83

CENTRAL & SOUTHERN FLORIDA PROJECT 

COMPREHENSIVE REVIEW STUDY:

ROAD MAP OR ROADBLOCK FOR THE FUTURE?

A CASE STUDY IN WATER RESOURCE PLANNING IN THE AGE OF

ECOSYSTEM MANAGEMENT

Cathleen C. Vogel

Director of Government Relations

Pavese, Garner, Haverfield, Dalton, Harrison & Jensen

In the realm of water resource management, 1997/98 will

long be remembered as the “El Niño Years.”

Nationwide, we have watched temperatures soar or

plummet while unrelenting storms and tornadoes have

resulted in loss of life and extensive destruction.

Extraordinary rains have caused serious flooding and

erosion. Florida has had its share of “El Niño.” To date,

the weather phenomenon has cost Florida more than $500

million in damaged crops, businesses and homes. On a

more somber note, 46 deaths have been attributed to

storms caused by El Niño.1

The effects of El Niño in South Florida can be

summarized in a word: WET! In early 1998, the region’s

typically dry winter months experienced close to 300% of

normal rainfall. This came on top of already saturated

conditions throughout the entire southern portion of the

peninsula. In fact, the main water storage feature of

South Florida, Lake Okeechobee, reached a record dryseason water level high of 18.33 ft. NGVD on February

27 causing serious problems for water managers in South

Florida: The dike surrounding Lake Okeechobee showed

signs of stress as twenty-three clear water boils were

identified. High water levels in the managed lake

required high discharges of water to be released through

a system of canals that connect the lake to the Everglades

and coastal estuaries.2 In turn, these freshwater

discharges wreaked havoc on estuaries and flooded

critical bird-nesting habitat in the southern Everglades. 

THE CENTRAL & SOUTHERN FLORIDA

PROJECT

Despite these crises, South Florida was able to contend

well with the water management challenges presented by

El Niño. Its primary defense against the extremes of high

water and torrential rains is a massive infrastructure

system known as the Central & Southern Florida Project

for Flood Control and Other Purposes. (C&SF Project,

for short) This United States Army Corps of Engineers

project is truly a marvel of engineering, land planning

and water control. Constructed primarily during the

period of 1950 to 1975, the C&SF project’s authorized

purposes include flood control, water supply, prevention

of saltwater intrusion, provision of water supply for

Everglades National Park, navigation and protection of

fish and wildlife. The project stretches from just south of

Orlando in central Florida to the southern tip of the

peninsula. It includes over 1000 miles of canals and

levees, 160 water control structures and 16 major

pumping stations, and it encompasses an area of 18,000

square miles.3 Designed to move and store water

throughout the incredibly flat, low-lying region of South

Florida, the C&SF Project also includes six major water

storage areas: Lake Okeechobee, Water Conservation

Area 1 (which is also the U.S. Fish & Wildlife Service

Loxahatchee Wildlife Refuge), Water Conservation

Areas 2A and 2B, and Water Conservation Areas 3A and

3B (See Appendix A, Central & Southern Florida Project

Map.)

More effectively than any land use planning effort, the

C&SF Project established a comprehensive blue print for

the development of southeast Florida. It designated the

area south of Lake Okeechobee for farming (the

Everglades Agricultural Area). It drew an “urban

boundary line” - the east coast protective levee - which

runs 100 miles from West Palm Beach to Homestead -

effectively setting off the urbanized east coast from the

Everglades. It established the Water Conservation Areas

to remain as Everglades habitat and water storage areas,

and it provided the facilities necessary to guarantee that

Everglades National Park would always receive adequate

water supply from the system. In fact, without the

Central & Southern Florida Project, Florida and South

Florida in particular would never have been able to

develop into the major economic and population centers

they are today. In 1950 when the project was just

underway, Florida ranked 18th among the states with a
84

population of 2.8 million. By 1990, Florida had grown to

nearly 13 million, making it the fourth largest state in the

country. Forty-nine percent of Florida’s population lives

within the region served by the C&SF Project, and this

region is critical to Florida’s economy given the income

generated by its agricultural and tourism industries.

What Price Drainage?

While the C&SF Project provides an array of direct and

indirect benefits for South Florida, it has also caused

substantial environmental problems. Florida’s

Everglades, one of its most prominent natural features, is

the largest wetland in the United States. What we

typically think of when we say the word “Everglades”

consists today of two major geopolitical regions: the

Everglades Water Conservation Areas, owned by the

state, and Everglades National Park. Together these

areas span well over a million acres. However, in its

original state, the Everglades encompassed an area twice

this size. While the idea of draining the Everglades was

first espoused in an 1848 report to the United States

Congress by Senator J.D. Westcott, 4 it took many early

attempts and ultimately the construction of the C&SF

Project to eventually succeed in this effort.

The pre-drainage Everglades ecosystem was

characterized by 1) extensive storage and natural sheet

flow (the extremely shallow elevation gradient of South

Florida - a drop in elevation of only 20 feet over the 100

mile distance from Lake Okeechobee to Florida Bay -

meant that surface water in the wetland flowed very

slowly); 2) an extraordinarily large spatial area (such

large areas sustained habitat diversity by providing

extensive feeding areas); and 3) heterogeneity of habitat.5

Drainage of this ecosystem and alteration of natural flow

patterns (the timing and volume of water moving

through the Everglades) has had two major negative side

effects that are the fundamental problems we are dealing

with in South Florida today: water quality deterioration

and reduced water supply. Stormwater runoff from

agricultural and urban activities is damaging the

remaining Everglades system as well as coastal estuaries.

In addition, the overall lowering of surface and

groundwater levels in order to drain and develop areas

and provide flood protection has resulted in a total water

storage loss from the natural system of up to 6,000,000

acre feet.6 This pre-drainage storage in essence

smoothed out the effects of erratic rainfall. It allowed

water to recede gradually during the dry season and it

also ameliorated floods and droughts.7 The loss of this

storage combined with the extreme volumes of water that

are either lost to evapotranspiration (estimated 10,470

million gallons a day) or that are discharged to the ocean

by the canal system (estimated 3,531 million gallons a

day)8 demonstrate quite clearly how a region such as

south Florida, which receives an average annual

precipitation in excess of five feet and which is one of the

two wettest areas in the country, can have a water

supply problem. 

