Aerial, Kissimmee River restoration, Gary Goforth, 2-9-20
My most recent blog post included the above photograph of Kissimmee River Restoration north of Lake Okeechobee taken by Dr Gary Goforth. My mother, Sandy Thurlow, commented: “ I would so like for Dr. Goforth to explain what we are seeing in his aerial of the restoration of the Kissimmee River.”
I wrote Gary on behalf of my mother and he provided such comprehensive and helpful insight that today I am sharing not just for my mother, but for everyone! Please read below.
When time allows my mother was hoping to get an explanation of the wonderful Kissimmee River restoration photo you shared in my blog post. Could you please write something? Thank you so much.
The Kissimmee River Restoration (KRR) Project is one of my favorite projects on the planet!In the 1960s, the historic 105-mile meandering Kissimmee River was transformed into a 56-mile ditch by the Corps of Engineers at the request of the State of Florida to help relieve flooding upstream.Public activism convinced Gov. Bob Graham to support restoration of the River in the 1980s, and as a US Senator he was instrumental in having Congress authorize the Corps to proceed with restoration.The SFWMD was way out ahead of the Corps (again) and had completed several phases of engineering design and prototype testing.The initial backfilling of the C-38 Canal was begun in 1999, and when completed later this year, the project will re-establish flow in 40 miles of the old river and rehydrate about 12,400 acres of former wetlands that were over-drained by the canal.
There are many reasons I love the picture taken Sunday as Ed was flying Mark and I north of the Lake:
·In the foreground of the photo you see a section of the meandering restored Kissimmee River!The construction work in this section of the river consisted of backfilling the 300-ft wide and 30-ft deep canal.It also included “re-carving” some sections of river channel that were destroyed during C-38 canal construction.This work has routed water to the native channel and floodplain of the Kissimmee River, and reestablished hydrologic continuity between the river and floodplain for the first time since the C-38 canal was completed in 1971!How amazing!
·The photo also shows smaller secondary river channels and a colorful mosaic of wetlands on their way to restoration!What has been amazing is that despite almost 50 years of over-drainage, there are tens of thousands (maybe millions) of resilient seeds of the former marsh vegetation in the soil that have regenerated upon reflooding!This is truly amazing!
·The photo shows the restoration area known as Phase II, located roughly in the middle of the KRR project.This phase is almost complete, with the remaining canal backfilling to be completed later this year.By the way, the balance of the restoration project should also be completed this year!!!
·The left hand side of the photo, where the road crosses the floodplain, shows the location of what was the water control structure and navigation locks known as S-65C.As part of the restoration project, structure S-65C was demolished in 2017.For spatial reference, the old structure was located about 5 miles upriver from the Hwy 98 bridge and about 23 miles upstream of where the C-38 canal empties into the Lake.About 30 miles to the north (left in the photo) is where the C-38 Canal exits Lake Kissimmee.
·A Google Earth image taken in 2017 is attached below.This image shows the S-65C structure prior to demolition.
·In the photo taken on Sunday you can see the footprint of the backfilled C-38 canal in the center of the photo – on either side of the rectangular open water. You’ll need to zoom in to make out this detail since the inundated floodplain has almost covered up the former canal footprint!
Today I share Dr. Gary Goforth’s (http://www.garygoforth.net/Other%20projects.htm) comments to the Army Corp of Engineers’ LOSOM scoping process that occurred on Tuesday, February 19, 2019, in Stuart: (https://www.saj.usace.army.mil/LOSOM/). Dr Goforth’s comments are helpful for all of us. I am publishing them today with his permission as a reference. You can read in PDF file link, or below. Thank you Dr Goforth for your continued scientific advocacy on behalf on the St Lucie River/Indian River Lagoon! Never, Never, Never Give Up!
It is a journey the state, federal, and local agencies don’t always wish to take–a journey to face the numbers of our watershed…
Today, Dr Gary Goforth (http://garygoforth.net) shares his most recent report, “Water Quality Assessment of the St Lucie River Watershed, For Water Year 2017, DRAFT.”
Mind you, for non-scientist people like myself, a “water year” is reported from May of one year, through April the next year, as opposed to a calendar year.
The full report is linked at the bottom of the post and contains numerous helpful charts. I have just included the key findings below.
Dr Goforth wanted to get the draft assessment out before the Florida Department of Environmental Protection’s Basin Management Action Plan workshop scheduled for this Friday Aug. 25th at 10:00 am at Martin County Building Permits Office, 900 Southeast Ruhnke Street, Stuart, FL 34994, Conference Rooms A & B because this is where the rubber hits the road! FDEP: (http://www.dep.state.fl.us/central/Home/Watershed/BMAP.htm)
Water Quality Assessment of the St. Lucie River Watershed –Water Year 2017 – DRAFT Gary Goforth, P.E., Ph.D.
Quis custodiet ipsos custodes? (Who watches the Watchers?)
1. Over the last water year (May 2016 – April 2017), the surface water entering the St. Lucie River and Estuary (SLRE) in general was of poor water quality. The best water quality entering the SLRE was from the highly urbanized Tidal Basins. The largest source of phosphorus, nitrogen and sediment pollution to the SLRE was Lake Okeechobee discharges. The C-44 Canal Basin contributed poor water quality, and was the only basin demonstrating a worsening in water quality over the last ten years.
2. It was estimated that stormwater runoff from agricultural land use contributed more flow and nutrient pollution than any other land use, even contributing more flow than Lake Okeechobee discharges.
3. The annual Basin Management Action Plan (BMAP) progress reports produced by the Florida Department of Environmental Protection continue to indicate water quality conditions in the tributaries of the SLRE are better than they actually are. Examples of flaws in the BMAP assessment process include the omission of Lake Okeechobee pollution loads, the use of simulated data instead of observed data, the inability to account for hydrologic variability, and the inability to assess individually each of the major basins contributing to the SLRE.
4. An alternative to the assessment approach presented in the BMAP progress reports was developed and used to evaluate water quality conditions of major inflows to the SLRE and to assess progress towards achieving the Total Maximum Daily Load (TMDL) load reduction goals. This alternative approach uses observed data, includes Lake discharges, accounts for hydrologic variability, and is applied to each of the major basins contributing pollution loads to the SLRE. For WY2017, observed nitrogen loads to the SLRE exceeded the Phase 1 BMAP target loads (adjusted for hydrologic variability) by 77 percent. Observed phosphorus loads exceeded the Phase 1 BMAP target loads (adjusted for hydrologic variability) by 53 percent.
5. The largest single source of total nitrogen, total phosphorus and sediment load to the SLRE was Lake Okeechobee discharges. In addition, total phosphorus concentrations in Lake Okeechobee discharges to the SLRE remained almost four times the lake’s TMDL in-lake target concentration of 40 parts per billion (ppb). In 2017, the South Florida Water Management District (SFWMD) reported that phosphorus loading to the lake from surrounding watersheds was almost 5 times the Lake’s TMDL of 105 metric tons, yet staff acknowledged the agency does not enforce permits that set numeric limits on phosphorus discharges to the lake (SFWMD 2016, SFWMD 2017). Unfortunately, despite the continued and well-publicized pollution of the lake, the Florida legislature in 2016 enacted a water bill that pushed back deadlines for achieving the lake’s TMDL by decades (Ch. 2016-1).
6. The best water quality entering the SLRE during WY2017 was observed in the highly urbanized Tidal Basins, with concentrations of 97 ppb and 819 ppb for TP and TN, respectively. Each of the remaining source basins, except the C-44 Canal Basin, exhibited a slight improvement in nutrient levels compared to their base periods, however, collectively these WY2017 loads did not achieve the alternative BMAP Phase 1 load target (Figures ES-1 and ES-2). The C-23 and Tidal Basins met the alternative BMAP Phase 1 target for TP, while the C-23, C-24 and Tidal Basins met the alternative BMAP Phase 1 target for TN. The predominantly agricultural C-44 Canal Basin exhibited poor nutrient conditions, and in fact, continued a trend of deteriorating nutrient conditions compared to its 1996-2005 base period. As a whole, the water quality entering the SLRE remains poor, although a slight improvement over the 1996-2005 period was observed.
In recent years we along the St Lucie River/Indian River Lagoon have been screaming because the ACOE and SFWMD have been discharging water from Lake Okeechobee and the C-44 basin into our waterways causing destructive toxic algae blooms and other issues to our area …
This year some are screaming because C-44 basin runoff water in southern Martin County is being pumped back into Lake Okeechobee. Yes, C-44 is “running backwards.” It’s a crazy world here in South Florida even through the water managers are working hard at “getting the water right…”
So two odd things are going on right now. First, water is being sent into Lake O from the C-44 canal as we were in a long-time drought, and also, now, water is being back-pumped into the lake from the south to help alleviate flooding in the Water Conservation Areas— as it has rained so much recently “down there.” This whole situation is exacerbated because the EAA, in the middle, “is kept dry to protect the property of the agricultural industry and safety of communities south of the dike.”
The graph and short write-up below are from friend and engineer Dr Gary Goforth. The graph “shows” the C-44 basin runoff (see image above) being sent to Lake Okeechobee in 2017 compared to other years since 1980 (other than ’81) “is at 100%.”
I have also included some articles and images on the other “back into Lake O” subject. Back-pumping was made illegal in the 1990s, but is allowed under certain circumstances such as endangering communities and agriculture in the EAA, and danger to wildlife in the conservation areas due to flooding…All of this is “back-pumping” not good for the health of the lake. In all cases, it is helping one thing while hurting another…
One day we will have to truly get the water right. Images below may help explain things.
