Wednesday, August 14, 2019

Northern Everglades Basin Management Action Plans "new approach"?

August 13, 2019

Sara Davis
Environmental Manager
Division of Environmental Assessment and Restoration
Florida Department of Environmental Protection
2600 Blair Stone Rd., MS 3565
Tallahassee, FL 32399-2400

Re:  Feedback on approach to update Northern Everglades Basin Management Action Plans

Dear Ms. Davis:

Sierra Club offers the following comments regarding the FDEP’s draft approach to updating the three Northern Everglades Basin Management Action Plans (BMAPs), which was shared at the public stakeholder meeting on July 30, 2019. While our comments below are aimed at the Lake Okeechobee’s BMAP, they are also applicable to the BMAPs for the Caloosahatchee and St. Lucie rivers and estuaries.

  • An overdependence on computer models versus actual monitoring data under the current BMAP makes the underestimation of nutrient pollution loads into Lake Okeechobee extremely likely.
  • Many sources of nutrient pollution are not properly addressed by the BMAP, including class AA biosolids, excess fertilization, the use of aquatic herbicides (lack of harvest of vegetative material), and legacy nutrients.
  • We agree with the recommendation to add more monitoring to gain better understanding of the nutrient loads where data is lacking; this monitoring must be comprehensive, detailed and recurrent, and used to re-calibrate water quality models more frequently.
  • While we are encouraged to see a recommendation for more monitoring of total nitrogen, a numerical goal is needed.  It is way past overdue for a Total Maximum Daily Load (TMDL) to be established for nitrogen in Lake Okeechobee.
  • Monitoring should also aim to identify nitrogen by species to better pinpoint sources of nitrogen pollution and the appropriate water restoration measures.
  • The BMAP update must include the entirety of the Lake Okeechobee watershed to fully account for all loads into the lake. Dr. Gary Goforth, PE has determined that the current BMAP ignores nutrient loads from about 23% of Lake Okeechobee watershed. A true accounting of the entire load is absolutely necessary. 
  • An updated BMAP must include a complete plan that achieves the TMDL with a hard deadline and suitable, aggressive consequences if not met. This hard deadline must reflect the urgency of our water quality crises. Accountability and enforcement must be hallmarks of an updated BMAP. There currently is no reliable mechanism to determine which BMPs are working and where stronger measures are needed and too little enforcement to ensure all landowners are held accountable. FDEP must include an annual assessment to ensure compliance.
  • Appropriate performance measures must be established to accurately identify trends, hot spots, and deficiencies.
  • An ounce of prevention is worth a pound of cure; to prevent pollution from compounding, a regulatory framework is needed that holds individual landowners accountable for pollution leaving their property.
  • Far stronger requirements are needed for permits issued in the Lake Okeechobee watershed. The FDEP approach must include more meaningful and enforceable permit regulations, and address shortcomings in the regulation of ERPs and the treatment of reclaimed water.
  • Projects must be identified to clean up legacy nutrient pollution entering and within the Lake.
  • Sufficient land must be acquired; the restoration of Lake Okeechobee and the broader Everglades ecosystem requires the ecological services that nature does best. Large swaths of wetland restoration, other surface water quality, and surface storage projects must be included. Currently planned projects by SFWMD are not sufficient. Larger volumes of water must be stored and treated before entering Lake Okeechobee.
  • Opportunities must be sought for BMAP land acquisition projects in the Lake Okeechobee watershed that will also add to the Everglades Headwaters National Wildlife Refuge, which was established in part to “protect, restore, and conserve the headwaters, groundwater recharge and watershed of the Kissimmee Chain of Lakes, Kissimmee River and Lake Okeechobee region, which will improve water quantity and quality in the Everglades watershed” (
  • The use of ASRs is contrary to Everglades restoration and must not be considered for archiving surface water TMDLs.  Pumping nutrient pollution beneath the ground is not a solution.
  • A truly effective BMAP will require a commitment to consistent and sufficient funding for all agencies involved.

The new approach for the Northern Everglades Basin Management Action Plans does not change in any substantial way the status quo and therefore is unacceptable.  It is time to stop passing this crisis on to another administration and another generation.

Thank you in advance for addressing the above.


Diana Umpierre, AICP
Organizing Representative
Everglades Restoration Campaign
Sierra Club
PO Box 2347 / 136A S Main St, Belle Glade, FL 33430
(561) 983-8655

cc: Thomas Frick, Director, Division of Environmental Assessment and Restoration, FDEP


A pdf version of this letter can be found here.

Blue-green algae along the south rim of Lake Okeechobee caused by nutrient pollution.
Photo taken 8/8/2019 by Diana Umpierre.