EVERGLADES RESTORATION AND THE

RESTUDY OF THE C&SF PROJECT

For many years, efforts have been underway to restore the

Everglades. Perhaps the most substantial of these was

begun in 1983 when then-Governor Bob Graham

initiated the state’s Save Our Everglades program. The

goal of this program was that by the year 2000 the

Everglades would look and function more like they did in

1900 than when the program was begun in the 1980's.

This noble but nebulous goal underscores one of the basic

problems that we wrestle with in Florida when we debate

the Everglades. While there is consensus that this

ecosystem is severely damaged and in need of restoration,

there is no agreement on what is meant by “restoring”

the Everglades. One thing is clear, however, the key to

Everglades restoration is hydrologic restoration. Water

built the natural ecosystem of South Florida, and in order

to restore that system, we need to restore the natural

distribution and flow of water.9

Restoration of the Everglades inevitably leads to the

C&SF Project. During the 1970's and ‘80's a number of

adjustments were made to the project in the interest of

environmental protection and enhancement. A “rainfalldriven” plan was instituted to improve water deliveries to

Everglades National Park. Agricultural runoff was

identified as a serious problem for Lake Okeechobee; as

a result, severe land use restrictions were placed on

property upstream of the lake and water management

practices were altered to redirect stormwater flows away

from the lake. The drive to restore the channelized

Kissimmee River was begun. But by the early 1990's,

these piecemeal activities gave way to the philosophy that

a comprehensive review of the C&SF Project would be

necessary in order to address the environmental impacts

of the project as well as to retrofit this infrastructure

system to provide for the water management needs of a

dramatically larger and different socio-economic

community that had evolved in South Florida since the

project’s inception. Interestingly, it was the experience

of a severe South Florida drought during the period of

1988-1990 that ultimately focused sufficient attention on

the need to correct the water management mistakes of the

past and prepare for the water management needs of the

future. The drama of threatened water supply combined

with the plight of the Everglades ecosystem set the stage

for congressional authorization of a comprehensive

“restudy” of the Central & Southern Florida Project.
85

Restudy - The Early Years

The Central & Southern Florida Project Comprehensive

Review Study (or “Restudy” as it is commonly called) was

authorized by the U.S. Congress in 1992 (see Appendix

B, C&SF Project Restudy - Alternative 5). In September

of that year, two resolutions of the House Committee on

Public Works & Transportation directed the Corps of

Engineers to determine whether the C&SF Project should

be modified “in the interest of environmental quality,

water supply and other purposes” specifically citing

purposes for Florida Bay (which at that time had garnered

national attention as a result of large algae blooms that

were occurring in the western reaches of the bay). One

month later, Congress, as part of the 1992 Water

Resources Development Act (Sec. 309(1)), authorized the

Corps to determine if the project should be modified “due

to significant changed physical, biological, demographic,

or economic conditions with particular reference to

modifying the project or its operation for improving the

quality of the environment, improving protection of the

aquifer, and improving the integrity, capability and

conservation of urban water supplies affected by the

project or its operation.”10

In order to fully appreciate the magnitude and complexity

of this task which Congress had assigned the Corps of

Engineers, it is important to understand the sociopolitical “atmosphere” which surrounds the Everglades.

Simply put, the Everglades is a war zone where

environmental interests clash with agricultural and urban

interests over water quality and quantity. The Everglades

is also a battlefield where federal interests in the form of

national parks and wildlife refuges clash with the state’s

rights in land use planning and water allocation. With

close to five million people living adjacent to one of the

most fragile and endangered ecosystems in the country,

it is little wonder that consensus and cooperation are rare

commodities in South Florida. In fact, at the time when

the Restudy of the C&SF Project was authorized, many

Everglades stakeholders of South Florida were being

consumed by a prolonged legal fight over water quality

entering the Everglades from the Everglades Agricultural

Area. This lawsuit cost taxpayers an estimated $25

million; it took almost five years to settle; it spawned tens

of related suits; and it has created an unrelenting

atmosphere of distrust and anger among the many

competing interests who have a stake in Everglades

protection and water management in South Florida.

Despite this contentious and litigious climate, the Restudy

of the C&SF Project was met with great enthusiasm on all

sides. No one questioned the fact that the 40-year-old

canal system was causing damage to the environment and

was incapable of providing the level of multi-purpose

service in the future that it had in the past. People

welcomed the notion of revamping the project so that the

Everglades could be enhanced and restored and so that

human water supply needs and adequate flood protection

for the region could be ensured. Furthermore, as a Corps

of Engineers initiative, it was anticipated that the

Restudy of the C&SF Project would bring substantial

federal dollars to bear on resolving the environmental

and water supply problems of South Florida. 

THE RECONNAISSANCE STUDY

Although the Restudy was authorized in 1992, it was not

until funding was appropriated the following year that

work on the project began. From the start, it was clear

that the Restudy would be unlike any traditional Corps

project. Considering the size, complexity, and

environmental, economic, political, and technical

characteristics of the South Florida region, the

Jacksonville District of the Corps of Engineers

determined early on to approach the Restudy in an

innovative manner. The Corps project team dedicated

itself to an open and public process that would involve

participation by every federal and state agency, interest

group or concerned public with a stake in the Everglades

and the management of water in South Florida.

Traditionally, a Corps of Engineers project involves a

two-step planning process. The first step is known as a

Reconnaissance Study which is entirely the responsibility

of the federal government. During the Reconnaissance

Study, issues are framed, problems are defined, and

potential solutions are explored. If it is determined that

sufficient federal interest exists to move beyond the

problem identification stage, then the next planning step

is a much more detailed feasibility study undertaken with

a local sponsor (in this case, the South Florida Water

Management District, local sponsor of the Central &

Southern Florida Project) to identify a preferred plan of

action to address the problem.

