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Press Release

    Issue Analysis 90 - The Final Integrated Feasibility Report on the Everglades Re-Study: Awash in Uncertainty


    The Everglades Re-Study is a project designed by the U.S. Army Corps of Engineers, and is intended to restore the Everglades while at the same time providing water for a growing South Florida population. On April 7, the Corps released a new report on the Everglades Re-Study, the "Final Integrated Feasibility Report and Programmatic Environmental Impact Statement." This report was intended to address concerns about the Re-Study raised by consumer groups, individual citizens, environmentalists, and even public utilities. However, the Final Feasibility report fails to resolve a number of grave uncertainties, and should demonstrate to policymakers that pressing forward with the Re-Study could squander the last chance to save the Everglades while at the same time endangering the health of South Florida’s families.

    In 1948, Congress authorized the Central and Southern Florida Project (C&SF). The C&SF, built by the U.S. Army Corps of Engineers, was designed to offer flood protection, drainage, and a safe and reliable source of fresh water for the people of South Florida. The C&SF now serves some 6 million people in a 16-county region.

    Although the C&SF has served as the primary water delivery system for South Florida, it also has caused extensive damage to the unique ecosystem of the region. In particular, it interrupted the natural flow of water into the Everglades, and upset the careful balance between fresh water and salt water in the St. Lucie and Caloosahatchie estuaries.

    In an effort to restore the Everglades while expanding the water supply to accommodate a growing population, Congress authorized an updating of the C&SF in 1992. This has become known as the Re-Study. The Re-Study proposes to make a number of changes to the C&SF including the removal of canals, the creation of several hundred aquifer storage and recovery wells, and a new series of complex pumps and water control structures to create a more natural flow of water into the Everglades.

    The Corps has issued a number of reports on the Re-Study that have attempted to demonstrate how the project is to become reality. However, these reports have failed to clearly define the Re-Study’s criteria for success and have left numerous questions unanswered. The Final Implementation Plan is no different from earlier reports in this regard.

    Confidence Undermined

    In the Final Implementation Plan, the Corps seemingly has a high level of confidence that the Re-Study will be successful. They claim that: "Implementation of the recommended Comprehensive Plan will result in the recovery of healthy, sustainable ecosystems throughout South Florida. … There are many reasons for having confidence that it will be successful."1 However, the Corps also admits to having grave doubts: "No plan can fully anticipate the uncertainties that are inherent in predicting how a complex ecosystem will respond during restoration efforts. … [T]he ways in which this ecosystem will respond to the recovery of more natural water patterns almost certainly will include some surprises."2 Later, the Corps adds more doubts about its ability to deliver as promised: "The Comprehensive Plan makes no claim that all the questions have been answered, that all the uncertainties have been addressed, or that all the issues have been resolved. No plan could do all these things."3 As in previous reports, the Corps’ claims of confidence are undermined by repeated justifications for potential failure.

    A Blank Check

    The Corps estimates that the Re-Study will cost $7.8 billion, split 50-50 between Congress and the state of Florida. However, this figure must be viewed only as a starting point. Ongoing restoration projects, which the Corps intends to fold into the Re-Study, will cost an additional $2 billion.4 There has also been talk of dredging Lake Okeechobee, which will cost an additional $1 billion.5 Thus, the real cost of the Re-Study might more accurately be set at nearly $11 billion. However, even this is unlikely to be the final figure. In February 1999, the Corps stated that "even with all the money in the world" they could not finish the bulk of Everglades restoration before 2017.6 Yet in the Final Feasibility Report, the Corps claims that most of the restoration will be completed by 2010. Either the Corps is overestimating their abilities, or they are underestimating just how much "all the money in the world" actually is. The Corps also states that they "view ecosystem restoration in south Florida much more as an open-ended process than as a specific set of targets..."7 Perhaps the Corps should have included the phrase "open-ended costs" in this sentence as well.

    Lack of Focus

    Before authorizing a multi-billion dollar project like the Re-Study, policy-makers should be able to determine what constitutes success or failure. However, as in previous reports, the Corps does not provide a definition: "It is too early in the South Florida ecosystem restoration project to state with certainty exactly what the ‘endpoint’ for the restored Everglades should become."8 In addition to having no definition of success, the Corps tells us that the Re-Study also has no focus: "The Restudy, to date, has no set direction; the details will come in time."9 As shocking as this sounds, the Corps goes on to tell us that they do not know what success means, they do not know how to achieve it, and that the science is just too uncertain: "There is very real and, to a great extent, unresolvable uncertainty about what the new ecosystem will look like. Because no one knows for sure what the ecosystem will look like, no one knows for sure what the hydropattern required to produce it will look like. This is, in our view, the greatest uncertainty in the entire study. Moreover, we do not know with certainty what the linkages between hydropatterns and the ecosystem are."10 Although this fundamental lack of focus may be the Re-Study’s greatest flaw, there are additional serious uncertainties.

    Untested Technology

    The Re-Study relies heavily on Aquifer Storage and Recovery (ASR) wells. Essentially, this technology involves capturing stormwater runoff that is currently sent out to sea and pumping it 1,000 feet underground into the brackish Floridian aquifer. When the water is needed later, it will be brought back to the surface for use. The Re-Study relies on ASR wells for approximately 1.6 billion gallons of water per day.11 Although these wells are a critical component of the Re-Study, the Corps admits that ASRs have never been operated on the massive scale envisioned, have never been used in the unique geology of South Florida, and have no long-term track record on which to rely: "Nonetheless, there are substantial unique uncertainties associated with the use of ASRs. Chief among these is the fact that ASRs have never been used on such a large scale in such a variety of geologic conditions before. In addition, because the technology is only 30 years old it has no long-term track record. … Will ASRs be able to provide the quality and quantity of water required at the times they are needed and wanted? Are there likely to be any unintended consequences of this technology? What will it cost?"12 These are all questions that need answers before policy-makers are asked to make a decision on the Re-Study.

