Subj: Public Comment on Everglades Strategic Plan Date: 6/14/00 6:34:56 AM Eastern Daylight Time From: JamInfo (John Arthur Marshall Info) To: RSalt@SFRestore.org, LDahl@SFRestore.org To: KBurger@SFRestore.org, JFanjul@SFRestore.org To: LFriar@SFRestore.org, AChildre@SFRestore.org To: CBeeler@SFRestore.org, mbansee@sfrestore.org To: Dick_Ring@NPS.gov, Bonnie.Kranzer@SFWMD.gov To: Ernie.Barnett@DEP.State.gov To: Neal.McAliley@USDoJ.gov, WDalty@SWFRPC.org To: FDuke@Co.Palm-Beach.FL.us To: Toy.Keller@DCA.State.FL.us CC: Bruce_Babbitt@ios.doi.gov, Mary_Doyle@ios.doi.gov CC: Senator_Voinovich@Voinovich.Senate.gov CC: Rich_Worthington@Voinovich.Senate.gov CC: Bob_Graham@Graham.Senate.gov CC: Senator@Boxer.Senate.gov CC: Becky_Liner@Graham.Senate.gov CC: Cathrine_Cyr@Graham.Senate.gov CC: Connie@Mack.Senate.gov CC: Nilda_Rodriquez@Mack.Senate.gov CC: CK_Lee@Mack.Senate.gov The Arthur R. Marshall Foundation & The Florida Environmental Institute, Inc. Everglades Restoration & Preservation in Perpetuity 12 June 2000 The Honorable Bruce Babbitt, Secretary of the Interior Attn: Mary Doyle, Chairwoman, South Florida Ecosystem Restoration Task Force United States Department of the Interior 1849 C Street, NW, Washington, DC 20240 Dear Chairwoman Doyle; We recommend that the Secretary of the Interior exercise leadership by mandating immediately, the use of accepted commercial and govt system standards, to outline overall system development of an Everglades Ecosystem Restoration Strategic Plan acceptable to Congress. This will lead to baselining system requirements and specifying targets top-down, using a govt performance & results approach, widely appreciated by Congress and the public. Lack of a coherent approach in the strategic plan being developed for delivery to Congress 31 July 2000, will have a major impact on impeding Congressional approval. The attached point paper defines. As we expressed to your predecessor, from time to time, our views on Greater Everglades Ecosystem concerns, we continue here by providing comment on the DRAFT Strategic Plan, as a reality check. We appreciate that a person familiar with the politics and science of the South Florida Ecosystem has now taken up the awesome responsibility of leading the Everglades restoration effort in the proper direction. We also find your testimony of March 1, 2000 a fine "opening" statement, and fully support moving in the direction you have outlined, smartly and quickly with as little delay as possible. The time to act on the recommendation is now! Revisions to the plan, attached, as suggested by Mr. Gene Duncan, Miccosukee Tribe Representative; The ARM Foundation; and the Environmental Advisory Committee provides a basis for acting. We are all for a Strategic Plan, knowing that with the proper perspective, this could be revised in a fortnight. We hope this information will be helpful in restoring leadership to the restoration process, as my late Uncle Art would have done it. Advanced Copy //s// John John Arthur Marshall President/CEO Attachments as noted (-) ------------------------------------------------ On Developing a Strategic Plan for Everglades Restoration, Preservation & Protection RECOMMENDATION: The Secretary of the Interior must exercise leadership by mandating immediately, use of accepted commercial and govt system standards, to outline system development of an Everglades Ecosystem Restoration Strategic Plan acceptable to Congress. This will lead to a govt performance requirements & results approach (GPRA), and overall system specification thereof, top-down, widely appreciated by Congress and the public. Lack of such an approach in the draft strategic plan being developed for delivery to Congress 31 July 2000, will have a major impact on impeding Congressional approval of a concept study & demonstration plan. General Accounting Office (GAO) reports referenced are germane. The following points amplify: A system development process is driven by system performance requirements & results, including specification, test & evaluation thereof, per ref [1], as outlined by attachment 1 (A-1). "Performance requirements" & "System specifications" are critical terms that require definition that is quantifiable. Yet these critical terms provided by A-1 are MIA. The terms that are used in the draft strategic plan include: · Goal · Subgoal · Output · Output indicator · Target All these terms are moving in the direction of "requirements" & "specifications" but are not getting there fast enough for a 31 July 2000 delivery of an acceptable plan, thus the strong recommendation to mandate standards now. Another group working independently of the Strategic Planning Team uses the terms: · Endpoints · Metrics · Expectations (See Footnote 1) In order for these two groups, working independently, to