Final Independent External Peer Review Report Central Everglades Planning Project, Florida Post-Authorization Change Report Everglades Agricultural Area Storage Reservoir Integrated Feasibility Report and Environmental Impact Statement Prepared by Battelle Memorial Institute Prepared for South Florida Water Management District 3301 Gun Club Road West Palm Beach, FL 33406 Purchase Order No. 4500104139 March 12, 2018 SFWMD CEPP PACR IEPR Final IEPR Report This page is intentionally left blank. BATTELLE March 12, 2018 SFWMD CEPP PACR IEPR Final IEPR Report Purchase Order No. 4500104139 Final Independent External Peer Review Report Central Everglades Planning Project, Florida Post-Authorization Change Report Everglades Agricultural Area Storage Reservoir Integrated Feasibility Report and Environmental Impact Statement Prepared by Battelle 505 King Avenue Columbus, Ohio 43201 for South Florida Water Management District 3301 Gun Club Road West Palm Beach, FL 33406 March 12, 2018 BATTELLE March 12, 2018 SFWMD CEPP PACR IEPR Final IEPR Report This page is intentionally left blank. BATTELLE March 12, 2018 SFWMD CEPP PACR IEPR Final IEPR Report Final Independent External Peer Review Report Central Everglades Planning Project, Florida Post-Authorization Change Report Everglades Agricultural Area Storage Reservoir Integrated Feasibility Report and Environmental Impact Statement Executive Summary PROJECT BACKGROUND AND PURPOSE The South Florida Water Management District (SFWMD), as local sponsor to the Central Everglades Planning Project (CEPP), has prepared a CEPP Post Authorization Change Report (PACR) (Integrated Feasibility Study and Environmental Impact Statement). Section 373.4598 Florida Statutes, passed and signed into law in 2017, mandates accelerated efforts by the SFWMD to pursue the PACR in support of a plan to increase water storage and water quality treatment wetlands in the Everglades Agricultural Area (EAA) south of Lake Okeechobee, Florida. The law directs the SFWMD to evaluate two alternative storage targets: 240,000 acre-feet on the A-2 parcel and A-2 expansion area, and up to 360,000 acre-feet of storage on A-1 and A-2 parcels combined, and associated conveyance improvements. The CEPP PACR is being conducted under the authority provided by Section 203 of the Water Resources Development Act (WRDA) of 1986, as amended by Section 1014(a) of the WRDA 2014, which authorizes non-Federal interests to undertake feasibility studies of proposed water resources development projects for submission to the Secretary of the Army. Upon approval of the CEPP PACR by the Governing Board of the SFWMD and the Assistant Secretary of the Army for Civil Works, the recommended plan will be submitted to Congress for authorization. The CEPP PACR does not represent a complete reevaluation of the CEPP. The focus and purpose of the CEPP PACR is to evaluate and select storage and treatment features in the EAA south of Lake Okeechobee that will increase the amount of storage and treatment wetlands in the CEPP Project Partnership Agreement (PPA) New Water and send additional water south to the historic Everglades ecosystem. The CEPP PACR will also reaffirm that the CEPP PPA South and North can accommodate additional flows south that will result from additional storage and treatment wetlands on the A-1, A-2, and A-2 expansion area flow equalization basins by evaluating the need for additional improvements to the conveyance system from Lake Okeechobee to the new storage features. No changes to the conveyance system south of the EAA, beyond those included in the CEPP, are anticipated as a result of the PACR. The benefit of management measures recommended in the CEPP PACR would be the reduction of undesirable regulatory discharges of freshwater from Lake Okeechobee to estuaries on the east and west coast of Florida and increased flows to the greater Everglades. All other project features authorized in the CEPP would not be affected by the scope of the CEPP PACR. BATTELLE March 12, 2018 i SFWMD CEPP PACR IEPR Final IEPR Report The increase in storage and treatment features and the associated improvements in conveyance to move more water to the new EAA storage features evaluated and recommended in the CEPP PACR would further improve the quantity, quality, timing, and distribution of water flows to the Northern Estuaries, central Everglades (Water Conservation Area 3 and Everglades National Park), and Florida Bay while maintaining water supply for municipal and agricultural users. Since the Comprehensive Everglades Restoration Plan (CERP) was approved:  Three projects were authorized in the 2007 WRDA and proceeded to construction (Indian River Lagoon-South, Picayune Strand, and Site 1 Impoundment) and a fourth project, Melaleuca and Other Exotic Plants Biological Controls, was implemented under the programmatic authority in WRDA 2000.  Three projects were authorized in the 2014 WRDA. The C-43 Reservoir and Biscayne Bay Coastal Wetlands Phase I Project proceeded to construction, and detailed design began on the Broward County Water Preserve Area Project.  The CEPP, which includes the first increment of the EAA Storage Reservoirs, was authorized in WRDA 2016. Despite this progress, ecological conditions and functions within the central portion of the Everglades ridge and slough community will continue to decline due to lack of sufficient quantities of freshwater flow into the central Everglades and timing and distribution problems. The SFWMD initiated the CEPP PACR in August 2017 to respond to this concern and evaluate alternatives for the final increment of CERP EAA Storage needed to achieve the CERP 300,000 acre-feet of average annual flow to the central portion of the Everglades to restore ecosystem conditions. Independent External Peer Review Process Independent, objective peer review is regarded as a critical element in ensuring the reliability of scientific analysis. SFWMD is conducting an Independent External Peer Review (IEPR) of the Central Everglades Planning Project, Florida Post-Authorization Change Report Everglades Agricultural Area Storage Reservoir Integrated Feasibility Report and Environmental Impact Statement (hereinafter: SFWMD CEPP PACR IEPR) which is being prepared for the U.S. Army Corps of Engineers (USACE) under the authority granted by Section 203 of the WRDA of 1986 (P.L. 99-662). As a 501(c)(3) non-profit science and technology organization, Battelle is independent, is free from conflicts of interest (COIs), and meets the requirements for an Outside Eligible Organization (OEO) per guidance described in the USACE Engineer Circular (EC) titled Water Resources Policies and Authorities: Civil Works Review (USACE, 2012). Battelle has experience in establishing and administering peer review panels for USACE and was engaged to coordinate this SFWMD CEPP PACR IEPR. The IEPR was conducted following USACE and Office of Management and Budget (OMB) guidance described in USACE (2012) and OMB (2004). This final report presents the Final Panel Comments of the IEPR Panel (the Panel). Details regarding the IEPR (including the process for selecting panel members, the panel members’ biographical information and expertise, and the charge submitted to the Panel to guide its review) are presented in appendices. Based on the technical content of the decision documents and the overall scope of the project, Battelle identified potential candidates for the Panel in the following key technical areas: Civil Works planning/ economics, environmental/ecological evaluation, hydraulic engineering, and geotechnical engineering. BATTELLE March 12, 2018 ii SFWMD CEPP PACR IEPR Final IEPR Report Battelle screened the candidates to identify those most closely meeting the selection criteria and evaluated them for COIs and availability. SFWMD was given the list of final candidates to confirm that they had no COIs, but Battelle made the final selection of the four-person Panel. The Panel received electronic versions of the decision documents (1,634 pages in total), along with a charge that solicited comments on specific sections of the documents to be reviewed. Following guidance provided in USACE (2012) and OMB (2004), Battelle prepared the charge questions, which were included in the draft and final Work Plans and approved by SFWMD for this IEPR. The SFWMD Project Team briefed the Panel and Battelle during a kick-off meeting held via teleconference at the start of the review to provide the Panel an opportunity to ask questions of SFWMD and clarify uncertainties. Other than Battelle-facilitated teleconferences, there was no direct communication between the Panel and SFWMD during the peer review process. The Panel produced individual comments in response to the charge questions. IEPR panel members reviewed the decision documents individually. The panel members then met via teleconference with Battelle to review key technical comments and reach agreement on the Final Panel Comments to be provided to SFWMD. Each Final Panel Comment was documented using a four-part format consisting of (1) a comment statement; (2) the basis for the comment; (3) the significance of the comment (high, medium/high, medium, medium/low, or low); and (4) recommendations on how to resolve the comment. Battelle also received public comments from SFWMD on the SFWMD CEPP PACR (approximately 174 pages of letters and individual comments received via email) and provided them to the IEPR panel members. The panel members were charged with determining if any information or concerns presented in the public comments raised any additional discipline-specific technical concerns with regard to the SFWMD CEPP PACR review documents. After completing its review, the Panel identified one new issue and subsequently generated one Final Panel Comment that summarized the concern. Overall, six Final Panel Comments were identified and documented. Of these, one had medium significance, one had medium/low significance, and four had low significance. The Panel did not identify any high or medium/high concerns. Results of the Independent External Peer Review The panel members agreed on their “assessment of the adequacy and acceptability of the economic, engineering, and environmental methods, models, and analyses used” (USACE, 2012; p. D-4) in the SFWMD CEPP PACR review documents. Table ES-1 lists the Final Panel Comment statements by level of significance. The full text of the Final Panel Comments is presented in Section 4.2 of this report. The following summarizes the Panel’s findings. Based on the Panel’s review, the SFWMD CEPP PACR is a well-written document that provides excellent supporting documentation on economic, engineering, environmental, and plan formulation issues and decisions. The report provided a balanced assessment of the economic, engineering, and environmental issues of the overall project. The Panel noted some redundancy of information provided in the various documents; however, the panel members recognize that the files they reviewed were submitted for review prior to the document being pulled together as one complete document. Even given the format in which the report was supplied, the Panel was able to find the information necessary to understand the decisions BATTELLE March 12, 2018 iii SFWMD CEPP PACR IEPR Final IEPR Report made and found the documentation necessary to validate those decisions. The Panel identified only a few elements of the report that should be clarified or elements of the project where additional documentation of information is warranted. Furthermore, the Panel identified only a few places in the report where project findings and objectives need to be documented or revised. Plan Formulation: The Panel believes that SFWMD has assessed all reasonable alternatives given the narrow scope of the purpose and need. However, during review of the public comments, it was noted that numerous comments focused on an alternative that does not appear to be discussed in the PACR. To ensure that the alternatives assessment meets the Council on Environmental Quality’s regulation 40 CFR Part 1502.14(a), SFWMD should conduct and document an objective evaluation of the public’s suggested alternative and, if applicable, provide information on why it was not carried forward for further detailed study. Engineering: The documentation reviewed was well written and very thorough given the breadth of the analysis performed to support the document. Informed public should be able to understand the complex analysis used to derive the decisions made throughout the document. However, the Panel believes that a little more information is necessary on the risks and uncertainty associated with the Tentatively Selected Plan (TSP). Currently, the TSP is presented as a static known solution without variability. However, it was developed based on data that had an upper and lower bound to each metric. Therefore, the TSP really has upper and lower bounds which represent the uncertainty and risk associated with it. The Panel believes these bounds should be included as part of the TSP discussion. In addition, information on the models that were used and how well they represent the area would be beneficial. Including this information will strengthen the conclusions drawn regarding the proposed project. Economics: The Panel noted that the economics evaluation clearly received great focus, scrutiny, and effort and that very few issues remain to be addressed from a benefit-cost perspective. The panel members also noted that the description of the future without condition for this large and complex study demonstrates an exceptional degree of accuracy that stands apart from other, similar analyses. As outlined in the engineering summary above, the panel members believe more information is needed on the uncertainty and risks associated with the TSP with regard to the benefits and costs. They also agree that more information on the economic models used to simulate expected future conditions is warranted. Finally, the review documents would benefit from additional information on the impacts to commercial and recreational navigation and flood risk reduction to address inconsistencies regarding these impacts. Environmental: The Panel determined that the conclusions drawn from the assessments conducted were reasonable and complete based on the information provided. The panel members understand that, because this is a Section 203 project, consultation with cooperating and permitting agencies and with the Tribes will be conducted by USACE in the next phase of the project. Therefore, concerns and comments regarding those consultations and possible changes arising from them are not included in this Final IEPR Report. BATTELLE March 12, 2018 iv SFWMD CEPP PACR IEPR Final IEPR Report Table ES-1. Overview of Six Final Panel Comments Identified by the SFWMD CEPP PACR IEPR Panel No. Final Panel Comment Significance – Medium 1 Risk and uncertainty associated with the future without-project conditions (FWO) and TSP are not clearly communicated. Significance – Medium/Low 2 During its review of the public comments, the Panel noted that several letters discussed a new alternative the commenters believe is a viable solution. However, the PACR does not explain why the alternative was not addressed in the screening process. Significance – Low 3 The PACR does not provide sufficient information on the specific models used and their overall performance. 