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From: Etichscuba@aol.com Date: June 1, 2006 9:33:16 AM EDT To: cwilkins@ameridive.com Chris, I hope you don't mind my sharing the letter you wrote last month to the EPA with the local dive operators and the response you received from NOAA. I think your letter articulates the concerns and frustration shared by all who make a living from, enjoy and are outraged by the preventable destruction of Palm Beach County's reefs. Something we have all witnessed first hand. I am also writing this letter to counter what I perceive to be misrepresentation of Reef Rescue investigations. I have presented below: 1) your original email, 2) the NOAA letter and 3) my comments. Thank you for sharing your concerns and understanding of threats to our coral reefs and bringing it to the attention of the regulatory community. Ed Palm Beach County Reef Rescue 561 699-8559 Letter from Chris Wilkens, AmeriDive Scuba, Boynton Beach, FL to EPA To All Concerned: Why are we wasting taxpayer dollars making a determination as to whether the current moves north or south for any specific period of time? We already know the answers to these questions. Ask any diver or boater in Palm Beach, and they will tell you "the current moves North 95% of the time." Thus, we earned ourselves the name "Drift Diving Capital of the World." Gee whiz guys, I wonder why that is??? I am sure that there are sat pics and daily Gulfstream reports that can present "a view over time" that would fix the normal Gulfstream/Inshore current as northbound. I personally would like to save the money. I wonder how the other taxpayers feel? I wonder what it takes to show a stall tactic for what it is? As to the dye tests: we already know via global/sat pics where the current goes and how it "disperses" the inlet waters and outfall effluent. I fear, as most divers do, that all the political mumbo/jumbo and political maneuvering will NOT get the job done when it comes to saving our reefs, and what we need to do is kick some political butt. We do NOT have the luxury of time of sitting around and waiting for NOAA to get their dye tests into the water, whilst partially treated effluent continues to be dumped and pumped onto the reefs. How many reefs have to die before we get the message? The keys are dead. They said so themselves. And here we sit on one of the last, and probably most viable, reefs in the United States and we are playing games!!!!! The mentality that exists within the many of the coastal towns is "we (meaning the political representatives of "the people") will do whatever we want - even though we see that what we are doing may be harmful to the environment." Case in point: the beach "re-nourishment" that just took place. What an ugly disgrace to our community: - Permissible turbidity levels were exceeded over and over again. Yet they continued.... - The salinity of the sand is different and the turtles will not nest in it - proven fact courtesy FAU turtle nesting/monitoring personnel. - Casino, Horseshoe, Fish Bowl were BURIED. I went there. They were BURIED under a thick layer of silt/sand/debris. - Lake Worth beaches were closed because the turbidity was so bad the lifeguards could NOT SEE. Is that within the permissible levels? - Dredging continued during the beginning of the turtle mating season, and they were allowed to chop up numerous turtles per day in their quest to put sand on the beach. By the way, who oversaw the dead turtle count? Who? Where are the stats, and how was the collateral turtle damage assessed? If the county issued the permit, then it was there responsibility to put in place a person/system to ensure compliance. Where is it? By the way, many of those turtles were tagged and part on a long, and difficult study currently taking place. Anyone check with the scientists in Juno first? Were any tags recovered so that they studies can take that into consideration? I find it ironic that it is a $10,000 fine to harass a turtle, but in the name of sand, we can kill a few endangered species here and there. After all, we need our sand on the beaches. I am very sure that it is against the Federal Law. I assure you, had this been a MANATEE it would not have happened. Guaranteed. By the way, this sand that will be blown away with the next hurricane or next several storms. I give it one season. That is because it is an artificial coastline and the tides, currents, underlying reefs and winds don't support it. Nature will have her way - I assure you. What a waste of money!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!! What a waste of environmental resources!!!!!!!!!!!!!!!!!!!!!!!!! Is anyone as angry as I am about this? I want my children to experience the reefs, but at this rate, it will not happen. Either we get serious, or, we take great movies. Choose. Chris Wilkins AmeriDive Scuba Center NOAA response to AmeriDive letter: Hello: My name is Dr. Thomas Carsey and I work with Dr. John Proni at NOAA/AOML. The following is a letter he wrote in response to a comment (attached) by an individual [Chris Wilkens] concerning the governmental response to the problems on Gulf Stream Reef. Dr. Proni is on travel until 14-June, but I can answer any questions you might have on the letter. Regards, Thomas Carsey ------------------- As I indicated earlier, I am always pleased to hear from citizens who have an interest in the coastal environment. Indeed, concern for the coastal environment with its beautiful coral reefs should be shared by all the citizens of south Florida. Concerned citizen-divers have observed the presence of algae on the Gulfstream reef. It has been suggested that these algae have appeared because of the presence of nutrients contained in the