uncertainties related to full-scale CERP ASR implementation by conducting scientific studies based on existing and newly acquired data, develop a regional groundwater model of the Floridan Aquifer System (FAS), and identify an appropriate magnitude of ASR capacity with minimal impact to the environment and existing users of the FAS. A fourth draft of the Project Management Plan (PMP) for the study (http://www.evergladesplan.org/pm/mgmtplns.shtml) was prepared by the USACE and the SFWMD in May 2002, and the Task Force requested that the CROGEE conduct a technical review of this document. To accomplish this task, the CROGEE formed a working group, composed of existing members of the committee and supplemented with special consultants.

The PMP is organized primarily into a series of “technical tasks,” each having a budget, a timetable, subtasks, and a list of assumptions. The Executive Summary and Table of Contents of the PMP are in Appendix A of this report. Most of this report focuses on Chapter 3 of the PMP, which outlines the technical tasks. There is also considerable discussion of Appendix L, which contains many of the details of Tasks 10 through 13 (water quality and ecological studies). Overall, this report evaluates the draft PMP with respect to the adequacy of the proposed scientific methods to address key issues raised in the 2001 NRC CROGEE report and other issues previously raised by the ASR Issue Team.

The Regional ASR PMP clearly responds to issues identified earlier by the South Florida Working Group ASR Issue Team and later by the CROGEE. The report recognizes the importance of acquiring information through the proposed Regional Study to resolve or better understand the issues that are involved with the consequences of implementation of ASR regionally in south Florida at the unprecedented scale of 1.7 billion gallons per day. The PMP goes a long way to providing the needed information. It is comprehensive, for the most part, and is integrated well with the pilot ASR studies. The authors of the document should be commended for the effort that went into producing the plan and for the comprehensiveness of the proposed study.

The most important overall improvement to the document would be a greater attention to the CERP principle that “each incremental step [be] viewed as an experiment accompanied by one or more hypotheses that predict how that step will improve the system” (USACE, 1999), a concept generally termed adaptive management. Some of the task descriptions suggest that the study will be conducted as a relatively routine engineering exercise rather than a comprehensive and integrated scientific study to “investigate regional technical and regulatory issues governing the feasibility of full-scale ASR implementation…and develop tools to assess the feasibility and increase the level of certainty of successful ASR implementation,” which is the stated objective of the study. This structure is of some concern given that results of the regional study may show that ASR at the scale being proposed is not feasible due to hydrogeological, geochemical, ecological, or other reasons. In such cases, the proposed plans to (1) apply the model (or collect the sample), (2) collect the results, and (3) move on to the next task will not be appropriate. Additional advanced consideration is warranted concerning what to do if the results of some phase(s) indicate that ASR, as originally planned, will not work.

The regional modeling described in Task 9 may come closest to this ideal; in this task the plan specifically discusses multiple model runs for a range of alternatives (in terms of well locations and numbers). Likewise, the flow chart of Figure 3, which shows “adaptive feedback” loops between water quality, ecological, and toxicological investigations, is a useful tool that might be more broadly applied elsewhere in the report. The PMP acknowledges the need for some flexibility in modification of the plan if early results warrant changes, and this is



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