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May 11, 2000
The Honorable Bob Smith
Chairman, Senate Environment and Public Works Committee
410 Dirksen Senate Office Building
Washington, D.C. 20510
Citizens for a Sound Economy is grateful for the opportunity to provide the Senate Environment and Public Works Committee with comments on the Comprehensive Everglades Restoration Plan included in S. 2437, the Water Resources Development Act of 2000. While CSE often has been outspoken in our criticism of the Comprehensive Plan, formerly called the Re-Study, we do have some areas of agreement with this legislation:
(1) We certainly agree with the statement in subsection (1) of the Findings that the Everglades is a national treasure, and that the South Florida ecosystem has been endangered by adverse changes in quantity, quality, distribution, and timing of water flows.
(2) We also agree with the proposition in subsection (2) of the Findings that the Central and Southern Florida (C&SF) project plays an important role in the economy of South Florida, and that modifications to this project will be necessary as the population of South Florida grows.
We also have a number of disagreements with the legislation, with the Final Implementation Plan upon which it is based, and with the overall manner in which the Comprehensive Plan is being advanced:
(1) We disagree strongly with subsection (4) of the Findings, which refers to the Plan as being "scientifically and economically sound." There are critical information gaps remaining with regard to the science, especially with regard to Aquifer Storage and Recovery (ASR) wells and wastewater reuse technology. In addition, cost projections have risen dramatically over the past several years, from an initial estimate of perhaps $1 billion to a current estimate of at least $7.8 billion if not $11 billion.
(2) We also disagree with the statement in subsection (6) of the Findings that the Plan will "significantly" improve the quantity, quality, distribution, and timing of water. The Corps of Engineers itself admits that they cannot predict how the Plan will affect ecosystems, much like no one realized how the original C&SF project would affect the environment. To quote from Section O, page 13 of the Final Implementation Plan:
"There is a 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. Moreover, we do not know with certainty what the linkages between hydropatterns and the ecosystem are."
(3) We do not believe Congress should approve the Comprehensive Plan as it is laid out in this bill. Should the Committee decide to move ahead with the Plan, we believe it is imperative that the initial authorization not include any components beyond the pilot projects. To be exact, the 11 projects in sub section (C) of the Specific Authorizations should not be authorized until we have empirical results from the pilot projects. This is particularly important since, as both the Corps of Engineers and members of this Committee have said, once you start implementing the Plan you cannot stop until it is finished, 20 to 30 years from now. In other words, once the initial batch of implementation projects have begun, Congress has irrevocably committed itself to the entire Comprehensive Plan. By the time pilot projects are complete, not until 2011 in one case, it will be far too late to turn back. Congress would have no choice but to continue throwing good money after bad. Essentially, Congress will have given the Corps of Engineers a blank check.
Two pilot projects in particular stand out: ASR and wastewater reuse. These two technologies are so central to the Comprehensive Plan that if pilot projects prove unsuccessful, the entire Plan as written cannot work. Moving ahead without this data puts the entire Everglades restoration program, and the people of South Florida, at risk.
(4) We disagree with the Programmatic Authority granted in subsection (d) of the Specific Authorization. Once again, these components should not be allowed to move forward without solid empirical data from pilot projects proving their viability.
(5) We also disagree with the proposition that the primary and overarching purpose of the Plan is restoration of natural systems. The overarching purpose of the plan, at least publicly, has seemed to vary depending on the audience. We hope that in this legislation, the water needs of the people actually living in South Florida will be considered just as important as any other aspect.
(6) Finally, we must criticize the legislation, and the entire Comprehensive Plan, for a sin of omission. There is no mention of providing the residents of the 8.5 square mile area with the flood protection that they were guaranteed a decade ago. The residents of this area are primarily Hispanic, and came to this country looking to escape oppression and find the American dream. Instead, they have found a system that, to some, seems little different from what they left behind. They have turned to Congress for help, often literally in tears, only to find dead end after dead end. The Comprehensive Plan, once again, leaves these Americans out in the cold, or in this case, under water.
We know that a great many people have put a great deal of time, effort, and resources into developing the Comprehensive Plan. However, history will not pass judgment on how large of a plan was implemented, but on how successful that plan was. If we believe that this plan is the last chance to save the Everglades, we must make sure that as many of the remaining uncertainties as possible are resolved. Should we discover ten years down the road that critical components of the Comprehensive Everglades Restoration Plan are not working as predicted, it will be too late. The Plan will have failed and the Everglades will be gone.