CERP cannot work as currently planned.

It can't save the Everglades, protect Miami's drinking water, and save the coastal estuaries as currently planned.

We've found one part for storing water for south of the Lake won't work. The ASR component, at best, can function for 70 of the 200 proposed ASR wells.For those 70 wells, there is no long term data to show that ASR wells will continue to function as designed for fifty years or more. Short term pilot projects cannot supply that long term data. Even if some of the ASR wells function they will be more expensive than a reservoir south of the Lake.

The EAA reservoirs for storage south of the Lake, were originally sited in the wrong place. The land purchased for those reservoirs has been turned into stormwater treatment areas so the state can meet court ordered water quality standards. There are currently NO plans in place for that siting required storage.

Without acquiring land south of the Lake, there is no place to store water for sugar cane users except IN the Lake. As long as it is stored in the Lake, it can't be sent south and it will be dumped on the estuaries when it's not needed. "Studying all alternatives" won't solve the problem. There are no alternatives to storing water south of the Lake that will make CERP work.

All of CERP is at risk for failure to deliver previously modeled benefits without ASR and EAA storage.

The TOP PRIORITY for all state and federal agencies needs to be a replacement strategy for ASR  and designation and acquisition of an EAA storage site which can;

- send more water south in sync with the seasonal needs of Everglades National Park.

- reduce damaging discharges to the northern estuaries.

We now have an option to buy 46,000 acres of land south of Lake Okeechobee from US Sugar.  That option runs out in October. It is possible to buy the land to provide the 360,000 acre feet of storage in the EAA that CERP modeling says is necessary.

If we do not exercise that option now, the alternatives are:

- a negotiation where the seller holds all the cards and doesn't have to sell,or

- condemnation proceedings which will take years and will probably doublele the price.

That purchase has to be the state and federal partners TOP PRIORITY.  It can remain in sugar until final design is complete. Parts of it can be sold back or traded for other lands if they is not needed.

We know ASR won't work.We know that no progress has been made in siting the needed storage reservoirs south of the Lake. We know CERP won't work without that storage. WE risk wasting billions on a Plan that won't work by putting other priorities ahead of buying land south of the Lake in 2015.

We've been told that other storage projects should be completed before we even consider land acquisition for EAA storage.The C44 reservoir will only reduce damaging discharges to the St. Lucie by 8%. It provides a water supply benefit to Lake Okeechobee users but it can't send water south. The same is true of C43.They are good parts of CERP, but spending state money on federal construction projects should not take precedence over buying the land we need to make CERP work.

If we commit $5 billion of taxpayers money to save the everglades, and the spending:

- won't provide necessary water to Everglades National Park

- won't protect the Biscayne Aquifer and keep dry season fires from increasing in the Everglades west of Miami, and

- won't prevent the ecological collapse of the coastal estuaries

Then our season of leadership will be remembered for squandering taxpayer dollars AND killing South Florida's environment and it's economy.

Maggy Hurchalla,,  February 2015