GAO

United States General Accounting Office

Report to Congressional Requesters

April 2000 SOUTH FLORIDA

ECOSYSTEM

RESTORATION

A Land Acquisition

Plan Would Help

Identify Lands That

Need to Be Acquired

GAO/RCED-00-84

Page 1 GAO/RCED-00-84 South Florida Ecosystem Restoration

Contents

Letter 3

Appendixes Appendix I: Members of the South Florida Ecosystem Restoration

Task Force 34

Appendix II: Federal and State Land Acquisition 36

Appendix III: Comments From the Department of the Interior 43

Appendix IV: Comments From the State of Florida 55

Appendix V: GAO Contact and Staff Acknowledgments 67

Tables Table 1: Land Acquisition by Federal and State Agencies and

Programs for the South Florida Ecosystem Restoration Initiative,

Fiscal Years 1996-99 13

Table 2: Farm Bill Grants and the State's Dollar Match 21

Figures Figure 1: The Everglades—Past and Present 7

Figure 2: Location of Lands Acquired With Farm Bill Funds 20

Abbreviations

CARL Conservation and Recreation Lands

GAO General Accounting Office

SOR Save Our Rivers

USDA U.S. Department of Agriculture
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United States General Accounting Office

Washington, D.C. 20548

Resources, Community, and Economic

Development Division

B-284599 Letr

April 5, 2000

Congressional Requesters

The South Florida Ecosystem Restoration Initiative is a complex, long-term

effort to restore the South Florida ecosystem, which includes the

Everglades, that involves federal, state, local, and tribal entities, as well as

public and private interests. In response to growing signs of the

ecosystem’s deterioration, federal agencies established the South Florida

Ecosystem Restoration Task Force in 1993 to coordinate ongoing federal

restoration activities. The Water Resources Development Act of 1996

formalized the Task Force, designated the Secretary of the Interior as its

chair, and expanded its membership to include state, local, and tribal

representatives. The Task Force is charged with coordinating and

facilitating the overall restoration initiative. Restoring the ecosystem,

which covers 18,000 square miles, or about 11.5 million acres, will take at

least 20 years and will require the continuous effort and commitment of all

the agencies involved.

A key component of the restoration initiative is acquiring lands. Land

acquisition is the critical first step in a series of activities−storing water

needed to restore natural hydrology, building water quality treatment areas,

restoring lost and altered habitats, and curtailing the outward growth of

urban areas (sprawl) and making urban spaces more livable by acquiring

green space. All of these activities are essential to accomplishing the goals

of the initiative. Yet opportunities to acquire undeveloped lands in South

Florida are diminishing, and some key lands face pressure from

development. To date, federal and state agencies have acquired lands using

their own funding and priorities or expending grant funds provided to the

state by the Department of the Interior. In particular, since 1983, the state

has carried out the comprehensive “Save Our Everglades” program to

protect and restore the South Florida ecosystem and has had several land

acquisition programs ongoing under state legislation. In addition, since

1996, when the federal and state governments began their joint restoration

initiative, the state agencies have acquired lands using grants from two

sources—$200 million provided to the Secretary of the Interior by the

Federal Agriculture Improvement and Reform Act of 1996 (Farm Bill) and

$151 million in appropriations from the Land and Water Conservation Fund

from fiscal year 1998 through fiscal year 2000. The federal government
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generally has required, through legislation or other agreements, that the

state match the funds provided through these grants.

Because of the importance of land acquisition to the success of the

restoration initiative, you asked us to determine (1) what the South Florida

Ecosystem Restoration Task Force did to identify and acquire lands needed

to accomplish the goals of the initiative from 1996 through 1999 and (2)

what the Department of the Interior did to help ensure that it maximized

the acreage purchased—that is, bought as much land as possible, with $200

million in Farm Bill grants. While moneys from another federal source, the

Land and Water Conservation Fund, have also been authorized for land

acquisition grants to the state, some of these funds did not require a cost

share, and the majority of the remaining funds have not yet been expended.

Of the $151 million available, $46 million was granted to the state from 1998

appropriations under a legal settlement requiring the federal government to

fully fund the acquisition of lands for a storm water treatment area. The

remaining funds—$105 million provided in 1999 and 2000—are subject to a

state matching requirement, but as of February 2000, only $3.8 million had

been expended.

This is our second report on the South Florida Ecosystem Restoration

Initiative. In April 1999, we reported on the federal funding provided for

this initiative and on how well the initiative was being coordinated and

managed.1

Results in Brief The South Florida Ecosystem Restoration Task Force has established

ecosystem restoration goals and identified land acquisition as critical to

achieving them, but it cannot acquire lands on its own. Instead, it must

accomplish its objectives through the participating federal and state

agencies. This puts a premium on having a systematic acquisition plan and

effective communication and coordination among the Task Force

members. However, the Task Force has not yet developed a land

acquisition plan that identifies all of the lands needed to accomplish the

goals of the restoration initiative; each federal and state agency has made

independent acquisition decisions. From fiscal year 1996 through fiscal

year 1999, these agencies acquired about 541,300 acres for the restoration

initiative. Without a land acquisition plan, the Task Force cannot (1)

1

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).
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identify all the lands needed for the restoration initiative, (2) reasonably

estimate the cost of land acquisition for the initiative, (3) measure progress

in acquiring lands for the restoration, or (4) increase the chances that the

lands being acquired are needed for the restoration initiative. For these

reasons, and because most of the information needed to develop the

framework for a land acquisition plan is available, this report recommends

that the Task Force develop a land acquisition plan that includes an

assessment of the lands needed to accomplish the initiative’s goals.

To maximize the acreage acquired with $200 million in Farm Bill grants, the

Department of the Interior developed a cost-sharing policy that required

the state of Florida to match the federal funds dollar for dollar. Under this

policy, the Secretary of the Interior retained the authority to waive the

matching requirement. Interior approved four grants, one of which the

state matched dollar for dollar. For the other three grants, the Secretary

waived the matching requirement or accepted lands in place of funds. The

state had already acquired, or was in the process of acquiring, these lands

that it used for matching purposes. Had Interior consistently applied its

cost-sharing policy, we calculate that an additional $77 million would have

been available for land acquisition. According to Interior officials, the

agency did not always apply its cost-sharing policy because it wanted to

give the state credit for lands that it had already acquired or was in the

process of acquiring.

Background The South Florida ecosystem extends from the Chain of Lakes south of

Orlando to the reefs southwest of the Florida Keys. This vast region, which

is home to more than 6 million Americans, a huge tourism industry, and a

large agricultural economy, also encompasses one of the world’s unique

environmental resources—the Everglades. Before human intervention,

freshwater moved south from Lake Okeechobee to Florida Bay in a broad,

slow-moving sheet. The quantity and timing of the water’s flow depended

on rainfall patterns and on slow releases of stored water. Even during dry

seasons, water stored throughout the vast area of the Everglades supplied

water to wetlands and coastal bays and estuaries. For centuries, the

Everglades provided habitat for many species of wading birds and other

native wildlife, including the American alligator, which depended on the

water flow patterns that existed before human intervention.

Following major droughts from the early 1930s through the mid-1940s and

drenching hurricanes in 1947, the Congress authorized the Central and

Southern Florida Project in 1948. The project, an extensive system of over
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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. However, as shown in

figure 1, the engineering changes from the Central and Southern Florida

Project, coupled with agricultural and industrial activities and

urbanization, have reduced the Everglades to about half its original size

and have had a detrimental effect on wildlife habitats and water quality.

The loss of habitats has caused sharp declines in native plant and animal

populations, placing many native species at risk.
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Figure 1: The Everglades—Past and Present

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

0 10 20 30

Miles

Historic Ecosystem

Lake

Okeechobee

Everglades

Florida Bay

Kissimmee

River

River

South Florida

Water Management

District Boundary

Everglades

Agricultural Area 

Water

Conservation Areas

Urban Area

Portion of

Everglades

National Park

Florida Bay

Florida Keys

National Marine

Sanctuary

Kissimmee

Fragmented Ecosystem

Lake

Okeechobee
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Recognizing that the natural system had been damaged, the federal and

state governments began efforts to acquire and protect lands in southern

Florida. Since 1947, when lands for Everglades National Park were

acquired, numerous federal, state, and county holdings have been set aside.

These include three other national parks or preserves, 30 state parks, 16

wildlife refuges, and 19 aquatic sanctuaries or preserves in South Florida.

According to state officials, from 1947 through 1995, the state acquired

about 3.1 million acres—many of which were conveyed to the federal

government to be managed as national parks and preserves. During the

same period, the federal government acquired about 1.0 million acres. The

state of Florida has also taken a number of actions to restore the

ecosystem, including the passage of the Florida Everglades Protection Act

in 1991 and the Florida Everglades Forever Act in 1994.2

Despite these efforts, the ecosystem continued to deteriorate, and efforts

to restore it have escalated. The Water Resources Development Act of 1992

authorized the U.S. Army Corps of Engineers (Corps) to review the Central

and Southern Florida Project. This review, commonly known as the

Restudy, was to determine if the project should be changed to restore the

South Florida ecosystem. In 1993, the administration made the restoration

of the Everglades and the South Florida ecosystem one of its highest

environmental priorities. Through an interagency agreement, federal

agencies established the South Florida Ecosystem Restoration Task Force

to facilitate the development of consistent policies, strategies, priorities,

and plans for addressing concerns about the ecosystem. The Water

Resources Development Act of 1996 directed the Corps to continue its

review of the Central and Southern Florida Project and to develop a plan

for restoring, preserving, and protecting the South Florida ecosystem. The

act also formalized the Task Force; expanded its membership to include

state, local, and tribal representatives; and designated the Secretary of the

Interior as the group’s chair. Appendix I lists the federal, state, tribal, and

local governments represented on the Task Force.

To accomplish the restoration initiative, the Task Force established the

following three goals:

2

The Florida Everglades Protection Act, passed in 1991, provided water management

districts with tools for restoring ecosystems. The Florida Everglades Forever Act, passed in

1994, established a plan to restore significant portions of the South Florida ecosystem

through construction, research, and regulation.
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• Getting the water right, which means restoring more natural hydrologic

functions of the ecosystem while providing adequate water supplies and

flood control. The goal is to deliver the right amount of water, of the

right quality, to the right places at the right times. This goal will be

accomplished primarily by modifying the Central and Southern Florida

Project to enlarge the region’s freshwater supply and to improve the

delivery of water to natural areas.

• Restoring and enhancing the natural system, which means restoring lost

and altered habitats and changing current land uses. Natural habitats

have become disconnected through growth and development, and the

cumulative loss of habitat and spread of invasive species have caused

sharp declines in native plant and animal populations. As of May 1999,

68 native plant and animal species were federally listed as threatened or

endangered. Restoring habitats and species will require acquiring lands

or changing current land uses. Restoring habitats and species will also

require reestablishing the physical and biological connections between

parts of the natural system.

• Transforming the built environment, which means rebuilding and

revitalizing urban cores to curtail outward sprawl. This third restoration

goal involves decreasing the impact of development on the natural

system in a way that balances human needs with those of the natural

environment. This will entail rebuilding or revitalizing urban cores to

curtail the outward sprawl of suburbs and development. It will also

involve making urban areas more livable by creating green spaces (i.e.,

parks, trail systems, or greenways that function for both wildlife and

people), improving transit systems, and providing jobs and affordable

housing.

