SAFER's Comments on the Revisions to the

1992 General Design Memorandum

We want to thank the U.S. Army Corps of Engineers (USACE) and the South Florida Water Management District (SFWMD) for the opportunity to review the proposed revisions to the 1992 General Design Memorandum (GDM) on Modified Water Deliveries (MWD) to Everglades National Park (ENP).

In the letter dated March 16, 2004, initiating the scoping process, the Corps proposes to replace the three gated structures on the L-67A canal, of the original 1992 plan, with fixed crest weirs, “in order to be more consistent with the present philosophy on Everglades restoration that emphasizes passive methods of water management.” At first glance, this decision would seem to be beneficial to the interests of the recreational anglers utilizing the Water Conservation Area 3A canals. Doing away with the expensive structures would cut back on the disruption caused by extended construction time, and would not require the building of small boat by-pass channels. Another restriction to navigation, the discharge conveyance channels and their tieback levees, that would carry the water from WCA 3A to 3B, would not be required. It was these interceptor levees, extending across the pocket between L-67A and L-67C that would block boat traffic eight miles up the canal.

It took hard lobbying by the Miami-based Fisherman Against the Destruction of the Everglades (FADE), stayed the Corps of Engineers’ hand at that particular time, but the organizational culture that supported the closure of the L-67C canal to anglers, has remained in place. The new proposal continues to stress, as the core of the plan, the disruption of boat traffic at the same point as the 1992 GDM:

“It is proposed to replace the S-345 structures…and remove the approximate 8 miles of

the L-67C levee that is directly downgradient from the three weirs…[The] levee would be

scraped down to marsh elevation and the removed material placed into the adjacent L-67

canal. The weir locations and the L-67C degradation would coincide with the locations

specified in the 1992 plan for corresponding features.”

SAFER believes that the goals of establishing the necessary sheetflow of water that scientists maintain is needed for Everglades Restoration, can be accomplished by degrading the levees, and plugging the canals, but not backfilling them. The canals become obstacles to sheetflow only if they are used a means of conveying water. As of now, there is no scientific proof available that filling in the canals is necessary. All the hydrological modeling that has been conducted by the SFWMD start with the premise of backfilling the canals to achieve sheetflow. SAFER is looking for the District to conduct hydrological modeling which leaves the canals in place.

SAFER’s position is summed up in the “Modified Water Delivery Consensus Report” published by the Recreational Issues Workshop of SFWMD’s Water Resources Advisory Commission:

The purpose of the Mod Water Project is to provide more natural water deliveries to

ENP…The Team discussed the challenge of maintaining the conveyance necessary

for restoration while providing recreational opportunities. Mod Water proposes, as

does the CERP, backfilling some canals. Recreational fishermen, bass fishermen in

particular, are seeking solutions that maintain the quality of the existing fisheries

within the canals. The Team is seeking ways to do a better job of maintaining and

improving existing recreation while achieving restoration.

The chart below clearly shows the extent to which construction of the proposed plan will affect canal closures:

L-67C Canal Boat Access		CSOP Target Dates
Project Plan	Accessible to Boats	Plan Item	Completion Date
Current	20.5 miles	Modeling, evaluation, NEPA	April, 2004
USACE (w/backfill)	7.5	Design refinements	October 2004
ENP	0	Construction starts	August 2005
USACE (w/o backfill)	15.5 miles	Construction complete	June 2006

Attachments:

• Memo to Rock Salt, 1/19/2004, SAFER’s Comments on the CSOP PDT Meeting
• Modified Water Delivery Consensus Report, 9/17/2003, Recreational Issues Workshop, Water Resources Advisory Commission, South Florida Water Management District