Public Comments to the South Florida Ecosystem Restoration Task Force (10/28/10)

Public Comment to the Task Force; Coral Gables, Florida, October 28, 2010

By John Arthur Marshall,
Representing the Arthur R. Marshall Foundation & Florida Environmental Institute, Inc.

As briefed by Mark Musaus, we applaud expansion of the Greater Everglades Ecosystem by the proposed establishment of the Everglades Headwaters and Fisheating Creek National Wildlife Refuges, as well as the proposed additions to the Florida Panther NWR, and other activities to increase spatial extent of natural area, noting that this meets the first goal/objective of CERP Table 5-1 in a most significant way.

We applaud the inclusion of Ecosystem Services as an emerging theme in the Task Force 2010 Plan for Coordinating Science, as noted in the Everglades Coalition resolution.

Connecting the dots: Recent Everglades Coalition members’ ecosystem services value studies and analyses indicate the high value of restoring and preserving spatial extent of the Everglades, with benefit to costs ratios exceeding 4:1, and in some cases much higher.

While methods used in two Everglades analyses differed significantly, the result ends up in the same ball park. Case studies also indicate that Benefit:Cost in the case of CERP will be somewhere in the vicinity of 6:1. This includes our 2010 Summer Intern work on Valuing Ecosystem Services of a Restored River of Grass, with handouts available.

The 6:1 B/C ratio exceeds the US Army Corps of Engineer’s go-no-go criteria of B/C greater than 1.5, and appears to make more sense than the somewhat arbitrary and esoteric assignment of habitat units, in B/C analysis.

With respect to pinning the tail on the donkey regarding the absolute value of restoring ecosystems, we recognize that the work done is a best estimate of projected outcomes.

We feel that analytic value is in consistently applying the methodology to different configurations to provide analysis of alternatives in a situation like the River of Grass workshop deliberations. That said, this does provide a general sense of value.

Should the ESV-B/C approach be applied to CERP without a overt mandate for doing so? Given the robust B/C ratios, maybe it is time to give more consideration to the ESV-B/C approach for CERP decision-support, with the synthesis of benefits in economic dollar value, that fully meets the WRDA Section 601 requirements to report to Congress the benefits to the natural system and the human environment achieved, in understandable terms.

We note that The DRAFT Report to Congress does give some credit to Defenders of Wildlife for Valuing Ecosystem Services. We concur with NRC that failure to put a value on Ecosystems leaves them at zero value, and at high risk of not meeting no net loss of wetlands policy.

Finally, as a matter of ethics, if we can’t put value added by our work, what does that say for us, and for hope of restoring the Everglades? Thanks for considering the EvCo resolution.

John Arthur Marshall