Dear DECOMP PDT Members

Dear DECOMP PDT Members:

Thanks for the opportunity to provide public comment at the DECOMP PDT (Project Delivery Team):

Attached is an e-copy of the National Research Council (NRC) summary on flow-ways in the EAA and restoring sheet flow, as a follow-up on Cheryl Ulrich's comments, much appreciated, on the need to read the NRC reports, especially the latest "First Progress Report" (2006) listing the five components of Everglades restoration that are critical. This paper summarizes the first two critical components which address the need to restore flow as a primary means of restoring the Everglades. Hopefully this will provide DECOMP insight and save some reading time.   Italics are NRC comments. Footnotes are yours truly comments regarding current events.

On the proposed big-picture hypothesis, regarding Storm-water Treatment Area (STA) performance:

Here is a summary of what was presented in the 12:15 public comment period, via e-mail, as promised.

PUBLIC COMMENT:   STA PERFORMANCE HYPOTHESIS (Using SFWMD map of all STAs)

o HYPOTHESIS: 10% of historic filter area will not filter 5 times the historic level of Phosphorous!

o Lake Okeechobee P range discussed is about 80-400 ppb; let estimated average = 200 ppb

o Consensus historic lake average = 40 ppb. 200 ppb/40 ppb = 5 times historic level

o Let projected STA acreage = 70,000 acres; EAA = historic filter area ~ 700,000 acres

o Self-Evident hypothesis? Hypothetically, present + planned 70K STA acres would have to be 5x10 = 50 times as effective as natural system to achieve P = 10 ppb [that likely existed in the sawgrass plains];

o This follows statements made by the DECOMP PDT members regarding the statement that P = 10 ppb many not be achievable, might have to live with more, up to 20 ppb.

o Picture is worth a 1000 words: Note postage stamp size of STA's relative to 700,000 acres of the historic "filter area" = the pond apple forest and the sawgrass plains.

CONCLUSION: Time to consider other options such as 1994 USACE Recon Study Plan 6 flow-way, or something like it.

This is likely one of many reasons why NRC peer review panel has restoration of flow in the EAA, and in general, as one of their top priorities.

For the Art Marshall approach,

Thanks again.

John Arthur Marshall

www.ArtMarshall.org

INTRODUCTION (page 5): Modeling of water flow is not very helpful for quantifying flows. Although the Natural System Model (and the SF Water Management Model) provide useful estimates of gross system inflows and outflows, estimates of flows with the system are much less accurate. Further neither model currently resolves flows at scales smaller than the 2x2 mile grid.[3]

Page 7: During the last few years there has been an increasing concern about whether the ecological objectives of the Restoration Plan can be achieved to the extent desired without greater attention to the issue of flow.

Ignoring flow introduces an important source of uncertainty in the implementation of CERP.[4]

Because it is not clear wither the ridge and slough landscape is maintained by average or extreme conditions, it is important to provide exact measurements of flow for the full range of flow conditions, especially extreme events… and what happened upstream (page 12-15),

Given the potential role of flow in landscape maintenance, restoration efforts should attempt to incorporate flows approximating historical discharges, velocities (speed and direction), timing and distribution in their design.

Facell Bill complemented the publication of Arthur R. Marshall’s For the Future of Florida, Repair the Everglades, commonly called “the Marshall Plan” (Marshall, 1981)[5], and it also complimented the initiation of the state’s Save our Everglades Program in 1983 by Governor Bob Graham. (page 13)

Re-Engineering Water Storage in the Everglades – Risks and opportunities. (2005)

EVERGLADES AGRICULTURAL AREA (Page 9, Executive Summary): The EAA immediately south of Lake Okeechobee was an important conduit for sheet flow in the unaltered Everglades….A possibility would be to consider uses of the EAA more aligned to restoration needs. These might include turning all or parts of it into a wetland with a cattail-sawgrass gradient. Perhaps it could simply be flooded and the water used for storage and to enhance sheetflow…. Committee recommends a re-evaluation of the EAA’s future in Everglades restoration. [6] This is a complex analysis, requiring estimates of the cost of land acquisition, the feasibility and likely costs of various options, and other matters. The analysis should begin as soon as possible.[7]

MAJOR FINDINGS AND RECOMMENDATIONS (Page 10), Recommendation 4: In addition to the contingency planning[8] that already is being undertaken, more intensive and extensive planning should be pursued. Options should be considered for using the EAA and Lake Okeechobee as elements of the Restoration Plan in ways that are not now part of the Plan.

