June 27, 2002

Comment Clerk for the Watershed Initiative Competitive Grant Program

Water Docket (W-02-05)

Environmental Protection Agency

Ariel Rios Bldg.,1200 Pennsylvania Ave. NW

Washington, DC 20460

Re: Federal Register: May 23, 2002 (Volume 67, Number 100)

DOCID:fr23my02-55

Environmental Protection Agency [FRL-7216-9]

Process for Designing a Watershed Initiative

Ladies and Gentlemen,

The Southwest Florida Watershed Council was organized just over a year ago as a stakeholder's group to examine water resource issues and to create and implement effective long-term strategies to address the needs of this region's growing population and the natural systems upon which our economy and quality of life depend. The Council is a grass-roots, multi-county coalition of individuals, elected officials, organizations, agencies and businesses that have come together to address the issues affecting the Caloosahatchee and Big Cypress watersheds.

We are writing to provide comments and suggestions on the potential design of the EPA's new Watershed Initiative. Our recommendations stem from our belief that the EPA needs to make a special effort to target genuine community groups in order to accomplish tangible outcomes that will truly improve watershed management efforts in our nation.

We do not want to see watershed projects nominated by State Governors or Tribal Leaders. Rather, we believe that any organization that wishes to nominate a watershed project should be able to do so directly to the EPA. No limits should be placed on the number of watershed projects in a given area that could be funded through this grant program – watershed projects that are funded through this effort should be the top twenty candidates, no matter what their geographic location.

When setting the criteria for the selection of watershed projects, there must certainly be a focus on success, but we are disturbed by the proposal to give preference to nominations that have substantially completed planning for projects and are ready to begin. Planning requires funding,

The mission of the Southwest Florida Watershed Council is to protect, conserve, manage and/or

restore the land and water resources of the Caloosahatchee and Big Cypress Watersheds through participation and cooperation of all stakeholders in consensus building, planning, and decision making to meet the

economic, natural and cultural needs for this and succeeding generations.

and most genuine community groups have extremely limited amounts of funds available for this type of work. Projects which are already underway (by virtue of having completed the planning process) are very likely projects which are also either already partially funded or are eligible for other types of funding. While they are certainly worthy for consideration, they should not receive priority ranking. The likelihood of success can be satisfactory demonstrated in many ways – through documentation of stakeholder partnerships; commitments from local, regional, state and national interests; establishment of both short-term and long-term project objectives and performance standards, along with evaluation criteria; development of a plan to extend the project (or components thereof) to other watersheds; integration of the project with ongoing watershed management programs, etc.

Lastly, we would like to see the nomination process for this program include a pre-application component. We expect that the EPA will receive a tremendous number of applications for this program. A pre-application process would allow all interested entities to submit watershed projects for consideration without going to the expense of preparing full-scale applications. Only those entities submitting project applications which make it through the first round of evaluation

would have to go the expense of preparing full applications. This would allow EPA to avoid wasting $2,500,000 (approximately 10% of the grant amount) in national resources by consuming the limited talent and time of many groups throughout the nation who will invest thousands of dollars through either paid or volunteer human resources assembling a full project application (50 states x 10 proposals per state x $5,000 value per proposal).  Without a pre-application process, the EPA would be structurally favoring the organizations that already have the excess capacity to allocate human resources to the proposal development process.  This would not be in accord with the stated objectives of the EPA program. 

Thank you for giving us the opportunity to provide input into this important program. We wish you well in your work to design this new watershed management initiative.

Sincerely,

Noel Andress, Chair

Southwest Florida Watershed Council