To carry out its duties, the Task Force established a Florida-based working

group that includes representatives of the agencies and entities

represented on the Task Force, as well as other governmental entities as

appropriate. The working group directs the tasks associated with the South

Florida ecosystem’s restoration and provides strategic oversight and

program management for all South Florida ecosystem restoration

activities.

In our 1999 report on the South Florida Ecosystem Restoration Initiative,

we reported that the Task Force had not developed a strategic plan that

outlined how this complex, long-term restoration initiative would be

accomplished. We recommended that the Secretary of the Interior, as the

Chairperson of the South Florida Ecosystem Restoration Task Force, in

conjunction with the other members of the Task Force, develop a strategic
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plan that would outline how the restoration of the ecosystem wouldoccur.

We also recommended that the Task Force work with organizations and

entities participating in the restoration initiative to develop and agree on a

decision-making process to resolve conflicts. The Congress included

language in the Conference Report accompanying the Department of the

Interior and Related Agencies Appropriations Act for Fiscal Year 2000 that

requires the Secretary of the Interior to develop a regionwide strategic plan

and recommendations for resolving the most difficult conflicts. The

strategic plan is to be submitted to the House and Senate Appropriations

Committees by July 31, 2000. The recommendations on conflict resolution

were to be submitted by February 15, 2000; Interior submitted

recommendations to the Committees on February 28, 2000.

Task Force Cannot

Identify Lands Needed

for Restoration

Because It Has Not

Developed a Land

Acquisition Plan

The South Florida Ecosystem Restoration Task Force cannot acquire lands

on its own. Instead it must accomplish its objectives through the

participating federal and state agencies. This puts a premium on having a

systematic acquisition plan and effective communication and coordination

among members of the Task Force. However, the Task Force has not yet

developed a land acquisition plan that identifies all of the lands needed to

accomplish the goals of the restoration initiative. A land acquisition plan,

which would supplement the strategic plan we recommended in our 1999

report, would also provide a blueprint of the lands necessary to achieve the

goals of the restoration initiative and enable the Task Force to provide the

Congress and the state of Florida with reasonable estimates of the acreage

needed and of the costs of the land acquisition. Although it has not yet done

so, the Task Force should be able to develop a framework for a land

acquisition plan by using land acquisition information and assessments

already available through the federal and state agencies.

Task Force Relies on

Federal and State Agencies

to Identify and Acquire

Lands

The Task Force relies on the multiple federal and state agencies to identify

and acquire lands, but it has not developed a plan that incorporates all of

their efforts. The lands that will be acquired for the restoration initiative

will not be acquired by the Task Force, but by the federal and state land

management agencies that have the authority to acquire and manage lands

for these purposes.3 The Task Force, as an entity, cannot acquire lands

3

In addition, numerous local governments in South Florida can acquire land, including the

governments of Miami-Dade, Palm Beach, and Martin counties and of the city of Miami.
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because it was not granted such authority when it was formally established

by the 1996 Water Resources Development Act. The federal and state

agencies that have acquired, and will continue to acquire, lands for the

restoration initiative include the U.S. Fish and Wildlife Service, the National

Park Service, the Florida Department of Environmental Protection, and the

South Florida Water Management District. The land acquisition programs

of these agencies are described in more detail in appendix II.

Each of the federal agencies identifies lands to be acquired to fulfill the

objectives of its individual programs and acquires lands under different

authorities. The Park Service—which manages lands to preserve, protect,

and interpret the nation’s natural, cultural, and historic resources—and the

Fish and Wildlife Service—which manages lands primarily to conserve

animals and plants—each acquire lands to create and expand parks and

refuges. Parks and refuges are usually created or expanded through

congressional authorization, although the Fish and Wildlife Service accepts

donated lands and lands acquired from other agencies. For example, under

legislation passed in 1989, the Park Service is acquiring lands in South

Florida to expand the boundaries of Everglades National Park, and the Fish

and Wildlife Service is seeking congressional approval to use moneys from

the Land and Water Conservation Fund4 to buy nonfederally owned lands

within one refuge’s boundaries and to expand several other refuges.

Like the federal programs, the state programs acquire lands for different

purposes and under different authorities. The Florida Department of

Environmental Protection, primarily through its Conservation and

Recreation Lands program, acquires lands throughout the state to conserve

animals, plants, and habitats and to provide for nature-based recreational

opportunities. On the other hand, the South Florida Water Management

District acquires lands primarily to protect the water resources of South

Florida. It operates under state legislation authorizing water management

districts and their acquisition of lands to protect water resources. In

addition, the South Florida Water Management District acquires lands as

the local sponsor for the Army Corps of Engineers. Together, the Corps and

the District will be responsible for the over 60 projects proposed in the

Restudy, if the Congress authorizes the Restudy.

4

The Land and Water Conservation Act of 1965, as amended, created the Land and Water

Conservation Fund and authorizes appropriations from the Fund for (1) matching grants to

states for outdoor recreation projects and (2) land acquisition for various federal agencies.
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Just as the federal and state agencies have different authorities and

different objectives, each of the four agencies has its own budget and

system of priorities for land acquisition. Each of the federal agencies

receives separate appropriations from the Land andWater Conservation

Fund to acquire lands on its list of priorities. Both the Park Service and the

Fish and Wildlife Service have a national priority list that incorporates and

ranks acquisitions proposed by the field offices. The state agencies receive

funds primarily from the Florida Preservation Trust Fund, which provides

about $300 million a year for land acquisition throughout the state.5 Each of

the programs has a process for accepting and ranking land acquisition

proposals, although the Conservation and Recreation Lands program

focuses on acquiring lands for conservation and recreation while the

District concentrates on acquiring lands for water-related purposes.

These agencies have already acquired lands that the Task Force agrees will

be used for the restoration initiative. From fiscal year 1996 through fiscal

year 1999, the agencies acquired about 541,300 acres. Table 1 shows the

agencies and programs acquiring lands, the acreage acquired, and the funds

expended.

5

The Florida Preservation Trust Fund was created by the Preservation 2000 Act. Enacted in

1990, the Preservation 2000 Act created a coordinated land acquisition program to protect

the integrity of ecological systems and provide multiple benefits, including the preservation

of fish and wildlife habitat, recreation space, and water recharge areas. The act provided

about $300 million per year for land acquisition. The Preservation 2000 Act was reauthorized

in 1999 as the Florida Forever Act.
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Table 1: Land Acquisition by Federal and State Agencies and Programs for the

South Florida Ecosystem Restoration Initiative, FiscalYears 1996-99

Dollars in millions

a

The data presented on acreage acquired and funds expended by the state agencies and programs

are by calendar years. The data presented for the federal agencies and programs and Farm Bill funds

are by fiscal years. The federal data presented are as of September 1999.

b

The Land and Water Conservation Fund grant to the state is included here because the lands

acquired with the funds are part of a settlement with the state under which the federal government

agreed to buy lands for storm water treatment areas.

c

Includes 108,000 acres that were part of the Florida-Arizona Land Exchange. In this exchange,

Interior traded 111 acres in downtown Phoenix for 83,000 acres to be added to the Big Cypress

National Preserve, 4,000 acres to be added to the Florida Panther National Wildlife Refuge, and

21,000 acres to create the Ten Thousand Islands National Wildlife Refuge.

Source: Prepared by GAO from data provided by participating federal and state agencies.

According to Task Force officials, the acreage acquired with the Farm Bill

funds will be used for water projects associated with the first goal, getting

the water right. The Task Force officials said that the lands acquired for

this goal would also support the second goal by providing habitat benefits,

particularly by creating or improving wetlands. According to Task Force

officials, the acreage acquired by the South Florida Water Management

District will be used mostly for water projects associated with the Task

Force’s first restoration goal. The acreage acquired by the state

Conservation and Recreation Lands program and the lands acquired by the

National Park Service and the Fish and Wildlife Service will be used for

habitat under the second goal.

Agency/programa Acreage acquired Funds expended

Department of the

Interior/state of Florida

(Farm Bill/state match) 73,617 $229

Department of the Interior

(National Park Service, Fish

and Wildlife Service, Land

and Water Conservation

Fund)b 153,187c 76

Florida Conservation and

Recreation Lands program 179,130 326

Save Our Rivers program

(South Florida Water

Management District) 135,328 217

Total 541,262 $848
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A Plan Would Coordinate

the Land Acquisition

Programs of the Federal and

State Agencies Participating

in the Restoration

The importance of acquiring lands to accomplish the goals of the

restoration initiative and the Task Force’s reliance on the participating

federal and state agencies for such land acquisition puts a premium on

having a systematic land acquisition plan and effective communication and

coordination among the Task Force members. A land acquisition plan

would allow the Task Force—as the entity responsible for (1) developing

plans and priorities to guide the restoration initiative and (2) coordinating

and facilitating the efforts of the agencies participating in the initiative—to

clearly communicate its land needs and priorities to the federal and state

agencies responsible for acquiring lands. Because the South Florida

ecosystem covers a vast area (about 11.5 million acres) and because much

of the undeveloped land is under development pressure, it is unlikely that

all of the lands needed to fully restore the ecosystem can be acquired,

making it important to prioritize the acquisitions that are possible. The

Task Force, in 1996 and 1999, developed two land acquisition lists, but

these lists were not complete and did not contain the elements of a land

acquisition plan. The first list, which was developed to allocate Farm Bill

funds, contained the lands that the members of the Task Force could agree

were important for the restoration initiative, many of them related to the

Corps’ Restudy. The second list, which was developed in response to

congressional inquiries, was a compilation of projects proposed by state

and local agencies and prioritized by the Task Force. Neither list identified

all of the lands needed for the acquisition, nor did the lists include other

elements of a land acquisition plan, such as estimated costs or time frames.

To be useful in coordinating the agencies’ acquisition efforts, a land

acquisition plan should identify

• the acres that will be needed to accomplish each of the goals of the

restoration initiative or, at a minimum, the general areas where lands

will be needed;

• the purpose of acquiring the lands and the way the lands will be

managed after they are acquired, such as for water management or

habitat;

• the agency responsible for acquiring and managing the lands; and

• the time frames when lands will be needed for projects and the

estimated costs of the lands.

The land acquisition plan we envision would supplement the strategic plan

we recommended in our 1999 report.We recommended that a strategic

plan be developed to lay out how the restoration initiative would be

accomplished and to set goals and performance measures to help

coordinate the participating agencies’ activities. A similar effort to develop
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a plan laying out the lands to be acquired for the restoration would help

coordinate the agencies’ land acquisition activities. In addition, a land

acquisition plan would provide other benefits. In particular, it would enable

the Task Force to give the Congress and the state of Florida—both of which

will provide the necessary funding—a reasonable estimate of the total

acreage needed and the full cost of the acquisition. As such, a land

acquisition plan would provide the necessary justification for acquiring

particular lands and for requesting the funding needed from the federal and

state governments. A land acquisition plan would also serve as a

benchmark for measuring the progress being made in acquiring the lands

needed to accomplish the restoration initiative’s goals, and would allow the

Task Force and the agencies to adjust project schedules, reallocate

acquisition budgets, or identify alternative lands for acquisition.