treated wastewater effluent plume emanating from the South Central outfall. The citizen writer of the email you forwarded focuses on the ambient currents present in the general area of the reefs and outfall and on dye tests. The writer expresses his dismay over the perceived condition of the coral reefs in the Florida Keys and is concerned that the reefs in the waters off southern Palm Beach County may die. The writer questions why it is that ambient current data will be gathered, in an upcoming study of the South Central effluent plume, when "we already know the answers" (to the question) "as to whether the current moves north or south for any specific period of time?". I believe that as responsible scientists, it is our obligation to provide the best possible scientific data and analysis to environmental managers and permit writers. What follows is written with that obligation in mind. A specific question which the study to be carried out by the Atlantic Oceanographic and Meteorological Laboratory (AOML) has been asked to address is whether the effluent plume from the South Central outfall reaches the Gulfstream reef. The thrust of this question deals with the exposure of the Gulfstream Reef to the effluent plume. The formulation of this question, as well as others, was done in cooperation with personnel from the Florida Department of Environmental Protection (FDEP). Clearly, understanding the possible exposure of the reef requires a thorough understanding the transport of the effluent plume by ambient currents. To understand the where the ambient current might transport the effluent plume, ambient current measurements, i.e., speed and direction, must be made over the entire water column (top to bottom), and the measurement period of such currents should extend over at least one year (preferably at least two years). The currents must be measured frequently, e.g. at least hourly for 24 hours per day. Furthermore, the ambient currents should be measured at several carefully chosen locations, e.g. one in the area of the outfall and one near the northern end of the Gulfstream reef, concurrently and continuously. We need the data from two current meters to see if the current deviates in going from the outfall to the northern part of the reef. There appears to be very little ambient current data recorded in the vicinity of the Gulfstream Reef. The group Reef Rescue has made some ambient current measurements at various sites in the general area of the Gulfstream Reef. In the time period August 16, 2005 to December 6, 2005 the group lists eleven ambient current measurements in a document entitled Boynton/Delray Coastal Water Quality Monitoring Project. Of those nine current measurements (see the attached Table) four indicate a southward directed ambient current (44%), and five (56%) indicate a northward flow (although one measurement indicates a "negligible" northward flow). Past studies at other locations in Broward and Miami-Dade coastal ocean waters have shown that several different current regimes can exist in coastal waters; these regimes include (1) a westerly meander of the Florida Current so that a particular coastal site would experience northward flow, (2) an eddy flow wherein northward, westward, southward and eastward flow may be experienced in approximately the sequence indicated, (3) a tidally controlled flow, (4) a wind driven flow and (5) storm flows. Other flows may occur as well and while tidal effects are always present they may not dominate the current field. So while the writer's comments on currents are based on valuable field experience, to proceed in a scientific manner, quantitative measurements of current speed and direction are needed throughout the water column for extended periods of time at different locations. From those data we may determine the percentage of time that the current flows northward at the reef over the course of a year, and the duration of time of a given northward flow event, and obtain a quantitative understanding of the extent of reef exposure from the outfall plume. The writer also comments as follows "As to the dye tests: we already know via global/sat pics where the current goes and how it ‘disperses’ the inlet waters and outfall effluent." However, we believe that tracer studies such as with dye or sulfur hexafluoride (SF6), interpreted with an understanding of the ambient ocean currents, provide the most unambiguous understanding of the impact of the outfall on the reef, especially when compared to satellite-derived data. The presence of the tracer provides a quantitative determination of whether a particular water sample does or does not contain water which emanated from the outfall. Beyond this, dilution estimates as a function of range from the outfall (or, prospectively, the Boynton inlet) may be made from the tracer data. Dilution is fundamental in exposure considerations. Furthermore the presence of a tracer in a water sample validates the measurement of other parameters, e.g. nutrients or ammonia, as being made in effluent originated water. The spatial resolution and water penetration of satellite measurements sometimes inhibits their utility for dispersion studies, particularly in areas where land features are included. Perhaps the writer would care to receive information on a novel program carried out by AOML to protect coral reefs while a major dredging program was undertaken in the port of Miami. In this program, real time measurements of ambient currents were used to guide when dredged material disposal in the coastal ocean could occur and when it could not. This pioneering project was an early example of "adaptive " discharge wherein the condition of the ocean currents, measured in real time, was used