Comprehensive Everglades Restoration Plan: Additional Water Quality
Projects May Be Needed and Could Increase Costs (Letter Report,
09/14/2000, GAO/RCED-00-235).

Pursuant to a congressional request, GAO reviewed the Army Corps of
Engineers' Comprehensive Everglades Restoration Plan.

GAO noted that: (1) the Plan provides a conceptual framework for
improving the quality, quantity, timing, and distribution of water in
the South Florida ecosystem; (2) 24 of the Plan's 66 projects are
intended, among other things, to improve the quality of water in the
natural areas of the ecosystem--the remaining projects deal more with
the water's quantity, timing, and distribution; (3) the water quality
projects in the Plan are intended to supplement the efforts of the
state, which has the primary responsibility for achieving water quality
standards in Florida; (4) under the Water Resources Development Act of
1996, the Corps is allowed to include water quality projects in the Plan
and equally share the costs with Florida if the projects are essential
to restoring the Everglades; (5) there are too many uncertainties to
estimate the number and costs of the Corps projects that will ultimately
be needed to address water quality in the ecosystem; (6) as
uncertainties related to implementing the Plan's projects are resolved
and more information is gathered about the extent of the ecosystem's
water quality problems, it is likely that modifications and additions to
the Plan will be necessary and that these changes could increase the
total cost of the Plan over the Corps' current estimate of $7.8 billion;
(7) for example, the state is determining the level of pollutants that
Lake Okeechobee can receive and what actions are needed to clean up the
lake; (8) some of the actions being considered, such as dredging the
lake to remove contaminated sediment, could cost over $1 billion; (9)
because the lake is the source of much of the water in the ecosystem,
the Corps could become involved in the effort if it determines that the
lake's cleanup is essential to the ecosystem's restoration; (10) other
efforts, such as the completion of feasibility studies for areas in the
ecosystem not covered by the Plan, could also lead to additional water
quality projects; (11) the Corps has acknowledged the level of
uncertainty in the Plan and has included a process for incorporating
project modifications and additions in its future reports to Congress;
(12) it has not, however, included a means for reporting: (a) cumulative
changes in projects and costs for the Plan as a whole; and (b) the
progress being made in implementing the Plan; and (13) such information
will be important for Congress in authorizing future projects.

--------------------------- Indexing Terms -----------------------------

 REPORTNUM:  RCED-00-235
     TITLE:  Comprehensive Everglades Restoration Plan: Additional
	     Water Quality Projects May Be Needed and Could Increase
	     Costs
      DATE:  09/14/2000
   SUBJECT:  Environmental policies
	     Federal aid to states
	     Federal/state relations
	     Strategic planning
	     Water resources conservation
	     Water pollution control
IDENTIFIER:  South Florida Ecosystem Restoration Initiative
	     Everglades National Park (FL)
	     Army Corps of Engineers Comprehensive Everglades
	     Restoration Plan
	     Lake Okeechobee (FL)
	     South Florida Water Quality Protection Program

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GAO/RCED-00-235

Appendix I: Description of the Major Types of Projects
Included in the Corps' Comprehensive Everglades Restoration Plan

34

Appendix II: Florida's Initiatives to Specifically Address
Water Quality in the South Florida Ecosystem

36

Appendix III: Comments From the State of Florida

44

Appendix IV: GAO Contact and Staff Acknowledgments

49

Figure 1: Relationship of Federal and State Agencies and
Tribes Involved in Implementing the Plan to
Improve Water Quality in the South Florida Ecosystem 11

Figure 2: Location of the Plan's Water Quality Projects 15

Figure 3: Location of Everglades Construction Project Stormwater Treatment
Areas 39

EPA Environmental Protection Agency

GAO General Accounting Office

RCED Resources, Community, and Economic Development Division

Resources, Community, and
Economic Development Division

B-285227

September 14, 2000

The Honorable George V. Voinovich
Chairman, Subcommittee on Transportation
and Infrastructure
Committee on Environment and Public Works
United States Senate

Dear Mr. Chairman:

The South Florida Ecosystem Restoration Initiative is a complex, long-term
effort to restore the South Florida ecosystem, which includes the
Everglades. Because water is key to restoring the ecosystem, one of the
initiative's major goals is "getting the water right"--or improving the
quality, quantity, timing, and distribution of water in the ecosystem. The
primary means of achieving this goal is through the U. S. Army Corps of
Engineers' Comprehensive Everglades Restoration Plan (the Plan). Although
achieving the right quantity, timing, and distribution of water is
important, improving water quality is critical to sustaining and restoring
the South Florida ecosystem. Currently, pollutants such as excessive
nutrients, metals, and other contaminants have diminished the quality of
water in the ecosystem and harmed plants, fish, and other wildlife. To
achieve and sustain the restoration of the ecosystem, its water needs to be
clean and unimpaired by pollutants.

In April 2000, the administration presented proposed legislation to the
Congress requesting the approval of the Plan as a framework for restoring
the ecosystem and authorizing an initial group of projects. The Plan, whose
development was authorized by the Congress in the Water Resources
Development acts of 1992 and 1996, provides a road map for increasing the
region's freshwater supply and improving the delivery and quality of water
to natural areas. This Plan represents one of the most ambitious restoration
efforts the Corps has ever undertaken; it contains 66 individual projects
that will take more than 20 years to complete.1, 2 Implementing the Plan is
currently estimated to cost $7.8 billion--a cost that will be shared equally
by the federal government and the state of Florida. The effort is unique in
that the Plan is conceptual. Because the Plan consists of a large number of
projects that will be designed and constructed over a long period of time,
it does not provide the level of detail normally found in a Corps
feasibility study. The Congress is currently considering this proposal. In
May 2000, Florida passed legislation approving the Plan and initially
committed $2 billion in resources for the effort. The legislation also
included a requirement for an annual report that provides information on the
funds received and expended for the implementation of the Plan as well as
the progress being made in implementing the Plan.

Because the Plan is conceptual and water quality is critical to sustaining
the restoration of the South Florida ecosystem, you asked us to (1) describe
the role of the Corps' Comprehensive Everglades Restoration Plan in
addressing the major water quality concerns in the ecosystem and (2)
identify modifications that may be needed as the Corps implements the Plan
after it has been authorized by the Congress. The information presented in
this report is primarily based on our discussions with officials from
federal and state agencies that have responsibilities for managing water
supplies and ensuring water quality in South Florida. Reliance on
discussions with federal and state officials was necessary because the Plan
is a conceptual document and detailed plans of the projects to be
constructed are not yet available. We also reviewed the portions of the Plan
that describe water quality projects and obtained and reviewed other
pertinent water quality reports and studies.

This is our third report on efforts to restore the South Florida ecosystem.
In April 1999, we reported on the federal funding provided for the South
Florida Ecosystem Restoration Initiative and how well the initiative was
being coordinated and managed. In April 2000, we reported on the status of
land acquisition plans for the initiative.3 In our first report, we
recommended that the Task Force, a multi-agency group responsible for
coordinating and facilitating the overall effort, develop a strategic plan.
The strategic plan would lay out how the initiative's three goals--getting
the water right, restoring and enhancing the natural system, and fostering
the compatibility of human and natural systems--would be accomplished. Our
second report recommended that the Task Force develop a land acquisition
plan to supplement the strategic plan. At the request of the Congress, the
Department of the Interior, which chairs the Task Force, estimated that
achieving all three of the initiative's goals would cost $14.8 billion. This
figure includes the estimated cost of the Plan--$7.8 billion--as well as the
estimated costs for land acquisition programs and several other federal and
state efforts.

The Comprehensive Everglades Restoration Plan provides a conceptual
framework for improving the quality, quantity, timing, and distribution of
water in the South Florida ecosystem. Twenty-four of the Plan's 66 projects
are intended, among other things, to improve the quality of water in the
natural areas of the ecosystem; the remaining projects deal more with the
water's quantity, timing, and distribution. The water quality projects in
the Plan are intended to supplement the efforts of the state, which has the
primary responsibility for achieving water quality standards in Florida.
Under the Water Resources Development Act of 1996, the Corps is allowed to
include water quality projects in the Plan and equally share the costs with
Florida if the projects are essential to restoring the Everglades.

Currently, there are too many uncertainties to estimate the number and costs
of the Corps projects that will ultimately be needed to address water
quality in the ecosystem. As uncertainties related to implementing the
Plan's projects are resolved and more information is gathered about the
extent of the ecosystem's water quality problems, it is likely that
modifications and additions to the Plan will be necessary and that these
changes could increase the total cost of the Plan over the Corps' current
estimate of $7.8 billion. For example, the state is currently determining
the level of pollutants that Lake Okeechobee can receive and what actions
are needed to clean up the lake. Some of the actions being considered, such
as dredging the lake to remove contaminated sediment, could cost over $1
billion. Because the lake is the source of much of the water in the
ecosystem, the Corps could become involved in the effort if it determines
that the lake's cleanup is essential to the ecosystem's restoration. Other
efforts, such as the completion of feasibility studies for areas in the
ecosystem not covered by the Plan, could also lead to additional water
quality projects. The Corps has acknowledged the level of uncertainty in the
Plan and has included a process for incorporating project modifications and
additions in its future reports to the Congress. It has not, however,
included a means for reporting (1) cumulative changes in projects and costs
for the Plan as a whole and (2) the progress being made in implementing the
Plan. Such information will be important for the Congress in authorizing
future projects. We recommend in this report that the Corps provide for such
reporting.