4 Impacts to navigation and flood risk reduction are not clearly described and the decision documents seem to be inconsistent. 5 Recreation feature costs discussed in Appendix F were escalated from fiscal year 2014 prices through indexing rather than following best practice methods and USACE guidance, which call for costs and benefits to be reevaluated if more than three fiscal years have elapsed. 6 FWO projections regarding population growth and economic development under the CEPP with-project conditions may be too conservative, an uncertainty that has not been addressed. BATTELLE March 12, 2018 v SFWMD CEPP PACR IEPR Final IEPR Report This page is intentionally left blank. BATTELLE March 12, 2018 vi SFWMD CEPP PACR IEPR Final IEPR Report Table of Contents Page Executive Summary ....................................................................................................................................... i  1.  INTRODUCTION................................................................................................................................... 1  2.  PURPOSE OF THE IEPR ..................................................................................................................... 2  3.  METHODS FOR CONDUCTING THE IEPR ........................................................................................ 3  4.  RESULTS OF THE IEPR ...................................................................................................................... 4  4.1  Summary of Final Panel Comments ............................................................................................. 4  4.2  Final Panel Comments ................................................................................................................. 5  5.  REFERENCES.................................................................................................................................... 13  Appendix A. IEPR Process for the SFWMD CEPP PACR IEPR Appendix B. Identification and Selection of IEPR Panel Members for the SFWMD CEPP PACR IEPR Appendix C. Final Charge for the SFWMD CEPP PACR IEPR List of Tables Page Table ES-1. Overview of Six Final Panel Comments Identified by the SFWMD CEPP PACR IEPR Panel. ............................................................................................................................ v  Table 1. Major Milestones and Deliverables of the SFWMD CEPP PACR IEPR ................................ 3  BATTELLE March 12, 2018 vii SFWMD CEPP PACR IEPR Final IEPR Report LIST OF ACRONYMS ATR Agency Technical Review CEPP Central Everglades Planning Project CERP Central Everglades Restoration Plan CEQ Council on Environmental Quality COI Conflict of Interest CSRM Coastal Storm Risk Management DMSTA Dynamic Model for Stormwater Treatment Areas EA Environmental Assessment EAA Everglades Agricultural Area EC Engineer Circular EFH Essential Fish Habitat EIS Environmental Impact Statement ENP Everglades National Park ER Engineer Regulation FDACS Florida Department of Agricultural and Consumer Services FDEP Florida Department of Environmental Protection FHM FIPR Hydrologic Model FRM Flood Risk Management FWCC Florida Wildlife Conservation Commission FWO Future Without-Project Conditions GRR General Reevaluation Report H&H Hydrologic and Hydraulic HEC-FDA Hydrologic Engineering Center Flood Damage Reduction Analysis HEC-RAS Hydrologic Engineering Center River Analysis System HTRW Hazardous, Radioactive, and Toxic Waste IEPR Independent External Peer Review IHM Integrated Hydrologic Model NED National Economic Development NEPA National Environmental Policy Act O&M Operation and Maintenance BATTELLE March 12, 2018 viii SFWMD CEPP PACR IEPR Final IEPR Report OEO Outside Eligible Organization OMB Office of Management and Budget PACR Post Authorization Change Report PIR Project Implementation Report PPA Project Partnership Agreement RECONS Regional Economic System RSM Regional Simulation Model SFWMD South Florida Water Management District SFWMM South Florida Water Management Model TSP Tentatively Selected Plan USACE United States Army Corps of Engineers USFWS United States Fish and Wildlife Service USGS United States Geological Survey WCA 3 Water Conservation Area 3 WRDA Water Resources Development Act BATTELLE March 12, 2018 ix SFWMD CEPP PACR IEPR Final IEPR Report This page is intentionally left blank. BATTELLE March 12, 2018 x SFWMD CEPP PACR IEPR Final IEPR Report 1. INTRODUCTION The South Florida Water Management District (SFWMD), as local sponsor to the Central Everglades Planning Project (CEPP), has prepared a CEPP Post Authorization Change Report (PACR) (Integrated Feasibility Study and Environmental Impact Statement). Section 373.4598 Florida Statutes, passed and signed into law in 2017, mandates accelerated efforts by the SFWMD to pursue the PACR in support of a plan to increase water storage and water quality treatment wetlands in the Everglades Agricultural Area (EAA) south of Lake Okeechobee, Florida. The law directs the SFWMD to evaluate two alternative storage targets: 240,000 acre-feet on the A-2 parcel and A-2 expansion area, and up to 360,000 acre-feet of storage on A-1 and A-2 parcels combined, and associated conveyance improvements. The CEPP PACR is being conducted under the authority provided by Section 203 of the Water Resources Development Act (WRDA) of 1986, as amended by Section 1014(a) of the WRDA 2014, which authorizes non-Federal interests to undertake feasibility studies of proposed water resources development projects for submission to the Secretary of the Army. Upon approval of the CEPP PACR by the Governing Board of the SFWMD and the Assistant Secretary of the Army for Civil Works, the recommended plan will be submitted to Congress for authorization. The CEPP PACR does not represent a complete reevaluation of the CEPP. The focus and purpose of the CEPP PACR is to evaluate and select storage and treatment features in the EAA south of Lake Okeechobee that will increase the amount of storage and treatment wetlands in the CEPP Project Partnership Agreement (PPA) New Water and send additional water south to the historic Everglades ecosystem. The CEPP PACR will also reaffirm that the CEPP PPA South and North can accommodate additional flows south that will result from additional storage and treatment wetlands on the A-1, A-2, and A-2 expansion area flow equalization basins by evaluating the need for additional improvements to the conveyance system from Lake Okeechobee to the new storage features. No changes to the conveyance system south of the EAA, beyond those included in the CEPP, are anticipated as a result of the PACR. The benefit of management measures recommended in the CEPP PACR would be the reduction of undesirable regulatory discharges of freshwater from Lake Okeechobee to estuaries on the east and west coast of Florida and increased flows to the greater Everglades. All other project features authorized in the CEPP would not be affected by the scope of the CEPP PACR. The increase in storage and treatment features and the associated improvements in conveyance to move more water to the new EAA storage features evaluated and recommended in the CEPP PACR would further improve the quantity, quality, timing, and distribution of water flows to the Northern Estuaries, central Everglades (Water Conservation Area 3 and Everglades National Park), and Florida Bay while maintaining water supply for municipal and agricultural users. Since the Comprehensive Everglades Restoration Plan (CERP) was approved:  Three projects were authorized in the 2007 WRDA and proceeded to construction (Indian River Lagoon-South, Picayune Strand, and Site 1 Impoundment) and a fourth project, Melaleuca and Other Exotic Plants Biological Controls, was implemented under the programmatic authority in WRDA 2000. BATTELLE March 12, 2018 1 SFWMD CEPP PACR IEPR Final IEPR Report  Three projects were authorized in the 2014 WRDA. The C-43 Reservoir and Biscayne Bay Coastal Wetlands Phase I Project proceeded to construction, and detailed design began on the Broward County Water Preserve Area Project.  The CEPP, which includes the first increment of the EAA Storage Reservoirs, was authorized in WRDA 2016. Despite this progress, ecological conditions and functions within the central portion of the Everglades ridge and slough community will continue to decline due to lack of sufficient quantities of freshwater flow into the central Everglades and timing and distribution problems. The SFWMD initiated the CEPP PACR in August 2017 to respond to this concern and evaluate alternatives for the final increment of CERP EAA Storage needed to achieve the CERP 300,000 acre-feet of average annual flow to the central portion of the Everglades to restore ecosystem conditions. Independent, objective peer review is regarded as a critical element in ensuring the reliability of scientific analysis. The objective of the work described here was to conduct an Independent External Peer Review (IEPR) of the SFWMD CEPP PACR (hereinafter: SFWMD CEPP PACR IEPR) in accordance with procedures described in the Department of the Army, U.S. Army Corps of Engineers (USACE), Engineer Circular (EC) Civil Works Review (EC 1165-2-214) (USACE, 2012) and the Office of Management and Budget (OMB), Final Information Quality Bulletin for Peer Review (OMB, 2004). Supplemental guidance on evaluation for conflicts of interest (COIs) was obtained from the Policy on Committee Composition and Balance and Conflicts of Interest for Committees Used in the Development of Reports (The National Academies, 2003). This final report presents the Final Panel Comments of the IEPR Panel (the Panel) on the existing engineering, economic, environmental, and plan formulation analyses contained in the SFWMD CEPP PACR review documents (Section 4). Appendix A describes in detail how the IEPR was planned and conducted, including the complete schedule followed in executing the IEPR. Appendix B provides biographical information on the IEPR panel members and describes the method Battelle followed to select them. Appendix C presents the final charge to the IEPR panel members for their use during the review; the final charge was submitted to SFWMD in the final Work Plan according to the schedule listed in Table 1. 2. PURPOSE OF THE IEPR To ensure that documents USACE relies upon to make decisions are supported by the best scientific and technical information, USACE has implemented a peer review process that uses IEPR to complement the Agency Technical Review (ATR), as described in USACE (2012). This process is also required to be implemented to project documents prepared under authorization of Section 203 of the WRDA. In general, the purpose of peer review is to strengthen the quality and credibility of the SFWMDdeveloped decision documents for water resource projects in support of the USACE Civil Works program. IEPR provides an independent assessment of the engineering, economic, environmental, and plan formulation analyses of a project study. In particular, IEPR addresses the technical soundness of the project study’s assumptions, methods, analyses, and calculations and identifies the need for additional data or analyses to make a good decision regarding implementation of alternatives and recommendations. BATTELLE March 12, 2018 2 SFWMD CEPP PACR IEPR Final IEPR Report In this case, the IEPR of the SFWMD CEPP PACR was conducted and managed using contract support from Battelle, which is an Outside Eligible Organization (OEO) (as defined by EC 1165-2-214). Battelle, a 501(c)(3) organization under the U.S. Internal Revenue Code, has experience conducting IEPRs for USACE, for state and local agencies, and for industrial clients. Prior to contracting for the SFWMD CEPP PACR IEPR, Battelle completed an internal organizational COI screening to ensure that the panel members were free from COIs before conducting the IEPR. 3. METHODS FOR CONDUCTING THE IEPR The methods used to conduct the IEPR are briefly described in this section; a detailed description can be found in Appendix A. Table 1 presents the major milestones and deliverables of the SFWMD CEPP PACR IEPR. Due dates for milestones and deliverables are based on the award/effective date listed in Table 1. Note that the actions listed under Task 6 occur after the submission of this report. Battelle anticipates submitting the pdf printout of the Comment Response Record (the final deliverable) on April 10, 2018. The actual date for contract end will depend on the date that all activities for this IEPR are conducted and subsequently completed. Table 1. Major Milestones and Deliverables of the SFWMD CEPP PACR IEPR Task Action Due Date 1 Award/Effective Date 12/13/2017 2 3 4 4b 5 6 c Review documents and Public