understand each other, excessive man-hours must be expended briefing definition of terms, because by internalizing (failing to consider standards) the groups reinvented accepted language provided by standard terms and definitions, rather than externalizing (considering standards for executing process cost-effectively). Many groups working independently (SCT, AET, ADT, AAT, RECOVER, SPT, WG, etc) have reinvented the wheel of many lessons-learned the hard way, adding confusion and expense to the process. Thus the recommended approach is that of the American National Standards Institute (ANSI), and DoD/Govt guidelines which also call for use ANSI standards, such as ref [1]. This provides the basis for a top-down approach to integrated ecosystem performance. The bottom-up approach is not working; it has produced confusion in a process that is out of control. One message of this point paper is that Congress does not have time to learn a new language, nor should one be perforced on them. Many Congressional staffers fully understand the system requirements and specifications approach, as it is the lead-in to Title 10 USC test & evaluation (T&E) mandates to verify that specified performance requirements are met, using a govt performance & results approach (GPRA). Putting the process in the ANSI standard format (A-1), and evolving a Strategic Plan based on a system requirements list, clearly baselined, from which progress can be determined by direct comparison of results to target requirements specified; this is the best chance for a Plan that will result in Congressional buy-in made easy. A doctrinal approach begins with of broad goals and needs statements which are then translated into thresholds and objectives or measurable targets. These are then transformed into performance requirements which become system specifications for detailed design. Broad goals and objectives are well stated in the C&SF Programmatic Environmental Impact Statement (PEIS), page 5-21, ref [2] and in the C&SF "Overview" page 15, ref [2a]. However these broad goals and objectives have yet to be translated into clearly delineated system performance requirements & specifications, referenced to established baselines, also yet to be fully defined, for example: Goal #1 of PEIS: "Increase Total Spatial Extent of natural areas" - by how many acres, referenced to what baseline (acres)? Goals are the foundation for the house to be built. Numerous GAO reports [3] - [6]. provide helpful hints on moving process (activity) in the direction of product performance per [1]. GAO/RCED-99-121 [3], notes "An Overall Strategic Plan and a Decision-making Process Are Needed to Keep the Effort on Track." This report specifically recommends a plan "that will outline how the restoration will occur". The Strategic Planning Team converted this into "how the restoration effort will occur" focusing on process activity rather than process product (end result). GAO also reports that "A Land Acquisition Plan Would Help Identify Lands that Need to be Acquired" [4]. Such an approach should be needs & requirements (goals & objectives) driven, based on an established baseline (acres), by which progress can be measured over time. However Goal #1 has been de-emphasized, when it ought to be a prime requirements driver for a strategic land acquisition plan that considers cause and effect requirements that relate to natural filter area need to achieve phosphorus level requirements of P = 10 parts per billion. "Acquire 607K acres" is a concept or broad need, not a plan. A GAO report on "Managing for Results" notes that "EPA Faces Challenges in Developing Result-Oriented Performance Goals and Measures" [5]. The report urges agencies to move from a focus on process activity to a focus on product, by establishing end results. This is also known as specifying requirements to meet a need [1], i.e. getting to a target of P = 10 ppb, based on science, traceable to a reference document, with the requirement target defined by a bell curve, per [6]-[8]. See footnote 2. Adaptive management, widely espoused as a means of corrective action, also remains a concept, in what is known in the standards world (and to many Congressional staffers) as a "concept study and demonstration plan" appropriately referred to as a re-study. A GAO report on "MANAGEMENT REFORM" [6] calls for the Results Act [GPRA] and total quality management [TQM] to improve federal performance, suggesting a move away from a preoccupation with activities to a greater focus on the results of those activities. TQM is the key to adaptive management. Ref [6]-[8] notes that TQM requires the demonstrated and clear commitment of agency top leadership. Thus we call on the Secretary of the Interior to do the honorable thing by acting on our