Arthur R. Marshall Foundation & Florida Environmental Institute, Inc., for the Everglades
Public Comment Oct 15, 2013 on
The CEPP DRAFT Project Implementation Report (PIR)
The Art Marshall.org is pleased to have the opportunity to comment on the Central Everglades Panning Project (CEPP) Draft PIR. These comments are an expansion of public comment provided to the Water Resources Advisory Commission (WRAC) Oct 3, 2013, following the CEPP update by Tom Teets, SFWMD.
EXECUTIVE SUMMARY: We support CEPP as the first step in CERP to restore sheet flow as envisioned in the 1981 Marshall Plan published as Friends of the Everglades News Letter and petition, by Marjory Stoneman Douglas: Effect repair requires restoration of sheet flow to the greatest possible extent from the Kissimmee Lakes to Florida Bay…. The purpose of this petition is to achieve environmental benefits accruing form repair of the Everglades. As it was in the Marshall Plan, benefits is a powerful word in the CEPP DRAFT PIR, with the word benefits appearing some 175 times in the CEPP main document. However the absence of a publishable ecosystem services valuation (ESV) to define benefits, relative to cost, thus also leaving absent a clear measure of CEPP return on investment, is a deficiency that makes the CEPP PIR sticker shock price harder to sell; as noted by the National Research Council (NRC 2005) no publishable value has a default value of zero (0). A Total Economic Valuation of CEPP benefits, a synthesis format per NRC 2005 remains an unfulfilled challenge to what could be a major enhancing feature for better environmental decision-support. Based on CEPP ESV Calculations in the attached spread-sheet, and previous demonstrations we conclude that a TEV of benefits will always lead to a robust B:C calculation of an order of magnitude approximating 20:1
DISCUSSION AND RESULTS
We support the CEPP. Having been involved in and observed at close hand, CERP/CEPP from December, 1997 to present, the CEPP process has been an amazing and encouraging process. Kudo’s to the CEPP PDT and all who supported it for speeding it along, with more streamlining of process to go.
In the list of public comments received summarized in the WRAC update, we would emphasize the need for a flow through system and additional land acquisition in the EAA.
We would add the need for a publishable CEPP Ecosystem Service Valuation (ESV) as the means to better sell the CEPP program and get funding by a synthesis that is clear to all. CEPP benefits are widely touted, with the word “benefit” appearing 175 times in the main report. However there is no published economic value given to these benefits. A major point made by a National Research Council (NRC) 2005 Study is that when no value is given the default value is zero (0).
As we have done in the past, (ARM Foundation: Economic Valuation of Restoring the River of Grass, 2010) we are providing as part of this comment, a demonstration on how a total economic valuation (TEV - NRC 2005) might be done for CEPP. We have used CEPP habitat unit assessment (HUA) “lift” data (difference in ESV before CEPP and after CEPP), and applied the benefit transfer method using generic ecosystem habitat ESV calculated in the Constanza Synthesis (1997).
The result is a demonstrated notional TEV of $53.353 Billion at an estimated cost of $2.024 million, for a benefit/cost of 26.36. The calculated B/C ratio of 26.36 fell just slightly higher than the same range of values demonstrated by our ARM 2010 summer interns where B/C = B:C ranged from 5 to 24.
From repeated demonstrations, we conclude that a govt calculated TEV would place the economic value of ecological benefits in its proper perspective, and when related to cost in the B:C ratio, would provide a clear measure of Return on Investment, i.e., a clear and measurable synthesis based on TEV would sell the program.
While the Costanza Synthesis has evoked some controversy as to its practical application, it appears to be the only ESV paradigm to follow to provide a quick, inexpensive reality check on the ESV expected value for a given ecosystem, and a guide-line on how to proceed with a more localized TEV. In the face of the PCAST (2011) Report to the President and the call for agencies of the federal government to move in this direction, and the NRC 2005 Study, the move in this direction is costly slow.
Consider the following Syllogism.