Comments received 2/5/2018 Battelle submits list of selected panel membersa 1/9/2018 SFWMD confirms the panel members have no COI 1/12/2018 Battelle convenes kick-off meeting with SFWMD 1/12/2018 Battelle convenes kick-off meeting with SFWMD and panel members 1/19/2018 Panel members complete their review of the documents 2/21/2018 Panel members provide draft Final Panel Comments to Battelle 3/1/2018 Panel finalizes Final Panel Comments 3/6/2018 Battelle sends public comments to Panel 2/6/2018 Panel identify and develop one Final Panel Comment with regard to the public comments 2/23/2018 Battelle submits Final IEPR Report to SFWMDa, b 3/12/2018 Battelle convenes Comment Response Teleconference with panel members and SFWMD 3/29/2018 Battelle submits pdf printout of Comment Response Recorda 4/10/2018 Contract End/Delivery Date a 7/1/2018 Deliverable. b The public comment review was conducted in time to include the information in the Final Report, therefore, the final report represents the deliverable for both Task 5a and Task 5b originally proposed. c Task 6 activities occur after the submission of this report. BATTELLE March 12, 2018 3 SFWMD CEPP PACR IEPR Final IEPR Report Battelle identified, screened, and selected four panel members to participate in the IEPR based on their expertise in the following disciplines: Civil Works planning/economics, environmental/ecological evaluation, hydraulic engineering, and geotechnical engineering. The Panel reviewed the SFWMD CEPP PACR review documents and produced six Final Panel Comments in response to 15 charge questions provided by SFWMD for the review. Battelle instructed the Panel to develop the Final Panel Comments using a standardized four-part structure: 1. Comment Statement (succinct summary statement of concern) 2. Basis for Comment (details regarding the concern) 3. Significance (high, medium/high, medium, medium/low, or low; in accordance with specific criteria for determining level of significance) 4. Recommendation(s) for Resolution (at least one implementable action that could be taken to address the Final Panel Comment). Battelle reviewed all Final Panel Comments for accuracy, adherence to USACE guidance (EC 1165-2214, Appendix D), and completeness prior to determining that they were final and suitable for inclusion in the Final IEPR Report. There was no direct communication between the Panel and SFWMD during the preparation of the Final Panel Comments. The Panel’s findings are summarized in Section 4.1; the Final Panel Comments are presented in full in Section 4.2. 4. RESULTS OF THE IEPR This section presents the results of the IEPR. A summary of the Panel’s findings and the full text of the Final Panel Comments are provided. 4.1 Summary of Final Panel Comments The panel members agreed on their “assessment of the adequacy and acceptability of the economic, engineering, and environmental methods, models, and analyses used” (USACE, 2012; p. D-4) in the SFWMD CEPP PACR IEPR review documents. The following summarizes the Panel’s findings. Based on the Panel’s review, the SFWMD CEPP PACR is a well-written document that provides excellent supporting documentation on economic, engineering, environmental, and plan formulation issues and decisions. The report provided a balanced assessment of the economic, engineering, and environmental issues of the overall project. The Panel noted some redundancy of information provided in the various documents; however, the panel members recognize that the files they reviewed were submitted for review prior to the document being pulled together as one complete document. Even given the format in which the report was supplied, the Panel was able to find the information necessary to understand the decisions made and found the documentation necessary to validate those decisions. The Panel identified only a few elements of the report that should be clarified or elements of the project where additional documentation of information is warranted. Furthermore, the Panel identified only a few places in the report where project findings and objectives need to be documented or revised. Plan Formulation: The Panel believes that SFWMD has assessed all reasonable alternatives given the narrow scope of the purpose and need. However, during review of the public comments, it was noted that numerous comments focused on an alternative that does not appear to be discussed in the PACR. To ensure that the alternatives assessment meets the Council on Environmental Quality’s regulation 40 CFR Part 1502.14(a), SFWMD should conduct and document an objective evaluation of the public’s suggested BATTELLE March 12, 2018 4 SFWMD CEPP PACR IEPR Final IEPR Report alternative and, if applicable, provide information on why it was not carried forward for further detailed study. Engineering: The documentation reviewed was well written and very thorough given the breadth of the analysis performed to support the document. Informed public should be able to understand the complex analysis used to derive the decisions made throughout the document. However, the Panel believes that a little more information is necessary on the risks and uncertainty associated with the Tentatively Selected Plan (TSP). Currently, the TSP is presented as a static known solution without variability. However, it was developed based on data that had an upper and lower bound to each metric. Therefore, the TSP really has upper and lower bounds which represent the uncertainty and risk associated with it. The Panel believes these bounds should be included as part of the TSP discussion. In addition, information on the models that were used and how well they represent the area would be beneficial. Including this information will strengthen the conclusions drawn regarding the proposed project. Economics: The Panel noted that the economics evaluation clearly received great focus, scrutiny, and effort and that very few issues remain to be addressed from a benefit-cost perspective. The panel members also noted that the description of the future without condition for this large and complex study demonstrates an exceptional degree of accuracy that stands apart from other, similar analyses. As outlined in the engineering summary above, the panel members believe more information is needed on the uncertainty and risks associated with the TSP with regard to the benefits and costs. They also agree that more information on the economic models used to simulate expected future conditions is warranted. Finally, the review documents would benefit from additional information on the impacts to commercial and recreational navigation and flood risk reduction to address inconsistencies regarding these impacts. Environmental: The Panel determined that the conclusions drawn from the assessments conducted were reasonable and complete based on the information provided. The panel members understand that, because this is a Section 203 project, consultation with cooperating and permitting agencies and with the Tribes will be conducted by USACE in the next phase of the project. Therefore, concerns and comments regarding those consultations and possible changes arising from them are not included in this Final IEPR Report. 4.2 Final Panel Comments This section presents the full text of the Final Panel Comments prepared by the IEPR panel members. BATTELLE March 12, 2018 5 SFWMD CEPP PACR IEPR Final IEPR Report Final Panel Comment 1 Risk and uncertainty associated with the future without-project conditions (FWO) and TSP are not clearly communicated. Basis for Comment All projections of future conditions and models of natural systems have uncertainty. There are two types of uncertainty in forecasting and modeling: parameter uncertainty and boundary uncertainty. Uncertainty in the model parameters can be minimized through model calibration. Uncertainty in the model and the forecast of external boundary conditions can include sea level rise or future economic, demographic, and climatic conditions. Neither model nor forecasting uncertainty are explicitly addressed in the CEPP PACR, and there is no documentation that the uncertainty in the model results includes upper and lower bounds for performance metrics that impact design criteria. Uncertainty in future sea level rise was included in the documentation at a high, medium, and low estimate. It is important to understand the uncertainty and the degree to which the model uncertainty propagates through the analysis as well as impacts to the design results. A high degree of model uncertainty combined with a high degree of risk could result in very different outcomes than would a low degree of model uncertainty combined with a low degree of risk. For example, depending on the actual sea level rise, the actual outcome of the FWO and TSP could be very different. If the upper and lower bounds identified for targeted evaluation metrics that impact design criteria are incorporated in the model, the uncertainty in the model results will be included in the document and the range of actual outcomes will be demonstrated. From a plan formulation perspective, the CEPP PACR is unclear on how risk and uncertainty affect the FWO condition and alternative plans. The decision document does indicate that at least some uncertain future conditions were evaluated. However, projections do not address uncertainty, nor do the documents address the risk that would result if the alternatives do not achieve the projected outputs. The reader is directed to the CEPP Project Implementation Report (PIR) for more information on risk and uncertainty, and the decision document unconvincingly states that there is no change in risk and uncertainty in the PACR. Furthermore, model uncertainty and probability-based outcomes are not sufficiently represented in the decision documentation. Specifically, the PACR does not evaluate output metrics using a probabilistic approach, nor are there any probability-based histograms describing how risk was calculated. To adequately evaluate uncertain conditions (such as the degree and timing of climate change and sea level rise), potential impacts should be modeled probabilistically. For example, designing structures for the 100-year event is designing to a 1% probability. Output metrics should be evaluated using a distribution of probability-based histogram. Significance – Medium Although some uncertainty analysis was performed, the partial analysis of risk and uncertainty affects the completeness of the report BATTELLE March 12, 2018 6 SFWMD CEPP PACR IEPR Final IEPR Report Final Panel Comment 1 Recommendations for Resolution 1. Include upper and lower bounds on model results that impact CEPP design. 2. Propagate model uncertainty through subsequent models and analysis. 3. Evaluate design metrics with probabilistic design criteria. BATTELLE March 12, 2018 7 SFWMD CEPP PACR IEPR Final IEPR Report Final Panel Comment 2 During its review of the public comments, the Panel noted that several letters discussed a new alternative the commenters believe is a viable solution. However, the PACR does not explain why the alternative was not addressed in the screening process. Basis for Comment Public comments provided by SFWMD are presented in Appendix C.2, Pertinent Correspondence. Numerous public comments state that the sizes of the reservoir and stormwater treatment areas for the alternatives evaluated in the PACR are inadequate and that a much larger reservoir, up to 13,000 acres, is needed to achieve the CERP goals for delivering water to the Everglades. Council on Environmental Quality (CEQ) regulations (Title 40, Chapter V, Part 1502.14(a)) state that agencies shall, “Rigorously explore and objectively evaluate all reasonable alternatives, and for alternatives which were eliminated from detailed study, briefly discuss the reasons for their having been eliminated.” The Panel notes that comments on this proposed alternative were received within the timeframe of the public meetings listed in Section 7.1. Further, Section 3.1 of the PACR states, “In addition to technical analyses, the planning process also requested and considered stakeholder input to develop alternative plans” (p. 3-1). The Panel does not find any acknowledgment or consideration of the larger reservoir and STA alternative in the PACR. Considering the CEQ regulation noted above, the Panel believes that an objective evaluation of the public’s concerns should be documented in the PACR, including the reason(s) why this alternative should or should not warrant evaluation. Significance – Medium/Low If the screening process is viewed as circumventing CEQ regulations, the process could be vulnerable to criticism and potential future dispute. Recommendation for Resolution 1. Evaluate this alternative in the PACR and explain why the alternative should either be carried forward or eliminated from further review. BATTELLE March 12, 2018 8 SFWMD CEPP PACR IEPR Final IEPR Report Final Panel Comment 3 The PACR does not provide sufficient information on the specific models used and their overall performance. Basis for Comment Section 3.2.1.3 briefly describes the suite of models used in or relied upon by the CEPP PACR. How these models are used to transparently simulate expected future conditions is not clear or well defined. Model performance is critical to the confidence and therefore certainty given to the model results. Models are used to predict the response to changes in the design and operation of physical features and to assess the cost effectiveness of management measures. Most models have parameters that require calibration (when feasible). These parameters are adjusted to improve the fit of the model results to observed events. The calibration process can eliminate model uncertainty as well as impart confidence in the predictive capability of the models. The better a model is calibrated to observed events, the more uncertainty in the model results will be reduced. In addition, the model performance is not well documented, and the reader cannot assess the predictive capability of the models used in the evaluation and design of the TSP. Significance – Low The lack of information on the models used affects the completeness of the document. Recommendations for Resolution 1. Document model performance metrics when possible. 