March 19, 2021

Aquifer Storage and Recovery Project Managers South Water Management District and U.S. Army Corps of Engineers

Submitted by email to [email protected]

To Whom It May Concern:

The Foundation commends the South Florida Water Management District (District) and the U.S. Army Corps of Engineers for preparing a science plan to govern implementation of Aquifer Storage and Recovery (ASR). Uncertainties around full-scale implementation of ASR as an element of the Comprehensive Everglades Restoration Plan (CERP) have been the subject of intense scientific investigation and scientific review since it was first proposed. The Final Draft 2021 Aquifer Storage and Recovery Science Plan (Science Plan) represents a significant step forward in conducting the research and investigation that the National Academy of Sciences says is necessary to determine whether full- scale implementation of ASR is feasible and cost-effective. The Everglades Foundation’s Science team offers the following recommendations concerning the Science Plan.

First, we recommend further detail be added about the scale of implementation. While most agree that a phased approach is necessary, the size of each increment is important. Additional information on the scale of the first phase of implementation would be beneficial. We endorse the recent National Academy of Sciences’ recommendation of two to five wells per cluster as a reasonable starting point1.

Second, we recommend including a review of the costs and benefits of ASR compared to other water storage alternatives suggested by the National Academy of Sciences. We recommend that a full cost accounting be undertaken and included in the proposed investigations.

Third, because of the technical nature of the information being gathered and analyzed, we recommend that the Science Plan allow for ongoing comments and a regular schedule for updates, perhaps on the same schedule as the workshops proposed in Section 2.4. We understand that the Science Plan will evolve, as the studies progress.

Last, we suggest identifying specific points in time when a “go/no go” decision will be made after reviewing and analyzing the information that is being gathered during various phases of the Science Plan. We also recommend applying the concept of adaptive management from CERP to the Science Plan as a whole.

1 National Academies of Sciences, Engineering, and Medicine. 2021. Progress Toward Restoring the Everglades: The Eighth Biennial Review - 2020. Washington, DC: The National Academies Press. https://doi.org/10.17226/25853 p. 73

18001 Old Cutler Road Suite 625 Palmetto Bay FL 33157 email: [email protected] tel: 305-251-0001 fax: 305-251-0039 website: evergladesfoundation.org

In conclusion, we fully support the District’s science-based approach to investigating the uncertainties that remain with ASR and establishing a transparent process for obtaining the information necessary to resolve those uncertainties. We stand ready to assist you in this scientific research and analysis as needed.

Sincerely,

Anteneh Abiy, Ph.D. Hydrogeologist

Yogesh Khare, Ph.D. Environmental Engineer

Rajendra Paudel, Ph.D. Senior Hydrologist

Andrew Stainback, Ph.D., J.D. Economist

Thomas Van Lent, Ph.D. Senior Scientist

Ruscena Wiederholt, Ph.D. Computational Ecologist

18001 Old Cutler Road Suite 625 Palmetto Bay FL 33157 email: [email protected] tel: 305-251-0001 fax: 305-251-0039 website: evergladesfoundation.org