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.