Furthermore, if certain lands cannot be acquired because a landowner is

unwilling to sell, a land acquisition plan would allow the Task Force and

the agencies to identify other means of protecting the lands. For example, if

a key parcel cannot be acquired, the Task Force—through an agency—may

elect to offer other incentives to a landowner to protect the land, such as an

easement or tax incentive.

Some Task Force officials we spoke with during our review did not believe

that enough information was currently available to develop a land

acquisition plan.We believe that considerable progress is possible. If the

Task Force were to (1) assess the lands already identified as needed by the

federal and state agencies, (2) assess additional lands that are needed, and

(3) incorporate the information from these assessments into a single

document, the Task Force would have the framework for a land acquisition

plan that could be expanded to include other necessary components, such

as costs, priorities, responsible agencies, and time frames for acquisition.

Such a plan would serve as a valuable tool for the Task Force to ensure that

the lands needed for the initiative are acquired. Other federal and state

officials were concerned that the development of a plan that publicly

identified the lands needed would cause the price of the lands to rise. While

this concern is valid, we believe that the benefits of developing the plan

outweigh the drawbacks. When specific lands cannot be identified, the

Task Force could identify the general areas where lands will be needed,

estimate the acreage needed, and indicate when the specific lands will be

identified. As the restoration initiative progresses, the land acquisition plan

could be revised to reflect changes and additions to the specific lands

identified as needed for the initiative.
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Task Force Has Not Used

Available Information on

Lands to Develop a Plan

Although the Task Force has not developed a land acquisition plan,

information that would be included in the plan is generally available. First,

the federal and state agencies participating in the initiative have already

identified some lands in the ecosystem that they plan to acquire. Although

the Task Force has not yet assessed those lands, it could do so to determine

how and to what extent they could be used to further the goals of the

restoration. Second, the federal and state agencies have also completed

studies and assessments that identify areas of potential acquisition. The

Task Force has not used these studies and assessments to independently

identify additional lands needed to achieve its restoration goals. A land

acquisition plan would specify the parcels needed and the purpose of the

lands, along with cost estimates and time frames. The plan could also

include the general areas where lands will be needed, together with the

purposes for which the lands will be used and general estimates of acres

and costs, until the information is refined. The following paragraphs

summarize, for each of the restoration goals, (1) the acreage already

identified by the agencies, (2) the studies and assessments that the Task

Force could use to identify other land needs, and (3) the additional

information that the acquisition plan would need to include.

Goal 1—Getting the water right: The Corps has estimated that about

220,000 acres are needed for water storage areas, such as reservoirs, and

for water quality treatment areas. The Corps identified the general

locations of these acres and modifications in the Restudy, completed in

1999. Of the 220,000 acres, 70,000 acres are on the land acquisition lists for

the state’s Conservation and Recreation Lands and Save Our Rivers

programs. The remaining parcels have yet to be identified. A land

acquisition plan would include the parcels already identified and could

include general areas until more precise information was developed. The

Restudy does not comprehensively address water quality issues, which is

one of the purposes of this goal. As a result, the lands that will be needed to

achieve the water quality portion of this goal have not yet been identified.

For example, in August 1999, the Task Force’s working group published a

plan, called the Lake Okeechobee Action Plan, that makes

recommendations for reducing phosphorous pollution in the lake—a water

quality problem. One of the plan’s recommendations—to create storm

water treatment areas for removing pollutants from urban and agricultural

runoff—will require lands. Until the state and federal agencies determine

what actions will be taken to improve the quality of the lake’s water, the

number of water quality areas and the acreage needed are unknown. If a

land acquisition plan were developed, it could include the lands that would
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be needed for these areas. Until the information is refined, the Task Force

can include general estimates.

Goal 2—Restoring and enhancing the natural system: While federal and

state agencies participating in the restoration have identified about 630,000

acres that need to be acquired for habitat in the South Florida ecosystem,

the Task Force has not assessed how or to what extent these lands would

be used to accomplish goal 2. In addition, the Task Force has not identified

other lands that will be needed to accomplish this goal. For example, the

goal requires that physical and biological connections be made between

existing natural areas, but Task Force officials could not identify where all

these habitat connectors or corridors would be and thus could not identify

the lands that remained to be acquired. Furthermore, the Task Force has

not used two assessments that identify lands or actions necessary to

preserve threatened and endangered species and their habitats in the South

Florida ecosystem, including potential habitat corridors, to identify

additional lands that might be needed to accomplish this goal. The first

assessment, the Multi-Species Recovery Plan produced by the Fish and

Wildlife Service, identifies actions to recover the 68 federally listed species

and their habitats. The second study, Closing the Gaps in Florida’s Wildlife

Habitat Conservation System, produced by the Florida Fish and Wildlife

Conservation Commission, identifies 4.8 million acres whose acquisition or

protection would preserve key species and their habitats throughout

Florida, including the South Florida ecosystem. If a plan were developed, it

could include the parcels the agencies have identified as needed. The plan

would also include a schedule for the Task Force to review the agencies’

assessments and identify other lands needed to accomplish this goal.

Goal 3—Transforming the built environment: The Task Force included a

few projects involving county lands on the list of priorities it developed in

1999. These projects were proposed by local governments, since the Task

Force has not assessed what lands would be needed to support this goal.

According to Task Force officials, the lands for the third goal will be

identified by local community and city governments, with state and Task

Force involvement. The state has two programs that the Task Force could

use to identify lands for this goal, the Florida Communities Trust program

and the Florida Greenways and Trails Acquisition Program. For this goal, as

for the first two goals, the land acquisition plan, if developed, could include

the parcels identified by the localities and would include a schedule for

reviewing lands in the available assessments to determine additional needs.
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Interior Has Not

Consistently Applied

Its Cost-Sharing Policy

to Maximize Its Land

Acquisitions

To maximize the acreage acquired with $200 million in Farm Bill grants, the

Department of the Interior developed a cost-sharing policy that required

the state of Florida to match the federal funds dollar for dollar. Under this

policy, the Secretary of the Interior retained the authority to waive the

matching requirement. Interior approved four grants to buy lands in the

East Coast Buffer, the Carroll property, the Southern Golden Gate Estates,

and the Talisman lands.6 While the state contributed matching funds for

one grant, the Secretary waived the matching requirement or accepted

lands in place of funds for the other three grants. The state had already

acquired, or was in the process of acquiring, these lands that it used for

matching purposes. Had Interior consistently applied its cost-sharing

policy, we calculate that an additional $77 million would have been

available for land acquisition. According to Interior officials, the agency did

not always apply its cost-sharing policy because it wanted to give the state

credit for lands that it had already acquired or was in the process of

acquiring. Furthermore, Interior agreed to share the cost of another 12

parcels equally with the state; the state had agreed to acquire these parcels

to settle a lawsuit that began almost 2 years before the grant was approved.

Had the Department not approved this purchase, we calculate that an

additional $4 million would have been available for land acquisition.

Interior and State of Florida

Agree to a 50/50 CostSharing Policy

Interior developed a cost-sharing policy for spending the $200 million in

Farm Bill funds, even though the legislation did not require such a policy.

To set forth the manner in which these funds would be spent, Interior

entered into a framework agreement with the U.S. Department of the Army

(Corps), the Florida Department of Environmental Protection, and the

South Florida Water Management District in October 1996. Interior entered

into an agreement with these agencies because they have active land

acquisition programs and would be the likely recipients of Farm Bill funds

to acquire lands for the restoration initiative. Both the Florida Department

6

More specifically, Interior approved three grants and one cooperative agreement. For this

discussion, we will refer to all of these as grants. In addition to these grants, Interior entered

into an interagency agreement with the Corps and the U.S. Department of Agriculture

(USDA) for the construction of a quarantine research facility for melaleuca (a rapidly

spreading exotic tree from Australia). Interior provided a total of $6.2 million to the Corps to

construct the facility. USDA will operate and maintain the facility, which will facilitate

ongoing research into the eradication of melaleuca through the use of biologic control

agents. If left unchecked, melaleuca displaces native plant and animal communities and

threatens the stability of the Florida Everglades ecosystem. Under the terms of the original

framework agreement, the Corps is not required to match the funds.
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of Environmental Protection and the South Florida Water Management

District receive funds for land acquisition from the Florida Preservation

Trust Fund—a fund that makes about $300 million available annually for

land acquisition throughout the state. The framework agreement included a

provision for leveraging that, unless waived by the Secretary, required the

Farm Bill funds to be matched dollar for dollar. According to Interior

officials responsible for overseeing these funds, the land acquisition needs

of the ecosystem exceeded the $200 million provided by the Farm Bill.

Having the state match the funds would have doubled the funding available

to acquire lands and maximized the acreage that could be acquired.

Interior approved four grants to buy lands in the East Coast Buffer, the

Carroll property, the Southern Golden Gate Estates, and the Talisman

lands. The East Coast Buffer consists of approximately 72,000 acres of

marshes, reservoirs, and groundwater recharge areas in Palm Beach,

Broward, and Miami-Dade counties. The East Coast Buffer is also referred

to as a water preserve area and is expected to become part of a future

Corps project that will help restore the Everglades ecosystem, in part by

preventing water from being lost through seepage and by regaining lost

capacity for storing water. The Carroll property consists of 1,233 acres in

the Everglades Agricultural Area and is also intended to become part of a

future Corps project. The lands would serve as part of a water management

area designed to assist in the restoration of the Everglades ecosystem by

improving water quality and regaining lost water storage capacity. The

Southern Golden Gate Estates comprises about 57,200 acres in southwest

Florida and is a diverse landscape of freshwater marshes, wet and dry

prairies, hardwood hammocks, and pine flatwoods. The acquisition of

these lands will protect essential habitat for numerous threatened and

endangered plants and animals and will help preserve and restore the

freshwater flow to Gulf Coast estuaries. The Talisman lands encompass

over 50,000 acres and are located south of Lake Okeechobee in the

Everglades Agricultural Area. According to agency officials, these lands

have been identified in the Restudy as a good candidate for regional water

storage to meet the ecosystem’s long-term restoration needs. Figure 2

shows the locations and boundaries of these projects.
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Figure 2: Location of Lands Acquired With Farm Bill Funds

Source: GAO’s adaptation of a map prepared by the Department of the Interior’s Fish and Wildlife

Service.

Everglades

National Park

Everglades

Agricultural Area

Carroll

Property

Talisman East

Coast

Buffer

Southern

Golden

Gate

Estates

Lake

Okeechobee

Florida Bay

Big Cypress

National

Preserve

Cypress

Seminole Indian

Reservation

Miccosukee

Indian

Reservation
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Interior Has Not Fully

Implemented Its CostSharing Policy

In granting the Farm Bill funds, Interior implemented its cost-sharing

policy requiring the state to provide a dollar-for-dollar match for one of the

four grants (the Carroll property). For the remaining three grants, Interior

either waived the cost-sharing requirement (Talisman) or accepted as a

match lands that the state had already purchased (Southern Golden Gate

Estates) or that the state had begun purchasing (East Coast Buffer). If

Interior had required the state to match the Farm Bill funds dollar for dollar

for each of the properties acquired with these funds, we calculate that an

additional $77 million could have been available to acquire lands in the

ecosystem. Table 2 summarizes the information on how the Farm Bill funds

were spent, how much the state contributed, and how much would be

needed for the state to fully match the Farm Bill grants as provided in the

framework agreement. A detailed discussion of each of the grants follows

the table.

