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SOUTHEAST FLORIDA CORAL REEF INITIATIVE
Thomas J. Goreau The Draft Plan for this meeting starts by asking: “Is there a recovery or decline in water quality? Can water quality be linked to land-based sources of pollution?” It proposes funding a program to find out. With all due respect, the decline in coastal water quality and the role of land based sources of pollution in triggering massive algae blooms that kill reefs, are long known to all experienced reef researchers who measured nutrients and the physiological and ecological response of algae to them. Because coral reefs are the most nutrient-sensitive of all aquatic ecosystems they require the highest possible water quality standards for their protection, and standards derived from any other ecosystem are inadequate. These standards are long known, having been established by Lapointe, Littler, and Bell. Instead of calling for their enforcement the LBSP TAC has instead spent a year and $40,000 to do a study that we were told yesterday found that no standards exist for coral reefs! This study and bibliography is seriously flawed and deficient. Three of my own peer reviewed publications on precisely this issue are not cited, 1) a paper from 1991 from a symposium on long term change in reefs published in American Zoologist, describing the history of reef eutrophication in Jamaica and its relation to land based sources of nutrients, 2) a paper on Coral Reefs, Water Quality Standards, and Sewage Treatment published in 1994 in the Journal of the Caribbean Water and Wastewater Association calling for enforcement of the Lapointe-Littler-Bell standards in all coral reef areas, and 3) a review of the impacts of land based sources of nutrients on coral reefs and fisheries and how to prevent them, published in 2002 by the United Nations Expert Meeting on Waste Management in Small Island Developing States, which also calls for enforcement of these standards and recycling of land-based anthropogenic nutrients on land. If all of my own publications on this issue could not be found by this study, how many more are missing? Instead of trying to rediscover what is long known, the LBSP TAC meeting needs to call for the immediate enforcement of already established biologically-sound water quality standards adequate to protect reefs. The Turks and Caicos Islands have already adopted these standards. Why can’t the US follow? Doing a study now to find if sound standards exist is effectively a time wasting ritual that is slowing down their implementation. The monitoring plans being proposed at this meeting do not propose to use modern rapid nutrient mapping technology to provide data adequate in space and time for designing meaningful control of nutrient sources to the coastal zone. They are inadequate even to find out how much loading is coming from the 6 major sewage outfalls, much less the canals and additional sources such as deep well injection leakage. People even objected to making direct nutrient measurements! Calling for inadequate monitoring is in effect a way of ensuring that the information needed to take action can always be claimed not to exist. Land based sources of pollution are not only in surface flows and sewage pipes. In addition we wish to call for three major sources of land based pollution that are not now included to be monitored and controlled. These are: 1) The high level of mud, nutrients, and possible organic contaminants in the inadequate “sand” being dumped on the beaches to be counted as a land based source of pollution that is an imminent threat to the officially designated threatened Acropora that lie a hundred yards from the beach. 2) Deep well injection is also an indirect land based source of nutrients with a time delay. Already these effluents are impacting Southeast Florida reefs and will do so much more as the built up underground nutrients trickle out and as the CERP greatly increases rates of pumping. 3) The Everglades is a major source of high levels of greenhouse gases, climatically active gases, sources of haze and condensation nuclei, and sources of coastal nitrogen. We have published several scientific studies measuring these emissions and showing that they are extremely sensitive to very small changes in water flooding or drainage, and to dissolved nitrogen. Yet the Comprehensive Everglades Restoration Plan includes no monitoring of any land based sources of atmospheric pollution, which affects the coastal zone, and instead claims incorrectly that there are NO atmospheric pollution or climate impacts! A serious effort to understand the role of all of these sources on the reef, in time to prevent the next bacteria and algae bloom from killing most of what coral is left, requires a much more serious and targeted program of standards, protection, and of state of the art continuous mapping of all relevant nutrients. The discussion at TAC indicated that no such program or commitment was emerging from their deliberations, only the appearance of action for public relations purposes. The Global Coral Reef Alliance and Cry of the Water have called for years for the best remaining parts of the Southeast Florida reef tract, which are now completely unprotected and un-managed, to be declared Outstanding Florida Waters, and for coral reef-adequate water quality standards to be enforced in it. We have called for detailed in-situ mapping of all land based sources of nutrients to the coastal zone using continuous real-time measurements to identify every source and track them to their origins. We have repeatedly called for the Coral Reef Task force to stop permitting projects that damage corals, whether inadequately treated sewage discharges or dredge-filling areas next to reefs. We have called over and over for an immediate ending of all sewage nutrient dumping in the coastal zone, as well as deep well injection, whose nutrients are now beginning to soak into the sea through cracks in the formations above the boulder zone, causing visible sources of nutrient rich fresh water that are triggering cyanobacteria and algal blooms in the deeper reefs just as the sewage outfalls do in shallower areas. The Task Force has not responded to these repeated formally submitted requests, and claimed only that they lack the authority to request their own members to stop permitting projects that damage corals (verbally, not in writing, of course!) I have just received the following comment on the failure to end nutrient discharges from the Delray Beach sewer outfall from Ed Tichenor, who could not make this meeting, and who asked me to add it for the record on his behalf: The Boynton/Delray Beach sewer plant's NPDES permit expired 12/05. Their permit application has been deemed incomplete five times since their 6/05 application for permit renewal. The sewer plant has declined the FDEP request to do nutrient monitoring in the receiving environment four times since 