flow per Recon Study Plan 6. The Chair, 10 County Coalition indicated that the Corps has received a Congressional request to do this. Hence…

Need for the State to take immediate action by designating the EAA region a state area of critical concern , and halting some of the proposed development and infrastructure that would preclude executing the trade-off that provides the most economical and ecological benefit.

The driving need for ASR is lack of dynamic storage and sheet flow.

Installing 330 ASR wells is a hi-tech, hi-risk, hi-cost approach, with high energy consumption

Restoring sheet flow is low-risk, low-tech, low-cost approach, with low energy consumption.

• Need to connect the Northern Part of the everglades ecosystem ( Kissimmee – Okeechobee Basin ) with the southern part of the ecosystem (Alligator Alley south to Everglades National Park and Florida Bay ): This is a very BIG GAP, second only to the need for more application of ecosystem ecology principles.

Need for additional conveyance south as all Storm-Water Treatment Areas come on line: Corps of Engineers has stated there is not enough conveyance presently.

Need to decompartmentalize and re-connect the entire ecosystem by restoring flow, the primary feature of the Everglades to the maximum extent feasible, the Marshall Plan , again!

Need for a strategic plan for this region, or the result may be two regional ecosystems insufficiently connected which is not representative of the historic Everglades ; i.e. result is that CERP implementation, as outlined to Congress and the public, is insufficiently restored.

• Need for an EAA strategic / contingency plan that takes into account cumulative impacts of the collection of development projects approved and proposed. While any one project might not break the threshold of a development of regional impact , it is obviously clear that the development proposed and approved will have a major adverse impact on CERP implementation in the EAA region.

In a March 17, 1997, letter, Colonel Terry Rice, then the Jacksonville District Engineer, declared that unity of effort was most lacking in the EAA, where contention has impeded progress for over a decade [now two decades], detracting from other key components in South Florida, and in need of a vision:

Our vision for the EAA is to sustain a primarily agricultural economy while restoring and preserving the ecological values of the region, with development and infrastructure that does not preclude either.

Without a plan or a vision there is no hope for sustainability.