ISSUE OF BACK-PUMPING:
ISSUE OF C-44 CANAL BASIN WATER BEING SENT INTO LAKE O RAHTER THAN TO SLR:
” For the period 1980-2016, about 32% of the C-44 Basin runoff was sent to the Lake, while 68% was sent to the St. Lucie River and Estuary. Historically (i.e., before 1923) virtually none of the C-44 Basin runoff went to the St. Lucie River and Estuary: some went to the Lake, some went to the Loxahatchee River and some went north to the St. John’s River. So far in 2017, virtually all of the basin runoff has been sent to the Lake.”
My brother, Todd, wrote to me on June 8th noting that the C-44 canal was flowing westwards into Lake Okeechobee rather than dumping eastwards into the St Lucie as is standard operating procedure after a big rain…
Yes this canal, as most of the others, can “flow” in either direction, seemly “backwards.”
So how can this happen? This backwards flow?
Dr Gary Goforth says the following:
“Yes this is normal operations; generally when the Lake level is below 14 ft the Corps leaves the locks at S-308 wide open which allows any local runoff to flow into the lake.”
Another way Lake Okeechobee can receive water in an unusual way is if the water is pumped into it–back pumped. This has recently been done from the EAA. Back pumping into Lake O has been outlawed, but it is allowed if communities or farmland would flood.
According to an exchange yesterday on Facebook, with Audubon’s Dr Paul Grey:
“St Lucie (C-44) backflows are just one of many southern inflows now, S-2 is backpumping, three other southern outlets are flowing backward into the low lake (L-8, S354, S-352) the Caloosahatchee was backflowing but appears equalized today. More water is flowing into the lake from downstream areas than upstream right now. Not the end of the world but not desirable either, it is very polluted water. http://w3.saj.usace.army.mil/h2o/reports/r-oke.html “
When I asked Dr Grey if this was being done to gather water in the lake as we’ve recently been in a drought, or to keep the farmlands in the EAA and surrounding areas dry, this was his response:
“Both, they want to fill the lake this summer, and so do I, in concept, but much of this backpumping and flowing is because the farmers have been pumping water so rapdily off their own lands they have made the canals too deep, and risk fooding the communities. And rather than tell the farmers the canal its too deep and they have to modererate their pumping, the SFWMD backpumps/flow it to the lake.”
In any case, when I visited yesterday during my trip to Belle Glade, S-308 was closed at Port Mayaca and no more water was entering Lake O from C-44. I’m not sure about S-2.
The water looks dark and full of sediment. The once beautiful beach is full of gritty rocks. Maybe the lake is healthy in the shallows south, near the islands, but by Port Mayaca it looks terrible. Algae has been reported by S-308 a few weeks ago according to a report from Martin County at the River’s Coalition meeting. But thankfully there is not algae reported in C-44 right now.
We have really made a mess of it. For our rivers and for Lake Okeechobee, the reservoir must be built and we must continue to advocate for sending cleaned water south and re -plumb this outdated system. Forward flow or backwards flow, just say NO.
Todd Thurlow notes 6-8-17
Interesting note: if this data is correct, C-44 has poured 10.7 billion gallons (aka 13.82 Stuart Feet) of water into Lake Okeechobee in the last three days. With all the recent “local” runoff into the canal, they have opened S-308, sending the water west to the Lake to help get the low lake level up.
48.5 million gallons passed through S-80 to the St. Lucie on June 5th…
Senate Bill 10, the bill associated with Senate President Joe Negron and his goal to stop the damaging discharges of Lake Okeechobee to the St Lucie River and Caloosahatchee… my gosh, up and then down, and then up again…Why such a roller coaster ride?
The last time I went on a roller coaster ride was many years ago when I in my twenties and teaching German at Pensacola High School. I took my IB high school students and 14 visiting German exchange students to Six Flags. I got so sick on the ride that I had to sit on a bench the remainder of the day. The students? They loved it and went multiple times! Roller coasters are not fun for everyone. But one thing’s for sure, if you’re on the ride, and you feel sick, be assured that it will end, but when it hasn’t, hold on! This bill, this ride, won’t end for another month plus, as it has to be voted on by the full Senate and achieve a matching bill in the House….
Thus far, the bill has really gone “double-full-circle-upside down-roller-coaster” in that Stuart’s Dr Gary Goforth ( http://garygoforth.net) mentioned the many configurations available to achieve “the goal” during the January 11th 2017 meeting of the Senate Natural Resources Appropriations Committee. At this time he pointed out that some of those “loopy configurations” on his visual went back to CERP’s birth year of 2000 and the first goals the state and federal government had for an EAA reservoir!
You can watch Dr Goforth’s presentation and see his handout linked at the top of this post. Gosh, I kind of feel sick, yes, there have been so many changes and so many numbers… 60,000, 14,000, 360,000, 240,000, A-1, A-2, my head is spinning! There is so much back and forth! Yes there is, but goodness, you can’t say this isn’t exciting! The St Lucie River and Indian River Lagoon a roller coaster for the whole world to see! Personally, I am going to try NOT to sit out on the bench this time, how about you? 🙂
Here is a Senate staff summary of what part of the rollercoaster ride the bill is on today:
Establishes options for providing additional water storage south of Lake Okeechobee, including the:
o Everglades Agricultural Area (EAA) reservoir project with the goal of providing a minimum of 240,000 acre-feet of water storage; and
o C-51 reservoir project with the goal of providing approximately 60,000 acre-feet of water storage.
Authorizes the Board of Trustees of the Internal Improvement Trust Fund (TIITF) and the South Florida Water Management District (SFWMD) to negotiate the amendment or termination of leases on lands within the EAA for exchange or use for the EAA reservoir project.
Requires lease agreements relating to land in the EAA leased to the Prison Rehabilitative Industries and Diversified Enterprises, Inc., (PRIDE Enterprises) for an agricultural work program to be terminated in accordance with the lease terms.
Requires the SFWMD, upon the effective date of the act, to identify the lessees of the approximately 3,200 acres of land owned by the state or the district west of the A-2 parcel and east of the Miami Canal and the private property owners of the approximately 500 acres of land surrounded by such lands;
Requires the SFWMD, by July 31, 2017, to contact the lessors and landowners of such lands to express the SFWMD’s interest in acquiring the land through the purchase or exchange of lands or by the amendment or termination of lease agreements.
Requires the SFWMD to jointly develop a post-authorization change report with the United States Army Corps of Engineers (USACE) for the Central Everglades Planning Project (CEPP) to revise the project component located on the A-2 parcel for implementation of the EAA reservoir project.
Requires that if, for any reason, the post-authorization change report does not receive Congressional approval by October 1, 2018, unless the district has been granted an extension by the Legislature, the SFWMD begin the planning study for the EAA reservoir project by October 31, 2018, and proceed with the A-2 parcel project component of CEPP in accordance with the project implementation report.
Requires the SFWMD to give preference to the hiring of former agricultural workers primarily employed during 36 of the past 60 months in the EAA, consistent with their qualifications and abilities, for the construction and operation of the EAA reservoir project.
Establishes the Everglades Restoration Agricultural Community Employment Training Program within the Department of Economic Opportunity to provide grants for employment programs that seek to match persons who complete such training programs to nonagricultural employment opportunities in areas of high agricultural employment, and to provide other training, educational, and information services necessary to stimulate the creation of jobs in the areas of agricultural unemployment. The program is required to include opportunities to obtain the qualifications and skills necessary for jobs related to federal and state restoration projects, the Airglades Airport in Hendry County, or an inland port in Palm Beach County.
Establishes a revolving loan fund to provide funding assistance to local governments and water supply entities for the development and construction of water storage facilities.
Revises the uses of the Water Protection and Sustainability Program Trust Fund to include the water storage facility revolving loan program.
Prohibits, beginning July 1, 2017, the use of inmates for correctional work programs in the agricultural industry in the EAA or in any area experiencing high unemployment rates in the agricultural sector.
Beginning in Fiscal Year 2018-2019, appropriates the sum of $100 million from the Land Acquisition Trust Fund (LATF) to the Everglades Trust Fund for the purpose of implementing the water storage reservoir projects, with the remainder of such funds in any fiscal year to be made available for Everglades projects.
The bill provides the following appropriations for the 2017-2018 fiscal year:
The sum of $30 million in nonrecurring funds from the LATF is appropriated to the Everglades Trust Fund for the purposes of acquiring land or negotiating leases pursuant to s. 373.4598(4), F.S., or for any cost related to the planning or construction of the EAA reservoir project.
The sum of $3 million in nonrecurring funds from the LATF to the Everglades Trust Fund for the purposes of developing the post-authorization change report pursuant to s. 373.4598, and the sum of $1 million in nonrecurring funds from the LATF to the Everglades Trust Fund for the purposes of negotiating Phase II of the C-51 reservoir project pursuant to s. 373.4598, F.S.
The sum of $30 million in nonrecurring funds from the LATF to the Water Resource Protection and Sustainability Program Trust Fund for the purposes of implementing Phase I of the C-51 reservoir project as a water storage facility in accordance with ss. 373.4598 and 373.475, F.S.
Post Hurricane Matthew, I am sharing Dr Gary Goforth’s “Updated Lake Okeechobee Discharges to the Estuaries and Everglades,” dated yesterday, October 10, 2016 as sent to state and local officials, as well as the press. Many helpful visuals are attached.
Dr Goforth continues to lead in documenting the destruction of what was once lauded as North America’s “most biodiverse estuary,” our beloved St Lucie River/Indian River Lagoon…
Through shared knowledge, we advocate for a better Florida water future.
