Friday, September 25, 2009

Public Comment to the Ten County Coalition for Responsible Management of Lake O & Estuaries

ArtMarshall.org Verbal Public Comment to the Ten County Commission Sept 25, 2009

Scenario: Followed Forest Michael, Planner, regarding economic benefits of restoring Lake Hicpochee and Lake “Clewiston”, then a presentation by Temperience Morgan, SFWMD, with a summary of River of Grass Process Phase 1, followed by much discussion on the need to clean up Lake Okeechobee to reduce phosphorous levels. Three minute time limit applies.

Comments paraphrased: I have written comments for the record, so I won’t go into detail over what is in the record; I also sent this ahead to those whom I had an e-mail address in my directory.

There has been a lot mentioned about economic benefits today. Forest gave us a few teaser examples, however much more needs to be done. Until economic benefits are posted in dollars we are not sending the right message. When benefits are mentioned without monetization, everything is left to our imagination; collectively that isn’t worth much either.

Thus we join a few govt and non-govt folks who are calling for monetizing the benefits of Everglades’s restoration for the south Florida Economy.

We appreciate the openness of the River of Grass planning process. We participated with an input called the Marshall Plan. Put simple, this was about restoring flow from the Kississimee Basin to Florida Bay [via Lake O and the Everglades Watershed].

Recall the governor’s plan was to restore the missing link [and revitalize the River of Grass]. By the way, given all the talk about cleaning up Lake O, we need to think of the CERP(+) effort as three regions [north to south]: (1) The Northern Everglades Ecosystem (Kissimmee Basin and Lake O]; (2) The missing link – River of Grass planning; (3) the Rest of the Everglades from WCA-3 south [to Florida Bay]. This does need to be an integrated effort [consistent with the comments on cleaning up Lake O, and the pollution sources to the North [also Sam Poole’s comment on behalf of Florida Crystals]

The Marshall plan (5th configuration) was about maximizing shallow wet storage in the form of a flow-way, because we knew Lake O would always have a pollution problem, and this was a way to maximize conveyance of clean water south. To get to the big numbers for the Marshall Plan configuration, we extrapolated results from the National Research Council study. We guesstimated the cost at $7.6 Billion and calculated the benefit at $69[+] Billion. This gave a Benefit/Cost ratio of about 6. USACE makes (go) decisions on B:C ratios of 1.5.

[More Scenario: Regarding Commissioner Echols call for the consideration of Agriculture in the EAA (everybody has to eat, and the EAA is the winter food basket for USA; USA Ag is in big trouble.)

Looking in Commissioner Echols direction: Commissioner, somewhat in cooperation with Florida Crystals and their approach, we moved our [Marshall} Plan west, on the least productive soils, and left the most productive soils to continue agriculture [at significant economic benefit]

We are also pushing for the restoration of the Pond Apple Forest, that was south of Lake O. Don’t forget CERP(+) is also about restoration of habitat, and there is economic benefit here too. [Rae Ann Wessel gave this honorable mention in follow-on public comment, thanks]

I will close with an informational item: The Marshall Foundation is hosting The 2010 Everglades Coalition Conference. The Conference will consider Valuing Ecosystem Services and the US Sugar Corp purchase in Break-out and Plenary sessions. Save the date Jan 7-10 in Palm Beach County; the PB County Commission is one of the Sponsors. [Ken Todd was representing Commissioner Karen Marcus, at the dais].

Thanks for your consideration.


