|Larry Fink Former Senior Scientist with the South Florida Water Management District.|
The following blog is reprinted from the Everglades listserve hosted by Sierra Club. Larry Fink is a former senior scientist with the South Florida Water Management District. He is taking a highly unusual approach in openly criticizing the District, federal agencies, and environmental organizations who have come together around multi-billion dollar investments to restore the Everglades that are mainly "work-arounds" of Big Sugar. Sugarcane is the primary economic activity in the region south of Lake Okeechobee; an area that was once Everglades wetlands. By commandeering water supply in South Florida, Big Sugar makes sure that the water it receives is never too much or too little. As a result, the Everglades and billions of dollars in real estate on the estuaries and coasts are suffering from toxic algae blooms and pollution. The piece meal approach to fixing the Everglades has already consumed decades and promises decades to come of highly engineered and costly projects. What Fink and some other environmentalists are advocating, now, is an approach that re-establishes a central flow-way from Lake Okeechobee to relieve the pressure on the estuaries and re-establish the severed connection between the Lake and the Everglades -- cleaning up the water in vast treatment marshes along the way. Here is Mr. Fink's post:
I have concluded in previous blogs and reiterated here that sugar cane farming is inherently incompatible with sustainable restoration and protection of South Florida’s fresh, estuarine, and salt water ecosystems in general and the Everglades in particular, irrespective of what the author of the Best Management Practices (BMPs) article concludes.
Farming practices that involve consumptive use of peat soil may not be considered a standard farming practice exempt from Clean Water Act permit requirement for point and nonpoint sources of wastewater, irrespective of tacit acceptance of the exemption by the U.S. Environmental Protection Agency (USEPA), and that legal theory should be tested in Federal court.
My purpose in posting the article was to provide readers of this blog space with access to a useful summary of the history, science, and law behind the Best Management Practices (BMPs) Program. The BMP Program was designed by the U.S. Environmental Protection Agency (USEPA) to reduce on a watershed basis the soil, nutrient, and pesticide mass loading rates to water resources receiving leachate and stormwater runoff from point and nonpoint sources exempted from permits containing enforceable water quality-based effluent limits for wastewater discharges based on Total Maximum Daily Loads for water quality-impaired water resources. The Clean Water Act exempts farm point and nonpoint sources from discharge permits if they are following standard farming practices. Whether the consumptive use of peat soil meets one or more of the criteria promulgated by USEPA in its regulations governing exceptions to the general farm exemption should have been the subject of a Federal court challenge.
The State of Florida's makes no such blanket exemption for agricultural practices, which is why Dexter Lehtinen sued then Florida Department of Environmental Regulation and now the Florida Department of Environmental Protection (FDEP) and the South Florida Water Management District (SFWMD) in Federal Court under Florida water law, not under the Clean Water Act. However, when BMPs are not sufficient to attain and maintain all applicable Water Quality Standards (WQS) in the downstream receiving water, FDEP usually does nothing to close the gap.
Regarding USEPA’s BMP Program, it presupposes the existence of a farm, a crop, and the extant physical, chemical, and biological conditions and then provides guidance as to how to reduce field losses of soil, nutrients, and pesticides by altering irrigation, nutrient, and pesticide application methods, rates, or timing, adding trap crops, adding or enhancing ditches to capture, treat, and recycle field leachate and runoff, etc. As to whether there is a slant in the article beyond assuming that sugar cane farming is occurring in the EAA, the author should have disclosed in the acknowledgements if he was paid by any EAA farm owner, consortium of farm owners, the Everglades Protection District, the Florida Departments of Agriculture or Environmental Protection, the Institute for Food and Agricultural Science (IFAS), or the South Florida Water Management District (SFWMD) for his work via grant or contract. He may also have relied disproportionately on readily accessible web pages, fact sheets, and reports published by or for any of the preceding to expedite the article’s preparation without a concomitant level of effort devoted to the search of websites, fact sheets, and reports from organized environmentalists.
Irrespective of what the author concludes, I have concluded that sugar cane farming is inherently incompatible with sustainable Everglades restoration and protection based on logic and evidence presented previously on this blog. If I had my druthers, the
unsustainable dry farming practice for sugar cane production would be replaced by sustainable wet farming practices that prevent peat oxidation, e.g., rice, aquaculture, perhaps together in what is referred to as polyculture, and algae ponds that would remove nutrients, heavy metals, and insoluble pesticides from these upstream operations prior to converting the algae into biofuels and any
solid waste residues that could not be safely recycled for proper waste disposal.
This alternative farming configuration is also compatible with the quantity, quality, routing, and timing of Lake Okeechobee releases through a spillway to a terraced flowway from the Herbert Hoover Dike through STA-3/4 and WCA-3A prior to hydrating the Everglades National Park and Florida Bay. The flowway also has collateral benefits for the East and West Coast estuaries already discussed at length in previous postings.
Larry E. Fink, M.S.
Waterwise Consulting, LLC