The C&SF Restudy Reconnaissance phase lasted

approximately eighteen months. During that time, three

rounds of public workshops were held throughout South

Florida to solicit public input. However, despite the

“openness” of this early data gathering process, property

owners and water user interests who were looking to the

Restudy to address long-term water supply needs of the

region began to feel uncomfortable with the direction that

the study was taking. As reported in the Reconnaissance

Report, in July 1993, an initial project scoping session

was held involving staff from the Corps of Engineers

and the South Florida Water Management District. At

that time, it was noted by the agency personnel that
86

federal policy dictates that state and local interests have

primary responsibility for the development of water

supply. It was further acknowledged that recent

administrative policies of the federal government

recommended against federal funding for water supply

work undertaken by the Corps of Engineers. As such,

“(T)he participants concluded that the Corps’ Review

Study would focus on Everglades and Florida Bay

ecosystem restoration while accommodating other water

resource demands.” (Emphasis added)11 This was quite

a departure from the comprehensive approach to

revisiting the multi-purpose attributes of the C&SF

Project that many stakeholders in South Florida had

anticipated in the Restudy. 

The Science Sub-Group Report

Water user stakeholders’ confidence in the

Reconnaissance Study was further undermined in

November 1993 by the publication of a report by the

Science Sub-Group of the federal South Florida

Management & Coordination Working Group. About the

time that the Restudy got underway, the federal

government established an Interagency South Florida

Ecosystem Restoration Task Force. This task force

brought together all federal agencies involved in the

Everglades (Interior, Commerce, Justice, Agriculture,

Army Corps of Engineers and Environmental Protection

Agency) to coordinate federal activities and budgetary

planning on Everglades issues. The assistant-secretary

level Task Force formed an interagency South Florida

Working Group to coordinate activities at the local level.

In September 1993, the federal Task Force determined

that the management objectives being developed for the

C&SF Restudy did not meet its expectations for

Everglades restoration. The Task Force directed the

South Florida Working Group to develop federal

objectives for ecosystem restoration that could be

submitted to the Corps of Engineers within 45 days for

incorporation into the Reconnaissance Study.12 The result

of this mandate was a hastily-produced publication

known as the Science Sub-Group Report.

By all accounts, the Science Sub-Group Report was a

sketchy document. It provided an overview of the

ecological problems that had developed in South Florida

as a result of drainage and development, outlining how

the natural landscape of the region had become highly

fragmented with loss of habitat diversity.13 However, the

document drew skeptics when it defined restoration as the

reconstruction of pre-existing ecological conditions. As

stated in the report, the “conceptual target of restoration

of South Florida wetlands and estuaries is pre-drainage

South Florida as defined for topography and hydrology by

the 1858 military map.”14 For property owners and

others in South Florida, the fact that a federal document

would suggest a return to the “typography and

hydrology” of 1858 seemed preposterous. The broad

conceptual restoration goals outlined in the report

seemed reasonable: 1) Restore areal extent as well as

hydrologic integrity of the system; 2) Adjust hydrologic

restoration to maximize ecologic restoration; 3) establish

a regional monitoring system to measure success.

However, specific proposals recommended in the report

were totally unrealistic. For example, one

recommendation, which was described as a “minimum

plan” to achieve restoration goals, was the conversion of

a 150,000 acres of productive farmland (one third of the

lands within the Everglades Agricultural Area) into a

“flowway” that would hydrologically connect Lake

Okeechobee with the Water Conservation Areas.15 Such

fantastic notions drew harsh criticism from the

potentially affected publics, property owners and local

governments in the region and undermined the

credibility of the document. Furthermore, the Science

Sub-Group Report was entirely dedicated to

environmental objectives. Water supply and other waterrelated needs of the region were completely absent from

the document. If, in fact, the report represented the

federal government’s objectives for the Restudy, it left

many interests in South Florida feeling very

uncomfortable about the federal motives for this project.

Reconnaissance Study Recommendations

A year after the release of the Science Sub-Group Report,

the Corps of Engineers completed its Reconnaissance

Report on the Comprehensive Review Study (November

1994). To its credit, the Corps presented a much more

balanced publication which described an ecological goal

for Everglades restoration as the recreation on a smaller

scale of a healthy ecosystem that would be large enough

and diverse enough to survive natural cycles of droughts,

floods, and hurricanes.16 The Reconnaissance Report

offered an optimistic outlook for Everglades restoration

noting that in spite of the negative alterations that had

occurred in the ecosystem, the opportunities for recovery

are great. Much of the original Everglades system

remains in public ownership and the total area of

remaining wetlands is relatively large in size, allowing

for almost all characteristic species to remain. 

The report outlined a number of goals for the Restudy of

the C&SF Project that included ecosystem restoration,

water quality improvement, water supply development,

flood control, and recreation. Still, most of the detailed

substance of the report was dedicated primarily to the

environmental restoration aspects of the Restudy. For

instance, the Reconnaissance Report concluded the

following:
87

• An adaptive management approach to the planning

process should be taken.

• Florida Bay would benefit from restoring the timing

and amount of natural freshwater flows into its

northeast section. Additional research is needed on

the bay.

• The spatial extent of wetlands in the system should

be increased through surface storage areas,

particularly along the eastern boundary of the east

coast levee which separates urban Palm Beach,

Broward and Dade Counties from the Everglades

(this concept became known as the Water Preserve

Areas), and through flowways.

• Operational changes to the C&SF Project alone could

improve some natural communities and could

improve flood protection. Operational changes in

connection with more storage areas and flowways

could substantially improve the ability to manage

more natural sheet flows, especially to Everglades

National Park.

• The models utilized in the Reconnaissance Study

were not sufficient to address water quality issues.