September 21, 2009

Arthur R. Marshall Foundation and Florida Environmental Institute, Inc. Public Comment
to
The NRC Committee on Independent Scientific Review of Everglades Restoration Progress
on
Valuing Ecosystem Services – Toward Better Environmental Decision- Making

Background - Committee Agenda Scenario: Benefits got honorable mention several times during presentations to the Committee. Eric Bush, USACE, emphasized the need to clearly state benefits as well as costs in the current competition for funds, in summarizing implementation needs after seven topical presentations on Restoration Challenges & Solutions in the WCA’s. Eric noted that the government is risk adverse, when it comes to funding projects with uncertainty, noting that projected Everglades restoration benefits need to be stated with certainty to ensure viable funding levels. Dewey Worth, SFWMD, mentioned the need for quality ecological benefits in a manner understandable by Congress (also the ArtMarshall.org view) in Use of Models for Project Planning: DECOMP. Dewey used the Habitat Unit approach to modeling benefits. He also called for one-number solutions for decision-support, however difficult this might be. All this begged the question of monetizing benefits in an understandable manner. [Most seem to agree that the habit units approach is not the answer, as they do not go in the direction of monetizing benefits, and are confusing to all but the HU users]. Agenda item just before Public Comment: Temperience Morgan, SFWMD: Update on U.S. Sugar Purchase, including a summary of River of Grass Planning Process Phase 1, and prospects for Phase 2, including a look at benefits.

Post facto comment: Fundamental questions arise as an extension of the Eric Bush/Dewey Worth call for a clear statement of benefits: Does this unequivocally establish the government requirement to monetize the economic benefits of Everglades restoration? Is this requirement the means to get to Benefit:Cost Analyses (BCA) to provide single figure decision-support? The ArtMarshall.org holds that these questions and statements do set the requirements for monetizing benefits, and that it is not as difficult as implied in comments to the Committee.

The four minute clock for public comment applied, so written and verbal comment for the record are paraphrased below, with the verbal comments in italics, [and a few after-thoughts]

Opening Public Comment Statements: It is appropriate for me to follow Temperience. And one of these scenarios is the Marshall Plan. Kudos to the openness of the process, as expessed by Nick Auman, NPS. We have recommended that the NRC approach be used as a River of Grass [ROG] decision-support tool. [Using the Book of same title as the presentation as a prop?… hopefully preaching to the choir] It was good that Eric Bush mentioned the benefits word. Another Eric, SFWMD Gov Board Chairman Buermanm, in fielding criticism about River of Grass Costs has also raised the question: What about benefits? Good question!

About a month ago SFWMD Governing Board Chairman Buermann got published in the Palm Beach Post, a Letter to the Editor, regarding the U.S. Sugar Land purchase to revitalize the River of Grass. Relative to costs, the Chairman called the question: What about the Benefits?

We think that that is an excellent question. I am here as a follow-up to the National Research Council (NRC) Study of the same title, to suggest that benefits be monetized same as costs.

NRC recommended methods to do this that have growing acceptance. We have suggested that the approach & methodology be used in the River of Grass Phase for decision-support.

We have also recommended that the NRC approach be incorporated in the Programmatic Regulations update. Written comments for the record amplify. We know that USACE/SFWMD/FDEP/DOI Staffers are working on the Programmatic Regs revision.

We also know the SFWMD River of Grass planners are looking for a way to highlight benefits, as well as costs. The price tag for the various ROG configurations carries some heavy sticker shock, and lots of cost controversy. However in first order estimates, and extrapolations from other Benefit:Cost Analysis (BCA) indicate the long-term benefit approaches an order of magnitude more than the costs. More long-term thinking is needed.

We ask the Committee to give the NRC approach an applications push in whatever manner is appropriate, as it appears that casting benefit in this manner is a way to demonstrate the value of applied science, understandable by Congress, the Office of Management and Budget, and the public. A recent news article, on this double sided written comment, amplifies. See http://www.palmbeachdailynews.com/opinion/content/news/2009/09/19/EditMarshallvoice0920.html
[A significant part of the Art Marshall legacy is to engage the public in the process of democracy]

In verbal public comment: What we have demonstrated [with the published article on Amendment 4] is that results of a case study in the 2005 NRC Report can be extrapolated to an Everglades Restoration application in a manner that demonstrates to the public that the benefits of Everglades restoration are well worth the cost. [What is now needed is more detail, per the recommendations of the NRC Report]

What is the impact of not monetizing benefits: The risk-adverse malcontents will continue to attack the high cost of various projects, without a clue of the long-term benefits, and needed full funding may get lost in the face of political competition.

