January 12, 2017
Akintunde O. Owosina, P.E.
Bureau Chief, Hydrology and Hydraulics
South Florida Water Management District
3301 Gun Club Road
West Palm Beach, FL 33406
Dear Mr. Owosina:
I received your January 9, 2017 letter. Given its contents and tone, I will respond immediately and then offer further dialogue on the technical issues
To begin, let me first express my profound disappointment in the vitriolic and malicious tenor of your letter – and the manner in which it was disseminated. Clearly, your agency, the South Florida Water Management District (SFWMD), is using this primarily as an attack piece, as evidenced by the nearly complete lack of specific technical information and considering this was supposed to be an engineer-to-engineer letter. After nearly two decades of working together on these issues, I would not have expected this of you. Sadly, rancorous attacks on private citizens and organizations have become common place at the SFWMD, a marked departure from its former role as an objective arbiter of fact and providing solid technical input.
None of your comments seemed particularly technical in nature. Instead, the bulk of them appear to be based on a mischaracterization of the purpose of the analysis. The preamble to our investigation makes it clear that these are not offered as optimized project proposals. Rather, we constructed three model runs to address this question: “Suppose that Components A and G of CERP were added to the existing infrastructure. What are the benefits to the estuaries?” This is a relevant question for several reasons. In the very month that toxic algae invaded the Treasure Coast as a result of Lake Okeechobee discharges, the SFWMD initiated planning for not one but two new Everglades restoration projects – proceeding with the original sequence of projects without taking into account an important legislative directive that was adopted in the Legacy Florida Act. The Legacy Florida Act signed by Governor Rick Scott directed the SFWMD to “give preference to those Everglades restoration projects that reduce harmful discharges of water from Lake Okeechobee to the St. Lucie or Caloosahatchee estuaries in a timely manner.” As a matter of public interest, it was an initial query to determine whether or not the SFWMD has a science basis for dismissing the southern reservoir and claiming that a northern reservoir is preferable based on the prioritization metric that is now codified in Florida law. It is not, as you incorrectly and unfairly portray, a substitute for a three-year planning process that the SFWMD should be undertaking.
Our fundamental finding was that both reservoirs show hydrologic benefits but of very different sorts. Most importantly, a reservoir with an outlet to the south allows for regulatory flows from Lake Okeechobee that are larger than the nominal capacity of the reservoir and outperforms a northern reservoir in that respect. We offered the evidence for that conclusion, and I stand by that conclusion. In your attack, you provide no evidence to suggest that this conclusion is not reasonable. Instead, you assert “…northern storage must be planned, funded and constructed before the full benefits of existing and planned storage features to the south can ever be realized.” (Emphasis added). You posit this with no evidence nor has the SFWMD ever provided any clear, scientifically-defensible argument to support this position, despite at least 18 months of public input asking specifically for such information.
Let me specifically address your comments:
(1) Did not consider FEB features on A-1 and A-2. As you undoubtedly know, the South Florida Water Management Model (SFWMM or 2×2 Model) has no capability to analyze water quality. Output from this model is fed into a separate water quality model. The A-1 and A-2 features are specifically designed as Flow Equalization Basins (FEBs), which are water quality features, not as reservoirs. The SFWMD intentionally conflates the role of reservoirs and FEBs, calling them both “storage.” In fact, there is a profound difference and the two are not interchangeable; you would never confuse a battery (a reservoir) with a surge protector (FEB). The SFWMD does a profound disservice by not educating the public on the role and importance of each.
(2) Did not use appropriate model. The preposterous premise that you seem to be offering is that any use of the SFWMM outside of the SFWMD is “unofficial” and, by definition, invalid. Our choice of versions was, in fact, entirely due to the obstacles the SFWMD uses to impede technical dialogue. Your implication that we manipulated code and did not utilize the “official version” of the model is disingenuous and is an irresponsible omission of fact that undermines your credibility as a scientist. We used the latest version of the model available to us with a complete CERP description. If we were to adopt your argument that not using a newer version (unavailable to us) somehow invalidates the results, then the SFWMD must repudiate all of its own work using previous versions.