We provided a draft of this report to the Corps, the U.S. Environmental
Protection Agency, the Florida Department of Environmental Protection, and
the South Florida Water Management District for review and comment. The
Corps, the Department, and the District agreed with our recommendation and
noted that they will be producing varied reports that will help them meet
our recommended reporting requirement. While they agreed with the
recommendation, the Corps, the Department, and the District noted areas in
which they believed the report was misleading. For example, the Corps
believes that it fully disclosed the uncertainties associated with the Plan
and developed a methodology to deal with the uncertainties, and it does not
believe that the Plan's total costs will necessarily increase. In our
report, we recognize that the Corps was aware of the uncertainties and
describe the process that it has in place for incorporating change.
Furthermore, we acknowledge that the Corps may achieve some cost savings in
some areas, but overall, we believe that the costs of implementing the Plan
may increase. In addition, the Corps and the Department objected to the
inclusion in our report of the $1 billion estimated cost of dredging Lake
Okeechobee and did not agree with our conclusion that the lake's cleanup
could become part of the Plan. We revised the report to indicate that the
cost estimate is preliminary, and we indicated the source of the estimate.
However, we continue to believe that projects to improve the lake's water
quality--if deemed essential to restore the ecosystem--should be included in
the Plan. The Department also objected to our inclusion of the estimated
costs for the entire restoration effort in the report, saying that this
total was not an agreed-upon cost. However, we believe that the cost of the
overall restoration is an important piece of information that places the
Plan in context, and therefore we did not remove this information. We did
identify the source of the estimate and clarify what it includes. Finally,
each of the agencies, including the Environmental Protection Agency,
provided technical comments that we incorporated as appropriate.

The South Florida ecosystem extends from the Chain of Lakes south of Orlando
to the reefs southwest of the Florida Keys. The ecosystem includes such
major water bodies as Lake Okeechobee; the Kissimmee, Caloosahatchee, and
St. Lucie rivers; portions of the Indian River Lagoon; and Biscayne and
Florida bays. Following major droughts from the 1930s through the mid-1940s
and drenching hurricanes in 1947, the Congress authorized the Corps to
construct the Central and Southern Florida Project. The project--an
extensive system of 1,700 miles of canals and levees and 16 major pump
stations--prevents flooding and saltwater intrusion into the state's aquifer
while providing drainage and water to the residents of South Florida. The
project's canals now divert much of the water that historically flowed south
from Lake Okeechobee through the Everglades to Florida Bay east and west to
the ocean or to agricultural and urban uses. The Everglades, which used to
extend from Lake Okeechobee to Florida Bay, has been reduced to about half
its former size.

Although the Corps' Central and Southern Florida Project accomplished its
objectives, it had unintended detrimental environmental effects. Coupled
with urban and agricultural development, the project has led to significant
deterioration in the South Florida ecosystem's water quality. By draining
off water to the ocean that historically flowed through the ecosystem to
Florida Bay and opening large land tracts for urban development and
agricultural practices, the project disrupts natural drainage patterns in
the region and releases stormwater runoff into the ecosystem in many areas.
Pollutants in the runoff, including excess nutrients such as phosphorus and
nitrogen, metals such as mercury (which is primarily deposited from
atmospheric incinerator emissions), and pesticides, have degraded the
natural areas of the ecosystem. Excess nutrients have caused a decline in
natural vegetation, such as sawgrass, and have caused the increase of
undesirable species, such as cattails. Mercury, which increases in
concentration as it moves up the food chain, and some pesticides can be
toxic to fish and wildlife.

Recognizing that the Central and Southern Florida Project needed to be
modified to address its negative impact on the environment of South Florida,
the Congress included provisions relating to the project in the Water
Resources Development acts of 1992 and 1996. The 1992 act provided the
Secretary of the Army, who delegated this responsibility to the Corps, with
the authority to study the original design of the project in order to
determine whether modifications were needed because of changes in the
ecosystem's physical, biological, demographic, or economic conditions. The
1996 act directed the Corps, on the basis of its initial review, to prepare
a feasibility report and a programmatic environmental impact statement to
determine what changes were needed to restore the South Florida ecosystem.
The act required that the Corps report back to the Congress by July 1999.

Using the authority provided by the acts, the Corps, with the cooperation
and assistance of multiple federal, state, local, and tribal agencies,
completed the feasibility study and developed the Comprehensive Everglades
Restoration Plan. The Plan, which was presented to the Congress in July
1999, proposes a set of 66 projects to modify the Central and Southern
Florida Project to protect and restore the South Florida ecosystem at an
estimated cost of $7.8 billion. The projects in the Plan, if authorized and
built, will restore water to the natural areas of the ecosystem and also
supply water to agricultural and urban areas. The natural areas of the
ecosystem are made up of federal and state lands, including the water
conservation areas owned by the state,4 wildlife refuges managed by the U.S.
Fish and Wildlife Service and the state, Everglades National Park, Big
Cypress National Preserve, and the coastal waters, estuaries, bays, and
islands. The goal of the Plan is to increase the water available for the
ecosystem by capturing much of the water that is now being drained, storing
the water in many different reservoirs and underground storage wells, and
releasing it when it is needed. (See app. I for additional details on the
projects included in the Plan.)

The administration presented proposed legislation in April 2000 asking the
Congress to approve the Plan with its projects as a conceptual framework for
restoring the ecosystem.5 Because the Plan consists of a large number of
projects that will be designed and constructed over a long period of time,
it is not as detailed as typical Corps feasibility studies. For example, it
does not identify specific sites for the proposed projects. The Corps also
plans to conduct additional feasibility studies because the time allotted to
complete the Plan did not allow for a thorough investigation of all of the
regional water resource problems in South Florida. The Corps will design the
projects in more detail and expects to request the Congress to authorize a
new set of projects every 2 years until all the projects are authorized,
which the Corps anticipates will take until 2014.6

The Plan will be carried out primarily by one federal agency--the Corps--and
one state agency--the South Florida Water Management District (the
District), which manages water resources for South Florida and is the Corps'
local sponsor, or partner.7 These agencies are responsible for operating the
Central and Southern Florida Project as it is currently configured and will
be responsible for planning, designing, and constructing the Plan's projects
to reconfigure it. The agencies are responsible for meeting both the water
supply and water quality goals in the Plan. Furthermore, under the Clean
Water Act, which seeks to restore and maintain the physical, chemical, and
biological integrity of the nation's waters, the projects must be designed
to meet applicable state water quality standards.8

The entities responsible for ensuring that the Plan's projects meets the
requirements of the Clean Water Act are the U.S. Environmental Protection
Agency (EPA), the Florida Department of Environmental Protection, and the
Miccosukee and Seminole tribes. EPA is responsible for developing
regulations and guidance for implementing the act, while the state and the
tribes have primary responsibility for programs to manage water quality.
Florida's Department of Environmental Protection is responsible for (1)
classifying the types of water in the state by designated use, (2)
establishing water quality standards for each type of water designed to
protect the designated use, (3) regulating discharges into waters, (4)
determining and reporting waters that do not meet standards to EPA and (5)
making plans to improve the quality of water that does not meet standards.
In addition, the Department is responsible for monitoring the quality of
each water body. In the South Florida ecosystem, the Department has
delegated water quality monitoring and assessment to the District. Other
agencies, such as the U.S. Geological Survey, contribute to water quality
monitoring and analysis. The tribes are responsible for these activities on
their reservation lands, which encompass about 165,000 acres in the South
Florida ecosystem. Figure 1 shows the relationship of the federal and state
agencies and tribes involved in improving water quality in the South Florida
ecosystem.

Note: The Florida Department of Environmental Protection has delegated
responsibility for water quality monitoring and assessment in the ecosystem
to the South Florida Water Management District.