We have it from reliable sources that Rock Salt is considering the ESV approach for application in USACE processes. That too would be a great help.

All this will also be the subject of a break-out session at the Everglades Coalition Conference; we will invite the top experts to be on the panel. We have used the Title of the NRC Study, for the title of the break-out session. We hope this does not violate any copyrights, and in fact will induce additional purchase and reading of the 2005 NRC Study by the uninformed.

[The 2010 Everglades Coalition Conference will take place 7 – 10 January, 2010, at the PGA Resort, in Palm Beach Gardens, FL. Additional conference information can be found at www.EvergladesCoalition.org.]

For BCA for better environmental decision-making, thanks for your consideration:

Respectfully submitted,

John Arthur Marshall (JAMinfo@AOL.com)
Chairman of the Board; www.ArtMarshall.org

Monday, September 21, 2009

From the Palm Beach Daily News--Amendment 4 a much-needed reality check on development

For those of you who missed my editorial from Saturday's edition of the Palm Beach Daily News...
Saturday, September 19, 2009

Until recently many conservationists doubted the efficacy of Amendment 4, owing to its potential to make existing permitting processes even more cumbersome and costly.

What we expected was reasonable compliance with rational comprehensive growth management plans for sustainable development, under the Growth Management Act. What we got was multiple deviations, with the imposition of multiple taxes, great profits for developers and little growth management realized.

That was then. Now is a developer push to severely limit or do away with impact fees, and a legislative threat to eliminate the Florida Department of Community Affairs. Now, with a glut of empty houses and condos, is a lobbying effort to do away with the growth management requirement for justifying growth. For those who understand the hidden costs to society and the resulting increased tax liability, this is the last straw.

The FDCA is the state agency that provides a reality check on developments run amuck, literally. By paving over paradise, there is an impact of uncalculated external costs to society, also known in economics as externalities, hence the need for impact fees. The reality check needed here is the calculation of all externalities' cost to the taxpayer.

Development externalities include all manner of infrastructure and services needed to support the proposed development and increased population: Schools, roads, fire and police, medical emergency services, garbage pick-up and landfills, sewers and waste treatment, and more government to handle this, and especially a viable water supply.

Another externality is the loss of property values across the board, caused by overdevelopment and increase in taxes per the aforementioned infrastructure and services, which the bureaucracy is finding not only hard to give up but in need of more. Hence nickel-and-dime taxes as a result in the news recently.

On the externality of water supply: For the snowbirds, here is a recognizable case study to compare what happened in New York City to what has happened in Florida, as another reality check.

To upgrade its water supply, New York City opted to restore the Catskills watershed at a cost of about $1 billion, as opposed to spending up to $8 billion on water plant construction and operation.

In South Florida, paving over paradise, by dredge and fill destruction of wetlands, has reduced our watersheds. This takes the cost of water supply for Florida residents in the opposite direction taken by New York. As the Everglades watershed has diminished, the effect is a local call for deeper drilling in the Floridan aquifer, reverse osmosis and desalination, all at a very high cost, when the New York remedy is available.

Guess what? The cost of reverse osmosis and desalination is six to eight times the cost of natural water supply. This is the same benefit-to-cost calculus that persuaded New York to opt for the low-tech, low-cost, low-risk attributes of the natural system.

Call our New York remedy the Comprehensive Everglades Restoration Plan, to restore a major part of Florida's natural watershed, at six to eight times the benefit, compared to high-tech, high-cost water supply methods, that also require more electricity.

