Public Comment on The CEPP DRAFT Project Implementation Report (PIR)

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.

References:

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

October 1, 2012

Statement on the upcoming “alligator hunt” at the Arthur R. Marshall Loxahatchee National Wildlife Refuge from the ARTHUR R. MARSHALL FOUNDATION FOR THE EVERGLADES.

After carefully reviewing the facts of the situation and listening to the concerns expressed by protestors, the ARTHUR R. MARSHALL FOUNDATION FOR THE EVERGLADES wishes to clarify our position:

1) While we appreciate the need for appropriate population maintenance, the Marshall Foundation can not support a “sport hunt” of alligators at the Refuge.

2) While it is troubling to be called vicious names by those who would normally be our conservation partners, we very much appreciate the environmental concerns that they have expressed and we join them in opposing the plan to offer "sport hunting" of alligators at the Refuge.

3) The right to protest is one of the greatest freedoms that we enjoy as Americans and the Marshall Foundation applauds those willing to take a public stand on controversial matters.

John A. Marshall

Chairman & Spokesman for the Florida Environmental Institute

Nancy Marshall

President

Josette Kaufman

Executive Director

Memo For Governing Board, SFWMD

Dear Governing Board Members;

Backpumping is a bet that a "tipping point" won't be reached turning Lake Okeechobee Lake Apopka green.

There is even a book about tipping points subtitled "little things make a big difference".

As in the Lake Apopka case, Tipping points notes that once infected - stay infected for a long time.

The Late Art Marshall warned of tipping points by the use of stress curves. Bodies of water would become increasingly polluted (infected), then a single event would push the ecosystem over the edge, corresponding to the "cliff" on the stress curve.

The gamble is that just adding a little more pollution won't bring about a tipping point, whereby Lake O turns pea green, and kills a monumental amount of game fish, alligators, birds and other critters, on which the Lake O economy depends, as Mary Ann Martin so adequately explained at the last WRAC meeting.

Not to mention this means less than a viable water supply for the local human-kind. There is a good reason that much of the local residential water supply is pumped from the aquifer, rather than taken directly from Lake O.

When the next hurricane/tropical storm stirs up Lake O, no problem right.

Place your bets. In this case, the odds are against the house.

The cost of such an occurrence will far exceed the minimal value of backpumping.

The Odum brothers (E.P, H.T.) put it another way in a 1979 paper:  If the perturbation [addition] involves toxic substances, or is destructive in some way, then performance is likely to be reduced - perhaps to a point where the community is replaced by a new more tolerant species, or ultimately, to a point where life in the area is severely reduced or exterminated entirely.  Art Marshall and H.T. Odum worked closely on these matters.

So far, it appears that there is only one user that benefits from backpumping/backflowing. When Lake O falls below 10.5 feet, all forward pumping takes a one-way path south; at least it has in the past.

In this scenario, the water needs of the Caloosahatchee Estuary go begging to significant economic impact to the local economy, and the City of West Palm Beach is told: At 10.5 Feet, you are on your own.

I live in the City of West Palm Beach. There could be a lot more sharing of the Lake O water supply, both for shared prosperity, and in shared adversity.

Respectfully Submitted,

John Arthur Marshall

Streamlining CEPP

Below is my presentation to the Everglades Legislative Caucus.

Describes streamlining the Central Everglades Project Planning (CEPP) process using CERP protocols resulting in short-cuts, simplification, and synthesis all can understand.

StreamliningCEPP ELC RC Feb 23

Hal Wanless Presentation at Palm Beach State College

Dr Hal Wanless,delivered another great presentation on Climate Change and the problems of Sea Level Rise. This time the host was the LCG Ecology Club at Palm Beach State College's South Campus. Dr. Wanless is a Professor and chair at the University of Miami.

120210 PBSC Ecology Club, Boca Raton - Wanless

Sunset Safari

PUBLIC COMMENT--CEPP Project Delivery Team/Water Resources Advisory Comission

Below you will find my public comments from February 1, 2012...

Public Comment to CEPP Project Delivery Team (PDT)/Water Resources Advisory Commission (WRAC)

Subj:  Central Everglades Planning Project (CEPP) Analysis of Alternatives? 
          Restoring the natural system V. deep water reservoirs.

Dear CEPP PDT / WRAC Members, et al;

We appreciate being a prime mover for enhanced pubic involvement and the opportunity to make public comment in taking the CEPP process forward post haste, and the opportunity to bring these matters to the Water Resource Advisory Commission (WRAC).

The report of a January record drought in today's PB Post appears to validate the hypothesis, that reduced surface waters in South Florida are a major cause of the effect of decreased rainfall and resulting drought, as discussed below in a previous e-mail to the CEPP PDT, along with analysis of alternatives to get to the long-term drought management fix.  See:  http://www.palmbeachpost.com/weather-news/county-has-driest-january-on-record-2141665.html

During CEPP (Central Everglades Planning Project) PDT (Project Development Team) Noon Public Comment period Jan 31, 2012, the Arthur R. Marshall Foundation challenged the PDT to consider the fundamental alternatives of restoring Dynamic Storage and Sheet Flow (Option A) per CERP Section 2.3.1, verses stacking water in a deep water reservoir (Option B) currently at the forefront of consideration. This included calling for trade-off's to consider various permutations of A, restoring sheet flow, i.e., A1, A2, A3, V. B1, B2, B3 deep water reservoirs, as presented in the overview slides.

