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Comments on the EIS for
Broward County's Thomas J. Goreau Broward
Beach Project EIS The Global Coral Reef Alliance is submitting the attached comments as part of the public review for the record of the EIS for the Broward County Beach Fill Project, USACE Permit # 199905545. We ask that Segment II be immediately dropped from the project because it would cause irreparable damage to the best remaining shallow reef in southeast Florida, and the only one that can be swum to from shore. This reef is a national treasure, deserving the strongest possible protection. It contains endangered species, large numbers of ancient corals, and large spreading fields of rapidly growing corals that are highly sensitive to sediments, as well as being essential fish habitat for vast swarms of juvenile coral reef fishes. This region should be designated as coral reef habitat, not hardground, and receive the full legal protection provided by the Coral Reef Protection Act, Executive Order 13089, and the Endangered Species Act. The EIS is rife with inaccurate statements, erroneous assertions, poor analyses, inadequate interpretations, irrelevant models, and suspect numbers. It incorrectly claims that there has been no damage to coral reefs from past dredging projects, uses worthless methods to minimize the estimated area that would be damaged, and appears to use questionable methods in the cost-benefit analysis, among many other serious flaws that are discussed in the attached comments. Previous dredging projects were done without any baseline studies to estimate the damage that was done, yet the EIS claims that they had no impact on reefs, in direct contradiction to the unanimous observations of divers that they destroyed large areas of reef. It may be true that in the past the existence of these magnificent coral reefs were not known to policymakers, it may be true that they did not realize that dredging would damage or kill them, and it may be true that there was no legally mandated protection for coral reefs then anyway, but none of these arguments can be made in 2002. We urge that the EIS for Segment II be rejected, and that this segment be immediately dropped from the dredging plan. We have no objection to beach amendment in Segment III, but ask that sand bypassing be used in preference to dredging and filling on both economic and environmental grounds.
Thomas J. Goreau, Ph.D. DETAILED COMMENTS The map on page 545 of the 612 page EIS shows the topography of the bottom and the area of best reefs as identified in the Cry of the Water and Global Coral Reef Alliance report (appended). This area is on the innermost ridge, next to the proposed dredge fill and “artificial reef mitigation” boulder dump. The large number of juvenile corals seen all along this hardground, dominated by the extremely sediment-sensitive staghorn corals, would certainly be chronically damaged, if not destroyed, by sediment from the proposed beach dredge-fill project. This would be a violation of the Coral Reef Protection Act and of Executive Order 13089. What is called hard bottom in Segment II is incorrectly classified and it should be characterized as Coral Reef, as it is very different biologically from what they are referring to as nearshore hardground. The entire area is a vast nursery for baby corals and fish, the only one of its kind left in East Florida. The key point is to preserve the only prime quality reefs left, which are in the only section that has NEVER been dredged, which is why they are still there when all the rest of good nearshore reef has been degraded by previous dredging projects. We ask that the entire area off Segment II be officially designated as coral reef habitat by the county, state, and federal agencies responsible, and provided the fullest protection that the law demands for such habitats. Pillar coral, Dendrogyra cylindrus, is listed as an Endangered Species. There are several very large ancient Pillar coral colonies lying directly offshore from areas that are due to be dredge-filled in Fort Lauderdale. Acropora species are also being added to the Endangered Species list. There are huge fields of staghorn coral (Acropora cervicornis) right offshore from Segment II. We believe that the Endangered Species Act should be fully applied to Segment II to prevent damage to coral species that are already listed as Endangered Species or soon will be. Th EIS states in several places that healthy corals are resilient and able to resist sediment stress, but fails to point out that corals vary greatly in their ability to do so, with the staghorn and elkhorn corals being the least able to resist sediment stress. It further assumes that there will only be a single muddy plume at time of emplacement, which will be swept away by the currents in days, when in fact what is always seen after each such dredging project is that a new plume of mud is resuspended as the dredge-fill is reworked by waves after every storm, and that these recurrent stresses continue for years or even decades afterwards. Corals that can survive a single rare mud event are largely unable to survive repeated events, especially if they are too frequent. Eventually corals run out of energy needed