Address Water Quality in the Ecosystem

The water quality projects included in the Corps' Plan supplement the
efforts of Florida, which is primarily responsible for ensuring compliance
with water quality standards in the ecosystem and for ensuring that the
projects meet state water quality standards. As authorized by the Water
Resources Development Act of 1996, the Corps included projects in the Plan
to improve water quality in the South Florida ecosystem that the Corps
deemed essential to achieve the restoration of the Everglades. The federal
and state governments will equally share the costs of these projects. The
Corps developed guidance establishing which water quality projects would be
considered essential for restoration purposes. Generally, the guidance calls
for the construction of water quality projects in locations where the Corps
will reintroduce water to natural areas of the ecosystem. Therefore, some of
the Plan's projects involve not only collecting, storing, and diverting
water that is now being drained by the existing Central and Southern Florida
Project, but also constructing water quality projects, such as treatment
facilities, to ensure that the water being put back into the natural areas
is clean.

the Ecosystem

Florida has the primary responsibility for achieving water quality standards
in the state and is taking steps outside the Plan to achieve water quality
standards in the ecosystem. Most significantly, the state is beginning to
develop pollutant reduction plans to improve the waters in the state. Under
the Clean Water Act, the state has to report water bodies to EPA that do not
meet the agency's standards or are considered "impaired."9 In 1998, the
state identified and reported 150 such water bodies or water segments in the
South Florida ecosystem. To improve these impaired waters, the state must
establish the amount of each pollutant that can be discharged into a
particular water body and still meet standards and limit discharges to those
levels. Florida currently has a 13-year schedule to establish the allowable
amounts of each pollutant, known as a "total maximum daily load," that can
be discharged into each body of water in the state, including those in the
South Florida ecosystem.10 If the state fails to establish the total maximum
daily loads, EPA is required to establish the amounts.

In addition to its statewide water quality programs, Florida has initiated
several efforts specifically designed to address the quality of water in the
Everglades and other natural areas in the South Florida ecosystem. For
example, Florida's Everglades Forever Act,11 passed in 1994, established a
plan to restore significant portions of the ecosystem through construction,
research, and regulation. Most importantly, the act requires the state to
reduce phosphorus levels entering the natural areas of the ecosystem. To do
this, six wetlands, called stormwater treatment areas, are being constructed
to filter pollutants in runoff from the agricultural areas south of Lake
Okeechobee.12 In addition, the state must develop a numeric criterion for
phosphorus in the Everglades. Another important state effort to address
water quality in the ecosystem, the Lake Okeechobee Protection Program, was
passed in May 2000. These and other state efforts intended to improve the
quality of water of the South Florida ecosystem are described in appendix
II.

With funding through a grant from EPA, Florida recently initiated an effort,
called the South Florida Water Quality Protection Program, to coordinate the
various ongoing efforts to improve water quality in the ecosystem. The
purpose of the program, which will be developed primarily by those entities
that have water quality responsibilities in South Florida, will be to
identify water quality problems in the ecosystem; recommend actions to deal
with these problems; and identify and coordinate the efforts of the federal,
state, tribal, or local agencies that will be responsible for taking action.
The key programs that will be coordinated are the state's total maximum
daily load program and its activities under the Everglades Forever Act, as
well as the Corps' projects in the Plan.

Twenty-four of the 66 projects that the Corps included in its Plan are
intended to improve water quality in the ecosystem. Many of the Plan's other
projects will also improve the quality of water by increasing the quantity
or changing the flow of water to degraded areas, but these 24 projects were
included specifically to improve water quality. To identify these projects,
the Corps established two criteria. First, the Corps included projects to
treat water that is being "reclaimed" as part of the Plan. This water is now
being discharged by the Central and Southern Florida Project into the ocean,
but under the Plan, it will be diverted, stored, and discharged into natural
areas to supplement water supply and improve habitat. Second, the Corps
included treatment projects for water that will be "reused." This water will
also be reclaimed, but its final use will be changed. For example, the Corps
now releases water from Lake Okeechobee to the water conservation areas for
flood control purposes and water supply, but under the Plan it will also
release water for environmental purposes. Figure 2 shows the location of the
24 water quality projects included in the Plan.

Source: GAO's adaptation of an illustration prepared by the U.S. Army Corps
of Engineers.

The Plan includes 19 stormwater treatment areas (17 projects--2 projects
each contain 2 treatment areas) in locations where new storage sites will be
built to reclaim water or modify its use. One of the major purposes of the
Plan is to create new storage for the 1.7 billion gallons of water per day
that historically flowed south into the Everglades but is now, because of
the Central and Southern Florida Project, being discharged into the ocean or
released for flood control purposes, thus depriving the Everglades of much
needed water. While this water generally meets standards for discharge into
the ocean, it will require additional treatment before it can be released
into the natural areas of the ecosystem because these areas are less able to
assimilate specific pollutants, such as phosphorus. A team of federal and
state water quality experts used available water quality models to evaluate
the potential effects of the Plan's projects on water quality and to
identify areas in which known water quality problems could be addressed by
the Plan's projects. As a result, the Corps added over 35,500 acres of
stormwater treatment areas. Ten treatment areas will be constructed along
the east coast between the natural areas and the developed coastal areas,
five are located around Lake Okeechobee to treat water entering the lake,
and four treat water entering the natural areas northwest of Everglades
National Park. In addition, the Plan relies on the six stormwater treatment
areas being constructed under the Everglades Forever Act to treat water
released from the Everglades Agricultural Area, Lake Okeechobee, and a
reservoir planned for the area. The design of the treatment areas was based
on that of the areas being built by the state under the act.

In addition to the stormwater treatment areas, the Corps identified a need
for two advanced wastewater treatment facilities to treat wastewater for
reuse to benefit natural areas. The two plants will take wastewater from the
Miami area, treat it, and return it to natural areas to increase the amount
of water being provided there. Water that is currently being released from
wastewater treatment facilities will be treated and used to recharge
groundwater to prevent water from seeping underground from Everglades
National Park and to meet the freshwater needs of Biscayne Bay. The Corps
included these projects as part of the Plan because it needed additional
water in these areas but faced limited supplies. Because of concerns about
potential overflows and accidents, such as pipe ruptures, the Corps is
considering alternatives for at least the facility near Biscayne Bay.

Finally, the Plan included five smaller projects that were selected because
they will have an immediate environmental benefit.13 These projects include
such activities as restoring wetlands or dredging sediments from lakes or
other water bodies. For example, one project involves dredging the
tributaries that flow into Lake Okeechobee to remove sediments, which will
help remove nutrients that contribute to algal blooms.

to Additional Water Quality Projects and Costs

As the Corps implements the Plan over the next 20 or more years, Corps
officials believe that modifications to existing projects and additional
projects may be necessary, as their details are further developed and as
uncertainties about their implementation are resolved. In addition, the
Corps plans to conduct several studies that may further identify water
quality problems in the ecosystem. If additional water quality projects are
identified during the Plan's implementation or as a result of these studies,
the costs to implement the Plan could increase above the Corps' current $7.8
billion estimate. Recognizing that additional projects could be needed as
the Plan is implemented, the Corps included a process in the Plan to
incorporate and report to the Congress on modifications and additions to it.
However, the Corps has not included a process for updating the Congress on
the cumulative effects of the individual changes on the overall Plan.

The Corps acknowledged that a number of uncertainties associated with
implementing the Plan's projects have not yet been resolved and could lead
to additional water quality projects. These uncertainties include (1)
whether planned stormwater treatment areas will be successful in achieving
the lowest phosphorus concentration needed, (2) whether 245,000 acre-feet of
additional water will be needed for Everglades National Park;14 and (3) what
type and level of treatment will be necessary for water stored in and
retrieved from aquifer storage and recovery wells--large underground wells
that are one of the primary means in the Plan for storing water.

Uncertainties About Stormwater Treatment Areas May Lead to Additional
Projects

Uncertainties about the degree to which pollutants can be removed by the
planned stormwater treatment areas may lead to additional water quality
projects. In particular, some natural areas in the ecosystem, such as
Everglades National Park and the water conservation areas, have a low
tolerance for phosphorus--only about 10 parts per billion of phosphorus can
be in the water without adversely affecting its designated use. Two or three
of the stormwater treatment areas in the Corps' Plan will be used to reduce
the levels of phosphorus in water that is being released into these areas,
and the treatment areas will have to be built so the released water meets
Florida's water quality standards for all pollutants. The state, however,
does not currently have a numerical standard for phosphorus in these water
bodies, although it is in the process of establishing one. The Corps based
the design of its stormwater treatment areas on similar areas being built by
the state that are designed to reduce phosphorus levels to meet an interim
standard of 50 parts per billion. Evidence gathered by EPA and the state
support a numeric criterion for phosphorus of 10 parts per billion; the
final standard will involve methods of monitoring and determining compliance
that could affect treatment options.15 If the state establishes a lower
phosphorus standard--for example 10 parts per billion--for Everglades
National Park and the water conservation areas, then the Corps will likely
be required to modify the stormwater treatment areas being built for these
areas to achieve that standard.

Additional Water for Park, If Needed, Could Require Water Quality Treatment

If the Corps determines that an additional 245,000 acre-feet of water will
be essential to the restoration of natural areas, particularly Everglades
National Park, it may need to add another water quality project. In response
to concerns by the Department of the Interior about needing additional water
for the Park during certain times of the year, the Corps determined that an
extra 245,000 acre-feet of water could be made available from eastern urban
areas. Because of uncertainties in the models for water quantity in the
Park, some federal and state officials disagree that the extra water is
needed for the Park. In the meantime, the Corps has considered ways to bring
the water to the Park, but it will not study the matter fully until a
decision is made on the amount of water needed. In addition, the amount of
water for the Park may be affected by the amount of water needed in Florida
Bay, which will be determined as part of follow-on feasibility studies for
the Bay. If the Corps and others determine that more water is needed for the
Park, then additional water treatment facilities could be needed to ensure
the quality of the water entering the natural areas. Under its criteria to
include reclamation projects to protect the quality of water in natural
areas, the Corps could be involved in constructing and funding the project.
According to Corps officials and others, because undeveloped land is scarce
on the east side of the natural areas, water treatment facilities using
traditional chemical treatment are the most likely option. According to
District officials, another option could be to relocate or resize some of
the treatment projects already included in the Plan.