to actually control discharge so that plumes of material from the discharges would not be transported towards coral reefs. J. R. Proni T. P. Carsey ***************************************************************************************** Reef Rescue response: The referenced Reef Rescue ambient current measurements were not performed as a statistical analysis of current characteristics. The sample size (nine observations), as I’m sure all would agree is too small to draw any meaningful conclusions. The EPA points out “the SEFLOE II study reported north current flow occurs approximately 60% of the time in Broward and Miami-Dade coastal ocean waters. [Palm Beach County outfalls were not included in SEFLOE II studies.] Irrespective of which current regime was predominant, current direction was generally the same at all depths, based on water column profiles. Slight variations in current speed occurred throughout the water column, with higher speeds occurring near the ocean surface. It is important to note that in reality the effluent plumes do not disperse equally over a circular area, as implied by the circular mixing zone calculations used by the SEFLOE study, but are instead dispersed by the strong Florida Current to form an extended plume, whose longest dimension is aligned with the northerly flowing Florida Current. It is not known what would happen if the northerly current flow were to weaken or disappear. It is probable that, for such a major change in the Florida Current to occur, there would have to be major changes in ocean circulation elsewhere as well.” Reef Rescue presented a more definitive current analysis in it’s February 2004 report based on 279 observations (May 1997 to January 2004, between 26 26 00 N, 80 03 00 W and 26 38 00 N, 80 01 50 W) and found the current to be north, in the vicinity of Gulf Stream Reef 73.9% of the time. The focus of the above NOAA referenced Reef Rescue study was to investigate nutrient levels in and around Gulfstream Reef and the South Central Wastewater Treatment Plant’s ocean outfall pipe (Delray outfall). Nine separate sampling episodes were conducted from August 16, 2005 through November 8, 2005, representing a total of 104 water samples collected from between Seagate Reef, Delray Beach, northward to the Boynton Beach Inlet. Results of that investigation demonstrate nutrient enrichment of the coral reef habitat down current of the sewage outfall pipe during north current events at levels sufficient to support the observed Lyngbya bloom. Conversely, during south current events nutrient levels north of the outfall were found to be at background levels. In an April 28, 2006, review of the Reef Rescue data to Richard Walesky, Director Palm Beach County Department of Environmental Resources Management, Dr. Brian Lapointe concluded “there is evidence to argue a nutrient contribution from the Delray Beach ocean outfall on Gulfstream reef during northerly current periods.” "Additional evidence exists to support the hypothesis that nitrogen derived from sewage is supporting alagl blooms on Palm Beach County's reefs. We [HBOI] have used stable isotope values in reef macroalgae and cyanobacteria... to identify the source of nitrogen supporting algal blooms in coastal waters, i.e. sewage..." I understand, FDEP has already commented ” From what I've seen of the Reef Rescue monitoring data, it doesn't really tell you anything” If that is in fact a conclusion based on four months of water samples representing over 300 individual chemical analyses, I wonder how they view the NOAA study based on two tracer tests? For the last year I’ve watched from the sidelines, withheld comment and witnessed the arduous attempt by the FDEP to drag the Delray/Boynton sewer plant into the 21st century. It has been over 30 years since the federal “Clean Water Act” was passed. The most basic tenet of which is for the permit applicant to demonstrate no unreasonable degradation to the receiving environment; something Delray/Boynton has never done. As we sit here in the 21st century the coral reefs of the world are dying, some recent estimates predict most will be gone by 2020. The Florida Keys have lost 97% of their Acroporid corals in the last 20 years. In May 2006 two Acropora corals were added to the “Endangered Species List”, one of which; Staghorn coral, is found in the down current effluent sewage plume on Gulf Stream Reef. The Delray/Boynton sewer plant has attempted to blame the down current Lyngbya algae bloom on everything from global warming to a lack of algae eating fish. Even in their efforts to focus attention away from themselves, Robert Hagel, Executive Director of the sewer plant in November 2005 correspondence to the FDEP touches upon the truth and states “Coral reef systems are highly oligotrophic and potentially vulnerable to changes resulting from nutrient enrichment.” [Oligotrophic: any environment, which offers little to sustain life. This term is usually used to describe bodies of water or soils with very low nutrient levels.] Coral researchers have known for decades the devastation even trace amounts of nutrient pollutants can cause in the coral reef environment. Dr. Thomas Goreau, writes: these values are extremely low levels, almost undetectable, in coastal waters. In recent years we have learned just how low nutrients must be to maintain healthy coral reefs. Two researchers working on opposite sides of the globe found the same limits independently. Dr. Peter Bell and Dr. Brian Lapointe independently determined exactly the same limit for acceptable nutrient concentrations. Biologically available nitrogen (nitrate plus ammonia) needs to be below 1.0 micromole per liter (less than 14 parts per billion), and biologically available