More than 204 billion gallons of polluted Lake water has been discharged to the St. Lucie (25% of total Lake discharges); more than 456 billion gallons of polluted Lake water has been discharged to the Caloosahatchee (55% of Lake discharges). By contrast, only 20% of Lake discharges has been sent to the south, with only 6% sent to the STAs/Everglades.
Ag runoff continues to contribute significant amounts of flow and pollution load to the St. Lucie: 39% of flow, 53% of total phosphorus and 42% of total nitrogen.
I added a chart comparing monthly Lake flows to the STAs – 2016 releases to STAs has been significantly less than 2014 and 2015.
Recently, at Rivers Coalition Defense Fund meeting, president Kevin Henderson brought along the old River League’s briefcase. It had been stored away for many decades in an aging house in Stuart. In case you have not heard of them, “The River League” worked tirelessly in the 50s and 60s to stop the expanding destruction of our rivers by the Florida Flood Control District (today’s South Florid Water Management District) and the Army Corp of Engineers.
I couldn’t believe the old brief case—a beautiful sight–aged leather, and rusted metal with the sweat of those who carried it unwashed from its handle…
Kevin placed the briefcase on the table and opened it. It had not been opened in almost 50 years! No pun intended, but the sound of the locks “clicked”and suddenly it was open…
I held my breath.
I swore for a second that I saw the spirit of Ernie Lyons come out of the old briefcase like a genie. He had a giant cigar in his mouth and dark rimmed glasses. His hair was greased back and he sat at a floating desk from the old Stuart News…He was leaning back in his chair with his hands behind his head smiling from ear to ear. His teeth were stained with tobacco juice and he looked happy as a clam.
“Ernie here….Ha! Good to see you workin’ so hard! Those bastards are still killing it aren’t they? The river that is! Don’t you for a moment have despair. As you know this war has been going on for a long, long time. All of us, who have passed, are on your side. We are here. All of us who worked so hard to save the paradise of this place. You’ve probably caught on. Good versus evil is not a game. And I got a secret to tell ya. —I know the end—and good wins. Don’t give up! And know we’re here working the magic behind the scenes to help you save the St Lucie/Indian River Lagoon.”
Then he looked away and started furiously typing…the words he was writing could be seen above his head:
Today’s column, 1968
HOW THROATS OF OUR RIVERS WERE CUT BY CANALS
“There was never anything more beautiful than a natural South Florida river, like the North and South Fork of the St Lucie…
A bank of cabbage palms and live oaks draped with Spanish moss and studded with crimson-flowered air-plants and delicate wild orchids– were scenes of tropical wonder, reflected back from the mirror-like onyx surface of the water….”
When I looked up, Ernie was gone and our meeting was in full discussion…
As a reflection from the mirror of the St Lucie’s onyx-like water–I know that Ernie is here…
The following update Comparison of Lake O Releases was shared by Dr Gary Goforth on 7-14-16. Thank you Dr Goforth. The more informed and studied we are about where the water is going, the better chance we have to change this situation.
1. Lake Okeechobee has received more than twice the watershed inflows since January compared to last year at this time.
2. Discharges from the Lake have increased 25% compared to last year this time, however the distribution of inflows has dramatically changed compared to last year (as you so clearly know):
3. Since January 1, a. approx. 525 billion gallons of Lake water have been sent to the estuaries (including Lake Worth Lagoon) b. Lake flows are averaging about 1 billion gallons per day to the St. Lucie River/Estuary and about 2.1 billion gallons per day, and about 0.1 billion gallons /day to Lake Worth Lagoon, for a total of about 3.2 billion gallons per day c. Twenty-five (25) times more Lake water has been discharged to the estuaries than to the Everglades d Ag runoff has contributed significant nutrient loads to the St. Lucie River/Estuary: i. Nitrogen loads: 36% from ag and 54% from Lake [Dear Gov. Scott and SFWMD Board members: Martin County septic tanks contributed about 2% of the nitrogen load] ii. Phosphorus loads: 53% from ag and 30% from Lake e. 93% of the sediment load to the St. Lucie River/Estuary this year has come from the Lake discharges (37 million pounds)
4. Only 32 billion gallons of Lake water have been sent to the STAs this year – less than 1/3 of the amount sent last year at this time.
Today’s photos were taken by Dr Gary Goforth this past Sunday. During a trip, he flew over Lake Okeechobee.
He writes: “Jacqui–The photos are of the southeast part of Lake; the plane had just passed over Clewiston and is headed northeast. The city of Pahokee is visible along the upper right shoreline. The FPL reservoir is visible in the background. The bloom is enormous – easily over 100 sq miles in extent, although areas are patchy.” GG
STATE OF EMERGENCY
It’s hard to understand state of emergencies.
Martin County waters are experiencing their third “state of emergency” since 2013–two of those being this year in 2016.
Yesterday, Governor Rick Scott declared one, after our county commission declared one first, over the blue-green algae blooms in the St Lucie River, Indian River Lagoon and Atlantic Ocean —I am very grateful.
What I do not understand is that when you really read between the lines, we will continue to be under siege.
After one sifts through the words of the declaration there are basic things that stand: the emergency order directs Water Management Districts and the Florida Wildlife Commission to stop flows into the lake as soon as possible coming from the north. It also allows a waiver of requirements to purchase pumps to move water south, and increases water testing.
This is all good and well, but there is one problem. This means the discharges from the lake continue– perhaps lessened, but they will continue…full of the same algae that is causing the emergency in the first place. And the lake is very high at 14.90. The dumping could go on for months even if no new water enters the lake from the north…
Until the gates at S-308 and S-80 are closed we will suffer. Like having the dike too high is a safety issue for those south of the lake, sending the lake’s algae waters to the St Lucie River is a safety issue too. Take a look.
The following was written by Dr Gary Goforth as a response to U.S. Sugar Corporation’s months long ad campaign in the Stuart News. http://garygoforth.net
· The health and economies of the St. Lucie River and Estuary, the Caloosahatchee Estuary, and Florida Bay have been sacrificed for decades by the management of Lake Okeechobee for the protection of US Sugar and other agricultural lands south of the Lake.
The recent ad blitz by US Sugar appears to be an attempt to divert the public’s attention away from this preferential treatment and from an egregious betrayal of south Florida taxpayers perpetrated by US Sugar, the Florida legislature and the Governor’s administration – the failure to exercise the willing seller contract to purchase US Sugar land south of the lake. Failure to secure needed land south of the Lake is the single biggest obstacle to long-term protection of the St. Lucie and Caloosahatchee estuaries from destructive Lake discharges, and providing Florida Bay and lower east coast wellfields with needed water.
· Water storage necessary to reduce high flows to the estuaries by about 90% will require about 10% of the land in the EAA – not complete elimination of farming in the area. The recent UF Water Institute study reconfirmed what scientists have been saying for decades – additional storage and treatment beyond what is currently planned in CERP and CEPP is needed south of the Lake: “If this required storage were to be provided strictly though deep 12-ft reservoirs, new land area between approximately 11,000 and 43,000 acres would be required south of Lake Okeechobee.” The upper limit – 43,000 acres – is less than ¼ of the amount of land US Sugar was willing to sell to the state (187,000 acres).
· Regarding the numbers in the ads – some are accurate, some are completely fictitious (e.g., the distribution of water from Lake Okeechobee), and many critical numbers are missing, e.g.,
-millions of pounds of nitrogen and phosphorus from lake Okeechobee that feed algal blooms and wreak havoc on the ecology of the river, estuary, lagoon and near-shore reefs. (million off pounds of nutrients that the State of Florida ignores in their BMAP progress reports for the St Lucie River.) – the hundreds of millions of pounds of Lake Okeechobee sediment that turned a once sand-bottom clear water estuary into a muck-filled lagoon that belches blackwater every time it rains. – the hundreds of millions of dollars of economic impact to local businesses, tourism and real estate values attributable to poor water quality If you’re interested go to the SFWMD’s (or my) website.
· Most of the area that the ads calls “local waterways” did not flow into the St. Lucie River (SLR) until after the major agricultural drainage canals (C-23, C-24, C-25 and C-44) were dug, connecting more than 250,000 acres to the SLR. Historically these areas flowed north into the St. Johns River watershed, south into the Loxahatchee and Everglades watersheds, evaporated or recharged the groundwater.
· The ads ignore the fact that more than half of the “local watershed” is agriculture, and that more than half of the flows and nutrient loads to the St. Lucie River and Estuary come from agricultural land use.
· Nutrient loads from septic tanks along the Indian River Lagoon need to be addressed in cost-effective ways based on good science. Nevertheless, nutrient loading and sediment from Lake Okeechobee and agricultural runoff constitute a far greater threat to the health of the St. Lucie Estuary than does loading from Martin County septic tanks. The loading from septic tanks in Martin County have been overstated by upwards of 200-300%.