• Very little was recommended with respect to water

supply; however the report did acknowledge that its

modeling had been based on 1990 water supply

demands.

• In terms of economic impact, the Report concluded

that the Restudy could have local and regional

economic impacts owing in large part to the

tremendous land acquisition activities that were

envisioned - the Reconnaissance Report suggested

that from 80,000 to 260,000 acres would need to be

acquired through the Restudy Project in order to

address environmental restoration.

Once again, the federal government had issued a

document that weighed heavily in favor of the

environmental restoration aspects of the Restudy of the

C&SF Project while seemingly giving short shrift to the

future water supply, flood control and other water

management needs of South Florida. Despite the fact that

property owners and water-user interests in South Florida

raised considerable concern about the Reconnaissance

Report, the recommendation of the Corps was to proceed

to the next phase of the Restudy - the Feasibility Report.

 

THE FEASIBILITY STUDY

Whereas the Reconnaissance portion of the Restudy

Project was conducted entirely by the Corps of Engineers,

the second planning phase, the Feasibility Study, had to

be undertaken in partnership with a local sponsor. In

fact, the decision to proceed to the Feasibility phase was

based on 1) the potential solution to problems identified

by the Reconnaissance Study have a federal interest; 2)

the solution is in keeping with federal policies and

budgetary priorities; and 3) the solution is supported by

a non-federal sponsor. 17 In this case, the non-federal

sponsor is the South Florida Water Management District,

one of Florida’s five regional water management

agencies which have broad authority for planning,

regulation and management of regional water resources.

The South Florida Water Management District was

established in 1949 (as the Flood Control District at that

time) in order to serve as the local sponsor for the

construction and operation of the Central & Southern

Florida Project. The District is financed primarily

through ad valorem taxes. As local sponsor for the

Feasibility Study, the District was committed to a 50-50

cost share on the expense of the Feasibility Study. The

terms of the study and responsibilities of the federal and

local partners are spelled out in what is called a Project

Study Plan.

The first Project Study Plan for the Restudy was issued in

July 1995. During the time it took to develop the Project

Study Plan, water-user interests in South Florida had

stepped up their involvement with the Restudy Project

and had voiced objections to any Restudy plan that would

not adequately address water supply and other water

management needs. For example, the water

management district’s Agricultural Advisory Committee

expressed concerns in the spring of 1994 that the Corps

Restudy Plan needed to address much more than just

Everglades restoration. It needed to deal with socioeconomic factors that depend on water supply and water

management. Flood control needed to be included in the

study, and goals and objectives needed to be clarified.

For instance, what did the government agencies mean

when they talked about ecosystem restoration? Could

they define a “restored Everglades?” In a similar vein,

Palm Beach, Broward and Dade counties’ water utilities

and other urban suppliers were concerned that the

Restudy process was failing to address urban water

needs and how these needs would be integrated with

Everglades restoration.

As a result of this heightened attention to the Restudy

and its perceived shortcomings, the Corps of Engineers

and the water management district worked more closely

with water-user interests in the drafting of the Project

Study Plan for the Feasibility Study. The plan admitted

that the Reconnaissance Study had identified important
88

components to achieve ecosystem restoration, but that

water supply and water quality were not fully evaluated

during the Reconnaissance phase. The Project Study Plan

concluded that additional studies were needed.18 As

such, it laid out a course of action wherein the Corps of

Engineers would look to the South Florida Water

Management District’s water supply planning initiative

for Florida’s lower east coast (Palm Beach, Broward,

Dade and Monroe counties) that had been begun in 1992

to serve as the basis for the Restudy’s approach to 

addressing water supply. As the Project Study Plan

noted, the Corps of Engineers would use the water

management district’s Lower East Coast Regional Water

Supply Plan (which was scheduled to be completed by

late 1996) to define water supply problems and develop

alternative plans to address them.19

This approach provided some degree of comfort to wateruser interests. Many of them had been participating

directly with the water management district as part of an

advisory committee on the development of the Lower East

Coast Regional Water Supply Plan. Water users

concurred that it made sense for the Corps of Engineers

to look to the work of the water management district and

to incorporate the locally-generated plan for addressing

future water supply needs into the broader plan of

Restudy of the C&SF Project.

Here, it is important to understand the role that a

Feasibility Study plays in the traditional development of

a Corps of Engineers water resource project. The

Feasibility Study is the final planning step. The report of

the study is submitted to the United States Congress for

congressional approval prior to the Corps being able to

proceed to undertake more detailed designs and

engineering plans to implement a project. As such, and

in accordance with the requirements laid out in the 1986

Water Resources Development Act, a Feasibility Study

must describe with reasonable certainty the economic,

environmental, social and engineering benefits and costs

of the recommended alternative plans. A Feasibility

Report serves as a complete decision-making document to

allow decision makers to judge the recommend solution.

(Emphasis added)20 

In recognition of these requirements for thorough

analysis, the 1995 Project Study Plan presented a six-year

work plan that included the development and peer review

of computer models, specific hydrologic and economic

studies and an $18 million planning budget. While a

typical feasibility study takes four years to complete, the

1995 work plan explained that the Feasibility Study for

the Restudy of the C&SF Project would take six years to

finish. The Study Plan explained that this time frame is

“necessary and justifiable” considering the size of the

study area, the need to maintain an ecosystem-based

focus, the magnitude of the project, and the fact that the

“study area has complex and controversial problems that

require intensive (and time consuming) public

involvement and environmental evaluations. For these

reasons, the six-year study time frame is reasonable and

appropriate.”

21

Feasibility Study Changes Course

Given the thoughtful and reasonable study approach

outlined in the 1995 Project Study Plan, property owners

and water user interests in South Florida finally gained

a level of comfort with the direction in which the Restudy

of the C&SF Project was heading. So, it was not

surprising that this comfort soon diminished as a series

of events unfolded that dramatically changed the course

of the Restudy Feasibility Study. 

