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COMMENTS ON BROWARD BEACH DREDGE FILL PLAN, SEGMENT II
Permit Authorization No. 0163435-005-JC

November 26 2002 

To:       the Governor and Cabinet of the State of Florida 

The Global Coral Reef Alliance asks the State of Florida to IMMEDIATELY CANCEL Segment II of the Broward County Beach Nourishment Plan, which would irreversibly damage the finest coral reef in East Florida, and the ONLY coral reef in North America than can be swum to from shore. We also ask the State of Florida to immediately officially designate these unique coral reefs as coral reef habitat (which they are not at present), and to give them the fullest possible protection as required by the responsibilities designated to the State of Florida under the Coral Reef Act. 

These reefs are a priceless national treasure, with among the highest live coral cover and fish densities of any US reef, even though they are right in front of a major urban area and at the very limit of their climatic range. They contain the largest known forest of staghorn coral left in the Caribbean region, a species that is severely threatened, as well as hundreds of other huge, ancient corals. This unique reef is the only place in the U.S. where corals and fish can spread northward as global warming continues. This is essential to maintaining and expanding coral reef species in the Atlantic region. 

Dredging and filling ("nourishing") the beach right next to these reefs will certainly destroy them. They have so far survived because they are in the only stretch of east Florida where the coral reefs have NOT been already destroyed by previous beach dredge-fill projects like this one. Pompano, Deerfield, and Hollywood now have only large dead corals, masses of algae, and few fish. Thriving reefs of this kind have been preserved only in the memories of the oldest divers and fishermen. Destroying the incredible and unique reefs of Segment II, a priceless heritage for naturalists, fishermen, divers, and snorkelers, would be like burning the last giant redwood grove in the name of roadside brush clearance. We appeal to the State of Florida to prevent the thoughtless and irresponsible destruction of these priceless reefs and to preserve them forever for their critical biodiversity, recreational, fish nursery, and shore protection importance. 

The claim that filling the adjacent beach could not possibly affect the reef just offshore is false; as experience with dredging projects around the world has repeatedly shown. The Jamaican reef on which I learned to swim--the first in the world to be studied by diving scientists where the depth patterns and the habits of coral reef creatures were first described, and the first reef to have had a management plan prepared for its protection as a marine park--was destroyed by dredging before that description could even be published. 50 years later, there is nothing there but a barren wasteland.  

Please don't let this happen to your reef. 

Although I have personally dived in the finest coral reefs all around the Caribbean, the Indian Ocean, and the Pacific for nearly 50 years, I was astonished to see coral reefs so rich in ancient corals and rare coral species, swarming with huge clouds of fish, right in front of a major city, far to the north of where all coral reef scientists believed the reefs ended. Although these fabulous reefs were long known to Broward County divers and fishermen, they were unknown to the rest of the world. Florida is incredibly fortunate to have accidentally preserved this unknown treasure, and to have the privilege to protect them forever. 

There is no place else in North America where one can swim from shore and be surrounded by fish and corals. There is no better place in Florida for people to see and learn the beauty and importance of coral reefs, Florida's unique heritage. Broward County should be building its long-term diving, boating, and fishing tourism programs around the protection of these unique reefs, which are protecting the shore and generating significant revenue and benefits to the ecosystem. 

Besides being environmental insanity, the project makes no economic sense. A recent economic study by the State of Florida showed that Broward County, not Monroe County, earns the highest revenue from coral reef diving and water sports. Once these reefs are gone, the beaches will be unprotected, and will need to be filled again and again, at vast cost, since there will be no more locally available sand. Destroying this long-term value for millions of people in order to temporarily enrich a few dredgers and consultants is the height of irresponsibility.  

We appeal to the State of Florida to reject this short sighted proposal. Your children and grandchildren will never forgive you if you allow this irreplaceable treasure to be destroyed. 

There are numerous inaccurate or false claims raised in the application for the dredging permit about the nature of these reefs, the effects dredging would have on them, and the "mitigation" that is proposed, which need to be refuted and rejected. These include: 

1) The permit claims that the area is not an Aquatic Preserve.

This is true only because, through an unfortunate error, Florida has not yet lived up to its responsibility under the Coral Reef Act to designate the area as a coral reef and to protect it. If the permit is granted the reef will be damaged to the point that there will be no reason to declare it an Aquatic Preserve. It will become, like all the rest of the East Florida reef tract, a totally destroyed marine environment. 

2) The permit further states that because the project is not in an aquatic preserve there is no need to prove that the project is "in the public interest", only that it be "not contrary to the public interest".

Destroying the best near shore coral reef in Florida is certainly "contrary to the public interest". 

3) The permit claims that there are "No Outstanding Florida Waters" involved, and therefore no reason not to award the permit.

As we have shown above, in conservation terms this area is in fact probably THE MOST OUTSTANDING FLORIDA WATERS 

4) The permit claims the applicant "has given reasonable assurance that the proposal will remain under essentially natural conditions, will not significantly impact fish and wildlife and other natural resources".

This is false in all regards. The corals will largely be killed, and the swarms of reef fish that live in in those coral, the only such habitat in East Florida, will vanish. 

5) The permit further claims that not only is the project "not contrary to the public interest", "restoration and nourishment of critically eroding beaches is in the public interest".

This assertion is false with regard to Segment II because there has been little or no beach erosion in the entire segment that is protected by a living reef. The beaches that are subject to critical erosion all lie in other parts of the County where the living coral reef was killed by previous dredge-filling of beaches, thereby making their erosion worse, or where the erosion is caused by building of jetties and groynes that have prevented the natural replacement of the beach sand by long-shore drift from the north, and where sand-bypassing would be the best and cheapest solution. 