The late Art Marshall provided this reality check in a 1981 news article: In Florida it has always been said that if we can just get a bigger population, we'll get more business and more dollars and it will solve all our problems. That's a bunch of crap. It doesn't work that way. Please observe that things have gotten much worse since 1981, with a lot more crap.

Now guess why the externalities are never mentioned. A salient quote: Success of the Growth Machine in Florida depended on the public not receiving information. Amendment 4 advocates are now the informed, but they are not the radicals. What development has done is to transform a natural asset to societal liability, with significant reduction of quality of life for all Floridians. As a recent editorial noted, "Unchecked growth is an unsustainable extreme."

In the quest for an approach to nearly unconstrained development at great cost to the taxpayers, Amendment 4 is the unintended consequence. Consider another externality: The developers' cost of political contributions to keep this tax debt spiral going.

Now, can anybody not understand why utilities are calling for increased rates to cover the cost of new infrastructure to meet increased demands, and for conservation of water and energy? ... And why the two are related?

For the long-term, big-picture thinkers, there is one more externality that portends significant costs to society: Global climate change and sea-level rise, accelerated by the loss of wetlands and more fossil fuel usage, with carbon emissions. Here the "unsustainable" word is appropriate. Needed reality checks are way past due.

As a final reality check, please have a read of Paving Paradise — Florida's Vanishing Wetlands and the Failure of No Net Loss. This may move rational folks to go beyond just voting for Amendment 4, to campaign for a much-needed reality check. Can we say taxation without representation?

With "4" there is a chance of representation and restoring the process of democracy. Without "4," past history and current events tell us nothing will change for the better.

JOHN ARTHUR MARSHALL

Palm Beach
http://www.palmbeachdailynews.com/search/content/news/2009/09/19/EditMarshallvoice0920.html##

Jazz It Up for the Everglades--update

Our annual Champions of the Everglades award recipients have been announced:
(2008 award)

http://browardnetonline.com/2009/08/champions-of-the-everglades-to-be-recognized/

Thursday, September 10, 2009

Public Comment to the Governing Board~September 9, 2009

Public Comment Paraphrased on Valuing Ecosystem Services to Agenda Item #18, 9/9/9:

River of Grass Phase 1 Summary/Phase 2 Projections
Introduction, in response to Board Member Mile Collins statement earlier, who said after the Kissimmee Basin presentation: Thirty years ago no one was looking at the total system.

Public comment: John Arthur Marshall, representing the Arthur R. Marshall Foundation; Let me begin by regressing to a remark made by Board Member Collins: Thirty years ago there was a person considering the total system. His name was Art Marshall. He was also throwing verbal hand grenades as the Kissimmee River was being canalized. That is the context from which I speak.
About a month ago [Governing Board] Chairman Buermann got published [in the Palm Beach Post] a Letter to the Editor, regarding the U.S. Sugar Land purchase to revitalize the River of Grass. Relative to costs, the Chairman called the question: What about the Benefits?
We think that is an excellent question. I am here to suggest that benefits be monetized in economic terms, same as costs.
The National Research Council [NRC] has recommended methods to do this that have growing acceptance. We recommend that the approach and methodology be used in the River of Grass Phase for decision-support.
We have also recommended that the NRC approach be incorporated in the Programmatic Regs update. Written comments for the record amplify. Board Member Powers has been provided an advance copy.
We know that [SFWMD] Staffers are working on the Programmatic Regs revision and ROG Phase 2. We ask the Board to give this some consideration.
We have it from reliable sources that Rock Salt is considering the ESV approach for application in USACE processes.
This will also be the subject of a break-out session at the Everglades Coalition Conference; we will invite the top experts to be on the panel.
Thanks for your consideration:

Chairman Buermann response: The Palm Beach Post has indicated they are interested in publishing the benefits. Perhaps we can get you involved.

Followed up with an e-mail: Just point me in the right direction.

Thursday, September 3, 2009

Public Lands Day at the Refuge


for anyone who wants to pitch in and protect the Everglades and our public lands...