For the hard core, an opinion by Larry Fink: Based on the background information embedded below, the Central Everglades Project Plan (CEPP) is too little, too late. Instead, I support the modified Alternative Plan 6 spillway/flowway. The primary purpose of this alternative is emergency relief of the imminent threat posed by the failing Herbert Hoover Dike (HHD) to the public health, safety, and welfare. In this configuration, water released from Lake Okeechobee will be stacked on private farmland between the HHD and Stormwater Treatment Area-3/4 (STA-3/4) that has been temporarily commandeered by the U.S. Army Corps of Engineers Jacksonville District Office (Corps) for that purpose to do the most public good with the least private harm. That land will then be purchased for permanent incorporation in the emergency water management footprint by the Corps using the eminent domain authority of the Federal Government. With minor modifications to the infrastructure required for the spillway/flowway in its emergency water management configuration and operational mode, it can provide a more natural water quantity, quality, timing, and routing of Everglades and Indian River Lagoon water supply than the plan adopted for CEPP without interfering with its primary purposes as an emergency relief valve for the HHD. Here are the proposed next steps for advancing the cause of the spillway/flowway alternative as a quantum leap over the plan adopted for CEPP: (1) Convene a series of no more than three web workshops to translate the conceptual design into a general design, draft operating plan, and construction sequencing for the modified Alternative Plan 6 spillway/flowway and supporting documentation. (2) Concurrently model the TP removal efficiency and compliance with the TPP WQS at the point of entry into the Remnant Impounded Everglades of the modified Alternative Plan 6 spillway/flowway versus CEPP. (3) Obtain sign-off of the general engineering design and emergency operating plan for the modified Alternative Plan 6 by a licensed civil engineer PE in Florida. (4) Obtain a cost estimate for the construction of the final general design and its annual operating, inspection, maintenance, repair, and replacement costs, as well as the insurances required to cover losses from its various failure modes, because SFWMD is under-self-insured in this regard. (5) Identify the laws, policies, and conventions that give precedence to agricultural water supply over Everglades restoration water supply. (6) Convene a web workshop for the drafting of the program and scheduling tentative dates for web-streamed public hearing with a web-streamed press conference per (7). (7) Conduct the web-streamed hearing and press conference on the imminent threat to the public health, safety, and welfare posed by the failing HHD, the modified Alternative Plan 6 general design and cost to substantially reduce that threat in a meaningful timeframe, and the laws, policies, and conventions that are barriers to its adoption. (8) Obtain spoken and written public and NGO support for the modified Alternative Plan 6 spillway/flowway supported by the majority of influential players, because we can never achieve consensus on this quantum leap over CEPP. (9) Use the political leverage obtained in (7) and (8) to press for Congressional hearings on the modified Alternative Plan 6 spillway/flowway as an emergency measure to relieve the stress on the failing HHD and reduce the imminent threat it poses to the public health, safety, and welfare in the greater public interest, albeit with the collateral benefit of Everglades restoration and protection of a more natural water quantity, quality, routing, and timing superior to that of CEPP. I would be available to speak at the public hearing and answer questions at the press conference on a comparison of the likelihood of attaining and maintaining the TP WQS prior to discharge into WCA-3A for CEPP versus the modified Alternative Plan 6 spillway/flowway conceptualized here. I could also speak on the comparative downstream water quality impacts from excess sulfate originating with EAA runoff versus Lake Okeechobee releases, including its influence on the downstream mercury cycle and the risks to endangered species posed by the excess methylmercury produced as a result thereof. Larry E. Fink, M.S. Owner and Principal Waterwise Consulting, LLC Background The purpose of Comprehensive Everglades Restoration Plan (CERP) authorized by the Water Resources Development Act (WRDA) of 1996 and project design authorized by WRDA 2000 is to restore and protect a more natural quantity, quality, timing, and routing of water for the Everglades. Congress partnered the U.S. Army Corps of Engineers Jacksonville District Office (Corps) with its local sponsor, the South Florida Water Management District (SFWMD), to design the CERP projects for subsequent authorization for construction. The Central Everglades Project Plan (CEPP), which was forced upon the Corps as punishment for its sloth in designing and implementing CERP, accelerated the design but not the implementation of a subset of CERP projects. CEPP met its 18-month redesign deadline, and the approval by the Corps hierarchy is imminent. However, SFWMD was able to redesign the Everglades Construction Project (ECP) and eliminate what was then the centerpiece of CERP, the Everglades Agricultural Area (EAA) Reservoir Project in response to then Governor Charlie Crist’s proposed $1.7 billion buy-out of U.S. Sugar as the River of Grass Initiative in 90 days. This is a record that is unlikely to be broken. The River of Grass redesign included a flowway, with the agricultural parcels between Lake Okeechobee and Stormwater Treatment Area-3/4 (STA-3/4) not owned by U.S. Sugar to be swapped with more desirable parcels purchased from U.S. Sugar that were outside the flowway. Subsequently, the collapse of the bond market, unwilling swappers, the departure of Governor Christ, and the election of Governor Rick Scott combined to shrink the River of Grass Initiative to three shallow reservoirs and an additional roughly 6,300 plus acres for a new shallow reservoir-assisted STA (RASTA). When it is fully operational at some ill-defined future date, CEPP will take an additional average 200,000 acre-ft per year of polluted water or 0.43 ft from the 730 sq mi of Lake Okeechobee surface area. Whether this will provide anything but an imperceptible benefit for the Indian River Lagoon (IRL) must be the subject of water quantity and quality modeling that was absent from the CEPP design process, because neither CERP nor CEPP included the IRL in its design targets or constraints. That polluted water must then be combined with roughly 1,500,000 acre-ft per year of even more polluted storrmwater runoff from the EAA for routing through the RASTAs prior to discharge to the Everglades. According to the Corps, this is because the use of Lake Okeechobee as a water supply for agriculture takes precedence over its use for ecosystem restoration by law, policy, or convention, even if WRDA 1996 and 2000 implied otherwise. The RASTAs, the design and operation of which are incorporated as is in CEPP, are under-designed for purposes of removing the excess total phosphorus (TP) down to its Water Quality Standard (WQS) of 10 ppb in EAA stormwater runoff. Further, the RASTAs are only capable of removing some of the excess nitrate in EAA runoff, which can be the limiting nutrient in our coastal waters, including Florida Bay. In addition, they have no measureable effect on excess dissolved organic carbon (DOC), which interferes with light transmission to submersed aquatic vegetation, or excess sulfate, which influences the downstream carbon, nitrogen, phosphorus, and mercury cycles and causes hydrogen sulfide to be present in toxic amounts under eutrophic conditions.
Posted on: Fri, 23 May 2014 19:48:45 +0000
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