Progress Toward Restoring the Everglades: The First Biennial Review (2006)[9]

1. Enough water storage and operations that allow for healthy estuaries and return of sheet flow through the Everglades ecosystem while meeting other demands for water.

2. Mechanisms for delivering and distributing the water to the natural system in a way that resembles historic flow patterns.

CERP (page 36); CERP is founded on the view that restoration is best achieved by re-establishing natural processes of the historic ecosystem. In its application to the Everglades, this means restoration of large-scale sheet-flow, the dominant feature of the natural system.

PROJECT PLANNING (page 64): A systematic approach to analyze the cost and benefits across multiple projects in plan formulation is notably lacking.

SCIENCE COORDINATION AND SYNTHESIS (page 89): Science Coordination Group (SCG) has neither the manpower nor the mandate to provide comprehensive science coordination and data synthesis.[10]

DECOMPARTMENTALIZATION (page 119): Justification is problematic because of the precise relationship between the degree of sheet-flow (e-g., volume, direction, velocity) and the response of down-gradient ecological performance is not understood sufficiently for benefits to be described quantitatively, even though there is a high likelihood that restoring those hydrological process will yield desirable ecological benefits. Committee is therefore concerned that the process may favor DECOMP actions that are limited in scope (e.g., allowing flow through small openings with less certain outcomes, e.g. removing levees that have the potential to offer greater restoration benefits.

EXAMPLES OF USING IAR[11] TO OVERCOME CURRENT CONSTRAINTS (page 144): Balancing Water Quantity and Quality for Restoration. This demands a detailed evaluation of the trade-off’s between water quality in the affected portions of the ecosystem and increased water flow in other areas of the ecosystems.[12]Research to improve performance of STA’s needs to be continued. Meanwhile, sheet-flow restoration should be initiated while STA efforts continue.

[1] CROGEE: Committee on Restoration of the Greater Everglades Ecosystem, NRC, National Academy of Sciences; some paraphrasing to keep the summary to one page double sided.

[2] CROGEE notes that much of this paper was based on the Science Coordination Team (SCT) Aug 2002 White Paper: The Role of Flow, and Workshops held by both the SCT, and CROGEE.

[3] An EAA flow-way was not modeled during the ’98 – ’99 formulation of the Re-Study (CERP).

[4] CROGEE member: Restoring flow is a no-brainer!

[5] The Marshall Plan was an early precedent for connecting Lake Okeechobee with the rest of the system by a flow way, using the same concept that subsequently appeared as Plan 6 in the USACE 1994 Recon Study

[6] The Everglades Coalition and the 10 County Coalition submitted formal requests to the South Florida Ecosystem Restoration Task Force to conduct such an evaluation; The Task Force declined.

[7] In lieu of an EAA future without a plan, the Environmental Community and the 10 County Coalition have requested a re-evaluation of establishing a flow-way in the EAA, with the 1994 Recon Study Plan 6 flow-way as a baseline to start the recommended analysis. The ArtMarshall.org, along with the Rivers Coalition has been a major catalyst for moving this along.

[8] An ASR contingency plan would need to consider a flow-way as an option in a significantly reduced ASR program (much less than the 330 wells proposed in the CERP yellow book. The ASR contingency plan, announced as an objective of planning in 2001, has yet to be developed.

[9] CISRERP: Committee on Independent Scientific Review of Everglades Restoration Programs.

[10] Transition of the SCT to the SCG appears to have had the effect of shifting the focus more on process than product. Flow is not mentioned in the SCG Science Plan which remains controversial, due to its scope and approach to identifying needs and gaps, or lack of same.

[11] IAR: Incremental Adaptive Restoration, as a means of incremental adaptive management; this is a major recommendation of the CISRERP in this report.

[12] This is consistent with CERP Section 7.5.3 requirement for Cost Effectiveness and Incremental Cost Analysis – which begins with a comparison of the cost and outputs of alternative plans. See yellow book Excerpt provided by the Marshall Foundation.