Table 2: Farm Bill Grants and the State’s Dollar Match

Dollars in millions

Note: Numbers may not add because of rounding.

a

In addition to the original Farm Bill grant of $36.9 million, Interior awarded $13.9 million in Farm Bill

funds to an existing Land and Water Conservation Fund grant that required the state to match the

grant.

b

As part of its match, the state provided 33 parcels that the South Florida Water Management District

had purchased for $21 million. If Interior had required the dollar-for-dollar match, $21 million would

have been available to acquire additional lands. The District has continued to acquire lands on its own

in the East Coast Buffer, spending an additional $10 million, thereby reducing its cost-sharing

requirement to about $11 million.

c

The state did not share the cost of the Carroll property. However, the state contributed an additional

$3.1 million to the East Coast Buffer grant and in doing so met its cost-sharing match for this grant. For

Grant Farm Bill funds

State’s actual dollarfor-dollar contribution

to the grant or

equivalent state

spending

Additional

amount needed

for a 50/50 match

East Coast Buffera $50.8 $39.8b $11b

Carroll property 3.1 3.1c 0

Southern Golden

Gate Estates 38.1 38.1d 0d

Talisman 100.6 34.4 66

Othere 7.5 f f

Total $200.0 $115.4 $77
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the purposes of our table, we have included the state’s contribution as part of the Carroll property

grant.

d

The Secretary of the Interior decided that the state had met the matching requirement because it had

already spent over $97 million to acquire lands in this vicinity and did not require the state to provide a

dollar-for-dollar match. However, the state also continued to acquire lands under its own program and

spent about $47 million in 1998 and 1999. In doing so, the state effectively met its cost-sharing

requirement of $38.1 million, even though matching was not required.

e

Included in the other category is $6.2 million provided to the Corps to construct a melaleuca research

facility and $1.3 million in administrative costs.

f

Not applicable.

Source: GAO’s analysis of federal and state land acquisition data.

Carroll Property Grant Interior implemented its cost-sharing policy when it acquired the Carroll

property. The state originally agreed to provide half of the acquisition costs

and anticipated using Preservation 2000 funds. However, because the

Carroll property generates income from a sod farm and the state is

restricted from acquiring income-generating lands with Preservation 2000

funds, the state was unable to share the cost of the property. Instead,

Interior purchased the Carroll property entirely with Farm Bill funds for a

total of about $3.1 million. To compensate for being unable to share in the

cost of the Carroll property, the state increased its contribution to the East

Coast Buffer grant by $3.1 million—the amount that Interior provided to

acquire the Carroll property. By contributing additional moneys to the East

Coast Buffer grant, the District retained an overall 50/50 cost-share ratio for

the Carroll property.

Talisman Land Acquisition Grant Interior entered into a cooperative agreement with the South Florida Water

Management District and The Nature Conservancy to purchase the

Talisman lands owned by the St. Joe Company. The Department chose the

framework of a cooperative agreement because it believed that acquiring

the Talisman lands would require significantly more federal involvement

and would allow Interior to bring in The Nature Conservancy, a third party

with extensive experience in complex real estate transactions, to assist in

the negotiations.
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The federal government decided to acquire the tract in full and obligated

$133.5 million for the acquisition because it was concerned that the state

would not have matching funds available. Later, the state of Florida

contributed a total of $34.4 million toward the purchase of lands that it

needed for water treatment within the Talisman area. The federal

government’s final share of the project totaled $100.6 million. Because

Interior waived its cost-sharing policy, the state was not required to provide

a full dollar-for-dollar match. As a result, in acquiring all of the Talisman

lands, the federal government paid 75 percent of their cost and the state

paid 25 percent.7 Had the state provided a full 50-percent match, an

additional $66 million could have been available for land acquisition.8

Southern Golden Gate Estates

Grant

Interior awarded a grant for $38.1 million to the Florida Department of

Environmental Protection to acquire 29,250 of the 57,200 acres in the

privately-owned Southern Golden Gate Estates. The grant agreement,

which was signed in April 1998 and amended in December 1999, did not

require the state to provide a dollar-for-dollar match because the Secretary

of the Interior accepted as a match lands that the state had already

purchased. According to Interior officials, the Secretary did this because

the Florida Department of Environmental Protection, through its

Conservation and Recreation Lands program, had met the matching

requirement by spending $97 million on lands in the Southern Golden Gate

Estates area and in four nearby areas. Over half of the $97 million—or $52

million—was spent by the state from 1993 through 1997—a period of 1 to 5

years before Interior and the Florida Department of Environmental

Protection signed the grant agreement. By giving the state credit for lands it

had previously purchased, Interior sacrificed its objective of maximizing

the acreage that could be acquired with the grant funds.

7

The Talisman transaction was more complicated than this because it involved third-party

cost-sharing. The total cost of the lands was actually $152.5 million, with an additional $0.7

million being paid to The Nature Conservancy for its services in the transaction. The federal

government paid $100.6 million for the transaction, including $99.9 million for the land (66

percent of the total cost) and $0.7 million for The Nature Conservancy’s expenses. The state

contributed $34.4 million to the total cost and other parties, which included other sugar

companies, provided $18.1 million toward the total cost. For the sake of discussing the

state’s cost share for the parcel, we focused only on the total costs provided by the federal

and state governments.

8

While we recognize that the additional $66 million would have exceeded the cost of the

Talisman acquisition, these funds could have been used to acquire lands in other projects.
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In fairness, the state has continued to purchase lands in these areas on its

own and, as a result, has essentially met the cost-sharing requirement, even

though it did not provide a dollar-for-dollar match. Since 1998—the year the

grant agreement was signed—the state has spent about $47 million to

acquire lands in the Southern Golden Gate Estates and nearby areas. This

$47 million exceeds the $38.1 million needed to satisfy the matching

requirement. However, the state’s expenditure of $47 million in 1998 and

1999 to acquire lands in this area was not a result of Interior’s actions or

efforts to ensure the purchase of as much land as possible with Farm Bill

funds. Moreover, in taking this approach, Interior does not retain control

over the management of these lands, as it would have done if the lands had

been purchased as part of the Farm Bill grant. Because the state acquired

the lands independently, they may not have to be managed to meet the

purposes of the Farm Bill (conservation and/or part of a Corps project) or

of the Fish and Wildlife Coordination Act (consideration of benefits to fish

and wildlife).9

East Coast Buffer Grant For this grant, Interior awarded $36.9 million to the South Florida Water

Management District in December 1996 to acquire lands in the East Coast

Buffer.10 The East Coast Buffer covers three counties and consists of 72,000

acres. According to state officials responsible for land acquisition, the East

Coast Buffer lands are under intense development pressure from urban and

agricultural expansion, and their acquisition must be accelerated to

prevent them from being converted to incompatible uses, such as housing

developments.

For the Farm Bill grant of $36.9 million for the East Coast Buffer, Interior

accepted as the state’s match (1) $15.9 million in funds and (2) 33 parcels of

land that the District was in the process of acquiring for $21 million. As part

of the grant agreement, Interior agreed to accept parcels that the District

9

Although the grant does not explicitly give the federal government any control over lands

acquired independently by the state in the project area, the Fish and Wildlife Service and the

state are drafting protocols that would require all the lands in the project area to be used

and managed according to the grant provisions, whether the lands were acquired with Farm

Bill funds or independently by the state.

10In addition, Interior awarded $13.9 million in Farm Bill funds to an existing Land and Water

Conservation Fund grant, also made to purchase lands in the East Coast Buffer. In total,

Interior awarded $50.8 million in Farm Bill funds to purchase land in the East Coast Buffer.

Interior also required the state to provide $13.9 million to match the Farm Bill funds that

were added to the Land andWater Conservation Fund grant in the East Coast Buffer;

however, no parcels have been approved for purchase with these funds.
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was acquiring as long as the parcels were purchased after the enactment of

the Farm Bill (Apr. 4, 1996). Although the acquisition of each of the 33

parcels was completed after this date, the District had begun to purchase

all of these parcels before the Farm Bill was passed. The District had

ordered appraisals for each of the 33 properties from 1 to 9 months before

the Farm Bill’s passage. According to Interior officials, the Secretary

accepted the 33 parcels as part of the state’s match because it wanted to

give the state credit for the lands it was acquiring. Because Interior

accepted parcels that the District was in the process of acquiring, it did not

further its goal of buying as much land as possible with the grant funds. If

Interior had required a dollar-for-dollar match, $21 million would have been

available to acquire additional lands.

In fairness, as with the Southern Golden Gate Estates grant, the District has

continued to acquire lands on its own in the East Coast Buffer and has thus

essentially met part of its cost-sharing requirement, even though the lands

it has acquired were not purchased as part of the grant. Since the grant

agreement was approved in 1996, the District has spent an additional $10

million to acquire lands in the East Coast Buffer. By acquiring these lands,

the District has effectively reduced its cost-sharing obligation to $11 million

($21 million − $10 million = $11 million).

Interior approved the purchase of another 12 parcels in the East Coast

Buffer area and agreed to share the cost of these parcels equally with the

state. The state was acquiring these 12 parcels as part of the settlement of a

lawsuit filed against the District in December 1994, or 2 years before the

approval of the Farm Bill grant. Specifically, the owners of the 12 parcels

sued the District for inverse condemnation,11 claiming that the District had

flooded their lands and publicly marked them for acquisition, thereby

decreasing their value. After the parties failed to resolve the lawsuit, the

District’s governing board agreed to acquire the 12 parcels by

condemnation for $4.3 million, a price set by the court that included

interest and legal fees. The federal share came from the $36.9 million in

Farm Bill funds, and the state’s share came from its $15.9 million

contribution—Interior paid $2.14 million, and the state paid another $2.14

million. Interior approved the purchase of these parcels because nothing in

the Farm Bill legislation or the grant agreement precluded the District from

11The term “inverse condemnation” refers to governmental action that substantially

diminishes the economic value of private property and for which compensation must be

paid.
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spending grant funds to acquire property by condemnation and because

Interior had previously accepted lands that the state had bought as part of a

legal settlement. Had Interior not accepted the purchase of these parcels,

$4.3 million would have been available to acquire additional lands.

Conclusions While land acquisition is critical to the success of the restoration effort, the

South Florida ecosystem is so large that not all of the lands within it can be

acquired and preserved. In our 1999 report, we concluded that a strategic

plan outlining how the restoration of the ecosystem will occur would

increase the chances of success for this complex, long-term restoration

initiative. Similarly, a land acquisition plan would increase the Task Force’s

chances of success. Although the Task Force cannot acquire lands, it is

responsible for coordinating the federal and state agencies that do acquire

lands. A land acquisition plan that clearly articulates the needs and

priorities of the Task Force to participating federal and state agencies

would be valuable in coordinating the agencies’ land acquisition activities.