In the spring of 1994, Florida Governor Lawton Chiles

established the Governor’s Commission for a Sustainable

South Florida. The commission’s 47 members

represented a variety of interests including federal, state,

tribal, local and regional governments, environmental

organizations, economic developmentrepresentatives and

agricultural interests. The mission of the Sustainable

South Florida Commission was to examine all aspects of

the South Florida ecosystem and to make

recommendations to further a sustainable economy and

maintain a quality of life for South Florida residents that

is compatible with a healthy natural system. The

commission’s first report, issued in October 1995,

contained 110 recommendations dealing with a multitude

of social, economic, and environmental issues in the

greater South Florida region. 

While the scope of the Sustainable Commission’s charge

was much broader than that of the Restudy of the C&SF

Project, many of the commission’s deliberations focused

on water as the key to both a sustainable economy and

environment in South Florida. Many of the government

agency members of the commission were directly

involved with the Corps of Engineers Restudy project.

And many of the initial recommendations of the

Sustainable South Florida Commission paralleled the

proposals being generated by the Reconnaissance Report

and under development through the Feasibility Study.

(This was not surprising since most of the staff and

technical support for the Governor’s Commission were

being provided by the water management district.) In

short, there were many similarities between the work of

the Governor’s Commission and that of the Corps and
89

the water management district in the Restudy Project.

Given these de facto connections, it made sense for the

Sustainable South Florida Commission to evolve as a

forum for discussion and debate relating to the Restudy.

So much so that in the immediate aftermath of the 1995

Project Study Plan for the Restudy Feasibility phase, the

Sustainable South Florida Commission undertook its own

review and analysis of Everglades restoration and water

supply needs of the region in order to publish a

“Conceptual Plan for the Central & Southern Florida

Project Restudy.”22

This eleven-month review concluded that the C&SF

Project Restudy plan should focus on thirteen main

thematic concepts to accomplish its objective for restoring

the environment and addressing the water supply and

other water related needs of the South Florida region.

These thematic concepts included:23

8. The need to increase regional water storage in the

headwaters of the Everglades and adjacent areas.

9. The need to revise Lake Okeechobee’s water level

regulation schedule to enhance environmental

protection and water supply.

10. The need to store more surface water in reservoirs

within the Everglades Agricultural Area.

11. The need to construct Water Preserve Areas along

the east coast to capture water that is otherwise

discharged to the ocean; to ameliorate groundwater

seepage from the Everglades; and to create a wetland

buffer between the urbanized coastal area and the

Everglades.

12. The need to establish continuity and

spatial/hydrologic connections between natural areas

within the Everglades ecosystem.

13. The need to address water supply and flood

protection for urban and agricultural areas.

14. The need to ensure adequate water quality for the

environment.

15. The need to expand the spatial extent and quality of

wetlands outside of the boundaries of the Everglades.

16. The need to control non-native, invasive plant

species in the Everglades ecosystem.

17. The need to further develop Aquifer Storage and

Recovery as a potential solution for future water

supply.

18. The need to protect and restore estuarine and coastal

marine ecosystems.

19. The need to enhance soil conservation, especially

within the Everglades Agricultural Area.

20. The need to address modifications to the operation

and maintenance of the C&SF Project.

The Sustainable South Florida Commission’s Conceptual

Plan was developed through a participatory and

consensus-based process which involved to as great a

degree as possible all those who had a vested interest in

Everglades issues. As a result, most water-user interests,

economic development representatives and property

owners felt it encompassed a more balanced approach

and placed much greater emphasis on dealing with all

water related needs of the region - not just environmental

restoration. 

Yet, there were a number of recommendations contained

within the Governor’s Commission report that generated

new concerns. For instance, the report expressed doubts

about the capacity of the traditional Corps of Engineers

project development process to deal with the Restudy of

the C&SF Project. The Conceptual Plan stated that

“given the complexity and size of the C&SF Project, the

existing piecemeal approach would likely fail...”. The

plan went on to recommend “an improved partnership

between federal and state government that streamlines

the review and authorization of the C&SF Project

modifications...”.24

What proved most distressing to some stakeholders who

had participated in the Conceptual Plan’s formulation

was a recommendation to accelerate the process of the

Restudy so that a Feasibility Report would be submitted

to Congress much earlier than originally planned. The

Conceptual Plan went so far as to recommend that the

Project Study Plan (which had been begun the preceding

year and which was scheduled to take six years to

complete) be finished as expeditiously as possible and

be amended to reflect the Sustainable South Florida

Commission’s Conceptual Plan. Furthermore, while the

C&SF Project Restudy was being developed, the

Commission recommended that Congress immediately

authorize modifications to the C&SF Project consistent

with the Commission’s Conceptual Plan, and that the

Corps and the local sponsor should have authority to

acquire lands consistent with the Commission’s Plan. 25

(Emphasis added.) It came as no surprise that many

water-user interests and property owners began to sound

the alarm over such proposals. Here, on the basis of little

more than a conceptual plan ( which by its own
90

admission did not involve a technical evaluation of its

recommendations) an appointed commission was

suggesting that Congress immediately under take land

acquisition and authorize changes to the way water is

managed in South Florida!

The 1996 Water Resources Development Act

If the Sustainable South Florida Commission’s

Conceptual Plan had re-ignited the doubts and concerns

of water user interests and property owners in South

Florida, then the ensuing passage of the 1996 Water

Resources Development Act threw gas on the fire! In

response to intense lobbying by environmental interests

and the Department of Interior, the Congress adopted

provisions in the act that substantially changed the course

of the Restudy of the C&SF Project. The Act directed the

secretary of the Army to develop as expeditiously as

practicable a comprehensive plan (emphasis added) for

the purpose of restoring, preserving and protecting the

South Florida ecosystem. The comprehensive plan would

provide for water quality in the Everglades (thereby

authorizing the Corps of Engineers to undertake

components that would address water quality - an issue

heretofore left to the responsibility of state and local

governments). As a result of last minute efforts by

business and agricultural interests, the act also directed

that the comprehensive plan would provide for the water

related needs of the region including flood control,

enhancement of water supplies and other objectives

served by the C&SF Project.26

The act mandated that the Corps would consider the

conceptual framework specified in the Sustainable South

Florida Commission’s Conceptual Plan as the basis for

the comprehensive plan. It went on to direct that the

submittal of the C&SF Restudy Feasibility Report along

with a Programmatic EIS be accelerated by two years.