6/05. Attached is the most recent FDEP letter, where for the first they discuss a "short term" permit. My questions: Does the Clean Water Act allow for such a permit? Is this a way for the FDEP to avoid having to deal with potential fines for noncompliance? Is this a way for the FDEP to avoid having to enter into an ACO with the responsible party? Would such a "short term" permit allow for the same public comment period as a real NPDES permit? If anyone can help answer these questions or direct me to a resource, please email or call me. Thank you, Ed Tichenor Palm Beach County Reef Rescue 561 699-8559 Pasted below is the most recent rejection letter from the FDEP to the Delray sewer plant's June 2005, NPDES permit renewal application. It is the fifth rejection letter to the plant within the last year for their continued refusal to do the requested monitoring in the receiving environment; a most basic premise of the federal "Clean Water Act." The plant's permit to discharge partially treated sewage into the near-shore coral reef environment expired December 2005. The FDEP seems to exhibit extraordinary patience with the plant. How much longer will this be allowed to continue before fines are levied? (as a reference, added below the letter is the March 2005 FDEP request for monitoring.) Florida Department of Environmental Protection Southeast District 400 N. Congress Ave., Suite 200 West Palm Beach, Florida 33401 May 22, 2006 ELECTRONIC CORRESPONDENCE Mr. Robert J. Hagel, Executive Director South Central Regional Wastewater Treatment & Disposal Board 1801 N. Congress Avenue Delray Beach, Florida 33445 Email: rhagel@scrwwtp.org Dear Mr. Hagel: RE: Application for Wastewater Permit South Central Regional WWTF DEP File No. FL0035980-020-DW1P-NR This is to acknowledge receipt of the additional information, dated April 21, 2006 for the referenced application for a wastewater permit. The application is incomplete. In order to complete review of your application pursuant to Section 403.087(4), Florida Statutes (F.S.) and Chapters 62-4 and 62-620, Florida Administrative Code (F.A.C.), please provide the information listed below. The items are numbered to coincide with our original request for information. Evaluation of the proposed project will be delayed until all requested information has been received. 1. Complete 2. Incomplete – In recent meetings with Dr. Proni (NOAA), he indicated that the first tracer test may be further delayed beyond this August. If this is the case, a short-term permit with a compliance schedule may be issued rather than waiting till the tracer test is completed. Regardless, the new permit will contain a requirement for a monitoring program in the receiving waters in the vicinity of Gulfstream Reef as described in our last letter. A proposal for the monitoring program should submitted as soon as possible. 3. Incomplete – Please provide an estimate of the average monthly costs (sewer bill) if one deep well with High Level Disinfection system were to be built, with the deep well sized to handle the average daily flows and the ocean outfall maintained for backup/peak flow disposal. 4. Complete Please provide the requested information as soon as possible, but no later than 45 days from the receipt of this letter. When referring to this project please use the DEP File No. given above. If you have any questions, please call me at telephone number (561)681-6684. Sincerely, Timothy W. Powell, P.E., Supervisor Wastewater Permitting Section ec: John Korochec, P.E. jkoroshec@hazenandsawyer.com Linda Horne, DEP/WPB linda.horne@dep.state.fl.us Dr. John Proni, NOAA john.proni@noaa.gov Dodie Stephens, DEP/WPB dodie.stephens@dep.state.fl.us Chantal Collier, DEP/MIA chantal.collier@dep.state.fl.us Janet Phipps, PBC ERM jphipps@co.palm-beach.fl.us Ed Tichenor, PBCRR etichscuba@aol.com *********************************************************************************************** FDEP March 2006 to South Central Regional Wastewater Treatment & Disposal Board: Due to the delay in the tracer studies, you need to re-evaluate the need for implementing a monitoring program in the receiving waters in the vicinity of Gulfstream Reef. The sampling program should include at least one location upstream (south) of the outfall and three near the reef - one at the south end, one at north end, and one near the middle. Sample depths should be at the ocean surface, at mid-depth and at the bottom. We also recommend at least one sample to be taken at the Boynton inlet (mid-depth) during outgoing tide, but this is your option. Parameters should include pH, Specific Conductance, Nitrite/Nitrate, TKN, Ammonia, Total Nitrogen, Ortho-phosphorous and Total Phosphorous. The monitoring program needs to begin as soon as possible (before the first tracer test) on a monthly basis for at least one year, after which time the sampling frequency could be reduced (or possibly discontinued, depending on the results of the sampling program and/or the dye/tracer studies). Here are links to newspaper articles published this week written in response to the latest FDEP rejection of the permit renewal application for the Delray/Boynton sewer plant. The sewer plant's permit to discharge millions of gallons a day of partially treated sewage from it's Atlantic Avenue ocean outfall pipe expired December 2005. This is the 5th time the FDEP has rejected the permit as incomplete in the last year. The reason it is incomplete is the plant's failure to address the most basic premise of the federal "Clean Water Act" - they must show they are not degrading the receiving environment, which in this case is an endangered coral reef. Sun-Sentinel (Thurs., May 25, 2006) Delray, Boynton told to increase monitoring of wastewater dumped into ocean Palm Beach Post (Fri. May 26, 2006) Divers fret as algae threaten coral reef
http://www.palmbeachpost.com/pbcsouth/content/local_news/epaper/2006/05/26/s1c_reef_0526.html Palm Beach County Reef Rescue PO Box 207 Boynton Beach, FL 33425 (561) 699-8559 CONCLUDING NOTE Is the TAC even willing to ask that sewage plants obey the law to stop disposing of it in the ocean? Following these public comments, the SEFCRI TAC refused once again to: 1) Call for the threatened Acropora area to be recommended for even the minimal level of legal protection 2) Call for the application of any water quality standards adequate to protect coral reefs This refusal comes despite repeated public petitions for these actions and specific motions proposed by members of TAC. Yet again, it seems that every time that the USCRTF or any of its agencies is asked to actually make any sort of decision to do anything meaningful protect corals, they claim to lack the authority, the information, and create any sort of excuse to avoid protecting corals, while spending vast sums on generating propaganda about their “successes” in the guise of “public awareness and appreciation”.
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