to push the sediments off their surfaces, and slowly die. Corals that are bleached or diseased, as many Broward corals are, especially in the summer when hurricane-induced sediment stress is most likely, are severely impaired or unable to resist sediment stress, and will die sooner. The EIS claims that there is no evidence that previous dredging projects have damaged reefs. This contention is untrue, and all long-term divers in Broward County have seen their favorite reefs damaged or destroyed by previous dredging projects. Previous dredging projects in Hollywood and Dania have damaged the natural protection for those beaches, so there is no alternative there now but to keep dredging and filling. GCRA does not object to dredge filling in Segment III because the reefs are already damaged. Previous environmental impact studies were all started AFTER dredging had taken place, that is they had NO BASELINE with which to compare changes, making the conclusions incorrect. The EIS uses a worthless method to determine how large an area will be impacted. It says “impacts to hardbottom and reef habitat can be predicted based upon proximity, currents, nature of borrow material, buffer zones, and other factors (USACE, 1998)”. This is based on the “Equilibrium Toe of Fill” (ETF) concept, that limit beyond which USACE methods say no sand will move, and beyond which they say no damage will take place. The assumptions behind these calculated ETF lines are taken to be literal truth but are never really stated and require close examination. Basically the equations use measured wave heights and angles, currents, and the slope of the beach to calculate how far out the surf zone of resuspended beach sand extends from the shore. This is fine as long as average assumed conditions prevail. They do not prevail during hurricanes, so that this model is useless in a region like Broward that gets hit by hurricanes. This is clearly shown by the intense erosion of beaches and opening of a new passage for the New River during the last great hurricanes to hit the area in the 1920s, a lesson that now seems to be forgotten. The height of the waves and their direction at any given spot are critically dependent on how far it is from the eye, and whether it is north or south of the eye. If it is close to the north of the eye, the ETF will be in the condominiums or the Intercoastal Waterway, if it is close to the south of the eye, the ETF will be over reefs, perhaps even over the drop off. Sand from previous beach fill in Dania and Lauderdale by the Sea has already moved way beyond the USACE-predicted ETF and buried hardgrounds and coral reef habitat. The EIS points out that during surveying for this project, they do not point out that the ETF will behave similarly. When a hurricane hits, as it surely will one day, the sand could travel hundreds of yards across the reef beyond the calculated ETF used in this EIS to define the areas of no damage. The proposed “mitigation” is a bad joke. Limestone boulders will provide shelter for fish if they are placed in an area where there is no natural shelter, but it will not generate a natural coral reef community that is equivalent in value to what would be damaged. Wrecked cars, ships, planes, rubber tires, and other forms of trash can do so better at lower cost, but also are incapable of producing real coral reef communities and in hurricanes they become projectiles that damage real reef. The boulders will roll in a direct hurricane hit, too, and the proposed “mitigation artificial reef” adjacent to the best staghorn reef area would flatten the fragile staghorn corals if the boulders roll over onto them. Failed and potentially damaging methods of artificial reef “mitigation proposed should be scrapped, and only state of the art methods that increase coral growth rates, reproduction, settlement, and ability to resist environmental stresses including sediment, pollution, and extreme temperatures, should be used. The algae data on pages 75-76 of the document show huge differences between north and south segments. The algae species found are named, but there is no discussion of the ecology of these species. When the ecological habitats of each species are considered, the algae species distributions and abundances clearly show that pollution with nutrients from sewage, agriculture, and urban runoff is far worse in the south, where almost all the bottom is covered with the worst sort of sewage-indicating slime. The area of best reef does not suffer from excess algae growth on the bottom, allowing the settlement and growth of baby corals, in particular staghorn corals. This is the result of the location of sewage outflows to the sea, and of runoff of lawn fertilizers, agricultural fertilizers, and road runoff through canals. The EIS states that Broward county reefs are typical of Caribbean reefs in that “Caribbean reefs are dominated by algae”. This completely fails to recognize that this algae domination is recent and is the result of pollution from land-based sources of excessive nutrients from sewage, agriculture, deforestation, and soil erosion, or that there are still coral reefs in Broward County in the zone in front of Fort Lauderdale that have never been damaged by these factors. It