6) The permit makes gross errors in describing the near shore hardbottom communities and the impact of the project. It claims that "Broward County coastal systems are depleted in scleractinian coral fauna (i.e. major reef builders)".

Following the destruction of East Florida reefs by previous dredge-fill projects this is now sadly true EVERYWHERE EXCEPT IN SEGMENT II, the subject of this permit. 

7) The permit further claims that "Few areas of hardbottom in Broward County have a cover by reef-building corals of more than 2-3%.

Again this is true EVERYWHERE EXCEPT IN SEGMENT II WHERE THERE ARE MILES OF REEF WITH NEARLY 40% LIVE CORAL COVER. 

8) The permit admits that Segment II has areas of staghorn coral, but dismisses this by describing the species as "opportunistic" and "not considered to be a primary reef-building coral".

These claims are disingenuous at best. Staghorn coral was formerly one of the most abundant corals throughout the Caribbean region but has practically vanished almost everywhere and it is now regarded as highly endangered. SEGMENT II HAS THE LARGEST STAND OF STAGHORN CORAL NOW KNOWN ANYWHERE IN THE CARIBBEAN REEF REGION. This is of crucial importance under the Endangered Species Act. 

9) The permit claims that in some areas live coral coverage reaches "as high as 7.4%", as if this were a single isolated case.

This again is a serious misrepresentation. Segment II has miles of reef with 30-40% live coral cover, or more. 

10) The permit further claims that the "mean stony coral cover at the 23 (official Broward County monitoring) sites in January/February 2001 was 2.25 + 3.41 %.

This only indicates that their monitoring sites completely failed to include any area of the miles of good reef to be found in the area. 

11) The permit claims that "scleractinian corals are not a major component of the epibenthic communities on the nearshore and offshore ridges along southeast Florida".

In the same paragraph it claims that "the richest patches of scleractinian cover are generally located on the offshore ridges.

Again this is not true: the highest live coral cover is on the INNERMOST ridge of reef 1, the reef closest to the beach to be filled, and the area which will suffer the worst effects. 

12) The permit curiously claims, in contradiction to all the previous claims that there are almost no corals to be damaged, that "In some areas favorable for coral settlement and growth, scleractinian coral cover can be as high as 25-30%".

Again, this is an underestimate, and fails to point out that the area concerned is the nearest reef to the beach--and completely unique in all of Florida. 

13) The permit further claims that these areas are safe because they are 700 feet away from the edge of where the dredge-fill will be dumped.

This ignores the fact that the dredge-fill sediments will be carried by waves and currents, especially during the hurricanes that are an unavoidable fact of life in Florida. This will bury and kill corals just as happened to all the nearshore reefs along every area of East Florida beaches that were dredge-filled in the past. The fact that "Two monitoring sites have been added within this area of significant coral cover" only tells us that after these reefs are seriously damaged by sediment we will know why the coral died. This is insufficient insurance against damage to the reef. 

14) The permit includes a "Mitigation" plan that is bogus in every way. It is proposed to dump 4.5 acres of large boulders, 4 to 6 feet in diameter, inshore of the natural hardbottom and offshore from the fill.

This places the boulders in the surf zone of highest turbidity, where they will be most affected by re-suspended sediments as the fill migrates seaward due to wave and current action.

It is further claimed that these boulders will make up for all loss to the natural coral reef.

 However previous efforts to use this technique in John Lloyd Park were a disastrous failure. Since the boulders were largely buried in the sand migrating away from the beach fill, coral settlement on them was minimal due to turbidity. 

15) The permit claims that these corals will "create bottom cover by coral of about 3%", to be contrasted with up to 40% in the areas that would be damaged.

This is like bulldozing a forest, turning it into a parking lot, and planting some geraniums in a pot in the name of "mitigation". 

16) The permit proposes that "approximately 1,000 to 1,200 corals greater than 15 cm in diameter will be translocated from the Segment II impact areas to the mitigation reefs".

Taking corals from an area being damaged by high sediments to an area nearer the shore where the turbidity is higher, will simply be condemn these corals to death; even if they survive being broken off the bottom and cemented onto the boulders.

Corals to be transplanted make up only around 4% of the nearly 25,000 corals that are estimated to be buried by the project even if the fill does not move. As a consequence, 96% of the corals can be expected to die. Since most of the corals to be broken and recemented onto boulders are low and flat, many of them will be seriously damaged by the process. 

17) The permit states that "the created coral community will also be the subject of a long-term monitoring program to document survival and growth of the translocated corals".

There is a long and disastrous history of this kind of bogus artificial reef restoration that strongly indicates that more corals will be killed under false pretenses. A recent report to the National Coral Reef Taskforce, discussing similar efforts by the National Fish and Wildlife Service, shows that around 85% of such projects failed. The major reason was excessive turbidity and nutrients—typical characteristics after dredging.

 In summary, this irresponsible permit should be revoked because it would irreparably destroy the only remaining good nearshore shallow reef in North America. The area should be immediately designated a Coral Reef Habitat by the State of Florida and be provided the fullest protection required by the Coral Reef Act.  

More than this, the unique location and character of this reef demands protection as a National Monument, National Marine Sanctuary, or Biosphere Reserve, similar to that of the last Giant Redwood groves. These reefs are the only survivors of 10,000 years of reef history in East Florida. They are a priceless treasure that must be saved for future generations, not destroyed for the short-term benefit of a handful of dredgers and their consultants. There will be no second chance to save them if this environmentally and economically destructive permit is granted.  

            Sincerely yours, 

Thomas J. Goreau, Ph.D.
President, Global Coral Reef Alliance