recommendation, per ref [6]: Top leadership of each federal agency needs to meld these various reforms in to a coherent unified effort; What has been outlined here is the framework for a unified effort to integrate Everglades restoration, preservation and protection, per WRDA/NEPA. Recommendations to move in this direction were also provided in public comment, not limited to detail attached. This includes a shell of a "Strategic Plan" one page executive summary, provided in public comment per A-5 & A-6, for Congressional approval of an Everglades restoration Strategic Plan, and authorization, and appropriation of same, by reflecting that restoration can be (or is being) executed in a cost-effective manner. Public comment is not given due consideration, either, hence the recommendation to add to WRDA 2000 language: After… "opportunity for public comment" - ADD - "and due consideration thereof"…. ------------------------------------------------- Footnote 1: Use of the term "expectations" - per A-1 standards, page 37, has activities comparing the established requirements baseline against customer expectations. In the current Strategic Plan, lack of baselines is a major deficiency; "internalized innovation" does not get to recognition that Congress is the customer, and approval demands that Congressional customer expectations must be in a language the customer understands; externalization is needed. Footnote 2: TARGET is a key defining term here. By TQM definition (Deming), TARGET is the average or expected value = mean of a normal distribution = bell curve; A TQM approach comparing requirements with results is USA(COE?) & DoD Doctrine, per refs [7], [8]; DoD subsequently mandated this in SD-15 Performance Specification Guide. The key to adaptive management is recognizing and controlling variation; TQM provides the approach & methodology to do so. Final Footnote. This is being forwarded in plain text, slightly modified, to avoid the difficulties of down-loading attachments, related viruses, etc. If you want the "original" with underlining/bolding, etc., reply and you will be sent the attachment form. JAMinfo@AOL.com ------------------------------------------------- REFERENCES AND APPENDIX LIST REFERENCES: [1] Standard for Application and Management of the [Eco]System Engineering Process; Trial use standard dated Sept 26, 1994. See Appendix 1 (A-1) for excerpts. [2] Central and Southern Florida Project Comprehensive Review Study [Re-study]; Programmatic Environmental Impact Statement, (Vol I); April 1999 [This is a concept study and demonstration plan, awaiting milestone I approval as noted in A- ]; [2a]; C&SF Restudy "Overview"; October, 1998. [3] GAO/RCED-99-121; "SOUTH FLORIDA ECOSYSTEM RESTORATION" - "An Overall Strategic Plan and a Decision-making Process Are Needed to Keep the Effort on Track; 22 April 99 [4] GAO/RCED-00-84: "SOUTH FLORIDA ECOSYSTEM RESTORATION" - "A Land Acquisition Plan Would Help Identify Lands that Need to be Acquired"; April 5, 2000 (GAO water quality report is pending) [5] GAO/RCED-00-77: "Managing for Results" - "EPA Faces Challenges in Developing Result-Oriented Performance Goals and Measures"; April 28, 2000 [6] GAO/T-GGD-99-151: "MANAGEMENT REFORM" - "Using the Results Act and Quality Management to Improve Federal Performance; July 29, 1999. [7] Army Material Command (AMC) Pamphlet 715-16: Program for Continuous Process Improvement; 15 July 1992: TQM: Use TQM Bell Curves to develop system performance requirements, and take data to measure achievement of same. [8] Army Material Command (AMC) Pamphlet 715- 17: Guide to Performance Specification Development: Use AMC Pamphlet 715-16 and ANSI standards as guides to develop performance specifications. APPENDIX LIST A-1: Excerpts of System Standards of ref [1] A-2: Public Comments on Strategic Plan to Col Rock Salt, Execute Director, South Florida Ecosystem Task Force Working Group; Gene Duncan, Miccosukee Tribe, June 2, 2K A-3: Public Comments on Strategic Plan to Col Rock Salt, et al; Arthur R. Marshall Foundation (mass distribution by e-mail) A-4: Public Comment on Strategic Plan by Environmental Advisory Committee; Report of meeting dated June 2, at SFWMD. A-5: "The Art Marshall Plan - [Requirements Driven] Case For Flow-ways"; Public Comment Presentation to CROGEE, 3 Dec 99, and to SFWMD Governing Board 9 Dec 99 (Single page executive summary for Congressional approval make easy is on page 19-20; Same summary was presented in A-6) A-6: Public Comment on C&SF Restudy to USACE/DOI/SFWMD/Congressional Representatives, et al; 7 Dec 98; ARM Foundation (with Attachment 6 only: Public Comment recommending doctrinal system approach, with Single page executive summary) A-7: Arthur R. Marshall Foundation Cypress Tree Planting Project Strategic Plan [outline]; 8 June 2K