· The 2016 Florida Legislature was an unmitigated disaster for the environment of Florida, with misappropriations of Amendment 1 funds for the second year in a row and the passage of a water bill that rolled back environmental protection for the benefit of agricultural interests. What role did lobbyists for US Sugar and other agricultural interests play in this debacle? —–Dr. Gary Goforth
*Dr. Goforth has more than 30 years of experience in water resources engineering encompassing strategic planning, design, permitting, construction, operation and program management. For the last 25 years, his focus has been on large-scale environmental restoration programs in the Kissimmee-Okeechobee-Everglades ecosystem. He was the Chief Consulting Engineer during the design, construction and operation of the $700 million Everglades Construction Project, containing over 41,000 acres of constructed wetlands. He is experienced in public education, water quality treatment design and evaluation, engineering design and peer review, systems ecology, statistical hydrology, hydrologic modeling, hydrodynamic modeling, water quality modeling, environmental permit acquisition and administration, hydrologic and water quality performance analyses. (Website: http://garygoforth.net)
It’s easier to communicate your message when you have billions of dollars, but it is not a limiting factor if you don’t…
Today, I will share a “Draft Report” from Dr Gary Goforth. This report is a response he has created specifically to U.S. Sugar Corporation’s May 1st full- page ad in the Stuart News entitled: “The Water That Ends Up In Our Local Waterways.”
This is one of multiple full-page ads U.S. Sugar Corporation has run in the local Martin County paper over that past months trying to “educate” our citizenry. Why are they spending so much money doing this? Why all the propaganda? Because they know that though our advocacy for the St Lucie River/Indian River Lagoon, we are changing the course of human events. For the first time, many people and some important politicians and are looking at South Florida and saying “It needs to be re-plumbed…..”
Dr Goforth (http://garygoforth.net) is no stranger to these water issues, nor to the controversy and ability to manipulate the numbers complicated by the historic and supportive relationship between those doing business in the Everglades Agricultural Area south of the lake and today’s South Florida Water Management District. Thus the intertwined propaganda.
So here we go, each idea is presented on a separate slide. You can click the slide to enlarge if you need to. Thank you Dr Goforth!
This year, the Army Corp of Engineers– with input from the South Florida Water Management District, and other stakeholders— has been discharging from Lake Okeechobee into the St Lucie River and southern Indian River Lagoon since January 29th, 2016. Today will review an April update.
We as citizens must pay attention and know what is happening to the river so that we can intelligently fight for its future.
Dr Goforth’s chart above gives a good visual comparison of 2016’s discharges, thus far, compared to those of 1997/98, another El Nino year with fish lesions, fish kills, and toxic algae reports. This chart also compares 2013, our recent “Lost Summer,” when toxic algae blooms filled the river, on and off, for about three out of five dumping months. (–Running May through October, 2013.)
One can see, that Lake Okeechobee’s 2016 discharge amounts are quickly approaching the total numbers released in 2013— although well below those of 1997/98.
Although discharges have been lessened lately, with the Army Corp of Engineers reporting a possible La Nina indications for the 2016 Hurricane season, (4-26-16 ACOE Periodic Scientist Call) considerably more rain could be on the way.
With the lake sitting at 14.29 today, —a high level going into “wet season,” starting June 1st—we should all be watching the situation very closely. Hopefully 2016’s total Lake O release numbers will be nowhere close to 1997/98.
We must continue to advocate hard for a third outlet, and land purchase south of the Lake Okeechobee, as this is the only way to spare our rivers’ repeated total destruction.
Thank you to Dr Goforth for his contribution today.
The following is from an email dated from Dr Gary Goforth on April 26, 2016 including the slide used for today’s blog and others of interest. Click on image to enlarge.
1. Summary of the 2016 Lake discharge event to the St. Lucie River and Estuary.
2. Preliminary Water Year 2016 (May 1, 2015 to March 31, 2016 – missing April 2016) summary, including a. Inflows to Lake Okeechobee by basin, with comparison to last year b. Outflows from Lake Okeechobee by region, with comparison to last year c. Flow diagram for Lake releases, with comparison to last year d. Lake releases to STAs, with comparison to last year e. Nutrient and TSS load from Lake discharges to the St Lucie and Caloosahatchee Estuary f. The graphs are shown for both acre feet and billion gallons
Today I am going to share an adventure of engineer and St Lucie River/Indian River Lagoon advocate Dr Gary Goforth. I will tie in his Lake Okeechobee experience with a few wonderful historic postcards from my mother, historian Sandra Henderson Thurlow. Although you couldn’t get my mother on a motorcycle if you paid her, there is a common thread. The lone cypress…
“The Lone Cypress…” You may have heard of it? As we know, cypress trees live for thousands of years. There were large forest of these magnificent trees prior to their being cut down around the turn of the last century. But a few still stand. Like this one in Moore Haven.
Dr Goforth’s account of his ride around the lake is inspirational. I have done it a couple of times by car, most recently during the final session of my UF Natural Resources Leadership Institute in Clewiston. During Dr Goforth’s ride, he visits the ancient cypress tree–the one in my mom’s historic post cards. I find this really cool. I hope you do too!
“Hi Jacqui – I know you’re very busy as always – in fact more so these days I imagine. I got around to reading a recent blog of yours entitled “Taking the Emotion out of “Clewiston”-UF’s Natural Resources Leadership Institute, SLR/IRL.” I enjoyed it so much I thought I would share a trip I took on Sunday afternoon – a motorcycle ride around Lake Okeechobee.
It started out as a leisurely Sunday afternoon ride around the Martin County countryside. When I got to Port Mayaca I decided to head south for a couple of mile to the trailhead of the Lake to Ocean Trail – a 55-mile hike I’ll get around to tackling during cooler weather. When I got to the trailhead, I said what the heck – might as well circle the Lake. I’ve done the route before, and love to roll through the small towns that we are linked to primarily because of the Lake releases. Probably my favorite stretch is along the eastern shore of the Lake where the old-growth linear forests still remain – the magnificent cypress, bay, and others. My companion for the entire way around the Lake was the Herbert Hoover dike – almost always in sight off to my right along the small roads I took. Before I knew it I was passing through Sand Cut and Pahokee on my way to Belle Glade with their motto “Our Soil is our Fortune.” I thought of my Dad’s cousin Jack Fullenweider who was a general manager of the old Talisman sugar mill (bought by the State prior to construction of STA-3/4), and whose son, Jack, Jr. was a sheriff’s deputy in Belle Glade. I thought of Fritz Stein – a former District Board member from Belle Glade and all around good guy.
The traffic was light and the weather was beautiful. Before long I was riding along US 27/SR 80 with the big dike/dam to my right. The site of the 1928 breach and untold deaths. Along this stretch the ground level is the lowest of the entire lake’s perimeter; the Lake’s water level that day was a foot or two above ground level, which has subsided more than 6 feet since records began decades ago due to the drainage canals and ag practices. Around the rest of the Lake, the actual lake level is below the surrounding ground level.
Soon I was in Clewiston where the banners were hung announcing the upcoming Sugar Festival (today through Sunday). I thought of the many good folks who worry about the State purchasing US Sugar lands with the purported 12,000 people who would be out of a job – the folks that get angry at the estuary folks – and wonder who they turned their anger toward when US Sugar announced they had struck a voluntary deal to sell the land to Gov. Crist. What a missed opportunity, and to think the Legislature and Gov. didn’t go through with the deal – likely out of spite towards Gov. Crist – they didn’t want anything to do with extending his legacy. Deplorable. I put that out of my mind as I rode through Clewiston – a lovely little town.
Before long I was in Moore Haven and thought about the big history of that small town – the early Indian canal excavations, the early dredging/draining activity of Hamilton Disston connecting the big lake to the Caloosahatchee, the farming community, the devastating hurricanes and the Lone Cypress Tree which has stood as a sentinel along the Caloosahatchee Canal since the days of Disston. The Lone Cypress Tree! I have always wanted to find that tree! So I rode around till I found it along the banks of the river/canal. It was beginning to send out the bright green needles and was remarkable in its majesty!
A few more miles on US 27 and I turned north onto SR 78 – a pleasant ride along the west side of the Lake. Pretty soon the road drops onto the floodplain of Fisheating Creek – the only unregulated tributary feeding Lake Okeechobee. I was reminded how the flows into the Lake from Fisheating Creek increased 6-fold this dry season compared to last year. All along the west side of the Lake are small mobile home and RV communities enjoying the good life!
Before long I crossed the Kissimmee River and was into the south side of Okeechobee. White pelicans ushered me along the road lined with hotels filled with seasonal fishermen and women. On around the lake and passing J&R Fish camp – busy with Sunday afternoon bikers. Many days I’ve enjoyed the free hot dogs and music. Before long I passed alongside of the FP&L cooling reservoir – site of the levee failure that occurred just before midnight in October 30, 1979.
Then I crested the bridge over the C-44 Canal with Port Mayaca off to the right. The calm water belied the massive and destructive discharges that were occurring, sending tons of sediment, algae and nutrients on their way to the troubled St. Lucie River and Estuary.
A quick turn back to the east onto SR 76, past DuPuis (my favorite public land to hike), past the sod and cane fields where once there was citrus and before long I parked the bike in the garage – it was a good ride.
The attached photo of me on the motorcycle was taken on a post card perfect day in 2009 at Port Mayaca – the wind was calm, the Lake was still and the air was so clear you could see all the way across to Moore Have, some 30 miles to the southwest! I love how the water and sky blend together on the horizon.
After reading Gary’s account I kept thinking about that lone cypress standing like a sentinel as all has changed around it… I wrote my mother to see what she had in her history files. She sent the following four postcards from her historic collection:
We should all go ride and see it and make post cards or Facebook posts of our own!
Florida is like Africa. We have a wet season and a dry season. This dry season has been very wet!
In today’s blog, I will share the most recent update by Dr Gary Goforth sent to Martin County on 3-13-15 entitled: “Summary of Dry Season Flows, November 1, 2015 – February 29, 2016.” Dr Goforth gives a summary and provides wonderful visuals. The “pages” he mentions in his summary for this post have been converted to slides. (Please view slides from left to right.)