Uncertainties About the Treatment Needed for Water Stored in Wells May
Result in Additional Water Quality Projects

Uncertainties about the type and extent of treatment needed for water being
pumped into and retrieved from over 300 aquifer storage and recovery wells
may result in additional water quality projects. The Corps has included
plans and costs for chlorination and filtration facilities to treat the
water being injected into more than 250 of these wells. Although the need
for chlorination has not yet been determined, concerns have been raised
about a possible chemical reaction between chlorinated surface water and the
aquifer's groundwater. According to Corps and state officials that we spoke
with, such a reaction could create trihalomethane compounds, which are
carcinogenic. In addition, the level of filtration required may vary
according to the quality of the water being injected into wells; in some
cases simple filtration will likely be needed to remove debris, but in other
cases, ultrafiltration may be needed to remove pathogens such as coliforms.
Corps officials think it is unlikely that chlorination and ultrafiltration
will be needed, and if not, the Corps estimates that about $500 million
could be saved. The Corps will design and implement pilot projects to
determine if these treatments will be needed and what problems arise from
using untreated or chlorinated surface water. If additional information from
the pilots indicates that chlorination and ultrafiltration are necessary,
additional projects to address water quality problems arising from chemical
reactions may be necessary.

Regardless of whether chlorination and filtration are used, other chemical
reactions could occur in the water stored underground, resulting in a need
for additional projects to improve the quality of water retrieved from the
wells. Some federal and state officials and scientists believe that chemical
reactions could occur when water is injected underground. For example,
un-ionized ammonia--which in excess amounts can kill freshwater species,
including fish--could be formed. Florida's monitoring of a small well has
demonstrated that underground chemical reactions have contaminated the water
with arsenic and radioactive materials, such as uranium, although not at
levels exceeding federal drinking water standards. According to officials
from EPA and the Florida Department of Environmental Protection, if such
chemical reactions occur, the water will require treatment when it is
retrieved from the wells. Corps and District officials said that any
pretreatment facilities, if constructed, could be used to treat the water
recovered from wells to handle such problems if they occur. Corps officials
noted that pilot projects the Corps has designed will gather information to
resolve these uncertainties and will identify any additional projects that
may be needed to address water quality issues created by the technology. If
the pilots indicate that the use of this technology is not feasible, Corps
officials said that other storage options would be substituted.

Recognizing that all the water quality problems of the South Florida
ecosystem have not been identified, the Corps plans to conduct several
feasibility studies to identify water resource problems in areas of the
ecosystem that were not included when it developed the Plan. These studies
will likely identify new water quality projects to add to the Plan.
Moreover, the Plan recommends the development of a comprehensive integrated
water quality plan to evaluate and determine whether any additional water
quality projects recommended by the state should be added to the Plan. Any
projects identified by these studies will be in addition to those needed to
address the uncertainties involved in implementing the Plan.

Feasibility Studies Will Likely Identify Additional Water Quality Projects

In addition to the 66 projects in the Plan, the Corps included several
feasibility studies for other areas of the South Florida ecosystem, which
could result in the addition of other water quality projects to the Plan.
These feasibility studies, which deal with the Southwest Florida and Florida
Bay/Florida Keys areas, were included because there was not enough time when
the Plan was being developed to allow for a thorough investigation of all
the water resource problems in these areas of the ecosystem. In particular,
water models and water quality models that exist for Biscayne Bay and
Florida Bay have not been calibrated or validated, and, as a result, the
Corps and other agency scientists could not rely on these models to conduct
detailed studies of the projects needed to improve the quality, quantity,
timing, or distribution of water for these areas. The feasibility studies
will identify new projects to be included in the Comprehensive Everglades
Restoration Plan to help solve any problems with water quality, quantity,
timing, and distribution. The Corps, in conjunction with other federal and
state agencies, is currently refining water flow and quality models for both
bays.

More detailed project designs and analysis from each feasibility study could
reveal additional water quality concerns and could result in additional
water quality projects. For example, the Corps' Plan already includes a
project to improve the circulation and quality of water in Florida Bay by
removing portions of the roadbed that fills some of the waterways between
islands in the Keys. The Corps will include this as a project in the Florida
Bay feasibility study, as well as other projects that have not yet been
identified. Additional projects may include solutions for the decline in sea
grasses and increases in algae that have occurred in the Bay. Federal and
state scientists and other experts are aware of the excess nutrients and
salinity in some parts of the Bay, and they believe that either one or both
are contributing to these problems. However, they have not reached consensus
on the source or effects of these problems or on the potential actions
needed to resolve them. As more information becomes known, additional
projects to improve water quality in the Bay may be identified. For these,
as for other water quality projects, the Corps will determine its
involvement according to whether they involve reclaiming water for the
natural system or reusing water.

In addition to the feasibility studies proposed in the Plan, the Corps is
currently conducting two feasibility studies under the authority of the
Water Resources Development Act of 1996--the Indian River Lagoon Feasibility
Study and the Water Preserve Areas Feasibility Study--and is conducting a
third for Biscayne Bay under a separate authority. According to a Corps
official, the Plan already includes most of the projects that will be
recommended in these reports, but the Indian River Lagoon study has
identified at least one water quality project that is not in the Plan. As a
result of the study, the Corps will likely add a water quality project to
its Plan to dredge the lagoon to remove sediments from the St. Lucie
estuary, a major tributary of the lagoon, to improve the water's quality and
clarity.

Comprehensive Integrated Water Quality Plan May Identify Additional Projects

Although Florida has the primary responsibility to clean up impaired waters
and ensure water quality in the South Florida ecosystem, the Corps of
Engineers could have a role in future water quality efforts if it determines
that the projects are essential for ecosystem restoration under the
provisions of the Water Resources Development Act of 1996. Recognizing that
not all of the ecosystem's water quality problems have been identified, the
Corps has included a recommendation in the Plan for the development of a
comprehensive integrated water quality plan. According to Corps officials,
the water quality plan will be closely coordinated with the South Florida
Water Quality Protection Program, which was recently initiated by the state.
Through their participation in the Indian River Lagoon Feasibility Study,
program officials have already helped to identify one modification to the
Plan--the need to add a stormwater treatment area to a reservoir project on
the St. Lucie River to help reduce the flow of sediment and pollutants into
the St. Lucie estuary.

As the state program identifies additional projects to improve water
quality, the Corps will evaluate whether the projects are essential and
whether the federal government should participate in them, share their
costs, and include them in its water quality plan. One of Florida's major
efforts to improve water quality will be identifying and enforcing total
maximum daily loads. To complete its 13-year schedule to establish total
maximum daily loads, the state will establish hundreds of load amounts for
the almost 150 impaired water bodies or segments of water bodies in the
South Florida ecosystem. The state will also be developing plans that will
identify projects for reducing the amounts of pollutants entering these
water bodies. This does not include efforts that will need to be undertaken
to address future impaired waters. According to Corps officials, the Corps
will apply the same criteria it originally used to include water quality
projects in the Plan to determine which additional water quality projects it
will participate in under its comprehensive water quality plan.

For example, the cleanup of Lake Okeechobee, which has been described as the
"liquid heart of the ecosystem," may require a number of projects to restore
the quality of the lake's water and, according to Corps officials, could
eventually require the Corps' involvement. Currently, Lake Okeechobee--which
was once a sandy-bottomed, clear, shallow lake--has high levels of
phosphorus that make it prone to algal blooms and cattail growth, adversely
affecting the quantity and types of plants and fish in the lake. Despite the
implementation of certain permitting programs by the state, the annual
phosphorus amounts exceed the state targets. Our discussions with state
officials responsible for water quality in Florida indicate that a
combination of actions, such as agricultural best management practices and
the use of storm water treatment areas, will be needed to lower the levels
of phosphorus entering the lake. The state passed legislation on recovering
Lake Okeechobee this year and will put in place additional best management
practices for agricultural lands, will build pilot projects to test sediment
removal and stormwater treatment areas, and will begin other programs to
reduce phosphorus in the lake, but it does not yet know how many stormwater
treatment areas may be needed. The Corps has already included five treatment
facilities in its Plan to remove phosphorus from some of the lake's
tributaries. The number of stormwater treatment areas that will be needed in
addition to those already planned by the Corps will depend on the final
target concentration that is set for reducing phosphorus in the lake and the
effectiveness of nonregulatory and regulatory actions in helping to reach
that target. According to Corps officials, the Corps may participate in the
construction of other stormwater treatment areas if the state determines the
areas are needed.