2. Provide details on the assumptions, parameters, and inputs for the models described in Section 3. 3. State whether models used in the PACR are certified for use by the appropriate USACE PCX. BATTELLE March 12, 2018 9 SFWMD CEPP PACR IEPR Final IEPR Report Final Panel Comment 4 Impacts to navigation and flood risk reduction are not clearly described and the decision documents seem to be inconsistent. Basis for Comment Navigation and recreation are congressionally authorized and economically important purposes of Lake Okeechobee and the Okeechobee Waterway. Sections 4 and 5 are not consistent in describing impacts of the CEPP PACR on these uses of the systems under evaluation. Section 4.5.1 states that none of the alternatives considered will impact navigation, while Section 5.2.15.3 states that the TSP will result in improved recreational navigation opportunities. Sections 4.5.1 and 5.1.15.2 are similarly inconsistent on flood risk reduction. The former indicates that existing flood risk reduction will be maintained, while the latter states that there will be improvement under the TSP. These apparent inconsistencies make it difficult to determine whether the TSP will result in economic impacts to very important purposes of the WRDA 2000 and subsequent authorizations. Significance – Low This minor technical inconsistency will not affect the selection or justification of the TSP. Recommendations for Resolution 1. Review performance measures to ascertain the magnitude of impacts to navigation and flood risk reduction. 2. Review the discussion of impacts in Sections 4 and 5 to ensure consistency. BATTELLE March 12, 2018 10 SFWMD CEPP PACR IEPR Final IEPR Report Final Panel Comment 5 Recreation feature costs discussed in Appendix F were escalated from fiscal year 2014 prices through indexing rather than following best practice methods and USACE guidance, which call for costs and benefits to be reevaluated if more than three fiscal years have elapsed. Basis for Comment Reasonable and current estimates of expected benefits and project feature costs are important to demonstrate economic feasibility to both Federal and non-Federal decision makers. Best practice and the Planning Guidance Notebook, Appendix E standard (USACE, 2000) have established that both benefit and cost estimates are considered current if they were developed less than three fiscal years since preparation of the study using them. If more than three years have elapsed since benefits and costs were last estimated, an economic reevaluation is strongly suggested. While it is unlikely that economic benefits attributable to recreation have changed significantly, there is a high probability that economic costs have changed in light of recent economic growth and scarcity brought about by Hurricane Irma. Significance – Low This issue affects the technical completeness of the report but will not affect project justification. Recommendations for Resolution 1. Perform a reconnaissance-level reevaluation of the economic costs of providing the proposed recreation features. 2. Explain the factors leading to any significant change in recreation feature costs. 3. Recalculate the benefit-cost ratio and net benefits. Literature Cited USACE (2000). Planning Guidance Notebook. Department of the Army, U.S. Army Corps of Engineers, Washington, D.C. Engineer Regulation (ER) CECW-P 1105-2-100. 22 April 2000. BATTELLE March 12, 2018 11 SFWMD CEPP PACR IEPR Final IEPR Report Final Panel Comment 6 FWO projections regarding population growth and economic development under the CEPP with-project conditions may be too conservative, an uncertainty that has not been addressed. Basis for Comment The CEPP PACR describes its FWO as a future in which the CEPP is constructed and operational. In turn, the CEPP’s with-project conditions represent an optimized, least-cost solution to the Everglades ecosystem degradation issues as described in the CEPP PIR. That solution is expected to improve the health, economic vitality, and sustainability of the Everglades. As a result of that improvement, there is a significant chance that the Everglades will respond more robustly than envisioned in the PIR’s assessment of with-project conditions, which may lead to greaterthan-expected population and economic growth. The uncertainty associated with these potential responses is not clearly addressed in the PACR. Accordingly, the Panel believes a better-than-expected response to CEPP implementation could drive greater economic development than envisioned in the PACR, which could spur additional economic growth and drive higher demand for municipal and industrial water demand, flood risk protection, navigation, and recreation. These possible outcomes could affect the economic impacts of the PACR. Significance – Low This technical omission in the PACR affects the completeness of the report but is unlikely to affect project justification. Recommendations for Resolution 1. Review the socioeconomic projections of the CEPP with-project conditions. 2. Consider the possibility of a more robust response of the Everglades to CEPP implementation. 3. Discuss veritable Everglades response to CEPP in the evaluation of uncertainty (Section 2 of the PACR). BATTELLE March 12, 2018 12 SFWMD CEPP PACR IEPR Final IEPR Report 5. REFERENCES OMB (2004). Final Information Quality Bulletin for Peer Review. Executive Office of the President, Office of Management and Budget, Washington, D.C. Memorandum M-05-03. December 16. The National Academies (2003). Policy on Committee Composition and Balance and Conflicts of Interest for Committees Used in the Development of Reports. The National Academies (National Academy of Science, National Academy of Engineering, Institute of Medicine, National Research Council). May 12. USACE (2012). Water Resources Policies and Authorities: Civil Works Review. Engineer Circular (EC) 1165-2-214. Department of the Army, U.S. Army Corps of Engineers, Washington, D.C. December 15. USACE (2000). Planning Guidance Notebook. Department of the Army, U.S. Army Corps of Engineers, Washington, D.C. Engineer Regulation (ER) CECW-P 1105-2-100. 22 April 2000. BATTELLE March 12, 2018 13 SFWMD CEPP PACR IEPR Final IEPR Report This page is intentionally left blank. BATTELLE March 12, 2018 14 SFWMD CEPP PACR IEPR Final IEPR Report APPENDIX A IEPR Process for the SFWMD CEPP PACR IEPR BATTELLE March 12, 2018 SFWMD CEPP PACR IEPR Final IEPR Report This page is intentionally left blank. BATTELLE March 12, 2018 SFWMD CEPP PACR IEPR Final IEPR Report A.1 Planning and Conduct of the Independent External Peer Review (IEPR) Table A-1 presents the schedule followed in executing the Central Everglades Planning Project, Florida Post-Authorization Change Report Everglades Agricultural Area Storage Reservoir Integrated Feasibility Report and Environmental Impact Statement IEPR (hereinafter: SFWMD CEPP PACR IEPR). Due dates for milestones and deliverables are based on the award/effective date listed in Table A-1. The review documents were provided by South Florida Water Management District (SFWMD) on February 5 and 6, 2018. Note that the actions listed under Task 6 occur after the submission of this report and are described in more detail in Section A.7. Table A-1. SFWMD CEPP PACR Complete IEPR Schedule Task Action Due Date 1 Award/Effective Date 12/13/2017 Review documents and public comments received from SFWMD Battelle submits draft Work Plana 2 1/5/2018 Battelle submits final Work Plana 1/9/2018 Battelle requests input from SFWMD on the conflict of interest (COI) questionnaire 12/15/2017 SFWMD provides edits, or confirms no edits, on COI questionnaire 12/20/2017 1/9/2018 SFWMD confirms the panel members have no COI 1/12/2018 Battelle completes subcontracts for panel members 1/19/2018 Battelle convenes kick-off meeting with SFWMD 1/12/2018 Battelle sends review documents to panel members 4 12/22/2017 SFWMD provides comments on draft Work Plan Battelle submits list of selected panel membersa 3 2/5/2018 2/6/2018 Battelle convenes kick-off meeting with panel members 1/19/2018 Battelle convenes kick-off meeting with SFWMD and panel members 1/19/2018 Battelle convenes mid-review teleconference for panel members to ask clarifying questions of SFWMD 2/16/2018 Panel members complete their review of the documents 2/21/2018 Battelle provides talking points to panel members for Panel Review Teleconference 2/22/2018 Battelle convenes Panel Review Teleconference 2/23/2018 Battelle provides Final Panel Comment templates and instructions to panel members 2/23/2018 Panel members provide draft Final Panel Comments to Battelle Battelle provides feedback to panel members on draft Final Panel Comments; panel members revise Final Panel Comments BATTELLE March 12, 2018 3/1/2018 3/2/2018 3/5/2018 A-1 SFWMD CEPP PACR IEPR Final IEPR Report Table A-1. SFWMD CEPP PACR Complete IEPR Schedule (continued) Task Action 3 Panel finalizes Final Panel Comments 3/6/2018 Battelle receives public comments from SFWMD 2/5/2018 Battelle sends public comments to Panel 2/6/2018 4 b 5 Panel members complete their review of the public comments 2/21/2018 Battelle and Panel review Panel's responses to public comments 2/12/2018 Panel drafts Final Panel Comment regarding the public comments 3/1/2018 Panel finalizes Final Panel Comment regarding public comments 3/6/2018 Battelle provides Final IEPR Report to panel members for review 3/7/2018 Panel members provide comments on Final IEPR Report 3/8/2018 Battelle submits Final IEPR Report to SFWMD 6 c Due Date a, b Battelle provides Final Panel Comment response template to SFWMD 3/13/2018 Battelle convenes teleconference with SFWMD to review Comment Response process 3/13/2018 Battelle convenes teleconference with Panel to review Comment Response process 3/14/2018 SFWMD provides draft Evaluator Responses to Battelle 3/23/2018 Battelle provides draft Evaluator Responses to panel members 3/26/2018 Panel members provide draft BackCheck Responses to Battelle 3/28/2018 Battelle convenes teleconference with panel members to discuss draft BackCheck Responses 3/29/2018 Battelle convenes Comment Response Teleconference with panel members and SFWMD 3/29/2018 SFWMD provides final Evaluator Responses 4/3/2018 Battelle provides final Evaluator Responses to panel members 4/4/2018 Panel members provide final BackCheck Responses to Battelle 4/6/2018 Battelle inputs the panel members' final BackCheck Responses in the Word file 4/9/2018 Battelle submits pdf of Comment Response Record* Contract End/Delivery Date a 3/12/2018 4/10/2018 7/1/2018 Deliverable. b The public comment review was conducted in time to include the information in the Final Report, therefore, the final report represents the deliverable for both Task 5a and Task 5b originally proposed. c Task 6 activities occur after the submission of this report. BATTELLE March 12, 2018 A-2 SFWMD CEPP PACR IEPR Final IEPR Report At the beginning of the Period of Performance for the SFWMD CEPP PACR IEPR, Battelle held a kick-off meeting with SFWMD to review the preliminary/suggested schedule, discuss the IEPR process, and address any questions regarding the scope and schedule. Some changes to the schedule occurred after this meeting and are documented in Table A-1 above. The final charge consisted of 15 charge questions provided by SFWMD (all included in the draft and final Work Plans) and general guidance for the Panel on the conduct of the peer review (provided in Appendix C of this final report). Prior to beginning their review and after their subcontracts were finalized, all the members of the Panel attended a kick-off meeting via teleconference planned and facilitated by Battelle in order to review the IEPR process, the schedule, communication procedures, and other pertinent information for the Panel. Battelle planned and facilitated a second kick-off meeting via teleconference during which SFWMD presented project details to the Panel. Before the meetings, the IEPR Panel received an electronic version of the final charge. The panel received the review documents and reference/supplemental materials listed in Table A-2 on February 5, 2018. Table A-2. Documents to Be Reviewed and Provided as Reference/Supplemental Information Document No. of Review Pages PACR 287 Appendix A – Engineering Appendix 171 Appendix B – Cost Engineering 44 Appendix C.1 – Existing FWO Project Conditions 168 Appendix C.2 – Environmental Effects 21 Appendix C.3 – Public Comments 174 Appendix C.4 – Environmental Compliance Information - Clean 17 Appendix D – Real Estate 32 Appendix E – Plan Formulation 18 Appendix F – Recreation 28 Appendix G – Environmental Benefits Model 62 Annex A – Draft EAA Storage Reservoir BA 86 Annex A-1 – Canal Conveyance Improvements Modeling Report and Pump Station Hydraulic Design Calculations 15 Annex A-2 – Wave and Overtopping Report 202 Annex B – Analyses Required by WRDA 2000 and Florida State Law 72 Annex C – Draft Project Ops Manual 41 Annex C-1 – Earthwork Typical Sections for TSP and Overall Site Plan for TSP 11 Annex D – Adaptive Management and Monitoring 110 Annex D-1 – Mechanical Plates 9 Annex F – Phosphorus Assessment 38 BATTELLE March 12, 2018 A-3 SFWMD CEPP PACR IEPR Final IEPR Report Table A-2. Documents to Be Reviewed and Provided as Reference/Supplemental Information (continued) Document No. of Review Pages Annex G – Invasive Species 28 Total Number of Review Pages 1,634 Supplemental Documents Appendix B – Cost Engineering, Attachment B and Beyond (pages 45 – 187 of original Appendix) 143 Annex G-1 – Core Borings 638 Annex H – HTRW 461 Total Supplemental Pages 1,242 In addition to the materials provided in Table A-2, the panel members were provided the following USACE guidance documents.  