is now too late to prevent eutrophication damage caused by excessive nutrient inputs along Segment III, but it is not too late to keep this from ever happening to the still vibrant reefs of Segment II and keeping its waters clear now and in the future. The EIS states repeatedly that no action will lead to increased pollution due to growing population. This is stated in a way implying that lack of dredging causes pollution! How will dredging reduce pollution? Dredging will act to re-suspend any pollutants in the sediments, causing repeated exposure to the corals. Furthermore the terms of reference provided by the US Army Corps of Engineers requires that water quality controls only be done “to the extent necessary to safeguard the health of bathers”. This ignores the fact that corals are hundreds to thousands of times more sensitive to nutrient pollution than human beings, that is to say by the time human health begins to be affected, most of the corals will have already been killed. We call for appropriate ecosystem-dependent water quality standards to be applied to this and other coral reef habitats. Available nitrogen concentrations (nitrate plus ammonium) should be maintained below 1 micromole per liter, and available phosphorus concentrations (orthophosphate plus dissolved organic phosphorus) should be maintained below 0.1 micromole per liter to prevent over-fertilized algae from over-growing and killing corals. The claim that dredging would be cost effective is based on severely underestimating the damage to the reef that it would cause. In our view, the most cost effective and least environmentally damaging option for Segment II would be No Action, along with bypassing to get the huge mass of sand trapped by the Port Everglades jetty over to Dania, where it would have gone had it not been prevented from getting there by the jetty. The erosion hot spot in Dania is there only because its natural sand supply has been completely blocked. The Fort Lauderdale beach is stable, it is not eroding, and it does not need to be dredge-filled at all, especially since doing so will damage the natural protection from living coral reefs that has protected the beach all along. Once this reef is damaged, dredge-filling will be needed over and over again, but this project will exhaust all the “borrowable” sand offshore, so much more remote and expensive sand sources will be needed. The EIS states repeatedly that “no action will result in continued beach erosion” but fails to point out that there is little or no beach erosion in the largest segment of the planned dredge-fill project. Why is no map provided showing how the amount of erosion varies along the entire length of Broward County Beaches, even though comparison of the beach profiles show little or no change between 1980, 1993, and 1998 in the Fort Lauderdale segment, in sharp contrast to the situation in Dania and Hollywood? The Segment II project is not needed because there is no erosion problem in this section, it is needed to keep taxpayer’s money flowing to dredge operators and consultants. We ask for the Segment II project to be dropped entirely as bad environmental and economic policy, and this region to be protected as a National Wildlife Monument Sand bypassing is the cheapest possible source of sand to the eroded areas, and should be the first option considered. Only if the amount of bypassable sand is insufficient would it need to be amended with expensive remote sources like dredge-fill from borrow pits, Lake Wales, or the Bahamas. Instead sand-bypassing is the last option considered in the EIS, considered only as a possibility for the future after "borrowable" sand is gone, and is not even properly assessed. There are many questionable features in the economic cost/benefit analysis presented in the EIS. An unrealistic value of the interest rate, 6.25% is used throughout, although the current rates are much different, throwing all of the economic estimates off by large cumulative amounts over the lifetime of the project. The benefit/cost ratios presented are exactly the same for each segment of the project, even though the erosion rates are very different and so the costs and benefits will be quite different. This exact equality cannot have resulted from coincidence! It appears instead that a favorable benefit/cost ratio has been assumed a priori (but not stated as such), and then used to calculate the “benefits” from the costs, i.e. that the costs were not independently estimated for each segment, which would have inevitably produced a different ratio in each section. It seems, in short, that the figures have been cooked to give the answer desired. More importantly the entire cost/benefit analysis is bogus because the economic benefits of Broward reefs, $2.1 Billion per year according to the State’s recent report on the socioeconomic value of reefs, are not taken into account in the EIS. Even a small degradation of their value would turn the net benefit from positive to negative, and the project would be rejected on purely economic grounds. THIS REEF IS LIKE THE LAST GIANT REDWOOD GROVE. IT IS UNTHINKABLE THAT IT COULD BE SACRIFICED IN 2002 WHEN SO LITTLE GOOD REEF REMAINS. |
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