Large deposits of phosphorus-laden sediment in the lake further exacerbate
the phosphorus problem. Some federal and state officials believe that if the
sediment remains in the lake, the lake's water quality will remain a
significant problem. However, dredging will involve removing as much as
30,000 metric tons of phosphorus from the lake's sediment and disposing of
it either in landfill or as potential fertilizer. No final decision has been
made on what actions to take pending Florida's completion of a feasibility
study on options to remove the sediment, which range from dredging the
entire lake to sealing or capping phosphorus-laden sediments. If a decision
is made to take some action to remove the sediments, then the Corps would
decide if the proposed action is essential to the restoration of the
ecosystem and if the federal government should become involved and share the
costs of the project(s). According to Corps officials, improving the water
quality of Lake Okeechobee, which is the source of much of the water in the
South Florida ecosystem, is critical to the lake's restoration. The Corps
has already included two similar, but much smaller, projects in the
Plan--the Lake Trafford16 and Lake Worth Lagoon dredging projects. In our
discussions with both federal and state officials, the main difference
between these two projects and a project to dredge Lake Okeechobee is that
Lake Okeechobee is many times larger and would cost more to clean up. A
preliminary estimate prepared by an issue team of federal and state
scientists showed that fully dredging the lake could cost at least $1
billion.

Another area that may involve the Corps in future water quality projects is
the abatement of mercury in the ecosystem. Mercury accumulates in fish and
in wildlife that eat fish affected with mercury and concentrates as it moves
up the food chain. Scientists believe that mercury in the atmosphere from
waste incineration and power generation is deposited in South Florida and,
under specific conditions, is converted to a toxic form that accumulates and
concentrates in fish and animals. At present, scientists continue to
research the problem. However, because of high concentrations of mercury in
fish and wildlife on federal lands, such as Everglades National Park, the
Corps or other federal agencies could become involved in trying to remove
mercury from these areas. Other federal agencies, such as EPA and the
Department of the Interior's U.S. Geological Survey, are already involved in
addressing the mercury problem to some extent through research and
monitoring programs.

To allow for changes that will result as uncertainties involved in
implementing the Plan's projects are resolved, including the possible
addition of water quality projects, the Corps' Plan includes three ways to
incorporate changes: (1) additional efforts, such as surveys, mapping, and
water quality analyses, that are needed to develop the final design of the
projects; (2) pilot projects conducted to resolve technical uncertainties;
and (3) an adaptive assessment process. The adaptive assessment process
involves monitoring the systemwide effects of projects on the ecosystem as
they are implemented, evaluating the achievement of each project's
objectives, and including the monitoring and evaluation results and new
information learned from continuing research to refine or alter the design
or sequencing of projects. According to the Corps, adaptive assessment will
allow it to recognize the need for change and adapt the Plan if the intended
results are not achieved or if new ways to increase the benefits to the
ecosystem are identified.

The Corps has also included a process in the Plan for authorizing future
projects, including any changes, either modifications or additions, that
result from its additional planning efforts. As it prepares to move forward
with a project, the Corps will submit to the Congress a project
implementation report that includes the detailed technical information
necessary to design a project or groups of similar projects. The reports
will contain the results of additional efforts, such as surveys and mapping,
economic analyses, and water quality analyses that are needed to develop the
final design of the projects. These reports will be used to add, remove, or
modify projects in the Plan and, except for the projects presented for
initial authorization, will be presented to the Congress for authorization
every 2 years until 2014--when the Corps anticipates that all of the
projects needed for the restoration effort will have been authorized. The
reports will contain recommendations for any modifications to the Plan whose
need was determined by systemwide evaluations. However, according to Corps
officials, the Corps does not currently plan to report to the Congress on
the cumulative changes that have been made to the Plan. Such a report would
provide the Congress and the state with an understanding of how the Plan is
evolving, as well as an update every 2 years on the costs of the projects
and the Plan.

Achieving water quality improvements in the South Florida ecosystem will
depend on several programs and efforts, including the Corps' Plan. Although
the Plan currently includes 24 projects to address the quality of water in
natural areas of the ecosystem, there are too many uncertainties to estimate
the number and costs of the projects that will ultimately be needed to
improve water quality. Even though the Corps believes that the costs of some
projects could be reduced, we believe that, with the potential addition of a
number of water quality projects to the Plan, it is likely that the overall
costs to improve water quality could result in an increase in the current
estimate of $7.8 billion for implementing the Plan. The Plan's water quality
monitoring and adaptive assessment process will be key to ensuring success
in addressing the water quality problems of the natural areas. Congressional
oversight of future project authorizations will be important to ensure that
the Corps consistently applies its criteria for including additional water
quality projects and monitors their additional costs. The Corps has
correctly acknowledged the Plan's need for flexibility and adaptability and
has included a means for reporting changes to the Congress. Where the Plan
falls short is in the type of report that the Corps will provide to assist
the Congress in its oversight. Although our review identifies the potential
for modifying and adding water quality projects, the other projects in the
Plan, such as the construction of surface storage reservoirs and barriers to
prevent underground water seepage, are subject to similar changes because
they have not yet been designed. If the Congress approves the Corps'
blueprint for restoration this year, given its conceptual nature and the
likelihood of changes and additions to its projects, the Congress--as well
as Florida, which is equally sharing the costs of implementing the
Plan--will need to understand how the Plan has evolved from the original
blueprint and how these changes will affect the Plan's total implementation
costs.

To promote well-informed decisions about the Plan's projects that are
presented for approval in future authorization acts, we recommend that the
Secretary of the Army provide the Congress with updates that (1) reflect the
cumulative project and cost changes to the overall Plan and (2) indicate the
progress being made toward implementing the Plan. The updates should be made
at the same time as subsequent authorization proposals. The Corps should
also provide these updates to the state of Florida.

We provided a draft of this report to the U.S. Army Corps of Engineers, the
U.S. Environmental Protection Agency, the South Florida Water Management
District, and the Florida Department of Environmental Protection for their
review and comment.

The Corps advised us that it concurs with our recommendation and plans to
implement it. The Corps noted that the recently finalized Master Program
Management Plan calls for the Restoration Coordination and Verification
team, which will evaluate and assess the performance of the Comprehensive
Everglades Restoration Plan, to produce five categories of written reports
covering such topics as the performance of the Plan and recommendations for
design and operational criteria. The Corps also expects to issue an annual
report card on the status, trends, and success of the Comprehensive
Everglades Restoration Plan. The Corps indicated that it would use the
information presented in these reports to implement our recommendation to
prepare an overall update to the Congress on the cumulative project and cost
changes to the Plan as well as on the progress being made in implementing
the Plan. The Corps also pointed out that the administration's proposal
contains a provision requiring periodic reports to the Congress on the
implementation of the Plan. The Corps expects to submit these reports every
5 years. We share the Corps' views on the importance of providing the
Congress with information showing the progress being made in implementing
the Plan. However, we believe that the Corps' progress report should include
an update of the cumulative changes that have been made to the Plan and the
effect of those changes on the Plan's implementation cost and schedule and
should be provided every 2 years when the Corps is submitting its request
for congressional authorization of a new set of projects.

The Corps also agreed that there are many uncertainties associated with the
implementation of the overall Plan and the projects to improve water quality
in the South Florida ecosystem. The Corps believes that the uncertainties
have been fully disclosed and has proposed a methodology that will address
them. This methodology includes the development of project implementation
reports. The Corps disagreed that the uncertainties will absolutely lead to
cost increases. We recognize in our report that the Corps was aware of the
uncertainties associated with the implementation of the Plan and describe,
in detail, the process that the Corps included in the Plan to incorporate
changes as the uncertainties are resolved. We believe that the resolution of
these uncertainties may lead to additional water quality projects and will
likely result in cost increases. However, because we recognize that the
Corps may also have opportunities to reduce the costs of some projects, our
report does not state that the resolution of these uncertainties will
absolutely result in an increase in the current estimate of $7.8 billion for
implementing the Plan.

The Corps believed that it was premature to suggest that dredging Lake
Okeechobee could increase the cost of the Plan and questioned the inclusion
of an estimate of the costs in our report. We specifically point out in our
report that the state is currently conducting a feasibility study on the
options to remove phosphorus-laden sediment from the lake and that no
decision on dredging Lake Okeechobee has yet been made. We also recognize
that any involvement by the Corps would be contingent on the Corps'
determination that the project(s) would be essential for the ecosystem's
restoration. However, we believe that the cleanup of Lake Okeechobee is the
type of water quality effort that could involve the Corps in the future
because (1) Lake Okeechobee is an important component of the South Florida
ecosystem, (2) the Corps has already included projects in the Plan to
address the lake's water quality, and (3) the Corps' Plan already includes
two similar, but much smaller, dredging projects. We revised the report to
identify the source of the $1 billion cost estimate for the possible
dredging of Lake Okeechobee.

