GAO

United States General Accounting Office

Report to the Chairman, Subcommittee

on Transportation and Infrastructure,

Committee on Environment and Public

Works, U.S. Senate

September 2000 COMPREHENSIVE

EVERGLADES

RESTORATION PLAN

Additional Water

Quality Projects May

Be Needed and Could

Increase Costs

GAO/RCED-00-235

Page 1 GAO/RCED-00-235 South Florida Water Quality

Contents

Letter 3

Appendixes 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

Figures 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

Abbreviations

EPA Environmental Protection Agency

GAO General Accounting Office

RCED Resources, Community, and Economic Development Division
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United States General Accounting Office

Washington, D.C. 20548

Resources, Community, and

Economic Development Division

B-285227 Letr

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.
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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

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.
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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.

Results in Brief 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

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).
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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
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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.

Background 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
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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

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.
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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

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).
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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.
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Figure 1: Relationship of Federal and State Agencies and Tribes Involved in

Implementing the Plan to Improve 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.

Environmental Protection Agency:

responsible for water quality regulation, research 

and monitoring under Clean Water Act

Plan projects: 

Water Resources Development acts

Designing and building the projects

Advising and overseeing the projects

water quality

Delegated

oversight

authority

Miccosukee and

Seminole Tribes

Florida Department of

Environmental Protection

U.S. Army Corps of Engineers:

federal sponsor

South Florida Water Mangement

District: state sponsor
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The Projects in the

Corps’ Plan

Supplement Florida’s

Efforts to 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.
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Florida Has Primary

Responsibility for

Addressing Water Quality in

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

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).

10Florida’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.

11The 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.

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

the federal government will build one.
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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.

Corps’ Plan Includes

Projects to Address Some

Water Quality Concerns

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.
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Figure 2: Location of the Plan’s Water Quality Projects

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

0 10 20 30

Miles

Florida Bay

Stormwater 

treatment 

areas

Advanced 

wastewater

treatment 

areas

Smaller 

 projects

Water

conservation

areas

Big Cypress

National

Preserve

Portion of

Everglades

National

Park

Fort

Lauderdale

West

Palm

Beach

Ft. Myers

Orlando

Miami

Biscayne Bay

Lake

Okeechobee

Kissim

mee River

St. Lucie River

Caloosahatchee River

Florida Keys

National Marine

Sanctuary
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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.
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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.

Resolution of Project

Uncertainties and

Outcomes of Studies

May Lead 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.

Resolution of

Implementation

Uncertainties

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

13Most 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.

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

a depth of 1 foot.
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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

15The 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.
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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 followon 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
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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.

Impact of Ongoing and

Planned Studies

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.
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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
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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
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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.
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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.

16The Lake Trafford project was funded as a critical project.
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The Plan Includes a Process

for Incorporating and

Reporting Change

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.

Conclusions 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
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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.

Recommendation 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.

Agency Comments and

Our Evaluation

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.
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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.
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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.
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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.

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

2000.
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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
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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.

Scope and

Methodology

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.
B-285227

Page 32 GAO/RCED-00-235 South Florida Water Quality

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.
B-285227

Page 33 GAO/RCED-00-235 South Florida Water Quality

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
Page 34 GAO/RCED-00-235 South Florida Water Quality

Appendix I

Description of the Major Types of Projects Apendxies

Included in the Corps’ Comprehensive

Everglades Restoration Plan ApendxiI

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:

• Surface storage reservoirs: More than 180,000 acres of reservoirs will

provide 1.5 million acre-feet1 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.

• 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.

1

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.
Appendix I

Description of the Major Types of Projects

Included in the Corps’ Comprehensive

Everglades Restoration Plan

Page 35 GAO/RCED-00-235 South Florida Water Quality

• 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.2

• 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.

• 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.

• 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.

• 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.

2

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.
Page 36 GAO/RCED-00-235 South Florida Water Quality

Appendix II

Florida’s Initiatives to Specifically Address

Water Quality in the South Florida Ecosystem ApendxiI

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.

The Dairy Rule 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.

Works of the District 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.
Appendix II

Florida’s Initiatives to Specifically Address

Water Quality in the South Florida

Ecosystem

Page 37 GAO/RCED-00-235 South Florida Water Quality

Everglades Forever Act 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.

Everglades Construction

Project

The Everglades Forever Act establishes a state plan to restore significant

portions of the remaining Everglades ecosystem, including a program of
Appendix II

Florida’s Initiatives to Specifically Address

Water Quality in the South Florida

Ecosystem

Page 38 GAO/RCED-00-235 South Florida Water Quality

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.)
Appendix II

Florida’s Initiatives to Specifically Address

Water Quality in the South Florida

Ecosystem

Page 39 GAO/RCED-00-235 South Florida Water Quality

Figure 3: Location of Everglades Construction Project Stormwater Treatment Areas

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

0 10 20 30

Miles

South Florida

Water Management

District boundary

Everglades

Agricultural Area 

Water

conservation areas

Everglades

Construction

Program:

stormwater 

treatment areas

Urban area

Portion of

Everglades

National Park

Florida Bay

Florida Keys

National Marine

Sanctuary

Lake

Okeechobee

K

si s

mi mee

River St. Lucie River

Caloosahat chee River

Cypress Seminole 

Indian reservation

Miccosukee 

Indian reservation
Appendix II

Florida’s Initiatives to Specifically Address

Water Quality in the South Florida

Ecosystem

Page 40 GAO/RCED-00-235 South Florida Water Quality

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.

Everglades Stormwater

Program

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
Appendix II

Florida’s Initiatives to Specifically Address

Water Quality in the South Florida

Ecosystem

Page 41 GAO/RCED-00-235 South Florida Water Quality

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.

Everglades Restoration

Investment Act

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.
Appendix II

Florida’s Initiatives to Specifically Address

Water Quality in the South Florida

Ecosystem

Page 42 GAO/RCED-00-235 South Florida Water Quality

Lake Okeechobee

Protection Program

and Lake Okeechobee

Protection 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

• 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;

• a phased protection plan that will include the accelerated construction

of stormwater treatment areas and the restoration of isolated wetlands;

• 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;

• a comprehensive research and water quality monitoring program;

• the identification and eradication of invasive exotic species; and

• 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,
Appendix II

Florida’s Initiatives to Specifically Address

Water Quality in the South Florida

Ecosystem

Page 43 GAO/RCED-00-235 South Florida Water Quality

retrofit water control structures, and buy land to construct a reservoirassisted stormwater treatment area in the watershed.
Page 44 GAO/RCED-00-235 South Florida Water Quality

Appendix III

Comments From the State of Florida ApendxiI
Appendix III

Comments From the State of Florida

Page 45 GAO/RCED-00-235 South Florida Water Quality
Appendix III

Comments From the State of Florida

Page 46 GAO/RCED-00-235 South Florida Water Quality
Appendix III

Comments From the State of Florida

Page 47 GAO/RCED-00-235 South Florida Water Quality
Appendix III

Comments From the State of Florida

Page 48 GAO/RCED-00-235 South Florida Water Quality
Page 49 GAO/RCED-00-235 South Florida Water Quality

Appendix IV

GAO Contact and Staff Acknowledgments ApendxiIV

GAO Contact Barry Hill (202) 512-3841

Acknowledgments Steve Elstein, Melissa Francis, Susan Iott, Chet Janik, Patricia McClure,

and Sherry McDonald also made key contributions to this report.

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