Ensuing discussion of water resources, and calls for a water budget, appeared to go beyond science, generating a need for a clear understanding of the relation between surface water (or the lack of same), EvapoTransporation (ET), rainfall, groundwater, seepage, aquifer recharge, drought, and extreme wet events.
A full understanding rainfall cycle of cause and effect here appears critical to consideration of alternatives by the CEPP PDT, especially the challenge to consider A options v. B options noted above.
Consider the following observations, many taken directly from the FL Water Atlas, as hypotheses, some intuitively self-proving:
     •    There is more than sufficient water going to tide, to keep a wet flow-way wet most years
     •    ASR may be a consideration in the few years that are not wet enough to wet a wet flowway.
     •    Often heard, 50% of the Everglades is left; Seldom heard: Nearly 100% of the Rainfall remains.
     •    ET is never a loss; ET + moist sea breezes drives rainfall (RF) such that RF is always greater than ET to the tune of RF = 1.25 ET, on average.
                o    If this were not true, S. FL would be a desert;
                o    Are we getting there by reducing wetlands, thus surface water, draining same to tide, stacking it in reservoirs > 4 ft., and pushing surface water down an ASR well?.. and;
                o    Failing to fully restoring surface water in the form of sheet flow to the extent feasible?
     •    The reduction of surface water, as in the loss of wetlands and reduction of dynamic storage and sheet flow, is an apparent cause of increasing drought, because decreased surface water means decreased ET means decreased RF, per the above equation traceable to the FL Water Atlas.
                o    A large % of the water now going to tide was historically ROG surface water subject to ET which drove RF making the Everglades a much wetter system than previously postulated.
                o    Stacking water in a deep water reservoir has the effect of reducing ET, therefore reducing RF, whereas historic Dynamic Storage and Sheet Flow, resulted in greater ET, ET being a part of dynamic storage driven by solar radiation
                o    Holding Lake O lower adds to the ET deficit because there is less Lake O surface water subject to ET which adds to the RF deficit.
                o    All this appears to be changing the climate in the direction of drought and moving the freeze line south
                o    Data appears to indicate that the water resources of the Everglades ecosystem are only fully replenished during extreme wet events (hurricanes and tropical storms), then it comes in the form of floods.
     •    Regarding the statement that a STA is more efficient than a re-vegetated flow-way in reducing nutrients, as in Dynamic Storage and Sheet Flow; what is the proof?
     •    There is notional proof that Dynamic Storage and Sheet Flow produces much greater benefit/cost ratios than STA's, owing to reduced construction costs, reduced O&M costs, and letting natural system do the work to provide the benefits.
                o    Dynamic Storage is three dimensional (3D) storage that includes ET, surface water including the ROG, forested wetlands, seepage, ground water, aquifer storage and recharge.
                o    In this scenario, Dynamic Storage and Sheet Flow provided no-cost nutrient removal
     •    Unfortunately there is only a circumstantially proven hypothesis than a re-vegetated flow-way consisting of a pond apple forest and saw-grass plains would reduce nutrients significantly, and more cost-effectively than a STA. Specifically, a re-vegetated flow-way between Lake O and WCA-3 has not been subject to rigorous analysis, rather it has been waved to the CEPP PDT Parking Lot.
                o    In this regard it was interesting to hear a CEPP PDT comment that the more distant from the Lake the less effective the land is for growing or words to that effect, i.e., the father away from the pond apple forest, the poorer the soils.
     •    Putting water on the landscape attracts wildlife (CEPP PDT member statement 1/31/2012)

Conclusion/Major Hypothesis:
     •    The optimum (maximum benefit at least cost) approach to CERP/CEPP and restoring what was a much wetter Everglades, is to restore a massive amount of surface water in the form of Dynamic Storage and Sheet Flow.
     •    This is just as Art Marshall stated in 1981: To repair (restore) the Everglades, restore sheet flow to the max extent possible from the Kissimmee Lakes to FL Bay.

Circumstantial proof: Kissimmee River Restoration results.
Precaution by the NRC Peer Review Committee: Avoid engineered solutions where possible.

Footnote: As previously noted in public comment, all this appears consistent with a CERP approach to streamlining CEPP, using CERP Section 2.3.1 Dynamic Storage & Sheet Flow (Primary characteristic therefore CERP/CEPP Baseline); 5.1 Table 5.1 Goals and Objectives; Section 7.5.2 Cost Effectiveness and Incremental Cost Analysis ... that considers cost and benefits; and the Adaptive Management Protocols in the more recent 2011 Adaptive Management Integration Guide, especially required activities 4 & 5: Consideration of a regional conceptual ecological model, CERP Table 5-1 Goals & Objectives, and benefits compared to costs.

Thanks for your consideration. Respectfully submitted, on behalf of the ArtMarshall.org S&T Committee, pro bono,
 John Arthur Marshall, Chairman of the Board,
Chair, Science & Technology Committee,
Arthur R. Marshall Foundation & Florida Environmental Institute, Inc.