Tuesday, August 20, 2019

Changes needed to revised plan for the Lake Okeechobee Watershed Restoration Project

August 19, 2019

Dr. Gretchen Ehlinger
U.S. Army Corps of Engineers Jacksonville District
P.O. Box 4970
Jacksonville, FL 32232-0019

RE:  Comments on the Revised Draft PIR and EIS for Lake Okeechobee Watershed Restoration Project

Dear Ms. Ehlinger:

Sierra Club submits the following comments on the Revised Draft Integrated Project Implementation Report (PIR) and Environmental Impact Statement (EIS) for the Lake Okeechobee Watershed Restoration Project (LOWRP) with the goal of seeing the LOWRP Optimized Tentatively Selected Plan (TSP) drastically improved. Sierra Club believes that ecosystem restoration projects in the Lake Okeechobee Watershed are essential for the following reasons: (1) for the health of the Lake Okeechobee ecosystem and its watershed; (2) to improve the quality, timing, and quantity of freshwater flows to the northern estuaries; and (3) for the redirection of freshwater from the lake to where it is most needed, south to the Everglades and Florida Bay.

1. While we support the wetland restoration of the Paradise Run and Kissimmee River Center sites, which would restore about 4,800 acres to wetlands, we urge SFWMD and USACE to not miss the opportunity to restore more wetlands. As stated in the Revised Draft PIR/EIS, “about 330,000 acres of wetlands have been lost in the LOWRP area” and “more wetland acres restored would generally be better” (Appendix E, Attachment B). The Lake Okeechobee West site has a high restoration potential. We cannot accept leaving out this excellent restoration site from further consideration just because it is not in “better ecological quality.” We urge SFWMD and USACE to modify the Optimized TSP to include this site, which would restore 2,800 additional acres of high value wetland habitat. The restoration of more wetlands will also provide additional opportunity for water quality improvements.

2. The goals of the CERP component referred to as "Lake Okeechobee Watershed Water Quality Treatment Facilities (OPE)" included not only wetland restoration, but also stormwater treatment areas to "retain phosphorus before flowing into Lake Okeechobee" (CERP Yellow Book, p. 9-4). The CERP Yellow Book makes it clear that an essential aspect of Everglades restoration is the inclusion of water quality features.  USACE must reconsider and include water quality features that are essential to Everglades restoration and improve the health of Lake Okeechobee. The USACE’s stated current policy of not cost-sharing on water quality features runs counter to CERP’s goals of restoration and therefore must be reconsidered and modified.  If the federal government does not cost-share, whether because of administrative policy or legislation, it is still incumbent upon the state to provide a locally preferred alternative that includes water quality features.

3. The Wetland Attenuation Feature (WAF)  must be modified and modeled as a water quality feature, such as a Stormwater Treatment Area (STA) and/or a Flow Equalization Basin (FEB). This will help in significantly reducing nutrient loading to Lake Okeechobee and thereby also reduce the level of nutrients discharged to the northern estuaries. Reducing the level of nutrients into Lake Okeechobee is essential to Everglades restoration; it must not be omitted from this important CERP project. Nutrient loads to Lake Okeechobee must be reduced and LOWRP can be designed to provide such a reduction.  Therefore, we urge USACE and SFWMD to modify this feature so it provides what the ecosystem needs, clean water for the heart of the Everglades.

4. We strenuously oppose the use of Aquifer Storage and Recovery (ASR) wells in CERP as they are contrary to the goals of restoration of the Lake Okeechobee watershed and the Everglades. ASRs would waste hundreds of millions of dollars of public funding that are needed for actual ecosystem restoration.  The proposed eighty ASRs will be a form of permanent artificial “life support”, creating a watershed ecosystem stuck in an Intensive Care Unit.

5. More shallow surface water storage is required. The Optimized TSP lacks the meaningful and long envisioned shallow storage needed in the Lake Okeechobee watershed.

Thank you in advance for your attention to the above. We look forward to providing additional input on an ongoing basis as the project proceeds.


Diana Umpierre, AICP
Organizing Representative, Sierra Club
136 S. Main Street, Unit A
Belle Glade, FL 33430
(561) 983-8655

A pdf of this letter can be found here.

Aerial view of Lake Okeechobee and parts of its watershed
Credit:  ESRI Scene Viewer