Thank you Dr Goforth. (http://garygoforth.net)
Are are an integral part in helping us understand why we must sent the water south…
Thought you might be interested in this comparison of dry season inflows to, and discharges from, Lake Okeechobee. Inflows to the Lake were 79% higher this dry season (Nov. 1 2015 – February 29, 2016) compared to a year ago, but Lake discharges have only been 1% higher due to the inability to send water south. Hence Lake stages have increased more than a foot above the level it was at this time last year.
The basins with the biggest increases in Lake inflows are those along the north and northwest shores of the Lake – but not the Upper Kissimmee, which exhibited a 50% reduction in flows to the Lake compared to last year.
As we’ve seen, because of the heavy rains south of the Lake and the agencies delay in moving water out of the Water Conservation Areas, WCAs, the estuaries have taken the brunt of Lake releases this year.
The flow estimates on the first 5 pages are in acre feet and in billion gallons on the second 5 pages.
Dr Gary Goforth has been kind enough to update his “Flows South Comparison”report. I posted his previous one just this week on 2-22-16. His most recent comparison is included below in slide format. Please click on the slides to enlarge and view information.
The numbers are staggering.
At this point, more than 171,000 acre feet (55.99 billion gallons) of Lake Okeechobee water (blackwater) has been dumped to the river/estuary during just the first 26 days of the 2016 Lake releases; this is equal to 41% of the entire 2013 releases and 16% of the 1997/98 El Nino event. …
We are in for a very difficult, long year of discharges for our St Lucie River/Indian River Lagoon; and they have more than likely “just begun.” We must remain updated, educated, and vocal —and documenting–take photos share what you see. Last night I was told there are dead fish in the area of Sailfish Marina. If you see such a thing take a photo and post it or send it to me with location etc….(firstname.lastname@example.org) Also continue contacting our state and federal partners and advocating that land be purchased south of the lake to offset these type of events. We shall and are turning this Titanic.
Today I am sharing in full Dr Gary Goforth’s ( http://garygoforth.net/resume.htm) note and summary of Lake Okeechobee releases for 2016 compared to 2013 and the last big El Nino event (1997-1998) as presented to Martin County. Please click on slides for larger view and thank you Dr Goforth for helping us with the numbers.
From the desk of Dr Gary Goforth regarding slide presentation:
1. More than 113,000 acre feet (36.9 billion gallons) of Lake water (“blackwater”) has been dumped to the River/Estuary during the first 20 days of the 2016 Lake releases; this is equal to 27% of the entire 147-day 2013 event, and 11% of the 1998 event.
2. The 2016 average daily rate of Lake releases is slightly less than the average 1998 rate, and more than twice the 2013 rate.
3. A distinguishing feature of the 2016 event is exceptionally high rates of C-44 Basin runoff in combination with the high Lake releases.
4. The 2016 average daily C-44 Basin runoff rate is 4 times the runoff rate of 1998, and more than twice the 2013 rate.
5. The 2016 average daily rate of combined flows through S-80 is more than the 1998 rate, and more than twice the 2013 rate.
6. The 2016 maximum daily rate of combined flows through S-80 is less than the 1998 maximum flow, but more than the 2013 maximum flow.
7. The 2016 Lake releases have already contributed more than twice the annual TMDL for phosphorus and nitrogen.
2016 data are preliminary and subject to revision.
I was on the IRL yesterday and travelled from the St. Lucie Inlet to the Ft. Pierce inlet – I saw no pockets of clear water and visibility was only 6 inches – 18 inches. I can’t imagine the sea grasses are getting any sunlight; I certainly didn’t see any sea grasses from the surface.
Notes: 1. More than 113,000 acre feet (36.9 billion gallons) of Lake water (“blackwater”) has been dumped to the River/Estuary during the first 20 days of the 2016 Lake releases; this is equal to 27% of the entire 2013 releases, and 11% of the 1997-1998 event. 2. The 2016 average daily rate of Lake releases is slightly less than the average 1998 rate, and more than twice the 2013 rate. 3. The 2016 average daily C-44 Basin runoff rate is 4 times the runoff rate of 1998, and more than twice the 2013 rate. 4. The 2016 average daily rate of combined flows through S-80 is more than the 1998 rate, and more than twice the 2013 rate. 5. The 2016 maximum daily rate of combined flows through S-80 is less than the 1998 maximum flow, but more than the 2013 maximum flow. 6. The 2016 Lake releases have contributed more than twice the annual TMDL for phosphorus and nitrogen. 7. 2016 data are preliminary and subject to revision.
Today’s blog will feature a common sense question. The question is basically why isn’t the dumping into the St Lucie River/Indian River Lagoon being alleviated by the large canals south of Lake Okeechobee, specifically the Miami and New River? Those two rivers were used before for drainage before our St Lucie canal was even constructed. The Miami River naturally had rapids before they were blown up with dynamite…Mother Nature had her way of dealing with the some of the spillover waters of Lake Okeechobee. Why aren’t we following that model?
I think a recent exchange between my brother Todd and Dr Gary Goforth gives insight into this question. I learned from it and the conversation is not yet over, thus I am posting it today.
By the way, just in case you don’t know, “S” means “structure” for water releases…. There are hundreds of structures that allow water to drain Lake Okeechobee and thus South Florida. The SFWMD deals with the structures south of the lake and the ACOE deals with the larger structures that go east west to the our northern estuaries.
Here we go:
“Right now… I am looking at the status map asking: “Why are the WCAs rising while very little water, if any, seems to go out to the New River (S-34) and the Miami River (S-31), which are historical tributaries of the Everglades (they even had rapids!) ?— all while we are getting dumped on because the Water Conservation Areas (WCAs) are over schedule?”
Recently, S-34 flowing into the New River was at 0 cfs. Now I see that it is at 233 cfs. A drop in the bucket compared to the 7523 cfs that has been hitting the St. Lucie for days.
That S-333 doesn’t seem to flow to the Park but instead to the Miami River also. (Someone correct me if I am wrong.) It was at 0 cfs on the 4th and is now at 1200 cfs. Even if that water isn’t going to the Park, at least it is going south and not east/west – but why the wait? The system is more complex than we will ever understand but the more we understand the better. Thank you, Gary, Mark Perry and others for keeping everyone informed.
Todd – you’re absolutely correct – the New River and Miami Canal were historical tributaries of the Everglades.
“Why are the WCAs rising while very little water, if any, seems to go out to the New River (S-34) and the Miami River (S-31)?”
The short answer is that flood protection for the suburbs of Ft. Lauderdale and Miami takes precedence over conveyance of floodwaters from the water conservation areas. The intervening canals are operated to provide flood protection to the urban areas between S-31/S-34 and the tidal structures (S-26/ – similar to S-80 in the C-44). When heavy rains occur in the suburbs, the canal capacity is primarily devoted to moving the stormwater out of the basin. After the storm events and water levels in the canals subside, S-31 and S-34 can be opened to move so-called “regulatory releases” out of the water conservation areas. This is similar (although not exact) to how S-308/S-80 and the C-44 Canal is operated – flood protection of the local basin takes precedence over Lake releases.
“why the wait?”
Opening S-333 allows water from WCA-3 to move into the Tamiami Canal (aka L-29 Canal); the one-mile bridge along Tamimi Trail allows water from the Tamiami Canal to enter Northeast Shark River Slough (see the map). S-333 couldn’t open without special authorization from the Corps to allow the water level in L-29 Canal to rise, which Gov. Scott requested in his letter last week, and the corps granted this week.
Interesting to think about…maybe there is more to explore here….
Our St Lucie River/Indian River Lagoon is again being destroyed by too much fresh, dirty, water….
Why is it so hard to send this water south?
It is “so hard to move water south” because the state of Florida has been compartmentalized to protect the Everglades Agricultural Area south of Lake Okeechobee and to keep-dry much of the lands that we live on. And now our waters are polluted…
Imagine, if you would, what would be going on here in South Florida now if modern man had never “conquered” it….Basically it would be a clean free-flowing marsh all the way from Shingle Creek in Orlando through Lake Okeechobee to the Everglades.
Well that it is no longer the case, is it? Since the 1920s, and more so since the 1940s, these lands have been drained, and diked, and altered, so that humans can grow food, and live here –inadvertently polluting the system. It is an imperfect situation and we must try to understand it, so we can make it better as we all need clean water.
So for the everyday person trying to figure out “what is going on” right now, let’s take a look at “today:”
It has been raining lot. Since the end of January, the St Lucie River/Indian River Lagoon and Caloosahatchee are being destroyed once again as the state of Florida and the U.S. Army Corp of Engineers dump incoming waters out of Lake Okeechobee so that the Everglades Agricultural Area south of the lake and surrounding communities are not flooded. Drainage and property in our area is part of this too.
A rare situation occurred this past week where Florida’s governor, Rick Scott, issued an order to release water south through a canal into the Everglades. He had to confer with the US ACOE to do this. (Due to poor water quality and safety, just “sending water south” is not allowed. But now with so much water, it is an emergency.)
The Water Conservation Areas south of the EAA, —these gigantic areas (see bottom slide) that are considered part of the Everglades and full of wildlife and in some places sacred Native American tree islands, are so full of water that they have to be dumped first. If they are lowered, then more water can enter from the Everglades Agricultural Area and hopefully Lake Okeechobee itself. Then, and only then, would there be less dumping into the St Lucie River/IRL and Caloosahatchee. We have a long way to go and its not even “rainy season.”
I commend all those working hard to alleviate the overflowing system and I encourage investment in working to improve this relic as well as investment in the children who must be part of the goal to re-plumb this system. Dr Gary Goforth shows us how it is working right now as I asked for a simple explanation to share with the River Kidz.