The Florida Department of Environmental Protection concurred with our
recommendation. The Department stated that the recommendation is consistent
with state law and requested that we recognize that Florida already requires
that cumulative project and cost information be reported. We commend the
state for having the foresight to establish this requirement and have
revised the report to include this information. However, we believe that it
would be useful for the Congress to receive information that shows how the
Plan has evolved and how those changes affect the Plan's original cost and
implementation schedule. For that reason, we have recommended that the Corps
provide such information to the Congress at the same time that it submits
new project authorization requests. The Department also stated its belief
that our report is misleading in the following instances:

First, the Department believes that the title of our draft report implied
that the Corps and the state were either unaware of the uncertainties
associated with the implementation of the Comprehensive Everglades
Restoration Plan or downplayed the uncertainties. We did not intend to imply
that the Corps and the state were either unaware of or downplayed these
uncertainties. However, we agree that the title could have been misconstrued
and, to prevent further misinterpretation, we revised the title of our
report to indicate that additional water quality projects may be needed and
could increase the Plan's cost.

Second, the Department took exception to the inclusion in the report of (1)
the $14.8 billion cost estimate to achieve all three goals of the South
Florida Ecosystem Restoration Initiative and (2) the $1 billion figure for
the possible dredging of Lake Okeechobee. The Department stated that any
reference to the $14.8 billion cost estimate should be deleted. In the
Department's view, the $14.8 billion figure is not comparable to the cost
estimate developed for the Plan and there is no consensus among state and
local governments on this amount. We believe it is important to recognize
that restoring the South Florida ecosystem will require more than
implementing the Corps' Comprehensive Everglades Restoration Plan, which
primarily addresses one of the initiative's goals. We agree that we should
acknowledge the source of this estimate, and we revised the report to
indicate that the $14.8 billion cost estimate was calculated by the
Department of the Interior, which chairs the interagency task force that
facilitates the overall restoration effort, at the request of the House and
Senate Appropriations Committees. In addition, the interagency task force's
recently published strategic plan, requested by the Congress, also uses the
$14.8 billion figure in discussing the estimated cost of restoring the
ecosystem.17

In taking exception to the inclusion of the $1 billion cost estimate for
dredging Lake Okeechobee, the Department maintained that we represented this
estimate as an official rather than as a rough estimate and that we
characterized the Corps' involvement as inevitable. We recognize that the
cost estimate is preliminary and agree that we should indicate its source
and precision. Accordingly, we revised the report to include this
information. We do not believe that we have characterized the Corps'
involvement in dredging Lake Okeechobee as inevitable. We included Lake
Okeechobee as an example of an area where, through the state's efforts to
identify actions needed to improve water quality in the South Florida
ecosystem, the Corps could have a future role. We already point out that the
state has not yet determined all of the actions that will be needed to clean
up Lake Okeechobee and that the Corps' role has not yet been defined.
However, to emphasize that point, we revised this section of the report to
reiterate that once the state determines which projects are necessary, the
Corps will determine if the additional projects are essential to the
ecosystem's restoration and decide if the federal government will
participate in and share the costs of the additional projects.

Third, the Department believes that our discussion of the uncertainties
associated with stormwater treatment areas is misleading and that we
misunderstood the applicability of the numeric criterion to be established
for phosphorus. We disagree. We recognize that the stormwater treatment
areas being built by the state are not part of the Corps' Plan and the Corps
assumed that these areas would achieve the numeric criterion that will
eventually be established. Furthermore, we specifically state that several
stormwater treatment areas in the Corps' Plan will release water into areas
of the natural system, such as Everglades National Park and the water
conservation areas, that will be affected by the numeric criterion that the
state is in the process of establishing. We acknowledge the state's
experience in constructing stormwater treatment areas to reduce phosphorus
levels and point out that the Corps used the stormwater treatment areas
being built by the state as part of the Everglades Construction Project as
the "model" for those included in its Plan. The state's stormwater treatment
areas, which are part of the Everglades Construction Project, were designed
to reduce phosphorus levels to the interim target of 50 parts per billion.
However, if the state establishes a 10-parts-per-billion numeric criterion
for Everglades National Park and the water conservation areas, we believe
that the Corps will be required to modify the stormwater treatment areas
included in its Plan that release water into this protected area.

Fourth, the state believes that our report characterizes two state
programs--the Lake Okeechobee Protection Program and the South Florida Water
Quality Protection Program--as dependent on the Corps' Plan. We disagree. We
concluded that the state's efforts to improve water quality in the ecosystem
could identify additional projects for the Corps to consider as part of its
integrated water quality plan, which was included in the Plan because the
Corps recognized that not all the water quality problems of the ecosystem
had been identified. The Plan is intended to be a "comprehensive plan for
restoring, preserving, and protecting the South Florida ecosystem," and as a
result, any future water projects that the Corps determines the federal
government should participate in as essential for the restoration of the
ecosystem would be part of the Plan.

Finally, the Department provided comments on several other issues. The
Department pointed out that the Corps had not yet decided to include the
water quality project to dredge the Indian River Lagoon in the Plan. We
agree and revised the report to indicate that the Corps will likely add this
project to the Plan. The Department also commented that our report implies
that the other projects in the Plan do nothing for water quality. Our report
states that many of the Plan's other projects will also improve water
quality by changing the flow of water to degraded areas. The report notes,
however, that the 24 projects discussed in it were specifically included in
the Plan to improve water quality. The Department believed that the appendix
on the state's initiatives to improve water quality in the ecosystem did not
mention essential activities, such as the state's water regulatory and water
quality monitoring programs. We agree that these are important parts of
Florida's overall effort to protect water quality in the state, including
the South Florida ecosystem. We discussed Florida's regulatory
responsibilities for managing water quality programs in the main body of the
report and did not include the information in appendix II because the
purpose of the appendix was to discuss the additional efforts the state has
undertaken specifically to improve water quality in the South Florida
ecosystem. For this reason, we did not add a discussion of Florida's
regulatory programs for water quality to appendix II. The Department's
comments are in appendix III.

The District also concurred with our recommendation and stated that it will
work with the Corps to carry it out. The District did not believe, however,
that we should characterize the Plan as unusual or atypical because of the
uncertainties associated with its implementation. We do not characterize the
Plan as atypical because of its uncertainties. It is atypical because it
does not provide the level of detail normally found in a Corps feasibility
study--a fact that the Corps recognizes--as a result of the large number of
projects that would be designed and constructed over a long period of time.
For this reason, we did not modify the report to reflect this concern. The
District's comments are in appendix III.

Finally, each of the agencies, including EPA, provided technical comments
that we incorporated as appropriate.

To describe the role of the Corps' Comprehensive Everglades Restoration Plan
in addressing the major water quality concerns of the South Florida
ecosystem, we reviewed portions of the Plan that described the water quality
projects. We also obtained and reviewed reports and studies, such as the
Everglades Consolidated Report, the South Florida Ecosystem Assessment
Interim Report, and the South Florida Water Quality Protection Program:
Phase I Document that identify water quality concerns of the ecosystem.

To identify the modifications that might be needed as the Corps implements
the Plan, we contacted officials from the Corps and discussed the
ecosystem's water quality concerns, how the Plan's water quality projects
address them, and the potential need for additional projects and
modifications as the Plan is implemented. We also contacted officials from
EPA, the Department of the Interior's National Park Service and Fish and
Wildlife Service, and Florida's Department of Environmental Protection and
South Florida Water Management District. These federal and state agencies
were among those involved in the Plan's development and have responsibility
for (1) designing and constructing the Plan's projects, (2) ensuring water
quality, or (3) managing lands within the ecosystem. We discussed the water
quality problems of the ecosystem, the projects included in the Plan to
address them, and potential future problems and projects. Because the
majority of the projects in the Plan have multiple purposes, the cost
estimate for each project is an aggregate cost for construction components
that make up the project, such as levees, canals, pumps and structures. For
this reason, the cost estimates attributable to water quality were not
readily available.

We also contacted the staff of the Committee on the Restoration of the
Greater Everglades Ecosystem, the peer review committee for the restoration
effort, to discuss the committee's draft work plan as it related to water
quality. Although the committee does not yet have a final work plan, it has
drafted a work plan that includes studies that address aspects of water
quality. Finally, we contacted the head of the Florida Keys National Marine
Sanctuary and representatives of the Miccosukee and Seminole tribes, the
National Audubon Society, and other environmental and special interest
groups and organizations participating in the effort to restore the South
Florida ecosystem to discuss their concerns about how the Plan addresses
water quality.

We conducted our review from May 2000 to August 2000 in accordance with
generally accepted auditing standards.

As arranged with your office, unless you publicly announce its contents
earlier, we plan no further distribution of this report until 15 days after
the date of this letter. At that time, we will send copies to the Honorable
Louis Caldera, Secretary of the Army; the Honorable Carol Browner,
Administrator, Environmental Protection Agency; the Honorable Jeb Bush,
Governor of Florida; and other interested parties. We will also make copies
available to others on request.

If you or your staff have any questions, please call me at (202) 512-3841.
Key contributors to this report are listed in appendix IV.