phosphorus (orthophosphate plus dissolved organic phosphorus) needs to be below 0.1 micromole per liter (less than 3 parts per billion). The Delray/Boynton sewage outfall discharges close to 2000 lbs./day of nitrogen into the local coral reef ecosystem. No amount of study can change this fact. When treated wastewater effluent from the plant is sold for golf course irrigation it is touted for its ability to make grass grow greener. It is absurd to think something other will happen when this waste is discharged into the ocean. The continued expenditure of tax payer dollars to research if the Gulf Stream flows north or if sewage makes plants grow is not intended to further science or develop a better understanding of how to protect coral reefs. Rather there is a cost benefit to Delray/Boynton to spend hundreds of thousands of dollars to drag out unending research as opposed to millions to upgrade a 1950’s sewer plant and disposal scheme. The FDEP/sewer plant correspondence of late has narrowed to a debate focused on nutrient monitoring and tracer studies and now seems to have ignored the remainder of standards which must be met for permission to be granted to discharge waste into the environment. In order to obtain a federal discharge permit the applicant must address the following: Transport of pollutants by currents, composition and vulnerability of potentially exposed biological communities, including unique species or communities, endangered or threatened species, and species critical to the structure or function of the ecosystem. Importance of the receiving water area to the surrounding biological community, e.g., spawning sites, nursery/forage areas, migratory pathways, and areas necessary for critical life stages / functions of an organism. Potential direct or indirect impacts on human health. Existing recreational and commercial fishing. The existence of special aquatic sites, including coral reefs. Reef Rescue has written the Palm Beach County Health Department several times in the last year requesting an opinion on the potential health risks associated with the sewage outfall; we have received no response. However, in a review of potential impacts relative to the south Florida sewer outfalls the EPA states: “There are a number of gaps in information concerning human health and ecological risks from pathogenic microorganisms remaining in treated effluent. The SEFLOE studies of enteric microorganisms in effluent and the dilute effluent plume did not include measurements of Cryptosporidium or Giardia. Other enteric viruses and bacteria were not measured. Ecological risks posed by effluent microorganisms could not be evaluated in this report because of the lack of long-term monitoring studies of benthic organisms in the effluent plume track or adjacent waters. Factors that decrease risk are the distance of the outfalls from land. The lowest risk outfalls are farthest from land (Miami-Dade Central outfall), while the highest risk outfalls are closest to land (Boca Raton, Delray Beach). Potential microbial stressors in treated wastewater include pathogenic enteric bacteria,protozoans, and viruses associated with human or animal wastes. Untreated raw sewage typically contains fecal indicator bacteria (such as fecal coliforms, total coliforms, and fecal streptococci) in concentrations ranging from several colonies to tens of millions of colonies per 100 mL . Other pathogens that are potentially present include other bacteria (Campylobacteria jejuni, Legionella pneumophila, Salmonella typhi,Shigella, or Vibrio cholerae), helminthes (such as hookworm, roundworm, or tapeworm),viruses (adenovirus, enteroviruses, hepatitis A, rotavirus, Norwalk agent, parvovirus, andothers), and protozoa (Cryptosporidium parvum, Giardia lamblia, Balantidium coli,Entamoeba histolytica). Human health risks are of some concern, both within the 400-m mixing zone and outside of it, primarily because treatment of effluent prior to discharge via ocean outfalls does not include filtration to remove Cryptosporidium and Giardia. The most probable human exposure pathways include fishermen, swimmers [scuba divers], and boaters who venture out into the Florida Current and experience direct contact, accidental ingestion of water, or ingest fish or shellfish exposed to effluent. We all know the sewage outfall surface boils are favorite fishing spots in south Florida and on any summer weekend there are literally 100s of scuba divers drifting in the downstream effluent plume of the Delray sewer pipe. There are many unanswered questions and serious risks to health, habitat and the economy, which derives over $200 million dollars a year from the county’s reefs. Delray and Boynton Beach have had decades to get their act together. To quote Mayor Perlman of Delray Beach, when asked why this condition is allowed to exist, emailed a concerned citizen and wrote, “ It had been ignored for 40 years.” The SEFLOE studies of the sewage outfalls were conducted 15 years ago. The sewer plant now wants to spend thousands of dollars and several more years to do a restudy, while as time passes the last coral reefs in Florida continue to die. Albert Einstein once said “Doing the same thing over and over again and expecting different results, is the definition of insanity”. I relied upon information from the EPA website for the referenced SEFLOE statistics. You can learn more about SEFLOE and Florida’s sewage outfalls @:http://www.epa.gov/region4/water/uic/downloads/ra/06-ocean.pdf Ed Tichenor, Director Palm Beach County Reef Rescue PO Box 207 Boynton Beach, FL 33425 www.reef-rescue.org fax: (561) 364-5951 phone: (561) 699-8559 Thomas J. Goreau, PhD President Global
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