Due to increased stormwater pumping from the EAA and surrounding areas and direct rainfall, the water levels in the WCAs are too high. Last week the Gov. sent a letter to the Corps requesting authorization to raise water levels in the Tamiami Canal allowing increased flows into the Park through Northeast Shark River Slough. Yesterday the District began making those increased discharges through structure S-333. Whether or not the District will send additional Lake water south is yet to be seen – lowering the stage in the WCAs should help. See the map above. (from page 2 of the attached).”
FOR IMMEDIATE RELEASE
February 11, 2016
CONTACT: GOVERNOR’S PRESS OFFICE
DEP and FWC Issue Orders to Allow Army Corps of Engineers to Ease Effects of Flooding
TALLAHASSEE, Fla. – Today, the Florida Department of Environmental Protection (DEP) and the Florida Fish and Wildlife Conservation Commission (FWC) issued orders that will allow the U.S. Army Corps to move more water south through Shark River Slough to ease the effects of flooding in South Florida. Click HERE (http://www.flgov.com/wp-content/uploads/pdfs/FFWCC.pdf)
to see the orders.
Earlier today, Governor Scott sent a letter to the U.S. Army Corps of Engineers to take immediate action to relieve the flooding of the Everglades Water Conservation Areas and the releases of water from Lake Okeechobee to the Caloosahatchee and St. Lucie Estuaries. To read the letter, click HERE (http://www.flgov.com/wp-content/uploads/2016/02/2.11.161.pdf).
Simply click on the image above to view 1980-2015. Numbers showing Lake Okeechobee and C-44 Basin flow rates and pollutants into the St Lucie River/Indian River Lagoon as presented by Dr Gary Goforth in his letter to Martin County dated February 9th, 2016.
This letter indeed helped the Martin County Commission decide to call a State of Emergency and perhaps Senator Joe Negron shared it with the Governor as well, inspiring the Governors’ call to the Asst. Secretary of the Army Corp of Engineers to “stop the discharges.” Great requests.
It would probably be easier for the ACOE to achieve such with some significant land south of the lake…..
The state knows it. The federal government knows it. We all know it. The St Lucie River/Indian River Lagoon have been sacrificed —–not for the common good, but for the interests of agriculture and development.
It is “death by the numbers” and it should stop.
Excerpt from Dr Gary Goforth letter to Martin County, 2-9-16.:
1. The intentional destructive Lake releases knowingly cause environmental and economic damage to the region; the State of Florida and US government intentionally cause these by sacrificing our region in order to protect the area south of the Lake, and should therefore, the Lake releases should be considered Emergency Operations. The BOCC should declare a State of Emergency and ask the State/feds to do the same. This may free up funds to help the region’s businesses and residents that will suffer losses as a result of the discharges.
2. In addition to water, the Lake releases carry significant amount of pollution and sediment/muck – the amount of nitrogen from the Lake over the next few months will likely dwarf the amount coming from septic tanks, and greatly exceed the TMDLs for nitrogen and phosphorus.
3. We can’t forget that the River & Estuary also receive local basin runoff in addition to Lake releases, so the Lake releases are destructive above and beyond impacts from local runoff. The “local” watershed is more than twice the natural drainage due to addition of C-23, C-24, C-25 and C-44 Canals.
4. The BOCC should ask the State and Corps to stop the releases immediately. They should ask that inflows to the Lake be reduced, that the Kissimmee Chain of Lakes be operated per their regulation schedules and NOT FOR USFWS purposes, that Holey Land and Rotenberger be used to the maximum safe depth (temporarily exceeding their 0-1 ft operating schedules), that the STAs receive as much Lake water as possible – based on hydraulic not water quality criteria, allow the WCAs to temporarily be operated above the regulation schedules up to maximum safe depths to allow Lake inflows, and that the District temporarily put water on as many public lands (e.g., a portion of DuPuis) as dispersed water management.
This week we will take a look back at Lake Okeechobee, a lake that since 1923–via the C-44 canal, has been connected to the St Lucie River/Indian River Lagoon.
Information for these posts is made possible through a book entitled “Environments of South Florida–Past and Present,” by Patrick J. Gleason. This text was lent to me by Dr Gary Goforth. I will transcribe portions of this rare and amazing text in order for us to contemplate the changes that have occurred and how those who first documented this once remote area experienced our region.
It continues to amaze me—the ability of the early map makers and surveyors who functioned without today’s technology.
For me it is noteworthy to notice how the original map of the lake “veers off to the south-east.” Looking below one can see that today this area is today’s Bell Glade and South Bay. These lands are the richest in “black gold” as they have the accumulation of thousands of years of muck. Now we can see why. Tremendous amounts of sugar and vegetable products are produced in this area. Also, I believe these lands are most valuable because they are less likely to freeze due to their proximity to the lake.
As we can see, although we must take the Captain’s map with a grain of salt–interestingly enough—this area was once the lake…
Here are the words of Captain Backus for us to ponder as I transcribe:
In 1838 map produced by Captain E. Backus had produced a map of Lake Okeechobee, which for a long time remained buried in the national archives records of the Seminole War. It reveals the knowledge of the lake that time, and his version of the lower Kissimmee River shows graphically how that crooked meandering stream flowed thirty-five miles from Fort Basinger to reach the lake only eighteen miles away– as the crow flies… In a brief statement in the lower left portion of the map, Captain Backus writes: “Many small streams flow into the Okee-cho–bee on the North-East and West side and also on the South- East side, but it is not known that it has any outlet, and probably has none, except at the high water when Grassy Lake (The Everglades) and Okee-cho-bee are united, and probably empties thought some streams into the Atlantic. This is corroborated by the statements of different indians and negroes who profess to have crossed from one side to the other in a canoe at high-water, and to have carried and dragged a canoe many miles over the portage at low tide.”
I wonder how we would have seen the lake had we been there? Would you have crossed it in a canoe? What would you have dreamt it to become?
There are only a handful of people who are qualified to help us navigate the turbulent and murky waters of Lake Okeechobee and its effects on our beloved St Lucie River/Indian River Lagoon….
One of these rare individuals is Dr Gary Goforth. “Gary” has more than 30 years of experience in water resources engineering, encompassing strategic planning, design, permitting, construction, operation and program management.
For the last 25 years, his focus has been on large-scale environmental restoration programs in the Kissimmee-Okeechobee-Everglades ecosystem. He was the Chief Consulting Engineer during the design, construction and operation of the $700 million Everglades Construction Project, containing over 41,000 acres of constructed wetlands.
With all this experience Gary spends a tremendous amount of time at River Coalition and SFWMD meetings, and with every day people, advocating to local, state, and national officials telling the story in a manner that the average person can understand but with the power and expertise of a scientist.
Dr Goforth teaches us that we CAN HOLD THE ACOE, AND ESPECIALLY THE SOUTH FLORIDA WATER MANAGEMENT DISTRICT ACCOUNTABLE.
We can ask such questions as “are you sending the maximum practicable amount of water south?” “Is it 28% more than in 1994 as required by the Everglades Forever Act?” ” Is an average per year of 250,000 acre feet going south from the lake to the Everglades as required by the Everglades Forever Act?” “Are the Storm Water Treatment Areas being used to full capacity?” “Is the truth of the destruction of the estuaries being reported?” “Should 2008 LORS, Lake Okeechobee Regulation Schedule, been revised?” “Should the Everglades Settlement’s Q-Bell (limit of Phosphorus) be reviewed-is it realistic?” “Is a large reservoir being created in the Everglades Agricultural Area as is called for in the Central Everglades Restoration Plan?” “Who are the Lake and the STAs really serving?”
In order to hold the agencies accountable we must be educated! We must ask questions. We must look at the figures for water flowing south of the lake every year and compare.
Dr Goforth provides regular public updates on these issues, directly and indirectly holding the fire to the agencies. Today I am publishing in full his DRAFT–WET SEASON 2015 LAKE DISCHARGE report.
Please read it, study it, familiarize yourself with it. Dr Goforth has a website if you have any questions. Thank you Dr Goforth for the gift of shared knowledge. It is the greatest gift of all.
Draft – Wet Season 2015 Lake Discharges by Dr Gary Goforth:
Goforth – December 18, 2015
Flows into and out of Lake Okeechobee were examined for the period May 1, 2015 – October 31, 2015, corresponding to the first half of the annual water year (May 2015 to April 2016), and roughly corresponding to the south Florida wet season. The flows and associated Lake water levels were compared to same period from last year. In light of the influence of the current strong El Nino, Lake water levels were compared to the levels that occurred during May- November 1997 which preceded over 1 million acre feet (347 billion gallons) of destructive Lake releases to the St. Lucie Estuary between December 1997 and May 1998.
Flows into Lake Okeechobee – excluding rainfall. For the period May 1 to October 31, 2015, surface inflows to Lake Okeechobee amounted to 1.43 million acre feet (466 billion gallons) (Table 1). This is 20 percent less than for the same period in 2014 (Table 2 and Figure 1).
Flows out of Lake Okeechobee – excluding evapotranspiration. For the period May 1 to October 31, 2015, surface outflows from Lake Okeechobee amounted to 780,000 acre feet (254 billion gallons) (Table 3). This is 37 percent more than for the same period in 2014 (Table 4 and Figure 2). Approximately 30 percent more Lake water was sent to the EAA and L-8 Canals during 2015 than 2014, likely in response to higher water supply demands (due to lower rainfall than in 2014).
