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The following
comments are provided to the Task Force as feedback on the proposal
presented by the Army at the September Task Force meeting to take
advantage of the “Mod Waters” Project by exploring more aggressive
options in the Phase 1 of the CERP Decomp component. The Army’s
proposal included two central concepts for consideration in the
initial phase of the Decomp project—an aggressive option to open up
the Southern Everglades to sheet flow and a revised “pipeline”
approach for dealing with “Savings Clause” requirements in South
Florida. The committee understands that if
selected for further
consideration, these concepts would be fleshed out as part of the
ongoing Decomp PIR development process and compared with other
options developed by the Project Delivery Team (PDT). The ultimate
decision (and ROD) would occur at the end of that full NEPA process
and construction would begin after completion of the “Mod Waters”
project.
In general, the committee
believes that the proposal—as a total package, or as separable
elements--has the potential to address important objectives that are
fundamental to restoration of the central Everglades, including:
• Enhancement of sheet
flow and ecological connectivity among Water Conservation Areas and
Everglades National Park.
• Restoration of a more
natural capacity to handle extreme high-water events
• Improved capability and
flexibility for conveyance of water from north to south
• Improved management
flexibility to deal with high lake stages and reduce damaging
discharges to the northern estuaries
The committee discussed and
received feedback from agency staff and private sector stakeholders
on a wide variety of topics and issues. Some of the feedback was
broadly applicable to any Decomp option and would be considered by
the PDT in its analysis of all the Decomp options. Several key issue
areas are unique to this proposal and would require careful analysis
during the PIR development process. These primary issue areas are:
A Issues
with the pipeline
1. Water Quality
issues – water entering the pipeline will likely be of relatively
poorer quality than water that currently exists in wellfields and
canals in the area where the pipe would discharge.
• Treatment to satisfy
“Savings Clause” requirements for wellfield recharge and water
supply
• Treatment at the end of
the pipeline, including land requirements, to protect downstream
natural areas--both wetlands and estuaries
• Potential impacts to
water quality caused by the pipe, such as low oxygen
concentration
2. Water budget issues – it is
unclear how much water is available and how it would be distributed
at the northern and southern end of the pipeline.
• Water quantity
assumptions at the northern end of the pipe and implications for
pipeline sizing
• Wet season and dry
season scenarios for distribution of water
• Ultimate fate of water
delivered by the pipeline
• Satisfy savings clause
requirements with respect to flood protection, particularly during
wet season, e.g. C-6 basin
3. Pipeline Alignment issues
• Impact of alignment on
ground water flows, particularly in South
• Other alignments should
be considered, e.g. New River canal
4. Pump station issues
• Unique air and water
quality issues in middle of the Everglades
• O&M costs—seek energy
efficient approaches
B Issues
with the proposal to open-up the southern part of the system
1. Sequencing issues
• Ensure enough water is
available to avoid “over-draining” the system
• Improved seepage
management along the L30 & L31N must be in place
• Integration with DAMP
to maximize learning
• Integration with other
CERP projects and Mod Waters
2. Potential Environmental
impacts
• “Tree island” concerns
• Endangered Species
concerns and potential conflict with critical habitat
rule
C
Level of support and affordability
1. Level of support?
2. Can we afford it?--$1-3
billion for pipeline, $xx million for southern E
3. What other projects would
have to slip?
4. Local sponsor concern and
input.
The following
feedback and issues were provided to the committee. Some apply to
any Decomp, Phase 1 proposal. They are grouped into seven broad
areas and all will require
careful consideration and analysis.
Impacts to
Natural Resources
• water diversion from
Biscayne Bay or other natural areas should be avoided or compensated
• seek ways to promote
the recovery of endangered species, especially the Cape
Sable Seaside Sparrow, the Snail Kite and the Wood Stork
• seek significant net
improvement to tree islands
• ensure appropriate
quality of fill for the Miami Canal
• goal of “Decomp” should
achieve natural flow distribution across Tamiami Trail
Water
Management Issues
• address “water budget”
issues, especially in the northern part of the system.
• include detailed
operating protocols, including operations and conveyance capacity of
the urban canals, especially during very wet and very dry conditions
• analysis should
quantify the reduction of water levels in Lake Okeechobee and the
improved flows to the estuaries
• review possible
flooding impacts and increased need for seepage management,
especially in the L-30 and C-6 basins
• review impacts from the
C 139 basin
Recreation
Issues
•
consider opportunities for substantially enhanced public access and
recreation, including current agreements for improved public access
•
include suggestions from SAFER to save fisheries
•
avoid canal backfilling that is not necessary for restoration
• seek
improved hunting opportunities in WCA’s
Water Quality
•
carefully analyze source transfer issues, (water quantity and
quality) for the wellfields (e.g. treatment may be needed near
wellfields, and potential other locations as well.)
•
water quality issues are more substantial than nutrient
concentrations and drinking water standards, e.g. dissolved oxygen,
pathogens, microcontaminants
(EPOCs).
•
clarify STA performance expectations for water to be delivered to
WCA 3
•
assess water quality impacts and requirements in other natural
areas, e.g. Biscayne Bay and the Southern estuaries.
Design Issues
•
review potential impacts during construction
• goal
is to maintain a watershed focus and include consideration of
factors such as the effective dynamic storage of the overall system
and soil subsidence.
Interface with
other Projects
•
consider how this project may reduce ASR dependency
•
closely integrate with seepage management projects along the L-30
and L-31
•
examine implications and opportunities for the Lake Belt component
•
ensure compatibility with Broward County WPA project
•
consider plans to expand EAA STA’s in analysis
•
consider opportunities to improve storage in Lake Okeechobee and
Biscayne Bay basins
•
consider interface with non-CERP projects such as CSOP
Science and
Adaptive Management
• the
links between DECOMP, Phase 1 and DAMP need to be carefully
described, particularly in relation to the effectiveness and timing
of the two efforts
•
recognize the limits of current hydrologic and ecologic models and
consider other tools to evaluate results
•
incorporate best available tools to assess water quality impacts
•
Identify potential opportunities for additional learning.
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