USACE guidance, Civil Works Review (EC 1165-2-214), December 15, 2012  Office of Management and Budget, Final Information Quality Bulletin for Peer Review, December 16, 2004 Near the middle of the review, the Panel provided Battelle four questions regarding various aspects of the project. Battelle submitted panel member questions to SFWMD. On the Battelle-facilitated mid-review teleconference, held February 16, 2018, SFWMD discussed the questions with the Panel and Battelle. SFWMD provided additional written responses to all of the questions on February 22, 2018. A.2 Review of Individual Comments The Panel was instructed to address the charge questions/discussion points within a charge question response form provided by Battelle. At the end of the review period, the Panel produced individual comments in response to the charge questions/discussion points. Battelle reviewed the comments to identify overall recurring themes, areas of potential conflict, and other overall impressions. At the end of the review, Battelle summarized the individual comments into a preliminary list of overall comments and discussion points. Each panel member’s individual comments were shared with the full Panel. A.3 IEPR Panel Teleconference Battelle facilitated a teleconference with the Panel so that the panel members could exchange technical information. The main goal of the teleconference was to identify which issues should be carried forward as Final Panel Comments in the Final IEPR Report and decide which panel member should serve as the lead author for the development of each Final Panel Comment. This information exchange ensured that the Final IEPR Report would accurately represent the Panel’s assessment of the project, including any conflicting opinions. The Panel engaged in a thorough discussion of the overall positive and negative comments, added any missing issues of significant importance to the findings, and merged any related individual comments. At the conclusion of the teleconference, Battelle reviewed each Final Panel BATTELLE March 12, 2018 A-4 SFWMD CEPP PACR IEPR Final IEPR Report Comment with the Panel, including the associated level of significance, and confirmed the lead author for each comment. A.4 Preparation of Final Panel Comments Following the teleconference, Battelle distributed a summary memorandum for the Panel documenting each Final Panel Comment (organized by level of significance). The memorandum provided the following detailed guidance on the approach and format to be used to develop the Final Panel Comments for the SFWMD CEPP PACR IEPR:  Lead Responsibility: For each Final Panel Comment, one Panel member was identified as the lead author responsible for coordinating the development of the Final Panel Comment and submitting it to Battelle. Battelle modified lead assignments at the direction of the Panel. To assist each lead in the development of the Final Panel Comments, Battelle distributed a summary email detailing each draft final comment statement, an example Final Panel Comment following the four-part structure described below, and templates for the preparation of each Final Panel Comment.  Directive to the Lead: Each lead was encouraged to communicate directly with the other panel members as needed and to contribute to a particular Final Panel Comment. If a significant comment was identified that was not covered by one of the original Final Panel Comments, the appropriate lead was instructed to draft a new Final Panel Comment.  Format for Final Panel Comments: Each Final Panel Comment was presented as part of a fourpart structure: 1. Comment Statement (succinct summary statement of concern) 2. Basis for Comment (details regarding the concern) 3. Significance (high, medium/high, medium, medium/low, and low; see descriptions below) 4. Recommendation(s) for Resolution (see description below).  Criteria for Significance: The following were used as criteria for assigning a significance level to each Final Panel Comment:  High: There is a fundamental issue within study documents or data that will influence the technical or scientific basis for selection of, justification of, or ability to implement the recommended plan.  Medium/High: There is a fundamental issue within study documents or data that has a strong probability of influencing the technical or scientific basis for selection of, justification of, or ability to implement the recommended plan.  Medium: There is a fundamental issue within study documents or data that has a low probability of influencing the technical or scientific basis for selection of, justification of, or ability to implement the recommended plan.  Medium/Low: There is missing, incomplete, or inconsistent technical or scientific information that affects the clarity, understanding, or completeness of the study BATTELLE March 12, 2018 A-5 SFWMD CEPP PACR IEPR Final IEPR Report documents, and there is uncertainty whether the missing information will affect the selection of, justification of, or ability to implement the recommended plan.   Low: There is a minor technical or scientific discrepancy or inconsistency that affects the clarity, understanding, or completeness of the study documents but does not influence the selection of, justification of, or ability to implement the recommended plan. Guidelines for Developing Recommendations: The recommendation section was to include specific actions that SFWMD should consider to resolve the Final Panel Comment (e.g., suggestions on how and where to incorporate data into the analysis, how and where to address insufficiencies, areas where additional documentation is needed). Battelle reviewed and edited the Final Panel Comments for clarity, consistency with the comment statement, and adherence to guidance on the Panel’s overall charge, which included ensuring that there were no comments regarding either the appropriateness of the selected alternative or U.S. Army Corps of Engineers (USACE) policy. At the end of this process, six Final Panel Comments were prepared and assembled. There was no direct communication between the Panel and SFWMD during the preparation of the Final Panel Comments. The full text of the Final Panel Comments is presented in Section 4.2 of the main report. A.5 Conduct of the Public Comment Review Following the schedule in Table A-1, Battelle received a PDF file containing 174 pages of public comments on the SFWMD CEPP PACR from USACE. Battelle then sent the public comments to the panel members in addition to the following charge question: 1. Do the public comments raise any additional discipline-specific technical concerns with regard to the overall report? The Panel produced individual comments in response to the charge question. Each panel member’s individual comments for the public comment review were shared with the full Panel. Battelle reviewed the comments to identify any technical concerns that were identified by the public. Upon review, Battelle determined and the Panel confirmed that one issue was identified related to the public comments. The Panel developed the Final Panel Comment at the same time as the other five Final Panel Comments documenting the Panel’s concerns. A.6 Final IEPR Report After concluding the review and preparation of the Final Panel Comments, Battelle prepared a Final IEPR Report (this document) on the overall IEPR process and the IEPR panel members’ findings. Each panel member and Battelle technical and editorial reviewers reviewed the IEPR report prior to submission to SFWMD.   A.7 Comment Response Process As part of Task 6, Battelle will provide a Word version of the Final Panel Comments so that SFWMD can review and respond to them. SFWMD will provide responses (Evaluator Responses) to the Final Panel Comments, and the Panel will respond (BackCheck Responses) to the Evaluator Responses. All SFWMD BATTELLE March 12, 2018 A-6 SFWMD CEPP PACR IEPR Final IEPR Report and Panel responses will be documented by Battelle. Battelle will provide SFWMD and the Panel a pdf of the Comment Response Record containing the final IEPR results. BATTELLE March 12, 2018 A-7 SFWMD CEPP PACR IEPR Final IEPR Report This page is intentionally left blank. BATTELLE March 12, 2018 A-8 SFWMD CEPP PACR IEPR Final IEPR Report APPENDIX B Identification and Selection of IEPR Panel Members for the SFWMD CEPP PACR IEPR BATTELLE March 12, 2018 SFWMD CEPP PACR IEPR Final IEPR Report This page is intentionally left blank. BATTELLE March 12, 2018 SFWMD CEPP PACR IEPR Final IEPR Report B.1 Panel Identification The candidates for the South Florida Water Management District (SFWMD) Central Everglades Planning Project, Florida Post-Authorization Change Report Everglades Agricultural Area Storage Reservoir Integrated Feasibility Report and Environmental Impact Statement (hereinafter: SFWMD CEPP PACR IEPR) Panel were evaluated based on their technical expertise in the following key areas: Civil Works planning/economics, environmental/ecological evaluation, hydraulic engineering, and geotechnical engineering. These areas correspond to the technical content of the review documents and overall scope of the SFWMD CEPP PACR project. To identify candidate panel members, Battelle reviewed the credentials of the experts in Battelle’s Peer Reviewer Database, sought recommendations from colleagues, contacted former panel members, and conducted targeted Internet searches. Battelle evaluated these candidate panel members in terms of their technical expertise and potential conflicts of interest (COIs). Of these candidates, Battelle chose the most qualified individuals, confirmed their interest and availability, and ultimately selected four experts for the final Panel. The remaining candidates were not proposed for a variety of reasons, including lack of availability, disclosed COIs, or lack of the precise technical expertise required. Candidates were screened for the following potential exclusion criteria or COIs. These COI questions were intended to serve as a means of disclosure in order to better characterize a candidate’s employment history and background. Battelle evaluated whether scientists in universities and consulting firms that are receiving SFWMD-funding have sufficient independence from SFWMD to be appropriate peer reviewers. Guidance in the Office of Management and Budget’s (OMB) Final Information Quality Bulletin for Peer Review (OMB, 2004, p. 18) states: “…when a scientist is awarded a government research grant through an investigator-initiated, peer-reviewed competition, there generally should be no question as to that scientist's ability to offer independent scientific advice to the agency on other projects. This contrasts, for example, to a situation in which a scientist has a consulting or contractual arrangement with the agency or office sponsoring a peer review. Likewise, when the agency and a researcher work together (e.g., through a cooperative agreement) to design or implement a study, there is less independence from the agency. Furthermore, if a scientist has repeatedly served as a reviewer for the same agency, some may question whether that scientist is sufficiently independent from the agency to be employed as a peer reviewer on agency-sponsored projects.” Panel Conflict of Interest (COI) Screening Questionnaire for the IEPR of the SFWMD CEPP PACR 1. Previous and/or current involvement by you or your firm in the Central Everglades Planning Project (CEPP), Florida Post-Authorization Change Report Everglades Agricultural Area Storage Reservoir Integrated Feasibility Report and Environmental Impact Statement and related projects. 2. Previous and/or current involvement by you or your firm in Comprehensive Everglades Restoration Plan (CERP) projects for the central Everglades region. BATTELLE March 12, 2018 B-1 SFWMD CEPP PACR IEPR Final IEPR Report Panel Conflict of Interest (COI) Screening Questionnaire for the IEPR of the SFWMD CEPP PACR 3. Previous and/or current involvement by you or your firm in the conceptual or actual design, construction, or operation and maintenance (O&M) of any projects for the CEPP or CERP-related projects. 4. Current employment by the South Florida Water Management District (SFWMD). 5. Previous and/or current involvement with paid or unpaid expert testimony related to CEPP or CERP. 6. Previous and/or current employment or affiliation with South Florida Water Management District (SFWMD) or any Federal, State, County, local and regional agencies, environmental organizations, and interested groups working on CEPP or CERP (for pay or pro bono) including, but not limited to:  Tetra Tech, Inc.  Jacobs Engineering  Everglades National Park (ENP)  Florida Department of Environmental Protection (FDEP)  Fish and Wildlife Service (FWS)  United States Geological Survey (USGS)  Florida Department of Agricultural and Consumer Services (FDACS)  Florida Wildlife Conservation Commission (FWCC)  Any Florida Counties or Municipalities within the CERP planning area  USACE  members of RECOVER 7. Past, current, or future interests or involvements (financial or otherwise) by you, your spouse, or your children related to Southern Florida, including the South Florida ecosystem. 8. Current personal involvement with other USACE projects, including whether involvement was to author any manuals or guidance documents for USACE. If yes, provide titles of documents or description of project, dates, and location (USACE district, division, Headquarters, Engineer Research and Development Center, etc.), and position/role. Please highlight and discuss in greater detail any projects that are specifically with the Jacksonville District. 9. Previous or current involvement with the development or testing of models that will be used for, or in support of, the CEPP PACR Everglades Agricultural Area Storage Reservoir Integrated Feasibility Report and Environmental Impact Statement.  South Florida Regional Simulation Model (RSM)  Dynamic Model for Stormwater Treatment Areas (DMSTA)  RECOVER PM  ECO Model (for Habitat Units) BATTELLE March 12, 2018 B-2 SFWMD CEPP PACR IEPR Final IEPR Report Panel Conflict of Interest (COI) Screening Questionnaire for the IEPR of the SFWMD CEPP PACR 10. Current firm involvement with other SFWMD projects, or projects/contracts with the USACE Jacksonville District. If yes, provide title/description, dates, and location, and position/role. Please also clearly delineate the percentage of work you personally are currently conducting for SFWMD or USACE Jacksonville District. Please explain. 