LOSOM Public Comments

As the U.S. Army Corps of Engineers (USACE) evaluates the Lake Okeechobee System Operating Manual (LOSOM), during part of their public comment period, it is imperative that we, as citizens and stakeholders speak up for our health, environment and economy. The latest versions of LOSOM alternatives have serious shortcomings in key areas related to the quantity and quality of water being discharged into the waterways of the State of Florida. We encourage you to take action by raising your voices and letting the USACE and their partner, the South Florida Water Management District (SFWMD), know that these are important issues to you and they must be addressed in any updates to LOSOM.  Please read below for some more details in regards to these critical issues.

 

Please submit your comments to the USACE via email at LakeOComments@usace.army.mil 

 

Talking Point 1:

Despite thousands of public comments during the LOSOM process, and a consensus of scientific opinion, the USACE and SFWMD are not listening to us! We need to reiterate our call to SEND MORE LAKE WATER SOUTH!

A significant deficiency of the LOSOM process is that every one of the 11 so-called “balanced plans” proposes to REDUCE the amount of Lake water sent south to the Everglades, compared to the amount that has been sent south during the current operating conditions.  This deficiency must be corrected – the amount of lake flow sent south to the Everglades must INCREASE over current conditions.

  • The current operating schedule for Lake Okeechobee, “LORS2008”, has been in place since May 2008.  According to the SFWMD annual reports and staff briefings, an average of 200,000 acre-feet/yr of lake water has been sent south to the Everglades during the current operations.
  • The LOSOM process proposes to reduce the amount of lake flows south to the Everglades.
    • All of the 11 “Pareto” Plans A-K considered in LOSOM send less water south to the Everglades than the current operation.  This is unconscionable, unacceptable and counter to the scientific consensus developed over the last 15 years
    • While we realize the modeling of alternatives produces “relative” results and are not exact, it is critical to establish the correct baseline conditions and future expectations for future policy decisions and public information.
  • Scientific consensus and environmental considerations dictate that the Corps move forward with a plan that INCREASES the amount of Lake water sent south to the Everglades.

 

Talking Point 2:

Any lake water discharged to the St. Lucie Estuary is considered detrimental to the environment. Scientific consensus and public advocacy are calling for LOSOM to objectively demonstrate and reduce the amount of polluted Lake water to be sent to the St. Lucie Estuary. However, rather than decreasing lake flows to the Estuary, almost half of the alternatives being considered by the LOSOM process INCREASE the discharges of polluted Lake water.  The discharge of this polluted Lake water to the St. Lucie Estuary must be stopped!

  • Four of the eleven “pareto” plans developed under LOSOM actually INCREASE the amount of polluted Lake water sent to the St. Lucie Estuary, totaling a range of 264,000 to 287,000 AF/yr. This is unacceptable!
  • During the current Lake operations (LORS2008) an average of 213,000 AF/yr of Lake water has been sent to the St. Lucie Estuary (SFWMD data).
  • The alternative labelled “Plan C” (4C-1_3307) REDUCES the discharge of polluted Lake water to the estuary to near 10,000 AF/yr. While above the ideal amount of 0 discharges, this alternative is closest to the goal.

 

Talking Point 3:

Stop poisoning our children, our economy and our environment! LOSOM needs to support zero discharges of toxic water to our estuaries. This would include water that is deemed toxic according to the U.S. Environmental Protection Agency (EPA) thresholds.

  • The LOSOM process has no recommendation for an operating policy of prohibiting the discharge of polluted Lake Okeechobee water to the St Lucie Estuary when levels of the poison in toxic blue-green algae (microcystin) are above the US Environmental Protection Agency threshold of 8 ppb, making water too hazardous to touch, ingest or inhale for people, pets and wildlife.  [Note the guideline for pre-school drinking water threshold is 0.3 ppb.]
  • With this significant deficiency, the USACE has ignored a primary directive from Congress to evaluate the impact of proposed Lake discharges on public health.
  • We urge the USACE to follow the directive from Congress to evaluate the impact of proposed Lake Okeechobee discharges on public health.

 

Talking Point 4:

The LOSOM process has neglected to consider the phosphorus and nitrogen loads in Lake discharges to the St Lucie Estuary, and neglected to evaluate the adverse impacts to public health, the economy and the environment from this pollution. In accordance with the federal Clean Water Act, the State of Florida established a Total Maximum Daily Load (TMDL) for Total Phosphorus and Total Nitrogen for the St. Lucie Estuary, both in terms of concentration and loads.  The LOSOM process has neglected to model and evaluate the impacts of the discharge of polluted Lake Okeechobee water on achieving the TMDLs. 

  • During the current Lake operations under LORS2008, Lake discharges have carried an average of more than 100,000 pounds per year of Total Phosphorus to the estuary.
  • During the current Lake operations under LORS2008, Lake discharges have carried an average of almost 900,000 pounds per year of Total Nitrogen to the estuary.
  • The LOSOM process needs to quantify the massive amount of nutrient pollution to be transported to the estuary by Lake discharges, compare those estimates to the TMDLs, and evaluate the adverse impacts to public health, the economy and the environment from this pollution.

 

Talking Point 5:

The LOSOM process has neglected to estimate the sediment loads in Lake discharges to the St Lucie Estuary, and neglected to evaluate the adverse impacts to public health, the economy and the environment from this pollution. The sediment load carried to the St Lucie Estuary by Lake Okeechobee discharges has been responsible for some of the most significant adverse environmental impacts in the region – from smothering seagrasses, oyster beds and other benthic organisms to the deposition of millions of tons of black oozy muck on the floor of the region’s waterways.  The CERP process recognized the severe consequences of sediment load carried by Lake discharges and has identified multiple projects to dredge area muck.

  • During the current Lake operations under LORS2008, Lake discharges have carried an average of 25 million pounds per year of sediment to the estuary.
  • The LOSOM process needs to quantify the massive amount of sediment to be transported to the estuary by Lake discharges and evaluate the adverse impacts to public health, the economy and the environment from this pollution.

 

Talking Point 6:

As part of the LOSOM process, the State of Florida must review and approve the selected alternative with respect to water quality standards and impacts to the environment.

  • To that end, the state must set a standard for microcystin, a toxic poison found in some blue-green algae. USEPA set a standard of 8 ppb for human contact with microcystin. For the health of the state's people the state needs to establish the same.  The State of Florida needs to demand that no lake discharges are allowed when toxic algae is present in the lake.
  • The State of Florida needs to insist that Lake discharges do not contribute to excessive nutrient levels. The State has set TMDLs for phosphorus and nitrogen - both concentrations and loads - entering the St Lucie Estuary, but current modeling ignores these critical water quality targets; the State needs to step up and demand the Corps evaluate how proposed discharges will impact nutrient levels and secondary effects in the estuary. The LOSOM evaluation has modelled nutrient levels in Lake water going south but has neglected to model nutrient levels in Lake discharges to the estuaries. Every drop of water going south the Everglades has been modeled, but none of the water going to the estuaries has been modeled for water quality impacts!
  • The state of Florida needs to insist that Lake discharges do not contribute harmful levels of sediment loads entering the St Lucie Estuary. Excessive sediment blankets oyster beds and sea grasses, blocking light penetration critical for photosynthesis. Excess sediment destroys these critical habitats! Current LOSOM modeling ignores these critical water quality targets and the State needs to step up and demand the Corps evaluate how proposed discharges will impact sediment levels and secondary effects in the estuary.
  • The Corps and State of Florida need to evaluate the effects of proposed Lake discharges on the health of endangered and threatened species within the St Lucie Estuary and the Indian River Lagoon, including manatees.
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