Under this congressional mandate, the Corps and the

district must now present the Feasibility Report by July

1999.

As a result of the 1996 Water Resources Development

Act, many stakeholders in South Florida were left

wondering how the Corps and the district would proceed.

Having admitted in their 1995 Project Study Plan that it

would be very difficult to complete an adequate

Feasibility Report is six years, they were now being

directed to do so in less than four. Yet, according to the

directive of the act, the Congress still required that a

feasibility report be submitted. Could the Corps and the

district achieve that level of analysis and detail required

by a Corps feasibility report in such a short period of

time? Many South Florida players participating in the

Restudy process did not believe this could be

accomplished, despite assurances from Corps leadership.

And in large part, many events that have unfolded in

South Florida since the passage of the 1996 Water

Resources Development Act have only served to bolster

this conclusion.

STATUS OF THE C&SF RESTUDY - 1998

To their credit, the Corps of Engineers, Jacksonville

District and the South Florida Water Management

District have done a herculean task in trying to comply

with the new congressionally-mandated schedule for the

C&SF Restudy, to incorporate the Sustainable South

Florida Commission’s Conceptual Plan as the framework

for the Restudy, and to continue to keep the Restudy

process open to the public and affected interests. But

some important components of a successful Restudy plan

have been left undone.

For example, upon receiving the new directives from

Congress, the Corps and the water management district

set about to revise the Project Study Plan for the C&SF

Restudy Feasibility phase. In May, 1997, a new work

plan was adopted.27 This $39 million study outlined a

course of action to identify the most plausible beneficial

alternative plan components for South Florida ecosystem

restoration and urban and agricultural water supply. The

work plan specified, however, that considering the

uncertainties regarding design and details - such as the

locations that may be proposed for surface water storage

reservoirs - the ultimate components recommended by

the Feasibility Report may need to be revised in the

future, especially in terms of design and cost estimates.28

The 1997 Project Study Plan continued to place great

emphasis on the utilization of the South Florida Water

Management District’s Lower East Coast Regional Water

Supply Plan as the basis for determining much of the

water supply portion of the Restudy Feasibility Report.

Unfortunately, the Lower East Coast Plan was never

completed. Work on a draft Lower East Coast Plan that

was issued in March 1997 was disbanded in the fall of

that year. In its place, a much smaller scale “interim”

plan was adopted by the District in December 1997.

There are several reasons for this. New state law

requirements for water supply planning were difficult to

incorporate into the existing planning process. However,

it is just as likely that the water management district was

unable to complete its water supply plan while at the

same time meet the accelerated work schedule for the

Restudy. While this is understandable, it does little to

address the uncertainties of concerned water-user

interests in the region.
91

Now, instead of a local water supply plan forming the

basis for the Corps of Engineers long-term

comprehensive program for the C&SF Project, the water

management district will be looking to the results of the

Restudy to direct regional water supply plans. And as we

are quickly approaching the time when the Corps and the

water management district will be selecting a preferred

plan to recommend in the Feasibility Report to

Congress,29 what is the outlook for the Restudy

recommendations?

Although the plan development is still in progress, South

Florida stakeholders have been closely following the

review and analysis of five alternative plans that have

been presented to date by the Corps and the water

management district. As of this writing, a sixth and final

plan is being modeled. Many of the major components

proposed for the Restudy have been reiterated from one

alternative plan to the next. Alternative 5 (see Appendix

B) includes the major proposals that the Restudy has

featured to date: 1) construction of a series of large

surface water storage reservoirs throughout the South

Florida region that will store water for water supply

purposes, ameliorate high water levels and provide

enhanced protection for estuaries and other natural water

bodies which presently bear the brunt of heavy

discharges, and serve to restore more natural flows to the

Everglades; 2) construction of hundreds of Aquifer

Storage and Recovery Wells to address urban water

supply needs; 3) re-establishment of more natural

hydrologic connections within the Water Conservation

Areas by removing canals and levees; and 4) creation of

an “in-ground” reservoir in northwest Dade County to

serve the water supply needs of greater Miami by

constructing a curtain wall 100-200 feet deep around

8000 acres of rock mining pits.

While these concepts are intriguing, many stakeholders

are left wondering about their cost-benefit and technical

efficacy. As recently as the spring of this year, the

Environmental Protection Agency voiced concerns about

the regulatory impediments to large-scale aquifer storage

and recovery. The Corps Restudy models assume that

any ASR injection water will be pre-treated to comply

with regulatory water quality issues. However, as several

water utility directors note, assumptions may work in

computer models, but when a plan is relying on 1.7 to 2

billion gallons per day of ASR capacity to meet future

urban needs, the water quality treatment costs alone could

add up to $4 billion to the cost of the Restudy plan.30

Urban water users were not the only ones to voice

concerns about the water supply proposals being

presented in the Restudy. Everglades National Park

publicly questioned the reasonableness of relying so

heavily on ASR, especially considering that pilot projects

in South Florida do not support the retrieval rate (70%)

upon which the Corps and water management district

were basing their analyses. Similarly, the Park raised

concerns about the engineering feasibility of the inground water supply reservoir proposed in northwest

Dade County that would be the future source of greater

Miami’s water supply.31

And water supply is not the only issue that is drawing

criticism: At an April 15, 1998 meeting of the South 

Florida Water Management District, a number of

stakeholders participated in a panel discussion to

elaborate their concerns about the Restudy. Major

questions were raised including:

1. The anticipated level of detail in the product being

submitted to the United States Congress in July 1999

seems woefully inadequate in many people’s minds;