Furthermore, without a plan, the Task Force cannot (1) determine how

much land will be needed to accomplish its goals, (2) estimate the full cost

of acquiring these lands, (3) measure progress in acquiring lands for the

restoration, or (4) increase the chance that the lands acquired are those

that are most needed. Such information is important to provide status

reports to the Congress and the state of Florida, which are jointly funding

the restoration initiative. The efforts of the federal and state agencies to

identify lands for acquisition could serve as a good starting point for

developing a plan, and the Task Force should build on these efforts. We

envision that the land acquisition plan will be a work in progress that the

Task Force and others—such as the Congress—can use to monitor

progress in land acquisition throughout the course of the initiative.

As important as a land acquisition plan is the acquisition of as much land as

possible with the funds available for this purpose, because undeveloped

land in South Florida is becoming increasingly scarce and costly. Although

the Farm Bill did not require cost sharing, Interior recognized the

importance of this approach and established a cost-sharing policy with the

state. To the extent that Interior did not choose to follow its own costsharing guidance, it did not achieve its goal of purchasing as much land as

possible with the Farm Bill funds. We are not making a recommendation

because the grant agreements for all of the Farm Bill funds have been

finalized and most of the $200 million in Farm Bill funds has been spent.

Furthermore, appropriations to Interior for land acquisition grants to the

state of Florida from the Land and Water Conservation Fund in 1999 and
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2000 provide for a 50/50 cost-sharing arrangement and provide that new

state appropriations must be used for the state’s share.

Recommendations To ensure that the lands needed to accomplish the goals of the South

Florida Ecosystem Restoration Initiative are identified and acquired, we

recommend that the Secretary of the Interior, as the Chairperson of the

South Florida Ecosystem Restoration Task Force, in conjunction with the

other members of the Task Force, develop a land acquisition plan. This plan

would include (1) an assessment of the lands needed to accomplish each of

the goals of the restoration, (2) a description of the purpose for which the

lands will be acquired and how they will be managed, (3) an estimate of the

cost of these lands, (4) an estimate of when the lands will be needed for

related restoration projects, and (5) the agencies responsible for acquiring

the lands. This plan should be updated to reflect changes and additions to

the restoration initiative’s land acquisition needs.

Agency Comments and

Our Evaluation

We provided a draft of this report to the Department of the Interior, whose

Secretary chairs the South Florida Ecosystem Restoration Task Force; the

state of Florida’s Everglades Policy Coordinator; the South Florida Water

Management District; and the Florida Department of Environmental

Protection for review and comment.

The Department of the Interior provided comments signed by the

Counselor to the Secretary, who, as the Secretary’s designee, also serves as

the chair of the Task Force. The Department concurred with our

recommendation that the Task Force develop an overall land acquisition

plan and stated that it would recommend that the member agencies

undertake an effort to integrate existing land acquisition programs into a

single overall plan. The Department, noting that the plan would build on the

land acquisition plans and programs of the Task Force’s member agencies,

agreed with us that the Task Force is the appropriate entity and has the

statutory authority under the Water Resources Development Act of 1996 to

coordinate the development of an overall land acquisition plan.

The Department did not agree with our conclusion that it did not follow the

cost-sharing guidance it established for spending Farm Bill funds and,

therefore, did not achieve its goal of purchasing as much land as possible

with these funds. In its comments, the Department stated that we did not

fully reflect the goals for the expenditure of the $200 million in Farm Bill
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funds and that we did not accurately represent the expected ultimate cost

share for the lands acquired with Farm Bill funds. The Department stated

that one of the goals of spending Farm Bill funds was to acquire the

Talisman lands. The Department decided to purchase these lands, even

though the state was not able to provide its full cost share for the

transaction, because the acquisition was of paramount importance for

future water storage and water quality improvement. In addition, the

Department stated that the East Coast Buffer and Talisman lands will

ultimately be used for the Corps’ Comprehensive Everglades Restoration

Plan (formerly called the Restudy) and, as such, will be subject to a full

cost share between the Corps and the state. The Department also provided

technical clarifications to the report, which we incorporated as

appropriate.

We recognize that these land acquisitions have been identified as important

to the restoration initiative, and we are not taking issue with their

acquisition. The focus of our review was to determine whether the

Department had accomplished its intended purpose of maximizing the

amount of land acquired with Farm Bill funds. The Department, in its

comments to us and in an internal memo, stated that the main purpose of

establishing the cost-sharing agreement was to increase the amount of

funds available so that it could buy as much land as possible. Numerous

federal and state officials have told us that the opportunity to acquire lands

in South Florida is disappearing and that lands—particularly those on the

east side of the natural system where the East Coast Buffer is located—are

under intense development pressure. We acknowledge that the costsharing agreement was not legislatively mandated, and we believe that the

Department showed financial acuity in establishing such an agreement.

However, while we recognize that the Secretary of the Interior retained the

discretion to waive the cost-sharing requirement under the framework

agreement, we continue to believe that that the Secretary’s decision to

waive the cost-sharing requirement or to approve other cost-sharing

approaches for the Farm Bill grants did not achieve the Department’s goal

of buying as much land as possible. Furthermore, although the Department

believes that the cost share for at least the East Coast Buffer and Talisman

parcels will be equalized when the Restudy components are built, we do

not agree that the Department should rely on future contributions—for asyet-unauthorized projects—to meet the cost-sharing requirement. The

Department of the Interior’s comments and our detailed responses appear

in appendix III.
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The state of Florida provided comments from the Everglades Policy

Coordinator, together with an additional set of consolidated comments

from the Florida Department of Environmental Protection and the South

Florida Water Management District. The state fundamentally disagreed

with the conclusions and recommendation in our report. The state’s

disagreement focused on three areas, which are presented and discussed

below. The state also provided technical clarifications to the report, which

we incorporated as appropriate. The state of Florida’s comments and our

responses appear in appendix IV.

First, the state believes that our report did not fairly characterize the state’s

past contributions and continued commitment to land acquisition in

support of the protection and restoration of the Everglades ecosystem. We

do not believe that this is true. We recognize throughout the report that the

state has a number of land acquisition initiatives and, over the years, has

contributed significantly to the acquisition of lands for the ecosystem.

Furthermore, our report discusses the role of the state agencies in

acquiring lands for the initiative and describes the programs in some detail.

Second, the state disagreed with our recommendation that the Task Force

create a land acquisition plan because it believes our report and

recommendation imply that the Task Force should plan to acquire and

manage all the lands needed for the restoration initiative. The state

indicated that because it has the best-funded and most comprehensive

conservation land acquisition program in the nation, it is in a better

position than the federal government to acquire and manage land

acquisitions for the restoration initiative. We did not envision, in

recommending that the Task Force develop a land acquisition plan, that the

Task Force would be the entity to acquire and manage all lands for the

initiative or that the process of acquiring lands would be federally driven.

We believe—and clearly state in our report—that the federal and state

agencies participating in the initiative are responsible for the acquisition

and management of lands and that these agencies have developed a

number of plans and studies that are a good starting point for the Task

Force to use in developing a land acquisition plan. The Task Force was

created specifically to coordinate and facilitate the efforts of the agencies

participating in the restoration initiative, and we believe that it is the

appropriate entity to develop a land acquisition plan to communicate the

initiative’s land needs and priorities to those agencies that have land

acquisition responsibilities.
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Third, the state said that throughout the report, our characterization of its

compliance with Interior’s cost-sharing requirement is misleading because,

according to the state, it has spent more than the amount needed for a 50-

percent match. The state’s assertion is not accurate. We specifically point

out the cost share required by each grant and identify the dollar amount

contributed by the state in each instance.We believe that the state

disagrees with our interpretation of what the cost-sharing requirement

entailed and would like us to count as part of its match lands that it

acquired before the Farm Bill grants were approved. However, we believe

that lands acquired or in the process of being acquired before the grants

were approved should not be counted as part of the match because these

lands do not maximize the acreage acquired with Farm Bill funds

(including the state’s matching funds) and do not, therefore, help the

Department meet its goal of maximizing the lands purchased with Farm Bill

funds. We did give the state credit for lands it acquired on its own after the

Farm Bill grants were approved because these lands increased the acreage

purchased after the Farm Bill was passed and the funds used to purchase

them could have served as the state’s match.

Scope and

Methodology

To determine what the Task Force has done to identify and acquire lands

needed to accomplish the goals of the South Florida Ecosystem

Restoration Initiative, we contacted officials from the South Florida

Ecosystem Restoration Task Force. We also obtained and analyzed

applicable reports, plans, and other documents related to identifying and

acquiring lands for the restoration initiative, such as the Task Force’s Fiscal

Year 2000 Cross-Cut Budget, Integrated Financial Plan: Calendar Year 1999,

and 1999 biennial report called Maintaining the Momentum. In addition, we

met with the Chair of the South Florida Ecosystem Restoration Task Force,

the executive director of the Task Force, the chair of the working group,

the chair of the Task Force’s Science CoordinationTeam, the counselor to

the Assistant Secretary for Fish and Wildlife and Parks, and the

environmental coordinator for the governor of Florida.We also met with

representatives of the Miccosukee Tribe and of Florida’s sugar industry.

Because the Task Force cannot acquire lands and must rely on the

participating agencies to do so, we contacted both headquarters and field

officials from the federal and state agencies involved in land acquisition.

These agencies include the National Park Service, the U.S. Fish and Wildlife

Service, the U.S. Army Corps of Engineers, the Florida Department of

Environmental Protection, and the South Florida Water Management

District. At each agency, we interviewed cognizant officials about their land
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acquisition programs, including the criteria and process used to identify

and prioritize land for acquisition. We also obtained and reviewed

information, including annual reports, related to the agencies’ land

acquisition programs. In addition, we obtained, analyzed, and compiled

data from these five agencies on the funds expended for land acquisition

for the South Florida Ecosystem Restoration Initiative from 1996 through

1999 and the acreage acquired.We did not independently verify the

reliability of these data or trace the data to the systems from which they

came, nor did we verify the completeness or accuracy of the data. Such an

effort would have required a significant investment of time and resources

and these data were not critical to our findings and conclusions.

To determine how the Department of the Interior maximized the lands

acquired with $200 million in Farm Bill funds, we interviewed officials from

the Department of the Interior, the South Florida Water Management

District, and the Florida Department of Environmental Protection who

were responsible for submitting, approving, and administering the grants

funded with these moneys. We reviewed applicable laws and regulations

and criteria developed by the Department of the Interior for allocating the

Farm Bill funds. We held extensive discussions with officials from the U. S.

Fish and Wildlife Service’s Division of Federal Aid in Atlanta about the

policies and procedures developed to administer the Farm Bill grants and

about Interior’s cost-sharing policy and process for reviewing, approving,

and monitoring individual grants and the funds expended. In addition, we

discussed the review and approval of specific parcels acquired under these

grants, including Federal Aid’s examination of appraisals. We also reviewed

the files maintained by Federal Aid officials on the individual grants. We

analyzed related quarterly and annual progress reports to determine how

the grant funds were expended and how many acres were acquired. In

addition, we obtained and compared the four Farm Bill grant agreements

with the Department’s cost-sharing policy to determine whether the grants

were consistent with the policy.We obtained and analyzed data on the

hundreds of individual parcels acquired with these funds to determine how

the costs were shared between the federal and state governments and

when the parcels were acquired. While Land and Water Conservation funds

have been authorized for grants to the state for land acquisition in fiscal

years 1998 through 2000, only the funds for fiscal years 1999 and 2000 have

a statutory matching requirement, which means that the state will match

these funds with new state funds. One grant has been awarded from the

funds for fiscal years 1999 and 2000, but the grant funds had not been

expended as of September 1999. As a result, we could not determine if the
B-284599

Page 32 GAO/RCED-00-84 South Florida Ecosystem Restoration

cost-sharing requirement for these funds had been applied and did not

include them in our review.

