June 27, 2000

Colonel Joe R. Miller, District Engineer
Jacksonville District, Army Corps of Engineers,
400 West Bay St., Jacksonville, FL 32202

RE: 70 Ph.D. Scientists Urge Higher Environmental Standards in Beach Dredge and Fill Projects


Dear Colonel Miller,

The existing paradigm for managing beach systems of the southeast United States using frequent and massive dredge and fill projects ("renourishments") may have significant cumulative effects upon coastal habitat quality and fisheries production. Despite mounting evidence of both direct and indirect environmental effects on fishes, invertebrates, and turtles in several marine communities across the shelf, over 100 acres of nearshore reefs are now proposed for burial by four beach dredging projects in east Florida. Given the available scientific information and the increased agency oversight of habitat quality mandated by the Essential Fish Habitat component of the Sustainable Fisheries Act, and the Presidential Coral Reef Initiative, we offer the following comments.

The biological impacts of large and frequent dredge and fill operations across the east Florida shelf are of particular concern due to the region's very high biodiversity. Several studies have documented over 325 invertebrate and algal species in association with nearshore reefs on the east coast of mainland Florida. These nearshore reefs also support high densities of juvenile fishes in areas otherwise devoid of any substantial three-dimensional structural habitats. Collectively, over 500 species have now been documented from these reefs. These habitats are important recruitment and nursery areas for a diverse marine fauna and flora, that includes rare taxa and important fishery species. For example, in the U.S., the striped croaker (Bairdiella sanctaeluciae) is limited only to nearshore reef formations of east Florida. Important new data also suggest nearshore reefs provide important feeding and shelter areas for endangered green sea turtles.

Several numbers suggest the scale of potential impacts:

• At least 50 large-scale offshore dredge and nearshore fill projects have occurred in southeast Florida since 1960, dumping over 50,000,000 cubic yards of offshore sediments into nearshore systems.
• Over 90 additional large-scale dredge projects are conservatively planned to occur between 2000 and 2046. At least 80,000,000 additional cubic yards of offshore sediments could be dumped within the same corridor of subtropical southeast Florida during this period.
• Dozens of large dredge craters have been dug among mid-shelf reef habitats of southeast Florida since 1960 with dozens more planned. The dumping of millions of cubic yards of fill directly into 3-5 m depths to build nearshore berms, a new activity in southeast Florida, is now in planning for over 10 sites.
• At least 100 acres of nearshore reefs and 35 acres of seagrass beds have been directly buried since 1970 (historical data on reef impacts is very limited). Hundreds of acres of shallow reefs will be buried in the next 50 years at the current rates.

Despite the number of projects, few field studies of short-term dredge-and-fill effects have been published in the peer-review literature. In addition, no studies of long-term effects are available. For example, no long-term water quality data have been examined to assess the potential for increased turbidity at either inshore fill sites or offshore dredge pits resulting from wind- or wave-induced resuspension of sediments. It is logical to hypothesize that chronically elevated turbidity may impact both primary and secondary production in substantial manners that will, however, be difficult to separate from confounding impacts such as overfishing.

The potential cumulative effects of repeated dredge excavations and habitat burials have never been detailed in environmental impact statements. In both past and recent EISs, a total of one paragraph is typically devoted to cumulative impacts. This is puzzling, given the above numbers and the many scenarios in which cumulative effects can develop. The impact statements for these open-shelf dredge projects have chronically assumed that areas effected are low-value habitats or that impacts are only short term. In time, such assumptions have evolved into administrative dogma that are not substantiated by the independent literature. This has occurred despite well-documented examples of negative cumulative effects in nearby systems (e.g., unanticipated cascade disturbance events impacting Florida Bay). In addition, all habitats impacted by these projects are now identified as Essential Fish Habitat - Habitat Areas of Particular Concern by the South Atlantic Fishery Management Council and should receive additional agency oversight.

Based on the available information, the administrative paradigm that repetitive, large-scale dredging and filling of coastal habitats of has no long-term environmental impacts is potentially false and, at best, premature. The above factors suggest that the "risk-averse" and "ecosystem-based" management approaches adopted by some federal and state agencies be functionally employed by the United States Army Corps of Engineers in its assessments of environmental effects, particularly cumulative impacts.

These points reflect the professional judgement of the undersigned researchers. They are not intended to represent the positions of their institutions. Thank you for your consideration of these comments.