· Environmental Capital provides the basis for all economic activity
· Environmental Capital in the form of Ecosystem Services is of significant value to society
· Assigning a Total Economic Value to Ecosystem Services over time is a way to sustain environmental capital to protect society and the economy.
· Conclusion: The dollar value of Ecosystem Services restored, enhanced, and sustained will be much greater than the cost to restore, enhance sustain same.
Thus robust B:C ratios greater than 20:1 should be no surprise. In the case of the attached calculations giving a B:C of 26.36, a few comments: (1) The big B:C should be no surprise; (2) the ESV calculation based on HUA may be mildly optimistic, as a result of computer generated habit units based on performance measures. (3) For a conservative estimate of the value of wetlands, swamps (forested wetlands) and estuaries, for back of the envelop calculations: Think $10,000 per acre per year and multiply $10,000 by number of acres and years of life cycle (~40 years).
There are three possibilities for calculating CEPP ESV in the TEV recommended by NRC 2005
1. Use the somewhat controversial Costanza Synthesis (1997) and benefits transfer for a quicker, better, cheaper approach for a ball park - same order of magnitude - expected value. (No other ESV paradigm appears to exists)
2. Spend three years and a few million dollars to provide the preferred local TEV calculation of benefits.
3. Absent a publishable TEV of benefits, as noted by the NRC 2005 study, the default value of benefits is zero (0), and there is over-focus on costs. This is the present case for CEPP.
If Mark Perry were here for the Rivers Coalition, instead of DC, [giving testimony to Congress on the need to protect and restore the estuaries] he would be calling for more flow south, Plan 6 being the fix, Plan 6 being a central element of the Marshall Plan.
We support CEPP as an initial increment of the Marshall Plan, 1981, which had as its central element, what became Plan 6 in 1994. This was not accident. Art’s vision expressed in the 1981 – 1984 Marshall Plan, published by Marjory Stoneman Douglas as a Friends of the Everglades News Letter, was to restore sheet flow from the Kissimmee Basin to Florida Bay.
In context of a principle objective of CERP, read this as Full DECOMP, and restoring habitat and functional quality. We need to keep our eyes on the prize. Given the WRAC comments October 3, 2013, that is not happening. The devil remains in the details which impedes the total ecosystem approach, a tenet of the Task Force strategic plan.
In a recent brief of the Regional Climate Action Plan (RCAP) Brief to the PB Count Commission, we made comments that CEPP was an essential element to an Action Plan. We were pleased to see at the top of the RECAP action list: Planting Trees!
This immediately brought to mind the need to restore the pond apple forest in CERP/CEPP as previously suggested as the means to (1) increase the spatial extent of natural area; (2) restore habitat and functional quality, and increase native species an abundance per CERP Table 5-1 goals and objectives.
Connecting the dots to the previous presentation which mentioned the Okeechobee Gourd as an endangered species. The pond apple forest provides the habitat for the Okeechobee Gourd.
Recognizing that actions on many of these comments must come in subsequent CEPP increments, we fully support CEPP increment 1 as a significant step to restore the Everglades and save the planet.
Thank you for your consideration.
John Arthur Marshall. Chairman of the Board.
Attachment: Spread-sheet model that demonstrates TEV by a notional CEPP ESV calculation.
Arthur R. Marshall Summer Interns (2010); Valuing Ecosystem Services of a Restored River of Grass; Anglique Giraud, et al; http://www.conference.ifas.ufl.edu/GEER2010/Poster%20PDFs/Marshall.pdf
Costanza Synthesis: 1997: The value of the world's ecosystem services and natural capital, Robert Costanza, et al; Google Nature 387.
NRC 2005 Study: Valuing Ecosystem Services – Toward Better Environmental Decision-Making; the National Academies Press
PCAST 2011: President’s Council of Advisors on Science & Technology; Report to the President: Sustaining Environmental Capital: Protecting Society and the Economy. http://www.whitehouse.gov/sites/default/files/microsites/ostp/pcast_sustaining_environmental_capital_report.pdf