11. Any previous employment by SFWMD or the USACE Jacksonville District as a direct employee. If yes, provide title/description, dates employed, and place of employment, and position/role. 12. Any previous employment by SFWMD as a contractor (either as an individual or through your firm) within the last 10 years. If yes, provide title/description, dates employed, and place of employment, and position/role. 13. Previous experience conducting technical peer reviews. If yes, please highlight and discuss any technical reviews concerning ecosystem restoration and flood management, and include the client/agency and duration of review (approximate dates). 14. Pending, current, or future financial interests in Central Everglades Planning Project, Florida Post-Authorization Change Report Everglades Agricultural Area Storage Reservoir Integrated Feasibility Report and Environmental Impact Statement-related contracts/awards from SFWMD. 15. Significant portion of your personal or office’s revenues within the last three years came from SFWMD contracts. 16. Significant portion of your personal or office’s revenues within the last three years came from USACE Jacksonville contracts. 17. Any publicly documented statement (including, for example, advocating for or discouraging against) related to CEPP or CERP. 18. Participation in relevant prior and/or current state or Federal studies relevant to this project, CEPP, and/or CERP. 18. Previous and/or current participation in prior studies relevant to this project and/or CEPP or CERP. 19. Has your research or analysis been evaluated as part of the CEPP or CERP? 20. Is there any past, present, or future activity, relationship, or interest (financial or otherwise) that could make it appear that you would be unable to provide unbiased services on this project? If so, please describe. Providing a positive response to a COI screening question did not automatically preclude a candidate from serving on the Panel. For example, participation in previous SFWMD technical peer review BATTELLE March 12, 2018 B-3 SFWMD CEPP PACR IEPR Final IEPR Report committees and other technical review panel experience was included as a COI screening question. A positive response to this question could be considered a benefit. The term “firm” in a screening question referred to any joint venture in which a firm was involved. It applied to whether that firm serves as a prime or as a subcontractor to a prime. Candidates were asked to clarify the relationship in the screening questions.  B.2 Panel Selection In selecting the final members of the Panel, Battelle chose experts who best fit the expertise areas and had no COIs. Table B-1 provides information on each panel member’s affiliation, location, education, and overall years of experience. Battelle established subcontracts with the panel members when they indicated their willingness to participate and confirmed the absence of COIs through a signed COI form. SFWMD was given the list of candidate panel members, but Battelle selected the final Panel. Table B-1. SFWMD CEPP PACR IEPR Panel: Summary of Panel Members Name Affiliation Location Education P.E. Exp. (yrs) Civil Works Planning / Economics (Dual Role) David Luckie Independent Consultant Mobile, AL B.A., Economics & Finance N/A 29 Naples, FL Ph.D., Biology N/A 39 Lutz, FL M.S., Civil Engineering Yes 27 Asheville, NC Ph.D., Civil/Geotechnical Engineering Yes 48+ Environmental / Ecological Evaluation Kris Thoemke Coastal Engineering Consultants, Inc. Hydraulic Engineering Patrick Tara INTERA, Inc. Geotechnical Engineering B. Dan Marks III Marks Enterprises of NC, PLLC Table B-2 presents an overview of the credentials of the final four members of the Panel and their qualifications in relation to the technical evaluation criteria. More detailed biographical information regarding each panel member and his area of technical expertise is given in Section B.3. BATTELLE March 12, 2018 B-4 SFWMD CEPP PACR IEPR Final IEPR Report Civil Works Planning / Economics (Dual Role) Minimum 10 years of demonstrated experience in public works planning with high public and interagency interests. X Minimum 10 years of experience directly related to water resource economic evaluation or review. X Familiar with USACE plan formulation process, procedures, and standards. X Familiar with evaluation of alternative plans for ecosystem restoration projects X Familiar with economic evaluation techniques, including cost-effectiveness/incremental cost analyses. X Familiar with procedures associated with identifying the National Ecosystem Restoration plan. X Experience should encompass projects with nearby project-impacted sensitive habitats. X M.S. degree or higher in economics X Environmental / Ecological Evaluation Minimum 10 years of experience directly related to water resource environmental evaluation or review and National Environmental Policy Act (NEPA) compliance. X Extensive experience working with wetlands and estuarine ecosystems. X Familiar with USACE calculation and application of environmental impacts and benefits. X Experience in the South Florida region X M.S. degree or higher in an appropriate field of study. X Hydraulic Engineering Expert in hydraulic and hydrologic modeling related to wetland restoration. X Minimum of 10 years of experience in hydrologic and hydraulic engineering or as professor from academia with extensive background in hydrologic and hydraulic theory and practice, knowledge of South Florida hydrology and water management. X Familiar with the application of integrated surface water and groundwater models, including the capability to review typical data output from hydrologic models. X Experience with hydrologic modeling tools selected for project application, including: RESOPS, LOOPS, RSMBN, SFWMM, RSMGL, DMSTA, HEC-RAS X Active participant in related professional societies. X M.S. degree or higher in civil engineering or a related field. X BATTELLE March 12, 2018 B-5 Marks Tara Thoemke Technical Criterion Luckie Table B-2. SFWMD CEPP PACR IEPR Panel: Technical Criteria and Areas of Expertise SFWMD CEPP PACR IEPR Final IEPR Report Marks Tara Thoemke Technical Criterion Luckie Table B-2. SFWMD CEPP PACR IEPR Panel: Technical Criteria and Areas of Expertise (continued) Geotechnical Engineer Minimum 10 years of experience directly related to geologic processes in coastal environments X Experience with geomorphic processes in wetlands and coastal ecosystems. X Experience in the South Florida region. X B.S. degree or higher in engineering. X B.3 Panel Member Qualifications Detailed biographical information on each panel member’s credentials, qualifications, and areas of technical expertise is summarized in the following paragraphs. Name Role Affiliation David Luckie Civil Works Planner/Economist Independent Consultant Mr. Luckie is an independent consultant with 29 years of professional experience in water resource economics, planning, plan formulation, benefit-cost analysis, and risk-based analysis. His public works experience encompasses decades of work with Federal and non-Federal agencies, as well as local and state organizations. He earned his B.S. in economics and finance from the University of South Alabama in 1986. His professional experience includes working with multidisciplinary teams to provide or review complex planning studies for coastal storm risk management (CSRM), dam safety, flood risk management (FRM), ecosystem restoration, and water supply and water quality studies. He is intimately familiar with Engineer Regulation (ER) 1105-2-100 and the 6-Step Planning Process and has prepared, supervised, or reviewed numerous planning studies in his career. Mr. Luckie is familiar with the evaluation of alternative plans for both CSRM and FRM studies and has conducted, supervised, or reviewed several water resource studies featuring numerous alternative plans constructed from an array of different management measures. Over the last three decades, Mr. Luckie has been involved in numerous CSRM studies. Two examples are the Panama City Beach, Florida, study, a multipurpose project that included structural, non-structural, and recreation outputs, and the Mississippi Coastal Improvements Program following Hurricanes Katrina and Rita. He has also served as a panel member on the IEPRs of the Hereford Inlet CSRM Study in New Jersey and the Encinitas – Solana Beach CSRM Study in California. He applied his knowledge of ER-1105-2-100 and the 6-Step Planning Process in each of these high-profile efforts. BATTELLE March 12, 2018 B-6 SFWMD CEPP PACR IEPR Final IEPR Report Least cost analysis, also known as cost-effectiveness analysis, has been a significant aspect of Mr. Luckie’s decades of work. He is familiar with the evaluation of alternative plans. As a Regional Economist with the USACE Mobile District (1988-2006), Mr. Luckie conducted, supervised, or reviewed benefit-cost analyses for a variety of water resource projects, both single-purpose and multi-purpose projects covering the full range of USACE missions. Relevant studies include the ApalachicolaChattahoochee-Flint River and the Alabama-Coosa-Tallapoosa Comprehensive Studies; the draft Programmatic Environmental Impact Statements covering the states of Alabama, Florida, and Georgia; and the Hunting Bayou General Reevaluation Report (GRR) in Houston, Texas. Mr. Luckie is very familiar with USACE standards and procedures. He has extensive experience performing National Economic Development (NED) analyses, specifically as they relate to flood and coastal risk management. For more than 25 years, he has performed, supervised, or reviewed NED procedures for technical accuracy and for compliance with policy, guidance, and accepted planning principles. Such studies as Panama City Beaches and Mississippi Coastal Improvements reflect this expertise. Mr. Luckie has been using the Hydrologic Engineering Center Flood Damage Reduction Analysis (HECFDA) software since its inception in the 1990s. He has also performed, reviewed, or trouble-shot scores of HEC-FDA analyses for Federal, non-Federal, and private-sector clients. In addition, he has mentored interns and junior economists in USACE methodologies for CSRM, requiring them to calculate withoutand with-project condition damages, either by hand or with a Microsoft Excel spreadsheet, before allowing them to use HEC-FDA. He is also very familiar with the USACE Regional Economic System (RECONS) model and the estimation of Regional Economic Development benefits, and has used the model for both Federal and non-Federal project proponents since its inception. Name Role Affiliation Kris Thoemke, Ph.D., CEP Environmental and ecological evaluation Coastal Engineering Consultants, Inc. Dr. Thoemke is a Senior Scientist for Coastal Engineering Consultants, Inc. He received his Ph.D. in biology from the University of South Florida in 1979 and is a Certified Environmental Professional. He has 39 years of experience as a professional ecologist in South Florida working as a researcher and land manager for the State of Florida, a private ecological consultant, an environmental and outdoor communicator, and as Everglades project manager for a non-profit organization. For the past twelve years as an environmental consultant, Dr. Thoemke has conducted marine and estuarine environmental assessments, environmental permitting, and listed species surveys along the Atlantic and Gulf coasts in Florida. Dr. Thoemke has conducted environmental consulting work related to water resource environmental permitting and National Environmental Policy Act (NEPA) compliance documentation. Additionally, he teaches graduate courses in environmental management, permitting and NEPA for the American Public University System. Dr. Thoemke is familiar with large, complex Civil Works projects with high public and interagency interests. His direct experience includes his work as a wetland scientist on the Florida Everglades restoration program, ongoing involvement as the environmental scientist for the Charlotte County, Florida, BATTELLE March 12, 2018 B-7 SFWMD CEPP PACR IEPR Final IEPR Report Erosion Control Project for Stump Pass, and participation on a team working on large Civil Works restoration projects for the State of Louisiana in the Mississippi Delta region. Dr. Thoemke’s experience with construction impacts on marine and terrestrial ecology of coastal regions and characterization of benthic communities includes identifying and assessing construction impacts to seagrass, mangrove, shorebird, and dune plant communities at Stump Pass and Blind Pass, Florida, and gopher tortoise habitat at Clam Pass and Vanderbilt Beach Parks, Florida. His Ph.D. research focused on estuarine benthic invertebrates, and he has more than 30 years of experience characterizing benthic communities. He also has extensive experience permitting and mitigating for construction impacts resulting from coastal and upland development, including assessing and monitoring impacts to beach and dune systems, nesting sea turtles, shorebirds, and upland listed species found in the coastal and beach/dune habitats. In addition, he has conducted post-storm analysis of beach and dune systems. Dr. Thoemke is familiar with all NEPA and environmental impact statement (EIS) requirements. He gained experience with environmental policies and processes by preparing reports and by serving on IEPR panels, including the Walton County, Florida, Hurricane and Storm Reduction Feasibility Report and Draft Environmental Assessment, and the CEPP Draft Project Implementation Report (PIR) and EIS. Dr. Thoemke was a member of an integrated team of scientists and engineers that prepared the EIS for the Terrebonne Basin Barrier Island Shoreline Restoration Project, Louisiana, including Endangered Species Act, essential fish habitat (EFH), and NEPA requirements. In addition, he has reviewed EISs and EAs for other coastal