Sincerely,

These points reflect the professional judgement of the undersigned researchers. They are not intended to represent the positions of their institutions. Thank you for your consideration of these comments.

Related Literature

Army Corps of Engineers. 1996. Coast of Florida erosion and storm effects study: Region III with final environmental impact statement. USACOE Tech. Rept., Jacksonville District. Three volumes and appendices.

Butler IV, M. J., J. H. Hunt, W. F. Herrnkind, M. J. Childress, R. Bertelsen, W. Sharp, T. Matthews, J. M. Field, and H. G. Marshall. 1995. Cascading disturbances in Florida Bay, U.S.A.: cyanobacteria blooms, sponge mortality, and implications for juvenile spiny lobsters Panulirus argus. Mar. Ecol. Prog. Ser. 129:119-125.

Dodge, R. E., R. C. Aller and J. Thomson. 1974. Coral growth related to resuspension of bottom sediments. Nature 247: 574-576.

Gilmore, R. G., Jr. 1977. Fishes of the Indian River Lagoon and adjacent waters, Florida. Bull. Fl. St. Mus. Bio. Sci. 22(3), 147 p.

Gilmore, R. G., Jr. 1992. Striped croaker, Bairdiella sanctaeluciae. pp. 218-222. In C. R. Gilbert, ed. Rare and endangered biota of Florida. II. Fishes. Univ. Press of Florida, Gainesville, FL, 242 p.

Gilmore, R. G., Jr. 1995. Environmental and biogeographic factors influencing ichthyofaunal diversity: Indian River Lagoon. Bull. Mar. Sci. 57(1):153-170.

Kirtley, D. W. and W. F. Tanner. 1968. Sabellariid worms: builders of a major reef type. J. Sed. Petrol. 38(1):73-78.

Lindeman, K. C. 1997. Comparative management of beach systems of Florida and the Antilles: applications using ecological assessment and decision support procedures. pp.134-164. In: G. Cambers, ed. Managing beach resources in the smaller Caribbean islands. UNESCO Coastal Region & Small Island Papers # 1, 269 p.

Lindeman, K.C. and D.B. Snyder. 1999. Nearshore hardbottom fishes of southeast Florida and effects of habitat burial caused by dredging. Fish. Bull. 97(3):508-525.

Nelson, W. G. 1989. Beach nourishment and hard bottom habitats: the case for caution. pp. 109-116. In: S. Tait, ed. Proc. 1989 National Conf. Beach Preserv. Technol. Fl. Shore and Beach Preserv. Assoc., Tallahassee, FL, 236 p.

Nelson, W. G. and L. Demetriades. 1992. Peracariids associated with sabellariid worm rock (Phragmatopoma lapidosa Kinberg) at Sebastian Inlet, Florida, U.S.A. J. Crust. Bio. 12(4):647-654.

Odum, W. E. 1982. Environmental degradation and the tyranny of small decisions. BioScience 32(9):728-29.

Pandolfi, J., D. R. Robertson, and D. R. Kirtley. 1998. Sabellariid worms: builders of a major reef type. Coral Reefs 17:120.

Sedberry, G. R. and R. F. Van Dolah. 1984. Demersal fish assemblages associated with hard-bottom habitat in the South Atlantic Bight of the U. S. A. Environ. Biol. Fishes 11(4):241-258.

Telesnicki, G.J. and W.M. Goldberg. 1995. Effects of turbidity on the photosynthesis and respiration of two South Florida reef coral species. Bull. Mar. Sci. 57(2):527-539.

Wilber, P. and M. Stern. 1992. A re-examination of infaunal studies that accompany beach nourishment projects. Proc. 1992 Natl. Conf. Beach Preserv. Tech. pp: 242-256.

cc: U. S. Fish and Wildlife Service, South Florida Field Office, Vero Bch.
U. S. Fish and Wildlife Service, Area 3 Office, Atlanta
National Marine Fisheries Service, Habitat Conservation Division, St. Petersburg, FL
National Marine Fisheries Service, Habitat Conservation Division, Washington, DC
Florida Dept. of Environmental Protection, Bureau of Beaches and Coastal Systems
Florida Fish and Wildlife Conservation Commission, Division of Marine Fisheries
South Atlantic Fishery Management Council
Environmental Protection Agency, Marathon Office
Army Corps of Engineers, Wilmington District
Florida Dept. of Community Affairs, Coastal Management Program