2. It is unclear what the role of the water management

district will be - does the district, as local sponsor,

have a responsibility to see that the final Feasibility

product of the C&SF Restudy live up to the

mandates of state water law?; 

3. The practicality of relying excessively on ASR is

questioned, especially when water users do not see

any back-up proposals for addressing future urban

water supply in the event that ASR does not work;

4. The proposals to decompartmentalize the Water

Conservation Areas (i.e. remove the canals and

levees that separate one Area from the next) raise

questions about whether such actions would hurt

rather than help the environment;

5. In general, the interested parties question the

adequacy with which the Restudy plan is addressing

urban and agricultural water supply needs;

6. The ability of the proposed surface reservoirs to

retain water for water supply purposes during the

dry season has come under fire. This is the time of

year when evapotranspiration is at its highest and

shallow surface waters typically add to water loss

from the system rather than retention within the

system. Likewise, in some areas the sandy sub-soils

and the direct interface between surface and ground

water lead may to believe that it would be impossible

for a surface system to hold water during dry times;
92

7. There are concerns that the plan does very little to

address water quality. Without this, it would likely

be impossible for increased flows to be discharged

into the Everglades;

8. Environmentalists question the capacity of the

Restudy planning process to incorporate, at this late

date, the findings of the U.S. Department of Interior

Multi-Species Recovery Plan for South Florida;

9. The nominal degree of sensitivity and risk analysis

that is being conducted as part of the Restudy

planning process has given some cause for concern;

10. Finally, the fact that proposals are already being

generated to modify the operations of the C&SF

Project prior to the conclusion of the Restudy

planning process, leave many people scratching their

heads. Why would the Corps or the water

management district want to change the water level

regulation schedule on Lake Okeechobee, for

instance, prior to completing its planning effort?.32

In short, there are many questions and concerns being

raised about the Restudy plan even as the Corps of

Engineers and the water management district are poised

to select a preferred alternative plan during the summer

of 1998 that will serve as the basis for a Feasibility

Report recommendation to the United States Congress.

None of the South Florida participants - the

environmentalists, the economic development interests,

the water suppliers, or agriculture - want to be perceived

as “Naysayers” in this process. However, they do feel

that they have a legitimate complaint: They are concerned

about sending a report to Congress that is designed to

result in Congressional authorization of a plan to

dramatically alter the landscape and water management

regime of South Florida, without more of their questions

being answered first.

In fact, concerned South Florida interests are not sure

exactly what the report that is going to Congress will be.

By its own admission, the Corps of Engineers notes in its

revised Project Study Plan that “Due to the geographic

extent of the study area and the need to complete this

study in a timely fashion, the level of detail will not be

sufficient to proceed directly into detailed engineering

design for the entire comprehensive plan. Many

components or features of the comprehensive plan will

require further study and additional evaluation before

proceeding into final design and preparation of plans and

specifications. Further, some work items, particularly

computer modeling efforts, will be initiated during the

feasibility phase in support of subsequent efforts.”33 This

being the case, South Florida interests question why a

report would be sent to Congress for authorization before

the computer models, further study and additional

evaluation are completed.

As a result of these concerns, water suppliers, property

owners, local governments, agriculture and economic

development interests took some rather dramatic and

unprecedented measures to ensure that their interests are

protected in this process. As of this writing, a bill is

pending before the 1998 Florida legislature34 that was

promoted and lobbied by these interests. The bill

requires that any project or modification to the existing

C&SF Project that results from the Restudy plan would

not only need approval of the local sponsor prior to

implementation, but would also need review by the

Florida legislature. Such a step involves the state much

more directly in the federal process than it has been to

date. The real rationale behind this legislative initiative

is quite simple: Present cost estimates for the Restudy

Plan range as high as $5 billion. The South Florida

Water Management District will not have the financial

capacity within its ad valorem tax base to provide its

50% share of this funding in the future. As such, most

of the local share will need to come from a new source

such as higher taxes, water use fees, or additional monies

from state land acquisition programs. In a nutshell, the

Florida legislature will be asked to pay for this. It only

makes sense then that the legislature be involved in

reviewing and approving the Restudy plans and projects.

LESSONS LEARNED

As we are fast approaching the conclusion of the

planning phase of the C&SF Project Restudy, what has

our experience to date taught us? Perhaps the clearest

lesson, when it comes to large-scale water resource

planning, was best articulated by Chuck Aller, Director

of Water Policy for the Florida Department of

Agriculture and Consumer Services. In recent comments

to the Governing Board of the South Florida Water

Management District, Aller noted, commenting on the

Restudy process, “When you increase the level of

uncertainty, you increase the level of resistance.”35 To

date, despite the best efforts of the Corps and the water

management district, there has been a huge degree of

uncertainty in the Restudy process. The process has been

substantially accelerated, and as a result, standard

feasibility-level analyses have not been completed. It is

unclear what the product that will be sent to Congress

will achieve. Is it intended as a “comprehensive plan”

that may well be very conceptual in nature, or is it

intended to fulfill the Corps requirement of a detailed

feasibility analysis? It is clear that until these concerns

and others are addressed there will continue to be serious
93

1. Long, Phil. “Forecast: Less El Niño and Not so Hot.” The Miami Herald. Sunday, April 26, 1998, p. 6B.

2. In early March, over 8000 cubic feet per second was being released from the lake into the Caloosahatchee

River to the west. On the lake’s east side, 7000 c.f.s. were being sent down the St. Lucie River. (South Florida

Water Management District, Water Conditions Summary, March 12, 1998)

3. U.S. Army Corps of Engineers. Central & Southern Florida Project. Reconnaissance Report - Comprehensive

Review Study, November 1994, p.3.

resistance to the Restudy by many local South Florida

interests. And this is understandable: people’s land and

water supply are at stake.