restoration projects in the Mississippi Delta. Dr. Thoemke was project manager on the Port Everglades Ocean Dredged Material Disposal Site Environmental Assessment, which included Marine Mammals Protection Act listed species. In addition, he has completed Section 7 assessments for listed species under National Marine Fisheries Service jurisdiction for projects in several south Florida locations, and he coordinated with U.S. Fish and Wildlife Service (USFWS) to prepare an updated Biological Opinion for swimming sea turtles and shorebirds on Marco Island, Florida. He has provided EFH consultation to several projects and continues to prepare EFH studies for marine and estuarine species as a part of his permitting work. Dr. Thoemke is a member of the National Association of Environmental Professionals and is a member and Chairman of the Certification Review Board of the Academy of Board Certified Environmental Professionals. Name Role Affiliation Patrick Tara, P.E., P.H. Hydraulic engineering INTERA, Inc. Mr. Tara is a principal water resources engineer with INTERA, Inc., and is a licensed engineer and professional hydrologist in Florida. He received his M.S. in civil engineering from the University of South Florida in 1991. Mr. Tara has over 27 years of experience in water resource engineering, focused on surface water hydrology, groundwater, hydraulics, and integrated surface water/groundwater hydrologic systems. He has developed hydrologic and hydraulic (H&H) models for environmental restoration, water supply, and minimum flows and levels. His project experience is focused in Florida; he has worked for all the water management districts in Florida as well as the Florida Department of Environmental Protection. Mr. Tara has experience with most of the hydrologic modeling tools selected for project application. His experience in H&H modeling projects includes the development and application of numerous model BATTELLE March 12, 2018 B-8 SFWMD CEPP PACR IEPR Final IEPR Report codes with a focus on shallow water table environments. His modeling studies have examined both surface and groundwater impacts. He has significant experience with integrated hydrologic models and was involved in the development and application of the FIPR Hydrologic Model (FHM) and Integrated Hydrologic Model (IHM), both of which are fully integrated hydrologic models. He has reviewed the Regional Simulation Model (RSM) code and applied the natural systems RSM model; he has also used the RSM code within a Monte Carlo-based uncertainty analysis to determine the uncertainty in model output based on the uncertainty of model parameters. He also has experience with the ELM, MIKE SHE, and WASH models and has used them to perform Monte Carlo uncertainty analyses. Additionally, Mr. Tara has experience with the South Florida Water Management Model (SFWMM) to define the boundary conditions for the ELM model and with DMSTA to evaluate the benefits of converting land adjacent to Lake Okeechobee into a stormwater treatment area. DMSTA was modified to support uncertainty analysis and used inside Crystal Ball to evaluate the model results given the uncertainty in both the settling rate and the input concentration. Mr. Tara has applied the Hydrologic Engineering Center River Analysis System (HEC-RAS) model to many riverine systems in Florida for minimum flows and levels development, floodplain delineation, and scour analysis. He has utilized the model in both steady-state and dynamic modes. He has also utilized HEC Geo-RAS to take advantage of the Geographic Information System data in the development of HEC-RAS models. He has extensive experience working on large rivers and large-river watersheds and has conducted engineering studies on such systems as the Alafia, Hillsborough, Apalachicola, St John’s, and Chattahoochee River in Florida. Many of these studies included secondary channels and branching and braided natural systems. Mr. Tara has served as a peer reviewer for many hydrologic models in Florida, including those for litigation support; has participated in numerous conferences; and has presented his works in journals, at conferences, and on conference posters. He is a member of the national and state American Water Resources Association and a member of the American Institute of Hydrology. Name Role Affiliation B. Dan Marks, Ph.D., P.E. Geotechnical engineering Marks Enterprises of NC, PLLC Dr. Marks is the owner and manager of Marks Enterprises of NC, PLLC, in Ashville, North Carolina, and is a registered professional engineer in North Carolina, Georgia, and South Carolina. He earned his Ph.D. in civil engineering from Oklahoma State University in 1970 and has over 48 years of experience as a geotechnical and civil engineer. His areas of expertise include administration and management of geotechnical engineering projects; dam and water-retention structure analyses and design; earthretaining structure analyses and design; landslide and slope stability analyses; remediation design; stabilization; erosion and sedimentation control; seepage analyses and groundwater flow evaluations; geosynthetics and geotextiles in drainage and reinforcement; and failure analyses and remediation consulting. Dr. Marks has direct experience related to geologic processes in coastal environments. He has completed over a hundred projects at state ports on the Atlantic Seaboard from Maryland to Florida, including the Nuclear Submarine Station at Goose Creek, South Carolina, and the Norfolk Naval Shipyard Berth & Pier Stability Evaluation. Dr. Marks has extensive experience working with geomorphic processes in wetlands and coastal ecosystems. He has completed more than 200 dam projects that included BATTELLE March 12, 2018 B-9 SFWMD CEPP PACR IEPR Final IEPR Report wetland and coastal ecosystem permits for design and construction. Dr. Marks has experience in the South Florida region, most recently with a groundwater control system project for city block development in West Palm Beach, Florida, and a potential hurricane flood dewatering system. He is experienced with erosion control of protected side slopes and level crowns against storm-generated wave overtopping. He co-authored the Technical Manual for Dam Owners: Impacts of Trees and Woody Vegetation on Earthen Dams for the Federal Emergency Management Agency and the first Erosion & Sedimentation Control Manual used by the Federal Highway Administration. He has authored 20 publications, more than 15 reports, and over 75 presentations in the geotechnical field, including stabilization, remediation, and erosion control. BATTELLE March 12, 2018 B-10 SFWMD CEPP PACR IEPR Final IEPR Report APPENDIX C Final Charge for the SFWMD CEPP PACR IEPR BATTELLE March 12, 2018 SFWMD CEPP PACR IEPR Final IEPR Report This page is intentionally left blank. BATTELLE March 12, 2018 SFWMD CEPP PACR IEPR Final IEPR Report Charge Questions and Guidance to the Panel Members for the Independent External Peer Review (IEPR) of the Central Everglades Planning Project, Florida, Post-Authorization Change Report Everglades Agricultural Area Storage Reservoir Integrated Feasibility Report and Environmental Impact Statement This is the final Charge to the Panel for the SFWMD CEPP PACR IEPR. This final Charge was submitted to SFWMD as part of the final Work Plan, originally submitted on January 9, 2018. BACKGROUND South Florida Water Management District (SFWMD), as local sponsor to the Central Everglades Planning Project (CEPP), has prepared this CEPP Post Authorization Change Report (PACR) (Integrated Feasibility Study and Environmental Impact Statement). Section 373.4598 Florida Statutes, passed and signed into law in 2017, mandates accelerated efforts by the SFWMD to pursue the PACR in support of a plan to increase water storage and water quality treatment wetlands in the Everglades Agricultural Area (EAA) south of Lake Okeechobee, Florida. The law directs the SFWMD to evaluate two alternative storage targets: 240,000 acre-feet on the A-2 parcel and A-2 expansion area and up to 360,000 acre-feet of storage on A-1 and A-2 parcels combined, and associated conveyance improvements. The CEPP PACR is being conducted under the authority provided by Section 203 of the WRDA of 1986, as amended by Section 1014(a) of the WRDA 2014, which authorizes non-Federal interests to undertake feasibility studies of proposed water resources development projects for submission to the Secretary of the Army. Upon approval of the CEPP PACR by the Governing Board of the SFWMD and the Assistant Secretary of the Army for Civil Works, the recommended plan will be submitted to Congress for authorization. The CEPP PACR does not represent a complete reevaluation of the CEPP. The focus and purpose of the CEPP PACR is to evaluate and select storage and treatment features in the EAA south of Lake Okeechobee that will increase the amount of storage and treatment wetlands in the CEPP Project Partnership Agreement (PPA) New Water and send additional water south to the historic Everglades ecosystem. The CEPP PACR will also reaffirm that the CEPP PPA South and North can accommodate additional flows south that will result from additional storage and treatment wetlands on the A-1, A-2, and A-2 expansion area flow equalization basins by evaluating the need for additional improvements to the conveyance system from Lake Okeechobee to the new storage features. No changes to the conveyance system south of the EAA, beyond those included in the CEPP, are anticipated as a result of the PACR. The benefit of management measures recommended in the CEPP PACR would be the reduction of undesirable regulatory discharges of freshwater from Lake Okeechobee to estuaries on the east and west coast of Florida and increased flows to the greater Everglades. All other project features authorized in the CEPP would not be affected by the scope of the CEPP PACR. The increase in storage and treatment features and the associated improvements in conveyance to move more water to the new EAA storage features evaluated and recommended in the CEPP PACR would further improve the quantity, quality, timing and distribution of water flows to the Northern Estuaries, central Everglades (Water Conservation Area 3 [WCA 3] and Everglades National Park [ENP]), and Florida Bay while maintaining water supply for municipal and agricultural users. BATTELLE March 12, 2018 C-1 SFWMD CEPP PACR IEPR Final IEPR Report Since the Central Everglades Restoration Plan (CERP) was approved:  Three projects were authorized in the 2007 WRDA and proceeded to construction (Indian River Lagoon-South, Picayune Strand, and Site 1 Impoundment) and a fourth project, Melaleuca and Other Exotic Plants Biological Controls, was implemented under the programmatic authority in WRDA 2000.  Three projects were authorized in the 2014 WRDA. The C-43 Reservoir and Biscayne Bay Coastal Wetlands Phase I Project proceeded to construction, and detailed design began on the Broward County Water Preserve Area Project.  The Central Everglades Planning Project, which includes the first increment of the EAA Storage Reservoirs, was authorized in WRDA 2016. Despite this progress, ecological conditions and functions within the central portion of the Everglades ridge and slough community will continue to decline due to lack of sufficient quantities of freshwater flow into the central Everglades and timing and distribution problems. The SFWMD initiated the CEPP PACR in August 2017 to respond to this concern and evaluate alternatives for the final increment of CERP EAA Storage needed to achieve the CERP 300,000 acre-feet of average annual flow to the central portion of the Everglades to restore ecosystem conditions. OBJECTIVES The objective of this work is to conduct an independent external peer review (IEPR) of the Central Everglades Planning Project, Florida Post-Authorization Change Report Everglades Agricultural Area Storage Reservoir Integrated Feasibility Report and Environmental Impact Statement (hereinafter: SFWMD CEPP PACR IEPR) in accordance with the Department of the Army, U.S. Army Corps of Engineers (USACE), Water Resources Policies and Authorities’ Civil Works Review (Engineer Circular [EC] 1165-2-214, dated December 15, 2012), and the Office of Management and Budget’s Final Information Quality Bulletin for Peer Review (December 16, 2004). Peer review is one of the important procedures used to ensure that the quality of published information meets the standards of the scientific and technical community. Peer review typically evaluates the clarity of hypotheses, validity of the research design, quality of data collection procedures, robustness of the methods employed, appropriateness of the methods for the hypotheses being tested, extent to which the conclusions follow from the analysis, and strengths and limitations of the overall product. The purpose of the IEPR is to assess the “adequacy and acceptability of the economic, engineering, and environmental methods, models, and analyses used” (EC 1165-2-214; p. D-4) for the decision documents. The IEPR will be limited to technical review and will not involve policy review. The IEPR will be conducted by subject matter experts (i.e., IEPR panel members) who meet the technical criteria and areas of expertise required for and relevant to the project. The Panel will be “charged” with responding to specific technical questions as well as providing a broad technical evaluation of the overall project. Per EC 1165-2-214, Appendix D, review panels should identify, explain, and comment upon assumptions that underlie all the analyses, as well as evaluate the soundness of models, surveys, investigations, and methods. Review panels should be able to evaluate whether the interpretations of analysis and the conclusions based on analysis are reasonable. Reviews should focus on assumptions, data, methods, and models. The panel members may offer their opinions as to whether there are sufficient analyses upon which to base a recommendation. BATTELLE March 12, 2018 C-2 SFWMD CEPP PACR IEPR Final IEPR Report DOCUMENTS PROVIDED The following is a list