Lake Okeechobee water levels. The level of Lake Okeechobee varied from 13.81 ft on May 1 to 14.55 ft on October 31, 2015, reaching a low level of 11.96 ft on July 16 (Figure 3). For 2014, the level of Lake Okeechobee varied from 13.07 ft on May 1 to 15.85 ft on October 31, reaching a low level of 12.32 ft on June 11. Lake water levels rose only 0.74 feet during the 2015 wet season compared with a rise of 2.78 ft during the same period in 2014. The Lake level on October 31, 2015 was approximately 1.3 ft lower than it was a year earlier, and approximately 0.5 ft lower than October 31, 1997 (Figure 4). In addition, the Lake level on November 30, 2015 was approximately 1 ft lower than it was on November 30, 1997, which preceded over 1 million acre feet (347 billion gallons) of destructive Lake releases to the St. Lucie Estuary between December 1997 and May 1998. Two important differences between 1997 and today that could influence Lake discharges to the estuary include rainfall over the Lake Okeechobee watershed and the regulation schedules governing Lake operations. According to the South Florida Water Management District (District), November 2015 was the wettest November since 1998, indicating inflows to the Lake over the next month may be substantially larger than average. Additionally, the Lake is currently operated under the LORS2008 schedule which was anticipated to result in increased frequency and magnitude of Lake releases to the estuaries compared to the regulation schedule in place during 1997-1998.
Lake flows to the STAs. Beginning in August 2015, the District began operating the EAA A-1 Flow Equalization Basin (FEB), which is approximately 15,000 acres in size and can store water up to 4 feet deep. The FEB can receive Lake releases and EAA runoff, and distribute flows either to STA-2, STA-3/4 or to the EAA for irrigation. At this time incomplete flow records are available to the public through the District’s DBHYDRO database to fully account for the various flow paths, and until additional data are available, the estimates of Lake releases and runoff to STA-2 and STA-3/4 will be subject to revision. Using these preliminary estimates, approximately 13 percent less Lake water has been sent to the STAs in 2015 compared with 2014 (Figures 5 and 6 and Table 5). During the same period, approximately 32 percent less basin runoff was sent to the STAs, reflecting less wet season rainfall in 2015.
Flows to the estuaries. Lower rainfall in 2015 resulted in less basin runoff to the estuaries for the period May to October than occurred in 2014 (Table 6). However, due to the Lake releases that occurred during January through May 2015, Lake discharges to the estuaries in 2015 far exceeded Lake releases during 2014.
SUMMARY. Lower rainfall during the May to October 2015 period resulted in about 20 percent less inflows to Lake Okeechobee than in 2014. However, outflows from the Lake increased compared to 2014, likely in response to higher water supply demands (due to lower rainfall than in 2014). Lake water levels rose only 0.74 feet during the 2015 wet season compared with a rise of 2.78 ft during the same period in 2014. The Lake level at the end of October 2015 was about 1.3 ft lower than in 2014. In addition, the Lake level on November 30, 2015 was approximately 1 ft lower than it was on the same date on November 30, 1997, which preceded over 1 million acre feet (347 billion gallons) of destructive Lake releases to the St. Lucie Estuary between December 1997 and May 1998. However, differences in rainfall and Lake regulation schedules prevent a forecast of potential 2016 Lake discharges compared to the 1997-1998 discharges to the estuaries based on Lake levels at the end of November.
Today I would like to briefly remember 1997 and 1998 and recall why this year is so important to our St Lucie River/Indian River Lagoon history. I would also like to note for some who may not know why these years are being brought back into the ACOE/SFWMD discussion this year.
Today’s slide is complements of a recent document shared by our friend, Dr Gary Goforth. (http://garygoforth.net) “Draft – Wet Season 2015 Lake Discharges – December 9, 2015.” This slide shows that Lake Okeechobee today is lower than it was in 1997.
Why is Dr Goforth comparing 1997? He is comparing 1997 because in 1997-98 there was a strong El Nino (rainy winter), just as we are experiencing right now in 2015/2016.
Certainly we have all noticed how much it is raining this winter so far!
The difference as far a Lake O management in 1997-98 was that there was no”LORS” schedule then….The 2008 LORS or “Lake Okeechobee Release Schedule” did not go into place until 2008 so prior to that year the lake was allowed to be over a foot higher. Since 2008, the lake is required to be lower because of work and safety issues on the Herbert Hoover Dike.
It is important that as we move forward to also look back. We must remember what happened in 1997-98, a similar El Nino to what is happening right now…. 1997-98 were not good years for the river…So much water was released into the St Lucie River/Indian River Lagoon in 1997-1998 that there were more reported fish lessons than ever before– due to too much and too long of exposure to fresh water. This is also why, in 1998,the Rivers Coalition was born. (http://riverscoalition.org)
When Miccosukee Tribe member, Houston Cypress, recently informed me that I needed to prepare a “Pecha Kucha” for the “Rights of Water” symposium at Love the Everglades August 22, 2015, I was amiss.
“What’s Pecha Kucha? Or was that Pechu Kuchu? Pecha, what? ” I inquired, thinking it must be a Native American term.
Houston calmly replied:
“It is Japanese for “chit-chat,” Jacqui. It consist of 20 slides in power point format that run only 20 seconds each” It keeps presentations interesting and succinct. Pecha Kuchas are now a popular format all over the world.”
“Wow, that’s cool,” I replied.” Thinking to myself, “The Miccosukee—near Miami–ahead of the game—I live in Stuart, 30 years behind the curve….Hmmm? I’ll act like I get it….”
“This should be easy.” ….I said to Houston. “20 seconds, 20 slides? Sure! Count me in!”
The weeks went by and I realized, well, I was wrong! The fast-moving slides force a familiarly and adaptability that I had never before adjusted to while speaking. Practice took on a new meaning because you really couldn’t. You just had to know your subject. “Live” became the theme.
I was terrified and realized I could not look at notes or do what I usually do when I speak, especially in an unfamiliar place. My husband, Ed watched me sweat and stumble trying to prepare. Scratching my plan altogether at least twice. He smiled just telling me to “look it over….”My slides that is…
“PechaKucha Night,” now in over 800 cities, according to their web site, was devised in Tokyo in February 2003 as an event for young designers to meet, network, and show their work in public.
Today I will share my attempt of a Pecha Kucha for the St Lucie River/Indian River Lagoon at the Miccosukee’s “Love the Everglades Conference “and the RIGHTS OF WATER 2015. Thank you to Ed for helping me prepare; thank you to videographer, activist, and friend, Kenny Hinkle, for his finesse in taping this experience. Also thank you to those whose photographs and maps I used in my presentation and help me all the time: Joh Whiticar, Dr Gary Goforth, Ed Lippisch, Sandra Thurlow, Nic Mader and the River Kidz, Julia Kelly, Sevin Bullwinkle, Val Martin, and Greg Braun. The slides are below.
Last, thank you most of all to Houston Cypress and the Miccosukee Tribe of South Florida for the opportunity to grow and to share, because from what I am learning, getting out of one’s comfort zone is where it all begins as we continue “our war” of which we too, “will never surrender” —St Lucie River/Indian River Lagoon.
There are over 2000 miles of canals draining precious fresh water off South Florida; it’s a good idea to know the main ones. I started thinking about this after going through some old files and finding this awesome 1909 Map Dr Gary Goforth shared with me showing a plan in 1909 to drain the Everglades and Lake Okeechobee WITHOUT killing the St Lucie River/Indian River Lagoon.
Well as they say: “The rest is history….” As we know, the C-44, or St Lucie Canal, was later built.
So when I was looking on-line for a good map to show the canals of South Florida today to compare to Gary’s canal map of 1909, believe it or not, I could not find one! One that was well labeled anyway. So I made my own.
It’s pretty “home-school” but its readable. From left to right, below, you will see canals Caloosahatchee, (C-43); Miami, (L-23); New River, (L-18); Hillsboro, (L-15); West Palm Beach, (L-12); L-8 that never got a name as far as I am aware; and St Lucie, (C-44.) I do not know why some are labeled “C” and others are “L,” but you can follow them to see where they dump.
I believe the first two built were the Miami and the New River— by 1911, as I often see those two on historic maps prior to 1920. Today our state canal plumbing system is outdated and wasteful sending on average over 1.7 billion gallons of fresh water to tide (to the ocean) every day. (Mark Perry, Florida Oceanographic.)
Even though I grew up in Stuart, I was never really taught about the canals. As a young adult and even older, I drove around for years not knowing about these canals and others like C-23, C-24, and C-25. If I “saw” them, I did not “recognize” them. I knew the land had been “drained” but really had no conception of what that meant or the extent thereof…
I remember my mom used to say if we were driving around in Ft Pierce in the 80s, “And to think there used to be inches of water covering all this land at certain times of the year….” I just stared at her but didn’t really “get it.” The pine trees flashed by and it seemed “impossible” what she was saying…
In any case, the young people today should be learning in detail about these canals so they can be “updated,” “refreshed,” “reworked,” and “replugged.” Say “no” to old-fashioned canals, and “hello” to a new and better South Florida!
Below is a history of the South Florida canals as written in an email to me by Dr Gary Goforth. It is very enlightening. Thanks Gary!
As you know, plans to manage the level of Lake Okeechobee (by discharging to tide) in order to develop and protect the agricultural lands south of the lake were developed before 1850 and evolved through the mid-1950s.
1. Buckingham Smith, Esq. in 1848 proposed connecting the Lake with the Loxahatchee River and/or the San Lucia (report to the Sec. of the US Treasury; copy available).