What can the Corps and the water management district

do to resolve this resistance? As a starting point, and at

a minimum, these government agencies can lay out a

clear game plan with reasonable time schedules of how

we proceed from this point forward. When will the

necessary hydrologic, ecologic, and economic studies be

completed? When will computer models be peer

reviewed? How will these results be incorporated into the

existing proposals for the Restudy, particularly if they

demonstrate the lack of feasibility of any components of

the Restudy plan? What alternatives to surface water

reservoirs or ASR wells will the Corps and district

pursue if these major foundations for the Restudy prove

impractical?

Secondly, and more importantly, if a major goal of the

C&SF Project Restudy is the restoration of the

Everglades, then we need to engage the public policy

debate over what our restoration goals for this ecosystem

really are. They have yet to be defined in a manner that

provides a useable guide for action by policy makers at

local, state and federal levels. Some have argued that the

Everglades of the mid 1800's should be our goal. But,

since that system has been reduced to half its original

size, is our real goal to create a smaller, but naturally

functioning system? If this is the case, then some leading

experts have pointed out that there is much we don’t

know or understand about how the ecosystem actually

functioned prior to drainage. Some of the computer

models that will help us understand the ecologic

relationships of the system are still under development.

And the hydrologic model that is being used to dictate

hydropattern goals - the Natural Systems Model - is really

a digital approximation of water levels and flows in preColombian Florida. It may not be a good predictor of

how best to restore environmental functions and values in

a system that has been dramatically altered.36 

On a final note, the C&SF Project Restudy process has

certainly taught us how difficult, if not impossible, water

resource planning is on a scale as large and complex as

that of the Everglades. It underscores the tensions,

contradictions and shifting goals and objectives with

which the Corps and the water management district have

had to struggle. On one hand there is ready agreement

that we can no longer do water resource planning in a

piecemeal fashion. We must integrate at a watershed or

water basin level our goals for meeting the needs of the

environment and the economy, recognizing the

interrelationships that exist throughout the natural and

manmade systems. The experience of the C&SF Project

Restudy may yet demonstrate, however, that such a

philosophy is noble but impractical on this scale. Just

consider that when the Restudy was first begun in 1993,

water shortages, a parched Everglades, and algae blooms

on Florida Bay were the climactic and ecologic issues

shaping the Restudy agenda. Five years later the

Restudy focus has shifted to high water levels in Lake

Okeechobee and excessive discharges to coastal estuaries.

Can any single plan deal with the dramatically shifting

hydrologic conditions, the competing socio-economic

interests and the scientific uncertainties of a region twice

the size of the state of New Jersey? Or will the

comprehensive Restudy plan for the C&SF Project

ultimately evolve into a series of smaller, discreet, sitespecific plans?

It remains to be seen how the Restudy will proceed. But

it is clear that the people of South Florida have great

hopes that a consensus-based plan or plans will

ultimately emerge to guide environmental protection and

economic development into the future. It is also clear

that water resource managers in South Florida will be

kept busy here for years to come!

ENDNOTES
94

4. Reconnaissance Report - Comprehensive Review Study, p.19.

5. “Federal Objectives for the South Florida Restoration,” Science Sub-Group Report of the South Florida

Management & Coordination Working Group. November 15, 1993, p.3.

6. “Everglades Water Budget Presentation,” Governor’s Commission for a Sustainable South Florida. July 20,

1995, p. 22.

7. ibid.

8. “A Public Utility’s Perspective on Water Supply Issues,” Palm Beach County Water Utilities Department

Presentation to the Governor’s Commission for a Sustainable South Florida. March 27, 1998.

9. “Federal Objectives for the South Florida Restoration,” p.1.

10. “Central & Southern Florida Project Review Study News,” U.S. Army Corps of Engineers, Jacksonville

District, June 1994, p.3.

11. Reconnaissance Report, p. 76.

12. Reconnaissance Report, p. 79.

13. “Federal Objectives for the South Florida Restoration,” Science Sub-Group Report, p. 9.

14. Science Sub-Group Report, p. 15.

15. Science Sub-Group, pp. 46-47.

16. Reconnaissance Report, p. E-2.

17. Reconnaissance Report, p. 203.

18. Central & Southern Florida Project Comprehensive Review Study Project Study Plan, July 1995, p.13.

19. Project Study Plan, July 1995, p. 6.

20. Reconnaissance Report, p. 193.

21. Project Study Plan, July 1995, p. 13.

22. The Governor’s Commission for a Sustainable South Florida, “A Conceptual Plan for the Central & Southern

Florida Project Restudy,” August 1996.

23. Conceptual Plan, pp. 2-3.

24. Conceptual Plan, p. 17.

25. Conceptual Plan, pp. 64-65.

26. Section 309 (1), Water Resources Development Act of 1996.

27. Central & Southern Florida Project Comprehensive Review Study, Project Study Plan for the Comprehensive

Plan, the Water Preserve Areas and the L-28 Feasibility Study, May 1997.
95

28. Project Study Plan, May 1997, p. 21.

29. In order to meet the July 1999 deadline for submitting the Feasibility Report and Programmatic EIS to

Congress, the Restudy project team must select a preferred plan by the summer of 1998 so that it can be

publicly reviewed, approved by the water management district as local sponsor by October 1998 and forwarded

for final Corps review.

30. Gary Dernlan, Palm Beach County Water Utility Director. Comments made at a public workshop of the

Governing Board of the South Florida Water Management District, April 15, 1998.

31. Department of Interior Views on Selected Restudy Water Supply Components. Presentation to the Sustainable

South Florida Commission, March 24, 1998.

32. South Florida Water Management District Governing Board Workshop. Presentation on the C&SF Restudy,

April 15, 1998.

33. Central & Southern Florida Project Comprehensive Review Study, Project Study Plan, revised May 1997,

 p. 25.

34. House Bill 4141 and Senate Companion Bill 2356.

35. South Florida Water Management District Governing Board Workshop, April 15, 1998.

36. MacVicar, Thomas K. South Florida Water Management District Governing Board Workshop, April 15, 1998.