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Public Comments on CERP Guidance Memorandum:
Failure to Monitor Atmosphere Impacts

June 6 2005

To:  GMComments@usace.army.mil
 

Dear Sirs,

       The monitoring program of the Comprehensive Everglades Restoration Plan still lacks ANY monitoring of emissions of greenhouse gases and other climatically active gases.

         South Florida ecosystems, in particular the Everglades, are a major natural Hot Spot of greenhouse gas emissions, which are as or more intense than sources in the Amazon Basin, and they vary enormously in response to very small changes in water levels and nitrogen fertilization (Goreau & de Mello, 2002, 2005).

Enormous changes in emissions of greenhouse gases to the atmosphere will inevitably result from changes in water flow and nitrogen loading, which will depend on the precise amount, duration, and timing of hydrological alterations and on the concentrations of nitrogen.

    Because of their complex response, these impacts cannot be easily predicted and must be measured directly.

       The CERP environmental impact monitoring plan includes NO monitoring of emissions of greenhouse gases and other climatically active gases.

       This is a very serious gap in the plan  that must urgently be corrected. Because of the large potential long term regional and global impacts on atmospheric quality these must be monitored just as changes in water  quality are being monitored.

      We request that you immediately remedy this serious deficiency in the plan so that base line studies can be conducted as a benchmark to assess future changes.

   We will be glad to provide  further information on our previous work documenting these impacts and providing recommendations on what is needed to assess them.

Sincerely yours,

Thomas J. Goreau

President
Global Coral Reef Alliance
37 Pleasant Street, Cambridge, Massachusetts 02139, USA

E-mail: goreau@bestweb.net