We conducted our review from July 1999 through March 2000 in

accordance with generally accepted government auditing standards.

We are providing copies of this report to the Honorable Bruce Babbitt,

Secretary of the Interior; the Honorable Jeb Bush, Governor of Florida; and

other interested parties.We will also make copies available to others upon

request.

If you or your staff have any questions, please call me at (202) 512-3841.

Key contributors to this report are listed in appendix V.

Jim Wells

Director, Energy, Resources,

and Science Issues
B-284599

Page 33 GAO/RCED-00-84 South Florida Ecosystem Restoration

List of Requesters

The Honorable Frank H. Murkowski

Chairman, Committee on Energy and

Natural Resources

United States Senate

The Honorable Craig Thomas

Chairman, Subcommittee on National Parks,

Historic Preservation, and Recreation

Committee on Energy and Natural Resources

United States Senate

The Honorable Slade Gorton

Chairman, Subcommittee on

Interior and Related Agencies

Committee on Appropriations

United States Senate

The Honorable Ralph Regula

Chairman, Subcommittee on

Interior and Related Agencies

Committee on Appropriations

House of Representatives
Page 34 GAO/RCED-00-84 South Florida Ecosystem Restoration

Appendix I

Members of the South Florida Ecosystem Apendxies

Restoration Task Force ApendxIi

The South Florida Ecosystem Restoration Task Force consists of

representatives from 15 federal, state, and local agencies and tribal

governments participating in the restoration initiative. The members of the

Task Force as of February 2000 are listed below.

Representatives of

Federal Departments

and Agencies

Mary Doyle, Chair

Counselor to the Secretary

Department of the Interior

Michael L. Davis

Deputy Assistant Secretary of the Army (Civil Works)

Department of Defense

Jonathan Charles Fox

Assistant Administrator for Water

Environmental Protection Agency

Vacant

Department of Transportation

Glenda Humiston

Deputy Under Secretary for Natural Resources

Department of Agriculture

Lois Schiffer

Assistant Attorney General—Environment

and Natural Resources

Department of Justice

Sally J. Yozell

Deputy Assistant Secretary—Oceans and

Atmosphere

National Oceanographic and Atmospheric

Administration

Department of Commerce

Terrence “Rock” Salt

Executive Director

South Florida Ecosystem Restoration Task Force
Appendix I

Members of the South Florida Ecosystem

Restoration Task Force

Page 35 GAO/RCED-00-84 South Florida Ecosystem Restoration

Representatives of

State and Local

Governments

J. Allison DeFoor, II

Environmental Policy Coordinator

Office of the Governor

State of Florida

David B. Struhs

Secretary

Florida Department of

Environmental Protection

Michael Collins

Chairman

Governing Board

South Florida Water Management District

Clarence E. Anthony

Mayor

City of South Bay

Raoul Valdes-Fauli

Mayor

City of Coral Gables

Representatives of

Native American Tribes

Dexter Lehtinen

Special Assistant for Everglades Issues

to the Miccosukee Tribe

Jim Shore

General Counsel to the Seminole Tribe

of Florida
Page 36 GAO/RCED-00-84 South Florida Ecosystem Restoration

Appendix II

Federal and State Land Acquisition ApendxiI

A number of federal and state agencies are acquiring lands for the South

Florida Ecosystem Restoration Initiative. The federal and state

governments already own and manage many lands in South Florida, and

these lands will be managed for restoration purposes. The federal

government manages over 20 areas, totaling about 2.9 million acres,

including 4 national parks and preserves and 16 federal wildlife refuges.

The state manages a total of about 1.7 million acres in the region, including

parks, refuges, forests, and water management areas. Both the federal and

state governments intend to acquire more lands for the restoration

initiative. Together with already existing parks, preserves, refuges, and

other public lands, the lands acquired will form the core of the natural

ecosystem and will be managed to achieve the three goals of the

initiative—getting the water right, restoring and enhancing the natural

system, and transforming the built environment.

Federal Land

Acquisition

The federal agencies that are acquiring lands for the South Florida

ecosystem are the National Park Service and the U.S. Fish and Wildlife

Service. In addition, the U.S. Army Corps of Engineers is acquiring lands for

water projects related to other lands being acquired by the Park Service.

The Park Service and the Fish and Wildlife Service each manage significant

portions of land in the ecosystem; in total, the agencies manage about 2.9

million acres of parks and refuges. The agencies generally acquire lands

either to expand the boundaries of existing parks or refuges or to acquire

inholdings—nonfederally owned lands within the boundaries of parks or

refuges. The Land and Water Conservation Fund is the primary source of

funding for lands acquired by the Park Service and one of the main sources

of funding for lands acquired by the Fish and Wildlife Service. The money in

this fund, which is largely raised through royalties on offshore oil and gas

development rights on federal lands, is appropriated by the Congress.

National Park Service The Park Service is acquiring lands for its South Florida parks and

preserve—Everglades National Park, Biscayne National Park, and Big

Cypress National Preserve. Lands for national parks are generally acquired

through congressionally authorized and funded expansions or purchases of

inholdings. Each year, the National Park Service proposes a number of land

acquisition projects, identified by the individual parks and prioritized by

Park Service headquarters. During the budget process, the Congress

authorizes and appropriates Land and Water Conservation Funds for these

projects. For fiscal year 2000, Everglades National Park received $20

million, Big Cypress National Preserve received $11.3 million, and Biscayne
Appendix II

Federal and State Land Acquisition

Page 37 GAO/RCED-00-84 South Florida Ecosystem Restoration

National Park received $600,000 from the Land and Water Conservation

Fund for land acquisition.

The Congress authorized a 146,000-acre expansion of Big Cypress National

Preserve in 1988 and a 107,600-acre expansion of Everglades National Park

in 1989. During fiscal years 1996 through 1999, the Park Service acquired

14,618 acres for Everglades National Park and, in total, has acquired 75,250

acres in the expansion area, including some lands donated by the state.

According to Park Service officials, the expansion lands will be mostly

acquired by the end of fiscal year 2000. The Park Service acquired 93,393

acres for the preserve from 1996 through 1999 and, in total, has acquired

107,002 acres for the expansion, including lands donated by the state. The

Park Service has been acquiring lands within the authorized boundaries of

Biscayne National Park and, from 1996 through 1999, acquired about 1,065

acres for the park.

Fish and Wildlife Service The Fish and Wildlife Service acquires lands to protect important wetlands,

protect important habitats for threatened and endangered species, and

provide wildlife-oriented public use. The Service identifies lands to create

or expand refuges under several authorities, including the Migratory Bird

Treaty Act of 1929, the Fish and Wildlife Coordination Act, and the Fish and

Wildlife Act of 1956. Lands for acquisition are generally identified by the

field offices, and then, depending on the source of the funds intended to be

used to acquire the lands, some lands are placed on a nationally prioritized

list and others are prioritized by the Service’s regional offices. Funds for

acquisition come primarily from the Land and Water Conservation Fund or

the Migratory Bird Conservation Fund, some of whose funding is raised

through the sale of duck stamps and taxes on hunting equipment. In

addition to acquiring lands for habitat, the Fish and Wildlife Service

develops protection plans for threatened and endangered species, some of

which include land acquisition. For South Florida, the agency developed

the Multi-Species Recovery Plan, which identifies habitats throughout the

ecosystem that can be acquired by other federal and state agencies or

protected through other means, such as purchases of conservation

easements.

The Fish and Wildlife Service manages 16 refuges in South Florida,

including the Ten Thousand Island refuge; the J.N. “Ding” Darling refuge,

the Matlacha Pass refuge, the Hobe Sound refuge, and the National Key

Deer refuge. The Fish and Wildlife Service also considers its activities in

three other refuges—Archie Carr, Lake Wales Ridge, and Pelican Island—to
Appendix II

Federal and State Land Acquisition

Page 38 GAO/RCED-00-84 South Florida Ecosystem Restoration

be part of the restoration effort; these refuges are outside the boundaries of

the South Florida Water Management District, which is the official

boundary of the ecosystem, but the Service includes these refuges because

they provide habitat protection to threatened and endangered species. In

South Florida, from fiscal year 1996 through fiscal year 1999, the agency

acquired 40,194 acres of land for nine refuges. The agency spent $12 million

for these lands, mostly from the Land and Water Conservation Fund. In

fiscal year 2000, the agency plans to spend $8.8 million to acquire lands for

four refuges.

State Land Acquisition The state of Florida has several ongoing land acquisition programs.Two of

the state’s key programs for land acquisition are the Conservation and

Recreation Lands (CARL) program and the Save Our Rivers (SOR)

program. CARL, which was created in 1979, identifies, prioritizes, and

acquires lands statewide for recreation and conservation purposes, and

SOR, which was created in 1981, identifies and acquires lands significant

for water management purposes. The state considers the recommendations

of the Fish and Wildlife Service’s Multi-Species Recovery Plan and the state

Fish and Wildlife Conservation Commission’s Closing the Gaps in Florida’s

Wildlife Habitat Conservation System in planning and prioritizing land

acquisition projects. In addition, the state acquires lands through its Fish

and Wildlife Conservation Commission, its Greenways program, and its

Florida Community Trust program. These programs acquire lands for the

conservation and protection of natural lands and open spaces, for the

creation of greenways (natural areas along rivers and other corridors such

as trails), or for wildlife management areas, parks, and forests.
Appendix II

Federal and State Land Acquisition

Page 39 GAO/RCED-00-84 South Florida Ecosystem Restoration

The state’s acquisition programs are funded from two primary sources—

the Florida Preservation Trust Fund and documentary stamp taxes. The

Preservation 2000 fund was established in 1990, when the state legislature

passed the Preservation 2000 Act to establish a land acquisition fund to

protect the integrity of ecological systems in the state, provide for the

preservation of fish and wildlife habitats, provide lands for recreation, and

protect water sources. The fund generated about $300 million per year

from the sale of bonds, which will continue through the end of 2000. In

1999, the program was reauthorized for another 10 years as the Florida

Forever program.1 Money from the Preservation 2000 fund is distributed to

each of the land acquisition programs in the state in varying shares—CARL

and SOR receive a total of 80 percent of the funds. The state’s documentary

stamp tax, which raised about $1 billion in fiscal year 1999, repays the

Preservation 2000 bonds and provides additional funding for the CARL and

SOR programs. These two sources provide an annual payment to the CARL

and SOR programs. In fiscal year 1999, the programs received about $213

million and about $153 million, respectively, to acquire lands throughout

the state.

Conservation and

Recreation Lands

This program, the state’s largest, acquires environmentally endangered

lands, lands to protect species and habitats, lands to protect or restore

important ecosystems, and lands to provide recreational opportunities. In

fiscal year 2000, CARL had 1.4 million acres remaining to be acquired in its

state plan. From 1996 through 1999, CARL acquired 179,130 acres in South

Florida, worth $326 million.2 According to state officials, about 630,000

acres in South Florida remain to be acquired for habitat and conservation

purposes.

