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