2. In 1905, Gov. Broward rejected a proposal to lower the Lake with a new canal connecting to the St. Lucie River.
3. Attached is a 1909 map of South Florida from the 1909 State of Florida report “Report on the Drainage of the Everglades of Florida, By J. O. Wright, Supervising Drainage Engineer”. The importance of this map and report is the recommendation to manage the water level in Lake Okeechobee via drainage into multiple canals from the Lake to the Atlantic Ocean – but NOT the St. Lucie Canal. The primary canal for moving Lake water to the Atlantic was to be the Hillsboro Canal which would connect the Lake to the Hillsboro River in present day Deerfield Beach / Boca Raton. Note the recommendation is to construct what is now called the “West Palm Beach Canal” and route Lake water into the Loxahatchee River and then out to the ocean via the Jupiter Inlet – this is actually being accomplished as part of CERP and the Loxahatchee River restoration program.
4. In 1913, the State accepted the recommendation of an NY engineer (Isham Randolph) to construct a canal connecting the Lake to the St. Lucie River (report available). The Everglades Drainage District was formed the same year, and was responsible for the construction of the canal and associated locks/water control gates. (historical construction photos available). Construction lasted from May 1915 through 1924, and the first Lake discharges to the St. Lucie occurred June 15, 1923 (ref: Nat Osborn Master’s thesis 2012, copy available)
5. After the 1928 hurricane, the State asked for and received federal assistance. The canal was enlarged by 1938; new St. Lucie Locks was rebuilt in 1941; the new spillway was constructed in 1944. —Dr Gary Goforth (http://garygoforth.net)
Today I will try to provide some insights for every day people trying to figure out what a basin management action plan is, why we have one, and how we are doing so far….
Before we begin, we must first note that in 2002 the state of Florida declared the St Lucie River “impaired.” Impaired as in “its health”— with too much nitrogen and phosphorus and other pollutants from fertilizer and other sources that run off agricultural and developed lands…If you want, you can read the 2002 report below.
Today we hear more about BMAPs (Basin Management Action Plans) and TMDLS (Total Maximum Daily Loads) than the original impairment report, but we must be aware that the only reason we have a BMAP is because the river is “impaired.” A BMAP is put in place by the state to “fix” impaired water bodies.
Our Martin County/St Lucie St Lucie River (SLR) impairment is compounded by the fact that the watershed has been heavily altered over the past 100 years. The Everglades Agricultural Area (EAA) south of Lake Okeechobee blocks the natural flow of Lake O. water going south to the Everglades; therefore the “overflow” waters of Lake Okeechobee are released into the St Lucie.
On top of that are canals C-23, C-24, C-25 that go way out west expanding the St Lucie River’s basin, draining parts of Okeechobee and St Lucie counties and even waters of the St John’s River that used to go north once located near Vero! Road runoff, marinas, agriculture, our yards, tributaries, non-functioning septic tanks, and other things all add up to create a pollution cocktail encouraging toxic algae blooms that kill seagrasses and wildlife and lower our property values for the entire area.
According to the St Lucie River Initiative our canals expanded the “flow” into the St Lucie River by as much as five times what Nature intended. See map below. The BMAP doesn’t really deal with this problem; it does not try to reroute these canals, it rather tries to “better the situation” we are in now as far as water inputs.
So with that in mind, let’s get back to the state of Florida’s created Basin Management Action Plans implementing “total maximum daily loads” (TMDLs) for nitrogen and phosphorus. “Everyone” is part of lowering their loads to the river through building projects that help lower loads and implementing Best Management Practices for fertilizer etc…. Everyone in the basin that is. (Not Lake O- They have their own plan). Not everyone is an equal polluter but everyone tries to lower their load.
The stakeholders agreeing to do projects and implement Best Management Practices to lower their inputs are:
City of Fort Pierce
City of Port St. Lucie
City of Stuart
Hobe St. Lucie Conservancy District
North St. Lucie River Water Control District (NSLRWCD) 10
Pal Mar WCD
St. Lucie County
Town of Sewall’s Point
These stakeholders work together with the help of DEP, the Department of Environmental Protection, and others to lower their measured inputs of Nitrogen and Phosphorus into the river over a period of fifteen years, in five-year increments beginning in 2013. The draft report now is just reviewing the first two years of the first five years. We have a long way to go….
This slide of the summary report provides some overall insights. You can see the load originally compared to now and how far they have to go together to achieve the first increment.
1.1 Summary of Accomplishments
Table 3 summarizes the projects completed during the second annual BMAP reporting period. These resulted in an estimated reduction of 118,163.3 lbs/yr of TN and 26,998.8 lbs/yr of TP. The reductions are in addition to those projects given credit before BMAP adoption. Therefore, the total reductions to date are 595,952.0 lbs/yr of TN and 157,540.8 lbs/yr of TP, which are greater than the required reductions in the first BMAP iteration of 316,024.2 lbs/yr of TN and 121,250 lbs/yr of TP. These reductions, in addition to those shown as completed in the BMAP, are 56.6% of the required TN reductions and 39.0% of the required TP reductions of the Phase I BMAP.
The progress towards the TMDL TN and TP load reductions in the St. Lucie River and Estuary Basin are shown in Figure 2 and Figure 3, respectively. The first bar in these figures shows the baseline load for stormwater runoff. The second bar shows the current estimated loading with the implementation of projects. The third bar shows the total allocation for stormwater runoff to meet the TMDLs. The line shows the target for the first BMAP iteration. (DRAFT REPORT)
So the St Lucie River BMAP is making “pretty good” progress according to the report. I imagine there is still a lot to improve. It is a process. We are learning….
These programs are definitely a major “participatory decision-making process” to be commended. I cannot imagine what it takes to coordinate this effort! It would be a nightmare actually. I rather just reroute the canals!
In closing we must note the Indian River Lagoon of which the St Lucie River is a tributary, has a BMAP, but it is for the central and northern lagoon not the southern lagoon where we are in Martin County. I don’t quite understand this. The river does not seem healthy in this area either.
*According to the Department of Environmental Protection: a BMAP is a “blueprint” for restoring impaired waters by reducing pollutant loadings to meet the allowable loadings established in a Total Maximum Daily Load (TMDL). It represents a comprehensive set of strategies–permit limits on wastewater facilities, urban and agricultural best management practices, conservation programs, financial assistance and revenue generating activities, etc.–designed to implement the pollutant reductions established by the TMDL. These broad-based plans are developed with local stakeholders–they rely on local input and local commitment–and they are adopted by Secretarial Order to be enforceable.
*Also for the first five years of the fifteen years the BMAP will take place, the stakeholders are getting extra credit because their SLR BMAP” credit includes storm water management strategies and projects that have been put in place since 2000 or will be implemented during the first five years of implementation June 2013-June 2018).”
I am adding a comment from Dr Gary Goforth to this blog post at 1:00 PM 8-13-15. I think his professional insights are helpful even to the lay person; he did attend the BMAP meeting yesterday; and he is a regular contributor to my blog. Thank you Gary. (http://garygoforth.net)
3-18-15 at 7:17 AM Gary Goforth commented on 2015 Annual Update, St Lucie River and Estuary Basin Management Action Plan, SLR/IRL
Inside cover of the Draft 2015 SLR BMAP Report. I …
I am very familiar with the TMDLs and BMAP for the St. Lucie River Basin. I attended the BMAP progress meeting yesterday along with Mark Perry and others. There were nice updates by Diane Hughes and her counterpart in St Lucie County on construction and operation of what should be good, effective projects for reducing nutrient loads to the St. Lucie River and Estuary. It is clear that local communities and others are working hard to reduce nutrient loading.
However that’s where the good news ended.
While the progress report leads the public to believe that great strides have been made by landowners in cleaning up their stormwater pollution, unfortunately the BMAP process and progress reporting is seriously flawed and present an overly optimistic assessment of the region’s water quality, and the progress made towards achieving the desired endpoint. I expressed this opinion to FDEP, FDACS and SFWMD staff at the meeting yesterday, with the following support:
1. The nutrient loading data in the progress report are not real (measured data), rather they are a combination of potential load reduction estimates superimposed on simulated data. No where in the progress report will you find the observed amount of nitrogen or phosphorus that actually entered the St. Lucie River and Estuary during 2015. As was discussed at the meeting, FDEP does not plan to bring real data into the progress reports until 2017.
a. The real data show a very different story, for example, phosphorus loading from the C-44 Basin (excluding Lake releases) has increased more than 50% from the 1996-2005 Base Period.
b. Until real data are shown, there can be no assessment of how well the BMAP program is working, and no mid-stream corrections will be made.
c. The majority of load reductions are attributed to agricultural land uses as a result of BMPs. However, FDACS and FDEP staff acknowledged that they have not yet documented the actual effectiveness of any ag BMP in the region – they repeatedly stated they were short on staff.
2. The progress report (and the BMAP) ignores the nutrient and sediment load from Lake Okeechobee discharges. In the 2015 reporting period, the assessment ignores over 400,000 pounds of nitrogen and 47,000 pounds of phosphorus that entered the River and Estuary from the Lake. And don’t expect future reports to reflect this loading – the BMAP process will continue to ignore loading from Lake Okeechobee, assuming instead that the Lake will achieve its own TMDL (another sad subject altogether).
3. The nutrient loads for the BMAP base period are not the actual loads that occurred in each of the basins – instead it is a simulated load that differs up to 25 percent from the observed load. Without an accurate base period load, true progress cannot be assessed.
I could go on for a while; I made many more suggestions how to improve the process and will follow up with written comments to the FDEP.