Lands to be acquired by the CARL program are first proposed by any party,

including the public, state or federal employees or agencies, or others.

These proposals are evaluated by biologists, land managers, and other

specialists to determine the boundaries needed to preserve important

natural communities and within which lands will be acquired. The lands are

also evaluated for public access and recreational opportunities. On the

1

The legislation includes some changes in the administration and allocation of the

Preservation 2000 fund. According to state officials, under the new program, the local

agencies will receive a larger share of the funding and the fund will be managed by a new

governing board.

2

These figures do not include the acres that the state acquired with Farm Bill grant funds.
Appendix II

Federal and State Land Acquisition

Page 40 GAO/RCED-00-84 South Florida Ecosystem Restoration

basis of these evaluations, the Land Acquisition and Management Advisory

Council—which includes the Secretary and Deputy Secretary of the Florida

Department of Environmental Protection, the Director of the Florida

Division of Forestry, the Executive Director of the Fish and Wildlife

Conservation Commission, the Director of the Division of Historical

Resources, and the Secretary of the Department of Community Affairs—

votes initially whether to conduct a further evaluation and public hearing

process.

After a project has been proposed and initially approved, it receives a

public hearing, during which landowners can request that their lands not be

considered for acquisition. If a proposal makes it through this public

hearing, the Advisory Council then holds another vote on whether to design

a project for the land, which includes an analysis of the land’s ownership,

ease of acquisition, and regulatory controls in place. A team of land

managers, real estate appraisers, and land acquisition agents develops a

plan to acquire the land, which includes the proposed cost, the possible

coordination among different agencies for land management, and proposed

phases for acquisition. Further public hearings are held, and then the

Advisory Council ranks the projects that have made it through this process.

New projects are added to the state priority list, which is organized into six

groups—projects that are a priority, projects that can be acquired at a

bargain or cost-shared price, projects that are substantially complete,

multiparcel projects, less-than-fee-simple purchase projects, and projects

involved in negotiations that have reached an impasse. These are then

approved by the Board of Trustees—the Governor and the Cabinet—of the

Internal Improvement Trust Fund.
Appendix II

Federal and State Land Acquisition

Page 41 GAO/RCED-00-84 South Florida Ecosystem Restoration

Save Our Rivers Program The state acquires land through SOR, which enables each of the state’s five

water management districts to acquire lands that are important for water

management, including river floodplains, wetlands, acquifer recharge

areas, springs, and lakes. The water districts are responsible for managing

the state’s water resources for the benefit of the public and for providing

environmental protection, water supply, flood control, and water-quality

protection. The South Florida Water Management District is responsible for

these activities within its boundary, which surrounds the Chain of Lakes,

Lake Okeechobee, and the Everglades area and is considered the official

boundary of the South Florida ecosystem for restoration purposes. The

District is also the local agency, with the Army Corps of Engineers,

responsible for acquiring land and constructing water projects proposed in

the review of the Central and Southern Florida Project (Restudy). From

fiscal year 1996 through fiscal year 1999, the District acquired about

135,328 acres worth about $217 million.3 According to the District, about

110,000 acres remain to be acquired in South Florida for water projects.

The lands that the District proposes to acquire are nominated by private

and public groups and by the District’s staff, in accordance with the

District’s strategic planning needs. A team of technical staff evaluates the

water and natural resource values of a proposed acquisition. This

evaluation analyzes the land’s usefulness for water management purposes,

water supply, conservation and protection purposes, habitat diversity,

species diversity, vulnerability (to development), public use, and other

purposes. In addition to this analysis, the team evaluates the benefits of

lands that will be used primarily for off-site benefits. For example, the

evaluation considers the ability of wetlands to serve as water quality

systems, to serve as recharge areas for underground acquifers, or to serve

as buffers to protect habitats or to provide public enjoyment. After this

evaluation, the projects are reviewed by the District’s management and are

discussed in public meetings. Projects that are approved at these levels are

discussed and selected by the District’s governing board. At any point in the

process, private landowners can request that their lands be removed from

consideration, and the District honors these requests.

3

These figures do not include the acres acquired by the state with Farm Bill grant funds or

the funds contributed by the state to match the grant funds.
Appendix II

Federal and State Land Acquisition

Page 42 GAO/RCED-00-84 South Florida Ecosystem Restoration

Other State Acquisition

Programs

The state, using its Preservation 2000 funds, also acquires greenways,

wildlife lands, and other community lands. The state programs, which have

received about $40 million per year from Preservation 2000 in addition to

other funding, include the following:

• The Florida Communities Trust helps local governments acquire

conservation lands and open spaces.

• The Florida Greenways and Trails Acquisition Program acquires lands to

conserve greenways and trails to link natural areas and open spaces,

conserve natural landscapes and ecosystems, and offer recreational

opportunities.

• The Florida Fish and Wildlife Conservation Commission, Florida State

Parks, and Florida Division of Forestry each acquire inholdings and

additions to wildlife management areas, state parks, and forests.

These programs identify and acquire lands. In addition, the Florida Fish

and Wildlife Conservation Commission conducted a statewide review of

habitat lands that can be acquired by other agencies or protected by such

means as conservation easements, cooperative agreements with private

owners, or tax breaks. This study, Closing the Gaps in Florida’s Wildlife

Habitat Conservation System, identifies strategic habitat areas that should

be protected to save rare plants, animals, and natural communities.
Page 43 GAO/RCED-00-84 South Florida Ecosystem Restoration

Appendix III

Comments From the Department of the

Interior ApendxIi

Note: GAO comments

supplementing those in the

report text appear at the

end of this appendix.
Appendix III

Comments From the Department of the

Interior

Page 44 GAO/RCED-00-84 South Florida Ecosystem Restoration

See comment 1.
Appendix III

Comments From the Department of the

Interior

Page 45 GAO/RCED-00-84 South Florida Ecosystem Restoration

See comment 2.
Appendix III

Comments From the Department of the

Interior

Page 46 GAO/RCED-00-84 South Florida Ecosystem Restoration
Appendix III

Comments From the Department of the

Interior

Page 47 GAO/RCED-00-84 South Florida Ecosystem Restoration

See comment 3.

Now on p. 4
Appendix III

Comments From the Department of the

Interior

Page 48 GAO/RCED-00-84 South Florida Ecosystem Restoration

See comment 4.

Now on p. 5.

See comment 7.

See comment 5.

Now on p. 10.

See comment 6.

Now on p. 10.

See comment 7.

Now on p. 23.
Appendix III

Comments From the Department of the

Interior

Page 49 GAO/RCED-00-84 South Florida Ecosystem Restoration

See comment 8.

Now on p. 24.

See comment 9.

Now on pp. 24 and 25.
Appendix III

Comments From the Department of the

Interior

Page 50 GAO/RCED-00-84 South Florida Ecosystem Restoration

See comment 1.

Now on p. 26.

See comment 10.

Now on pp. 31 and 32.
Appendix III

Comments From the Department of the

Interior

Page 51 GAO/RCED-00-84 South Florida Ecosystem Restoration

See comment 11.

Now on p. 36.
Appendix III

Comments From the Department of the

Interior

Page 52 GAO/RCED-00-84 South Florida Ecosystem Restoration

The following are GAO's comments on the Department of the Interior's

letter, dated March 10, 2000.

GAO's Comments 1. Our review focused on the Department's establishment and

implementation of the cost-sharing policy. While one of the Department's

goals was to acquire the Talisman lands with Farm Bill funds, we believe it

is evident that the purpose of requiring a dollar-for-dollar match is to

increase the funds available and thus acquire more lands than otherwise

would be possible. Furthermore, our report noted that the lands acquired

with Farm Bill funds—particularly the East Coast Buffer and Talisman

lands—will likely be used for the Corps' Comprehensive Everglades

Restoration Plan (formerly the Restudy). While it is expected that the cost

of the Corps' restoration plan will be shared equally by the federal and state

governments, the Department's assertions about the future use of the land

and about sharing the cost of the plan's projects—which may or may not

come to pass because the plan has not yet been authorized—are not a

substitute for the finite match required under its own policy. By not

consistently requiring that this cost-share be met, the Department did not

achieve its goal of acquiring as much land as possible with these funds,

which had to be obligated by December 1999, and missed opportunities to

acquire more land.

Our report recognizes that the Congress did not require a cost-share for the

Farm Bill funds, and the report commends the Department for

demonstrating the financial acuity to establish one.We do not take issue

with the acquisition of the Talisman lands, nor do we disagree that one of

the purposes of the Congress in providing Farm Bill funds was to acquire

the property. However, because we believe that the establishment of the

cost-sharing requirement reflects the Department's intent to acquire as

much land as possible with the Farm Bill funds, we continue to believe that

the Department should have required a 50/50 match from the state.We

therefore did not revise the report.

2. The Department also notes that its concern that the state of Florida

would not be able to provide 50 percent of the funds for the acquisition. As

noted in our report and in the comments provided by the state, Florida has

$300 million per year for land acquisition programs and is working closely

with the Task Force and federal agencies on the acquisition of lands that

will be used for the restoration. We believe that the Department and the

state could have worked out an arrangement—as they did for the Carroll

property when the state could not provide its share for that parcel—under
Appendix III

Comments From the Department of the

Interior

Page 53 GAO/RCED-00-84 South Florida Ecosystem Restoration

which the state would have acquired lands in other areas over time to

provide its match. The Department indicated in an internal memo that it

was going to seek a commitment from the state to fund land acquisition at

least equal to the state's matching requirement; however, the Department

never sought such an agreement.

3. We revised our report accordingly.

4. Our report acknowledges that the 1996 Farm Bill did not include a costsharing requirement and that the Secretary of the Interior retained the right

to waive the matching requirement established by the Department.

However, our purpose is to point out that the Department, after taking the

commendable step of establishing a policy to increase the funds available

for land acquisition, did not consistently apply this policy. While the

Department correctly states that in-kind contributions are allowed under

the federal grant regulations, its acceptance of lands that had already been

purchased or were in the process of being purchased in place of cash did

not increase the funds available for land acquisition and thus did not

maximize the lands purchased with Farm Bill funds.

5. We revised our report accordingly.

6. We revised our report accordingly.

7. Our review focused on the cost-sharing agreement between the federal

and state governments. The Department is correct that the total cost of the

parcel was $152.5 million, plus $0.7 million for The Nature Conservancy's

administrative costs, and that the federal government's share of the total

cost was 66 percent. The remaining share (34 percent) was paid not only by

the state but was also by third-party purchasers. Therefore, we did not

change our discussion of the federal and state costs for this reason, but we

revised our report to reflect the full cost of the parcel and the contribution

of outside parties in the transaction.