(3) Did not use CERP assumptions. That is an entirely false assertion. As noted above, our analysis looked at the system as it currently operates today (using the Existing Condition Base in the model) to isolate benefits of specific reservoir projects to assure an apples-to-apples comparison could be made. Thus, we used the LORS 2008 schedule for Lake Okeechobee because it is the current regulation schedule. We used the parameters in the CERP run to describe Components A and G.
The footprint and depths for both northern and southern reservoirs are used from the CERP0 run developed by SFWMD and U.S. Army Corps of Engineers. We followed the Yellow Book description of the reservoir, specifying its 360,000 acre-ft capacity. We looked at different footprints and found that it made no difference to our conclusions. We don’t know the exact location of the reservoirs; therefore, the footprint and depth of the reservoirs, and conveyance features are preliminary assumptions. That is exactly what the SFWMD should be investigating rather than repeating baseless statements that the storage is not needed.
(4) Cannot be implemented. This criticism is, at best, the result of an utter lack of understanding of the purpose of the modeling effort, or at worst, a deliberate attempt to mischaracterize the stated purpose of our exercise. So there can be no confusion, let me reiterate the purpose of the modeling effort was to isolate and quantify benefits of two specific reservoir projects after the Legacy Florida Act’s new mandate for how Everglades restoration projects must be prioritized, an exercise we had to undertake because your agency performed no analysis whatsoever and just proceeded with the pre-Legacy Florida Integrated Delivery Schedule (IDS). Our modeling was not a substitute for the detailed engineering effort that occurs during the official planning process, a process that you would be well into had you combined the planning efforts for north and south of the lake as we recommended you do.
(5) Did not consider water quality standards. This criticism is also based on a lack of understanding or a deliberate attempt to mischaracterize the exercise we undertook. As you well know, but the public likely does not, the SFWMM is a hydrological model. It does not model water quality. It would be equally impossible for you to have assessed water quality performance using this model, and it is another example of a baseless criticism.
Nevertheless, we did, in fact, look at water quality. We chose not to add the water quality analysis to our short monograph because it required some iterative design calculations that went far beyond the simple question we asked. We certainly found nothing that supports your contention that water quality standards could not be met with an integrated reservoir/FEB/STA design, and you certainly offer no proof to support your claim.
(6) Used expanded EAA canals. You criticize our modeling for including expanded canal conveyance capacity. It is alarming that I need to remind you that the Component G description specifically includes increased conveyance capacity as part of the project, and the numbers we used came directly from the SFWMD’s full CERP 2×2 model run.
(7) Considered one metric for evaluation. You criticize our use of reduction of discharges from Lake Okeechobee to the estuaries as the metric for evaluating the projects. The Everglades Foundation did not select that metric; the Florida Legislature and Governor Scott did. If you have issue with that metric, you and the SFWMD should have raised it last year when the Legislature overwhelmingly passed the Legacy Florida Act or with the Governor before he signed it.
In summary, I respectfully disagree with your offered critique, finding it baseless. Moreover, I condemn your use of a letter completely devoid of technical specifics as a technique of intimidation. I will not remain silent and instead will increase my efforts to hold the SFWMD to a reasonable scientific standard in their public statements. As with the SFWMD comments on the recent National Academy Report, you misrepresent the premise and conclusions, and then attack the messenger. As one of the most powerful public agencies in Florida, the publicly-funded resources of the agency are better applied to educating the public on the pressing water issues facing the state.
Thomas Van Lent, Ph.D.
Vice President of Programs
 See Laws of Florida, Chapter 2016-201.
 See Central and Southern Florida Comprehensive Review Study Final Integrated Feasibility Report and Programmatic Environmental Impact Statement (USACOE, April 1999), p. 9-9.