    A further potential danger of using ASRs is that Florida is the only state that allows underground injections of municipally treated sewage. Every day, 400 million gallons of this waste are injected under the Floridian aquifer using Class 1 injection wells.13 Studies show that this waste is migrating into the Floridian Aquifer in the same counties where ASRs are planned. However, there is no program in place to determine if this waste could threaten water supplies should the Re-Study be implemented.

    Uncertain Modeling

    Computer models played a central role in formulating the recommended plan for the Re-Study. While the models may be the best that are currently available, the Corps admits: "Nonetheless, there are unique and significant uncertainties that remain with these models and their application."14 According to the Corps, much of the data that went into the models "had to be approximated or even guessed."15 The Corps acknowledges that much more data needs to be gathered before these models can be relied upon: "Improved topographic data has been identified as a high priority need for future study efforts, and it will be collected."16 Moreover, the Corps states that uncertainties in one model may compound uncertainties in another model. Problems with this inherent flaw have not even been investigated: "Another unique model-related uncertainty concerns the manner in which the uncertainty in one model combines with the uncertainty in another model to produce greater cumulative uncertainties or to cancel one another out. This is a reasonably possible impact that has not yet been formally investigated."17 The unreliability of the Corps models casts even more doubt upon the Re-Study.

    First Things First

    The Corps will submit its final plan for the Re-Study to Congress on July 1, 1999. Congress will then decide whether or not to authorize construction of an initial batch of Re-Study component features and pilot projects, which are estimated to cost nearly $1.2 billion.18 It is a decision that Congress should not take lightly. Although additional rounds of component features will receive separate authorization, the Corps has made it clear that all features of the Re-Study must be approved without exception or the entire project will fail: "… the Comprehensive Plan must be fully implemented to achieve the planning objectives and adequately meet performance measure targets throughout South Florida."19 In other words, regardless of how the initial batch of components and pilot projects performs — in fact, no matter how any Re-Study component performs — Congress will have no choice but to continue throwing good money after bad as the Corps pursues an elusive and undefined goal of restoration. Careful deliberation before authorizing the Re-Study becomes even more important in light of the Corps’ statement that certain components will involve an "irreversible and irretrievable commitment of resources."20

    In order to ensure that resources are not wasted on a plan that may not work, Congress should not allow the Corps to move forward with any Re-Study components until, at the very least, initial ASR and other pilot projects have proved successful. After all, the results of these pilot projects will indicate whether the Re-Study will need to be drastically changed. For example, the Corps states that: "If ASR use is to be reduced or eliminated, other features will be substituted for them."21 The Corps is not particularly clear on just what sort of features will be substituted, but they are certain that these new features will be expensive and have significant environmental costs. These features carry several problems including higher cost, and, in particular, environmental problems such as the tripling of fresh water discharges to the St. Lucie Estuary and doubling of discharges to the Caloosahatchee Estuary.22

    What is to be Done?

    Despite the grave uncertainties surrounding the Re-Study, and the fact that there are no guarantees of success, the Corps insists that the project move forward immediately. The Corps may be correct when they say that inaction is not an option; however, the choice is not between doing nothing or plunging full speed ahead with implementation of the Re-Study. There is a third option. Existing Everglades restoration projects, which the Corps admits are expected to have "some level of ecological improvement," can continue to move ahead while the Corps resolves the serious uncertainties surrounding the Re-Study.23 Until there are more answers, it makes little sense to commit scarce resources to a multi-billion dollar plan that may not work. If this is, in fact, the last opportunity to save the Everglades, we must make certain that we choose the right option. Twenty to thirty years down the road, the Corps will not be able to redo its work. The Everglades will be gone.

    1U.S. Army Corps of Engineers, "Final Integrated Feasibility Report and Programmatic Environmental Impact Statement," April 7, 1999, p. x.

    2Ibid., p. xiii.

    3Ibid., p. xvi.

    4Miami Herald, 4/4/99.

    5Cox News Service, 1/17/99.

    6The Palm Beach Post, 2/2/99.

    7U.S. Army Corps of Engineers, Ibid, section 5 p. 37.

    8Ibid., Section 5, pg. 36.

    9Ibid., Section O, p. 1.

    10Ibid., Section O, p. 13.

    11Ibid., page viii.

    12Ibid., Section O, p. 18.

    13Donald Sutherland, "Is Florida Drinking from its Own Toilet?" Environmental News Service, 10/98.

    14U.S. Army Corps of Engineers, "Final Integrated Feasibility Report and Programmatic Environmental Impact Statement," April 7, 1999, Section O, p. 6.

    15Ibid., Section O, p. 9.

    16Ibid., Section O, p. 6.

    17Ibid., Section O, p. 9.

    18Ibid., Section 10, p. 41.

    19U.S. Army Corps of Engineers, "Draft Implementation Plan," 1/25/99, p. 27.

    20U.S. Army Corps of Engineers, "Final Integrated Feasibility Report and Programmatic Environmental Impact Statement," April 7, 1999, Section 8, p. 20.

    21Ibid., Section O, p. 20.

    22Ibid., Section 7, p. 43.

    23Ibid., 5, p. 4.