of documents, supporting information, and reference materials that will be provided for the review. The review assignments per panel member may vary slightly according to discipline. Review Documents No. of Review Pages PACR 287 Appendix A – Engineering Appendix 171 Appendix B – Cost Engineering 44 Appendix C.1 – Existing FWO Project Conditions 168 Appendix C.2 – Environmental Effects 21 Appendix C.3 – Public Comments 174 Appendix C.4 – Environmental Compliance Information - Clean 17 Appendix D – Real Estate 32 Appendix E – Plan Formulation 18 Appendix F – Recreation 28 Appendix G – Environmental Benefits Model 62 Annex A – Draft EAA Storage Reservoir BA 86 Annex A-1 – Canal Conveyance Improvements Modeling Report and Pump Station Hydraulic Design Calculations 15 Annex A-2 – Wave and Overtopping Report 202 Annex B – Analyses Required by WRDA 2000 and Florida State Law 72 Annex C – Draft Project Ops Manual 41 Annex C-1 – Earthwork Typical Sections for TSP and Overall Site Plan for TSP 11 Annex D – Adaptive Management and Monitoring 110 Annex D-1 – Mechanical Plates 9 Annex F – Phosphorus Assessment 38 Annex G – Invasive Species 28 Total Number of Review Pages 1,634 Supplemental Documents Appendix B – Cost Engineering, Attachment B and Beyond (pages 45 – 187 of original Appendix) 143 Annex G-1 – Core Borings 638 Annex H – HTRW 461 Total Supplemental Pages BATTELLE March 12, 2018 1,242 C-3 SFWMD CEPP PACR IEPR Final IEPR Report Documents for Reference  USACE guidance Civil Works Review (EC 1165-2-214, December 15, 2012)  Office of Management and Budget’s Final Information Quality Bulletin for Peer Review (December 16, 2004). SCHEDULE & DELIVERABLES This schedule is based on the receipt date of the final review documents and may be revised if review document availability changes. This schedule may also change due to circumstances out of Battelle’s control such as changes to SFWMD’s project schedule and unforeseen changes to panel member and SFWMD availability. As part of each task, the panel member will prepare deliverables by the dates indicated in the table (or as directed by Battelle). All deliverables will be submitted in an electronic format compatible with MS Word (Office 2003). Task Action Attend Meetings and Begin Peer Review Battelle convenes kick-off meeting with panel members 1/19/2018 Battelle convenes kick-off meeting with SFWMD and panel members 1/19/2018 Prepare Final Panel Comments Battelle sends review documents to panel members 2/6/2018 Battelle convenes mid-review teleconference for panel members to ask clarifying questions of SFWMD 2/16/2018 Panel members complete their individual reviews 2/21/2018 Battelle provides talking points for Panel Review Teleconference to panel members 2/22/2018 Battelle convenes Panel Review Teleconference 2/23/2018 Battelle provides Final Panel Comment templates and instructions to panel members 2/23/2018 Panel members provide draft Final Panel Comments to Battelle Battelle provides feedback to panel members on draft Final Panel Comments; panel members revise Final Panel Comments Review Public Comments Due Date 3/1/2018 3/2/2018 – 3/5/2018 Panel finalizes Final Panel Comments 3/6/2018 Battelle receives public comments from SFWMD 2/5/2018 **Battelle sends public comments to Panel 2/6/2018 Panel completes its review of public comments 3/21/2018 Battelle and Panel review the Panel's responses to the charge question regarding the public comments 3/23/2018 Panel drafts Final Panel Comment relevant to the public comments 3/1/2018 Panel finalizes Final Panel Comment regarding public comments 3/6/2018 Battelle provides Final IEPR Report to panel members for review 3/7/2018 BATTELLE March 12, 2018 C-4 SFWMD CEPP PACR IEPR Final IEPR Report Task Action Review Final IEPR Report Panel members provide comments on Final IEPR Report *Battelle submits Final IEPR Report to SFWMD *Battelle submits Addendum to the Final IEPR Report to SFWMD Comment/ Response Process Battelle provides Final Panel Comment response template to SFWMD Due Date 3/8/2018 3/12/2018 Not Applicable 3/13/2018 Battelle convenes teleconference with SFWMD to review the Comment Response process 3/13/2018 Battelle convenes teleconference with Panel to review the Comment Response process 3/14/2018 SFWMD provides draft Evaluator Responses to Battelle 3/23/2018 Battelle provides draft Evaluator Responses to panel members 3/26/2018 Panel members provide draft BackCheck Responses to Battelle 3/28/2018 Battelle convenes teleconference with panel members to discuss draft BackCheck Responses 3/29/2018 Battelle convenes Comment Response Teleconference with panel members and SFWMD 3/29/2018 SFWMD provides final Evaluator Responses to Battelle 4/3/2018 Battelle provides final Evaluator Responses to panel members 4/4/2018 Panel members provide final BackCheck Responses to Battelle 4/6/2018 Battelle consolidates panel members' final BackCheck Responses into the Comment Response Record 4/9/2018 *Battelle submits pdf printout of Comment Response Record project file 4/10/2018 * Deliverables ** Battelle will provide public comments to the Panel after they have completed their individual reviews of the project documents to ensure that the public comment review does not bias the Panel’s review of the project documents. CHARGE FOR PEER REVIEW Members of this IEPR Panel are asked to determine whether the technical approach and scientific rationale presented in the decision documents are credible and whether the conclusions are valid. The Panel is asked to determine whether the technical work is adequate, competently performed, and properly documented; satisfies established quality requirements; and yields scientifically credible conclusions. The Panel is being asked to provide feedback on the economic, engineering, environmental resources, and plan formulation. The panel members are not being asked whether they would have conducted the work in a similar manner. Specific questions for the Panel (by report section or appendix) are included in the general charge guidance, which is provided below. BATTELLE March 12, 2018 C-5 SFWMD CEPP PACR IEPR Final IEPR Report General Charge Guidance Please answer the scientific and technical questions listed below and conduct a broad overview of the decision documents. Please focus your review on the review materials assigned to your discipline/area of expertise and technical knowledge. Even though there are some sections with no questions associated with them, that does not mean that you cannot comment on them. Please feel free to make any relevant and appropriate comment on any of the sections and appendices you were asked to review. In addition, please note that the Panel will be asked to provide an overall statement related to 2 and 3 below per USACE guidance (EC 1165-2-214; Appendix D). 1. Your response to the charge questions should not be limited to a “yes” or “no.” Please provide complete answers to fully explain your response. 2. Assess the adequacy and acceptability of the economic and environmental assumptions and projections, project evaluation data, and any biological opinions of the project study. 3. Assess the adequacy and acceptability of the economic analyses, environmental analyses, engineering analyses, formulation of alternative plans, methods for integrating risk and uncertainty, and models used in evaluating economic or environmental impacts of the proposed project. 4. If appropriate, offer opinions as to whether there are sufficient analyses upon which to base a recommendation. 5. Identify, explain, and comment upon assumptions that underlie all the analyses, as well as evaluate the soundness of models, surveys, investigations, and methods. 6. Evaluate whether the interpretations of analysis and the conclusions based on analysis are reasonable. 7. Please focus the review on assumptions, data, methods, and models. Please do not make recommendations on whether a particular alternative should be implemented, or whether you would have conducted the work in a similar manner. Also please do not comment on or make recommendations on policy issues and decision making. Comments should be provided based on your professional judgment, not the legality of the document. 1. If desired, panel members can contact one another. However, panel members should not contact anyone who is or was involved in the project, or prepared the subject documents. 2. Please contact the Battelle Project Manager Lynn McLeod (mcleod@battelle.org) for requests or additional information. 3. In case of media contact, notify the Battelle Project Manager Lynn McLeod (mcleod@battelle.org) immediately. 4. Your name will appear as one of the panel members in the peer review. Your comments will be included in the Final IEPR Report, but will remain anonymous. Please submit your comments in electronic form to the Project Manager, Lynn McLeod, no later than 10 pm ET by the date listed in the schedule above. BATTELLE March 12, 2018 C-6 SFWMD CEPP PACR IEPR Final IEPR Report Independent External Peer Review of the Central Everglades Planning Project, Florida, Post-Authorization Change Report Everglades Agricultural Area Storage Reservoir Integrated Feasibility Report and Environmental Impact Statement Charge Questions and Relevant Sections as Supplied by SFWMD The following Review Charge to Reviewers outlines the objectives of the Independent External Peer Review (IEPR) for the subject study and identifies specific items for consideration for the IEPR Review Panel. The objective of the IEPR is to obtain an independent evaluation of whether the interpretations of analysis and conclusions based on analysis are reasonable for the subject study. The IEPR Panel is requested to offer a broad evaluation of the overall study decision document in addition to addressing the specific technical and scientific questions included in the Review Charge. The IEPR Panel has the flexibility to bring important issues to the attention of decision makers, including positive feedback or issues outside those specific areas outlined in the Review Charge. The IEPR Panel can use all available information to determine what scientific and technical issues related to the decision document may be important to raise to decision makers. The Panel review is to focus on scientific and technical matters, leaving policy determinations for the SFWMD, and subsequently to USACE and the Army, following submittal of the report to the Assistant Secretary of the Army (Civil Works) in accordance with Section 203 of the Water Resources Development Act of 1986, as amended. The Panel should not make recommendations on whether a particular alternative should be implemented or present findings that become “directives” in that they call for modifications or additional studies or suggest new conclusions and recommendations. In such circumstances the IEPR Panel would have assumed the role of advisors as well as reviewers, thus introducing bias and potential conflict in their ability to provide objective review. Panel review comments are to be structured to fully communicate the Panel’s intent by including the comment, an explanation of why it is important, any potential consequences of failure to address, and suggestions on how to address the comment. The IEPR Panel is asked to consider the following items as part of its review of the decision document and supporting materials. Broad Evaluation Review Charge Questions 1. Are the need for, and intent of, the decision document clear? 2. Does the decision document adequately address the stated need and intent relative to scientific and technical issues? 3. Assess the adequacy and acceptability of the project evaluation data used in the study analyses. 4. Assess the adequacy and acceptability of the economic, environmental, and engineering assumptions that underlie the study analyses. BATTELLE March 12, 2018 C-7 SFWMD CEPP PACR IEPR Final IEPR Report 5. Assess the adequacy and acceptability of the economic, environmental, and engineering methodologies, analyses, and projections. 6. Assess the adequacy and acceptability of the models used in the evaluation of existing and future without-project conditions and of economic or environmental impacts of alternatives. 7. Assess the adequacy and acceptability of the methods for integrating risk and uncertainty. 8. Assess the adequacy and acceptability of the formulation of alternative plans and the range of alternative plans considered. 9. Assess the adequacy and acceptability of the quality and quantity of the surveys, investigations, and engineering sufficient for conceptual design of alternative plans. 10. Assess the adequacy and acceptability of the overall assessment of significant environmental impacts and any biological analyses. 11. Evaluate whether the interpretations of analysis and the conclusions based on analysis are reasonable. 12. Assess the considered and tentatively selected alternatives from the perspective of systems, including systemic aspects being considered from a temporal perspective, including the potential effects of climate change. Battelle Summary Charge Questions to the Panel Members Summary Questions 13. Please identify the most critical concerns (up to five) you have with the project and/or review documents. These concerns can be (but do not need to be) new ideas or issues that have not been raised previously. 14. Please provide positive feedback on the project and/or review documents. Public Comments Review Question 15. Do the public comments raise any additional discipline-specific technical concerns with regard to the overall report? ADDITIONAL COMMENTS OR ISSUES IDENTIFIED Please feel free to make any relevant and appropriate comment on any of the sections and appendices you were asked to review, including any typographical errors or editorial issues that you caught. Typos and editorial issues typically do not rise to a significance level or a Final Panel Comment, but instead can be provided separately to the SFWMD. BATTELLE March 12, 2018 C-8 SFWMD CEPP PACR IEPR Final IEPR Report This page is intentionally left blank. BATTELLE March 12, 2018 It can be done