8. As noted in our report, state-purchased lands located within the

Southern Golden Gate Estates are not subject to the same management and

use provisions as those included in the grant. However, we did revise our

report to indicate that the Department of the Interior and the state are

currently developing protocols that will govern the use and management of

lands acquired in the Southern Golden Gate Estates, whether these lands

are acquired with Farm Bill funds or independently by the state. Once the

protocols are finalized, the lands acquired independently by the state will
Appendix III

Comments From the Department of the

Interior

Page 54 GAO/RCED-00-84 South Florida Ecosystem Restoration

be subject to the same grant provisions as those acquired directly with

federal funding. In addition, in discussing the state's cost-share for the

Southern Golden Gate Estates, we gave the state credit for effectively

matching the $38.1 million in federal funds provided in the grant, even

though the Department did not require the state to match the funds. We did

not change the figure to $60 million as the Department suggested because

the figure cited by the Department is an anticipated amount, not a final

amount, and because we already acknowledged in our report that the state

had independently purchased lands in the area worth $52 million.

9. We recognize that in-kind contributions are allowed under the federal

grant regulations. However, as we noted earlier, the Department, by

accepting lands that had already been purchased or were in the process of

being purchased instead of cash, did not increase the funds available for

land acquisition and thus did not maximize the lands purchased with Farm

Bill funds. We also believe that the state was responsible for acquiring the

12 parcels in the East Coast Buffer that were part of a legal settlement

against the South Florida Water Management District because the state

took the actions that resulted in the settlement and the subsequent

acquisition.

10. We revised our report accordingly.

11. We revised our report accordingly.
Page 55 GAO/RCED-00-84 South Florida Ecosystem Restoration

Appendix IV

Comments From the State of Florida ApendxIVi

See comment 1.

Note: GAO comments

supplementing those in the report

text appear at the end of this

appendix.
Page 56 GAO/RCED-00-84 South Florida Ecosystem Restoration

See comment 2.

Now on p. 3.

See comment 3.

Now on p. 3.

See comment 4.

Now on p. 4.

See comment 5.

Now on p. 4.
Appendix IV

Comments From the State of Florida

Page 57 GAO/RCED-00-84 South Florida Ecosystem Restoration

See comment 6.

Now on p. 5.

See comment 7.

Now on pp. 1 and 8.

See comment 8.

Now on p. 10

See comment 9.

Now on p. 11.
Appendix IV

Comments From the State of Florida

Page 58 GAO/RCED-00-84 South Florida Ecosystem Restoration

See comment 10.

Now on p 13.

See comment 11.

Now on pp. 14 and 15.

See comment 12.

Now on p 16.

See comment 13.

Now on pp. 17 and 38.

See comment 14.

Now on pp. 18 and 19.

See comment 15.

Now on p. 21.
Appendix IV

Comments From the State of Florida

Page 59 GAO/RCED-00-84 South Florida Ecosystem Restoration

See comment 16.

Now on pp. 21 and 22.

See comment 17.

Now on p. 24.

See comment 18.

Now on pp. 26 and 27.
Appendix IV

Comments From the State of Florida

Page 60 GAO/RCED-00-84 South Florida Ecosystem Restoration
Appendix IV

Comments From the State of Florida

Page 61 GAO/RCED-00-84 South Florida Ecosystem Restoration

See comment 1.
Appendix IV

Comments From the State of Florida

Page 62 GAO/RCED-00-84 South Florida Ecosystem Restoration

See comment 10.

See comment 5.

See comment 19.
Appendix IV

Comments From the State of Florida

Page 63 GAO/RCED-00-84 South Florida Ecosystem Restoration

The following are GAO's comments on the state of Florida's letter, dated

March 10, 2000.

GAO's Comments 1. Our report does not recommend that the Task Force acquire and manage

all lands for the restoration initiative; we clearly state that the federal and

state agencies participating in the initiative are responsible for these

activities. We recognize that the state is committed to the restoration effort

and has initiated a number of activities and programs aimed at restoring the

ecosystem. However, because the Task Force was created specifically to

coordinate and facilitate the efforts of the numerous federal, state, local,

and tribal entities participating in the restoration initiative, we believe that

the Task Force is the appropriate body to develop a land acquisition plan.

Furthermore, we believe that a land acquisition plan will allow the Task

Force to clearly communicate the initiative's land needs and priorities to

the federal and state agencies that are responsible for land acquisition. Our

recommendation does not envision that the Task Force would usurp the

authorities of the agencies that acquire lands, nor that it would supplant or

duplicate the planning processes they have under way. As we point out in

our report, we believe that the planning efforts of the federal and state

agencies are a good starting point for the Task Force to develop a land

acquisition plan.

2. The numbered items referred to by the state were not intended to reflect

the goals but were intended to describe activities for which lands will be

needed. However, to avoid confusion with the goals, we revised the report

accordingly.

3. The state is correct that regional and local agencies acquire lands in the

ecosystem. However, we did not make this change because our report

focuses specifically on lands acquired by the federal and state agencies.

4. Our report recognizes that the Farm Bill legislation did not require costsharing and that the state agreed to match Farm Bill funds dollar for dollar.

Our report also acknowledges that the state has continued to acquire lands

on its own—separate from the grant agreements—in the Southern Golden

Gate Estates and the East Coast Buffer. In the case of Southern Golden

Gate Estates, our report clearly states that the funds expended by Florida

in this area have more than exceeded the cost share required for the grant.

In addition, we point out that the state's expenditure to acquire lands in the

East Coast Buffer that were not part of the grant reduced its cost-sharing

obligation. Therefore, we did not revise our report.
Appendix IV

Comments From the State of Florida

Page 64 GAO/RCED-00-84 South Florida Ecosystem Restoration

5. As we stated earlier, our recommendation does not envision that the

Task Force would usurp the authorities of the agencies that acquire lands,

nor that it would supplant or duplicate the planning processes they have

under way. However, we believe that because lands are so critical to

achieving the initiative's goals, a land acquisition plan such as the one we

recommend would increase the initiative's chances of success.

Furthermore, we believe that the map recently developed by the state that

shows the past and planned acquisitions of the federal and state agencies is

a valuable tool to visualize the ecosystem and locate lands for future

acquisition. However, because the map does not provide the information on

cost, time frames, or alternatives to acquisition that a land acquisition plan

would provide, we do not believe that the map alone can take the place of a

land acquisition plan.

6. Our report recognizes that state of Florida has a history of acquiring

lands for conservation purposes, and our report includes information in the

introduction and background sections and in appendix II on the state's land

acquisition programs and holdings. We do not disagree that the state has

spent more than the federal government on restoration activities. However,

our report correctly points out that the state agreed to match the Farm Bill

funds dollar for dollar. This cost share was established, even though the

Farm Bill legislation did not require it, because the Department of the

Interior recognized that lands in South Florida are under development

pressure and wanted to maximize the lands acquired with these funds. In

addition, we acknowledge that the state has continued to buy lands in the

ecosystem on its own.

7. Our report already includes some discussion of Florida's efforts in 1991

and 1994. However, we added a statement to describe the 1983 Save Our

Everglades effort and indicate that the program is ongoing.

8. Our report does not state that the “right” lands for the restoration

initiative have not been identified. Rather, our report focuses on the fact

that the Task Force has established three restoration goals and has not

identified all the lands needed to achieve these goals. Our report refers to

hundreds of thousands of acres of land, including many lands identified by

the state programs, that could be used for the restoration goals. We believe

that as the entity responsible for coordinating the federal, state, local, and

tribal restoration activities, the Task Force should develop a plan that

identifies lands needed for each of the restoration goals. Most important,

we do not envision that the Task Force would supplant the ongoing efforts
Appendix IV

Comments From the State of Florida

Page 65 GAO/RCED-00-84 South Florida Ecosystem Restoration

of the federal and state agencies; rather, we see it as building on those

efforts.

9. We revised our report accordingly.

10. For the purposes of describing lands acquired for the South Florida

Ecosystem Restoration Initiative, we focused on lands acquired from 1996

through 1999. We chose this period of time because the South Florida

Ecosystem Task Force was expanded in 1996 to include state, local, and

tribal representatives, as well as federal agency representatives. While not

presented separately in the report, information on the acreage acquired by

the state for conservation and preservation purposes was added to the

report. In addition, the state's land acquisition programs are described in

appendix II of the report.

11. Because the South Florida Ecosystem Restoration Task Force

established three goals to accomplish the restoration—all of which require

lands, we believe that the Task Force is the appropriate entity to develop a

land acquisition plan. Accordingly, our recommendation is addressed to the

Secretary of the Interior, as the Chairperson of the Task Force.

12. We revised our report accordingly.

13. Our purpose in discussing the Multi-Species Recovery Plan and Closing

the Gaps in Florida's Wildlife Habitat Conservation System in our report is

to show that studies and assessments identifying lands needed for

conservation and habitat preservation have already been done and that this

information is available to the Task Force. We also revised our discussion

of the state's land acquisition programs in appendix II of the report to

reflect the state's consideration of this information in its planning process.

14. We agree with the state that questions such as how much land has been

acquired and where, and how much remains to be acquired are critical and

need to be answered. Accordingly we recommended that the Task Force

develop a land acquisition plan that would identify the lands that need to be

acquired to accomplish the initiative's goals. We also agree that lands need

to be acquired to protect and restore the ecosystem. As we have stated, we

commend the Department of the Interior for showing the foresight to

establish a cost-sharing policy that would enable it to acquire as much land

as possible, given that undeveloped land in South Florida is becoming

increasingly scarce.
Appendix IV

Comments From the State of Florida

Page 66 GAO/RCED-00-84 South Florida Ecosystem Restoration

15. Our report already acknowledges the efforts of the state to

independently acquire lands for the protection and restoration of the

ecosystem. Although we recognize that several local governments have

established land acquisition programs, consolidated information on the

acreage and the funds expended by local governments to acquire lands for

the restoration initiative was not readily available.

16. The purpose of this table is to show the state's dollar contribution to the

Farm Bill funds, as written into each of the grant agreements. Our report

clearly shows that the state continued to acquire lands independently in the

East Coast Buffer and Southern Golden Gate Estates grant areas. As the

state requested, we revised the table to reflect the state's ongoing

independent acquisition of lands in the grant areas—we added $10 million

for the East Coast Buffer and $38.1 million for the Southern Golden Gate

Estates.

17. As noted in our report, state-purchased lands located within the

Southern Golden Gate Estates are not subject to the same management and

use provisions as those included in the grant. However, we did include a

footnote to indicate that the Department of the Interior and the state are

currently developing protocols that will govern the use and management of

lands acquired in the Southern Golden Gate Estates whether the lands are

acquired with Farm Bill funds or independently by the state. Once the

protocols are finalized, the lands acquired independently by the state will

be subject to the same grant provisions as those acquired directly with

federal funding.

18. We carefully considered all of the state's comments and incorporated

the suggested changes where appropriate. However, we believe that our

report accurately reflects the results of our work, and we did not revise our

conclusions.

19. We recognize that the Farm Bill grant was in place when the 12 parcels,

which the South Florida Water Management District had agreed to buy to

settle an inverse condemnation action, were acquired. However, we believe

that the state should be responsible for acquiring these lands because the

actions that resulted in the legal settlement and subsequent acquisition

were the state's.
Page 67 GAO/RCED-00-84 South Florida Ecosystem Restoration

Appendix V

GAO Contact and Staff Acknowledgments ApendxVi

GAO Contact Barry Hill (202) 512-3841

Acknowledgments Alfredo Gómez, Susan Iott, Chet Janik, and Sherry McDonald also made

key contributions to this report.

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