Sincerely yours,

Jim Wells
Director, Energy, Resources,
and Science Issues

Description of the Major Types of Projects Included in the Corps'
Comprehensive Everglades Restoration Plan

The Comprehensive Everglades Restoration Plan (the Plan) was presented to
the Congress in July 1999. As it was presented, the Plan contained 68
projects to modify the Central and Southern Florida Project, which consists
of a system of 1,700 miles of canals and levees and 16 major pump stations
that drain water from the ecosystem and provide water and flood protection
to the developed areas of South Florida. If implemented, the Plan will
increase the region's freshwater supply and improve the delivery and quality
of water to natural areas in the ecosystem.

The Plan, as it was presented to the Congress, consisted of 41 large-scale
projects to modify the Central and Southern Florida Project and 27 smaller
projects that were selected by the Corps, with the assistance of other
federal and state agencies participating in the restoration effort, to
provide immediate environmental improvements. Since the Plan was introduced,
two of the projects have been funded under an authority, called the critical
projects authority, in the 1996 Water Resources Development Act. This
authority allowed the Corps to construct small projects that would have an
immediate environmental effect. As a result, the Plan has 66 projects--25
small-scale projects and 41 large projects. The 41 projects can be generally
categorized by the type of function they will serve in the ecosystem:

ï¿½ Surface storage reservoirs: More than 180,000 acres of reservoirs will
provide 1.5 million acre-feet18 of water storage in areas around Lake
Okeechobee, the Caloosahatchee and St. Lucie rivers, and the Everglades
Agricultural Area and along the lower east coast of Florida.

ï¿½ Aquifer storage and recovery: More than 300 underground wells will be
built to store water at a rate of as much as 1.6 billion gallons a day with
little evaporation loss, for use during dry periods.

ï¿½ Stormwater treatment areas: Approximately 35,600 acres of man-made
wetlands will be built to treat urban and agricultural runoff before it is
discharged to natural areas, including Lake Okeechobee, the Caloosahatchee
River, the Everglades, and Florida's lower east coast. This is in addition
to 47,000 acres of stormwater treatment areas (41,500 acres of effective
treatment area) being constructed by the state in the Everglades
Agricultural Area.19

ï¿½ Seepage management: Millions of gallons of water per day seep underground
or through levees and canals from the Everglades toward the east coast.
Along the eastern side of Everglades National Park and the water
conservation areas, impervious barriers will be built in levees, pumps will
be installed to redirect water back into natural areas, and water levels
will be held higher to prevent such seepage.

ï¿½ Reuse water: Two advanced wastewater treatment plants, which will have
increased capability to remove pollutants from the wastewater, will treat
220 million gallons of water per day in Miami-Dade County for release into
underground aquifers and wetlands along Biscayne Bay.

ï¿½ Removing barriers to sheetflow: More than 240 miles of canals and internal
levees that are part of the original Central and Southern Florida Project
and that lie within the Everglades and the water conservation areas will be
removed to establish the natural broad, shallow flow of water in the
ecosystem.

ï¿½ Operational changes: The delivery of water to different parts of the
ecosystem will be changed to improve the health of Lake Okeechobee and to
enhance the timing of water flows.

Florida's Initiatives to Specifically Address Water Quality in the South
Florida Ecosystem

Outside of the Comprehensive Everglades Restoration Plan (the Plan), Florida
has initiated several efforts specifically designed to address the quality
of water in the Everglades and other natural areas of the South Florida
ecosystem. In addition to developing numeric phosphorus standards, the state
has several ongoing efforts, including the Dairy Rule, the Works of the
District, the 1994 Everglades Forever Act, and the Lake Okeechobee
Protection Program. The following sections describe the details of these
initiatives.

In 1987, the state adopted the Dairy Rule in response to serious water
quality problems contributing to the degradation of Lake Okeechobee. The
water quality problems were determined to be associated, at least in part,
with the nutrient-rich runoff from dairy farms in the Lake Okeechobee basin.
The Dairy Rule requires farm owners in the Lake Okeechobee area, who were
previously exempt from permitting requirements, to obtain permits from the
Florida Department of Environmental Protection. The rule also requires the
dairy farmers to construct waste management systems and to use best
management practices to control runoff from their dairy farms. Runoff from
the area around the barns, which is heavy with animal manure, is collected
and treated as wastewater. Many facilities reuse the wastewater by applying
it to their farmland and using the nutrient-rich water as fertilizer. The
farmers must obtain industrial waste permits that require monitoring of
effluent and groundwater near the application sites.

In the Lake Okeechobee and Everglades basins, Works of the District permits
are required for landowners who discharge water to the canals, rights of
way, lakes, streams and other water resources for which the South Florida
Water Management District (the District) has responsibility. The Lake
Okeechobee permit program uses performance-based phosphorus controls
designed to achieve the annual phosphorus loading targets set for Lake
Okeechobee. The Everglades permit program requires all landowners in the
Everglades Agricultural Area with land that discharges to District works to
obtain a permit, implement best management practices, and monitor the
quality and quantity of water they discharge and provide this information to
the District. If a permit holder fails to comply with the terms of a permit,
the District retains the right to revoke it or take appropriate legal
action.

In 1994, the state enacted the Everglades Forever Act. The legislation was a
result of a lawsuit filed against the state of Florida by the federal
government for allegedly not enforcing its water quality standards in
federal areas such as Everglades National Park. The Florida Legislature
found that the Everglades was endangered by adverse changes in the quality,
quantity, timing, and distribution of water flows. The Legislature also
found that the programs established by the District and the Florida
Department of Environmental Protection to improve the tributary waters of
the Everglades were not being implemented in a timely manner. The waters
flowing into the Everglades contained excessive levels of phosphorus that
endangered the flora and fauna of the Everglades. The act established an
Everglades Protection Area that includes Everglades National Park and the
state water conservation areas. The act is intended to expedite the state's
plans and programs for improving water quality and quantity in this area;
provide water supply for Everglades National Park, urban and agricultural
areas, and Florida Bay; and replace water previously available from the
coastal ridge in areas of southern Dade County.

The long-term goal of the Everglades Forever Act is to ensure that waters
discharged into the Everglades Protection Area achieve water quality
standards by December 31, 2006. The act directs the state to review existing
water quality standards and to establish a numeric criterion for phosphorus
in the Everglades Protection Area. The long-term goal is to reduce
phosphorus discharges to levels that do not cause an imbalance in natural
populations of aquatic plants and animals. Although the standard for
phosphorus has not yet been set, the Everglades Forever Act provides a
default standard of 10 parts per billion if a standard is not adopted by
December 31, 2003. In addition, the act requires farmers in the Everglades
Agricultural Area to implement best management practices to reduce
pollutants in runoff from their farms and to pay an Agricultural Privilege
Tax to fund the construction of stormwater treatment areas to provide
additional water quality treatment. The Everglades Forever Act establishes a
monitoring program to determine the effectiveness of best management
practices, which are determined by the District in cooperation with the
Florida Department of Environmental Protection. Finally, the act also
requires the state to implement advanced water quality treatment measures
and increase the amount of water flowing to the Everglades by 28 percent.

The Everglades Forever Act establishes a state plan to restore significant
portions of the remaining Everglades ecosystem, including a program of
construction projects, research, and regulation. A critical element of this
program is the Everglades Construction Project, whose primary component
consists of six large stormwater treatment areas. The treatment areas will
encompass 47,000 acres, of which about 40,000 acres were once used as
farmland, and will reduce the phosphorus content of stormwater runoff from
the Everglades Agricultural Area and some releases from Lake Okeechobee into
the Everglades Protection Area. (Fig. 3 shows the location of the stormwater
treatment areas.)

Source: GAO's adaptation of an illustration prepared by the South Florida
Water Management District.

Under a consent decree settling the lawsuit between the federal and state
governments, the District is responsible for the design and construction of
five of the stormwater treatment areas, and the Corps is responsible for the
design and construction of one area. In conjunction with best management
practices, the treatment areas are designed to reduce phosphorus
concentrations to an interim target of 50 parts per billion. The long-term
target is to reduce phosphorus concentrations to achieve and maintain
compliance with the long-term water qualty standard that the state will
establish. As of August 2000, the District had completed the construction of
over 18,000 acres of wetlands in four treatment areas, and it will begin
constructing the fifth area within several months. The Corps began
constructing the sixth treatment area this year. Achieving the long-term
standards may require future modification of treatment areas.

The Everglades Stormwater Program was established by the District after the
Florida Legislature passed the Everglades Forever Act of 1994 to improve
water quality in basins not addressed by the Everglades Construction
Project. The program includes two main components, the Everglades
Agricultural Area phosphorus reduction program and the Urban and Tributary
Basins Program. The District's staff is working with local governments,
state and federal agencies, drainage districts, Indian tribes, affected
landowners, and members of the general public in these efforts.

The goal of the Everglades Agricultural Area phosphorus reduction program is
to reduce by 25 percent the annual phosphorus load--that is, the mass of
phosphorus mixed in with runoff--discharging into the Everglades from the
area. The program includes regulatory programs developed to reduce
phosphorus loads from the area by reducing phosphorus on the surrounding
farms and other adjacent land. The 25-percent reduction goal is to be
accomplished by implementing best management practices that eliminate or
reduce pollutants at their source rather than treating stormwater runoff
downstream. The best management practices in use include new methods of
fertilizing farms, detaining stormwater runoff, controlling sediments, and
other management methods that prevent or reduce the introduction of
pollutants into surface waters. The District has issued each farm parcel
within the Everglades Agricultural Area a permit that details the best
management practices and water quality monitoring program being implemented
on each farm. Records are kept to ensure accurate implementation of the
practices, and each farm must also measure the flow and phosphorus level of
water discharging from the farm. If the discharges from the Everglades
Agricultural Area into the Everglades meet the 25-percent reduction goal,
then the area is determined to be in compliance with the District's permits,
and the farmers receive state tax credits. If the discharges do not meet the
goal, the individual farms with the highest measured phosphorus discharges
are identified and required to implement additional best management
practices. According to recent water monitoring data, the farmers have
reduced phosphorus loading for 1997 through 1999 by an average of 44 percent
(19 percent above the required 25-percent level).

The Urban and Tributary Basins Program was developed to ensure that eight
basins discharging into the Everglades other than those included in the
Everglades Agricultural Area meet state water quality standards. The program
identifies schedules and strategies for achieving compliance by December 31,
2006. It tests over 250 pollutants (such as phosphorus, metals and
pesticides) at more than 40 structures that discharge water into, within, or
from the Everglades Protection Area. The District is required to collect,
review, and evaluate the water quality data in order to measure progress
toward achieving compliance with state water quality standards. In
particular, a key goal of the program is to lower phosphorus concentrations
in the water discharged from these basins to comply with the state's
long-term water quality standard. If the Florida Department of Environmental
Protection does not establish a standard by December 31, 2003, the default
will be 10 parts per billion. For the period from May 1, 1998, through April
30, 1999, phosphorus concentrations were well below 50 parts per billion at
most structures.

On May 16, 2000, the state enacted the Everglades Restoration Investment
Act, which represents the state's commitment to paying 50 percent of the
costs of the Corps' Comprehensive Everglades Restoration Plan. The
provisions of the law indicate that, over the next decade, more than $2
billion in state and local resources will be directed toward restoration.
Through the newly created "Save Our Everglades Trust Fund," resources will
be carried forward across fiscal years to help ensure that resources will be
available when needed. The law also requires accountability based on
performance for all involved in restoration activities.

Trust Fund

Also enacted on May 16, 2000, were two pieces of legislation dealing with
the restoration of Lake Okeechobee. One act created the Lake Okeechobee
Protection Program, which is intended to achieve and maintain compliance
with state water quality standards for the lake through a phased,
comprehensive program to reduce phosphorus levels both in the lake and
outside of it. The act requires that the state's actions to clean up Lake
Okeechobee be coordinated with, and if possible, developed through the
Corps' Plan. The program will proceed in a phased approach and will commit
the state to a long-term effort to construct new water containment and
treatment structures to better control phosphorus at its source. An initial
focus will be to cooperate with landowners around the lake basin to promote
existing efforts to reduce and control the release of excess phosphorus from
their farms. The act provides for

ï¿½ a watershed phosphorus control program, calling for the phased
implementation of phosphorus load reductions, a total maximum daily load
proposal, and the formal establishment of restoration goals;

ï¿½ a phased protection plan that will include the accelerated construction of
stormwater treatment areas and the restoration of isolated wetlands;

ï¿½ an internal phosphorus management and control program, which uses best
management practices for agricultural and nonagricultural sources of
pollution that do not come from wastewater treatment or other specific
points of discharge;

ï¿½ a comprehensive research and water quality monitoring program;

ï¿½ the identification and eradication of invasive exotic species; and

ï¿½ the completion of a feasibility study on the removal of phosphorus-laden
sediment in the lake.

A second piece of legislation created the Lake Okeechobee Protection Trust
Fund to pay primarily for the requirements of the Protection Program. Trust
funds will be appropriated annually by the Legislature. Of the $38.5 million
that will be spent on Lake Okeechobee this year, $15 million will be spent
to research, develop, demonstrate, and implement best management practices
and other measures to improve Lake Okeechobee's water quality. The remaining
$23.5 million will be used to implement the Source Control Grant Program,
restore isolated wetlands, retrofit water control structures, and buy land
to construct a reservoir-assisted stormwater treatment area in the
watershed.

Comments From the State of Florida

GAO Contact and Staff Acknowledgments

Barry Hill (202) 512-3841

Steve Elstein, Melissa Francis, Susan Iott, Chet Janik, Patricia McClure,
and Sherry McDonald also made key contributions to this report.

(141449)

Figure 1: Relationship of Federal and State Agencies and
Tribes Involved in Implementing the Plan to
Improve Water Quality in the South Florida Ecosystem 11

Figure 2: Location of the Plan's Water Quality Projects 15

Figure 3: Location of Everglades Construction Project Stormwater Treatment
Areas 39
  

1. The Plan includes 68 projects, but 2 of these projects were funded under
another program's authority. As a result, there are 66 projects remaining in
the Plan. Many of the projects have multiple purposes and contain multiple
features. Throughout this report, we use the term "projects" to refer to the
66 projects and their features.

2. The Corps estimates that most projects will be completed within 20 years;
however, the projected time frames for two large reservoir projects extend
over 35 years. According to Corps officials, appropriation levels will
affect these time frames.

3. South Florida Ecosystem Restoration: An Overall Strategic Plan and a
Decision-Making Process Are Needed to Keep the Effort on Track
(GAO/RCED-99-121 , Apr. 22, 1999) and South Florida Ecosystem Restoration: A
Land Acquisition Plan Would Help Identify Lands That Need to Be Acquired
(GAO/RCED-00-84 , Apr. 5, 2000).

4. The state has three water conservation areas that comprise about 1,350
square miles of land south of Lake Okeechobee. These areas--one of which is
managed by the U.S. Fish and Wildlife Service as a national wildlife
refuge--are natural areas of remnant Everglades that are used for multiple
purposes, such as storing water that has been discharged from Lake
Okeechobee and other sources. The areas also serve as a source of water for
Everglades National Park, the lower east coast agricultural lands, and urban
areas.

5. The administration's proposal also asks the Congress to authorize 4 pilot
projects, 10 initial projects, and 25 smaller projects that will have
immediate benefits if implemented.

6. Design work is already progressing under the authority of an existing
design agreement between the Corps and the District.

7. Although the South Florida Water Management District is the primary
nonfederal sponsor, as many as five counties and city governments and Native
American tribes could also serve as nonfederal sponsors for portions of the
Plan. The Seminole Tribe of Florida signed a project coordination agreement
with the Corps in Jan. 2000 to implement a water resources project on its
Big Cypress Reservation.

8. Enacted in 1972, the Federal Water Pollution Control Act is commonly
called the Clean Water Act (33 U.S.C. 1251-1387).

9. The state indicated that there are questions about the process and data
used to achieve this listing. GAO has reported on the inaccuracy of the data
used by the states to report impaired waters in Water Quality: Key EPA and
State Decisions Limited by Inconsistent and Incomplete Data (GAO/RCED-00-54
, Mar. 15, 2000).

10. Florida's schedule has been adjusted to reflect the results of a lawsuit
against EPA for not reviewing the establishment of total maximum daily loads
in the state. The state has rescheduled the establishment of some total
maximum daily loads to meet the schedule set in the consent decree settling
the lawsuit.

11. The Everglades Forever Act codifies much of a consent decree
establishing a settlement agreement between the United States and the state.
The consent decree settled a lawsuit against the state for not enforcing its
water quality standards in federal areas.

12. Under the consent decree cited in footnote 11, the state will build five
of these areas and the federal government will build one.

13. Most of the small-scale projects were selected from the list of critical
projects compiled under the 1996 Water Resources Development Act that
allowed the Corps to construct small projects that would have an immediate
environmental effect. This list of critical projects was developed by the
South Florida Ecosystem Restoration Task Force, and about half of them have
been funded. In addition, some small-scale projects were selected from a
list of projects submitted by the Florida Governor's Commission's Conceptual
Plan for ecosystem restoration and from suggestions by the scientists and
agency officials compiling the Plan.

14. An acre-foot of water is equal to about 326,000 gallons of water--enough
to cover 1 acre to a depth of 1 foot.

15. The Miccosukee Tribe adopted a phosphorus standard of 10 parts per
billion for its lands in the water conservation area. In May 1999, EPA
approved that standard determining that the Tribe's 10-parts-per-billion
criterion is protective of the water's designated use, is reasonable and is
scientifically defensible.

16. The Lake Trafford project was funded as a critical project.

17. Coordinating Success: Strategy for Restoration of the South Florida
Ecosystem, July 31, 2000.

18. An acre-foot of water is equal to about 326,000 gallons of water--enough
to cover 1 acre to a depth of 1-foot.

19. The Everglades Agricultural Area consists of 1,122 square miles of
highly productive agricultural land directly south of Lake Okeechobee and
north of the state's water conservation areas.
*** End of document. ***