In response to a flurry of applications for permits to carry out beach renourishment projects off Palm Beach County, Indian River County and Broward County in Florida, which would bury over 100 acres of coral habitat -- including the renowned Breakers Reef -- ReefKeeper International has demanded of the Army Corps of Engineers, Department of Environmental Protection, and county-level agencies the following:
Breakers Reef, located between Florida Department of Environmental Protection (FDEP) monuments R-94 and R-95 is a significant coral reef and diving resource. Destruction of this reef, as proposed by the applicant, is totally unacceptable.
Breakers Reef is not simply a nearshore pile of rocks but is a thriving coral reef ecosystem at its northernmost limits, with hard corals, soft corals, fish, and other reef-associated organisms. Attached to this letter are summary sheets of data collected by volunteer divers since 1996 for two locations on Breakers Reef, one shallow (approximately 8-10 meters deep) and one deep (approximately 17-22 meters deep). This data clearly shows that coral and reef organisms are present in a functioning ecosystem.
The data presented for the Breakers Reef area by the applicant (Attachment 37) is over 10 years old. The more current data gathered by volunteer divers illustrates the extensive development of the Breakers Reef. Divers and snorkelers in Palm Beach county and surrounding areas utilize the Breakers Reef extensively. Breakers Reef cannot be viewed as a disposable or easily replaced asset.
ReefKeeper International has requested that FDEP require that the project be modified from that proposed to prevent any damage to Breakers Reef. Efforts must be made to save this valuable site from the negative impacts of beach renourishment, such as direct burial or increases in turbidity.
Oculina varicosa is a slow-growing, delicate branching species of hard coral that grows off the coast of Florida. This coral is easily damaged by contact or siltation. Oculina spp. corals are known to be habitat essential for snappers, groupers, calico scallops, and rock shrimp.
Based on maps provided in the South Atlantic Fishery Management Council's Comprehensive Amendment Addressing Essential Fish Habitat (SAFMC, 1998), some of the proposed borrow areas may be located in areas where Oculina spp. corals are present. Destruction of Oculina spp. corals by dredging must not be allowed.
Therefore, ReefKeeper International has requested that detailed hardbottom surveys be conducted to determine if Oculina spp. corals are present in or near the proposed borrow areas. If Oculina spp. corals are detected, then ReefKeeper International has requested that the FDEP require the applicants to redesign the borrow areas and not allow any dredging in or near the Oculina spp. corals.
The cumulative projects as proposed call for the placement of 9.5 million cubic yards of material, extending the beach hundreds of feet into the ocean along 26.6 miles of shoreline. The vast extent of these renourishment from the current shoreline only increases the adverse impacts to marine life from the projects. Many acres of coral hardbottom will be destroyed by these projects. This mass destruction of habitat is unacceptable.
Two marine protected areas have been proposed in Broward County, one between the Pompano fishing pier and the Lauderdale-By-The-Sea fishing pier, and a second area between the Dania fishing pier and Port Everglades. The proposed marine protected areas are within the boundaries of one of the beach renourishment projects. Obviously, the proposed beach renourishment destroys the very habitat for which protection is being sought.
Therefore, ReefKeeper International has requested that an evaluation of a potential reduction in the sizes of the projects be required. Reducing the length of shoreline to be renourished will reduce the amount of hardbottom buried. A project smaller in width may necessitate more frequent renourishing but would also significantly decrease adverse environmental impacts. The potential costs and benefits of this must be examined. The potential use of sand dredged from nearby inlets may make smaller, more frequent renourishment activities both economically and environmentally more viable than the current proposed projects.
The South Atlantic Fishery Management Council has declared live hardbottoms as Essential Fish Habitat (EFH) and Habitat Areas of Particular Concern (HAPC) for snapper and grouper species. These designations denote the incredible importance of these habitats to the survival of many fish species. Since the proposed projects will impact over 100 acres of HAPC, a complete EFH assessment and consultation is required by the Magnuson-Stevens Fishery Conservation and Management Act.
Therefore, ReefKeeper International has requested that the applicants be required to complete EFH assessments for submission to the National Marine Fisheries Service and the South Atlantic Fishery Management Council. ReefKeeper International has also requested that the projects not be approved without first obtaining the approval of these two agencies.
The seafloor near the shoreline and the proposed borrow areas contains significant coral reefs and hardbottom communities. Corals can grow as slowly as 1/5 to 1 millimeter per year (McConnaughey, 1983), with a knee-high coral head possibly being hundreds of years old. These characteristically slow growth rates simply mean that scleractinian reef-building corals are not a renewable resource on a biological time scale but rather should be viewed on a geological time scale. Based upon the slow growth rates of these organisms, coral colonies, including recently established colonies, must not be put at risk of destruction from dredging and beach renourishment activities.
ReefKeeper International has requested that current detailed mapping of all coral reefs and hardbottom areas near the proposed borrow sites, along the pipeline paths, and along the shoreline to within 1000 feet seaward of the equilibrium toe of the fills be conducted to determine the current location and extent of these important features. This mapping must adequately characterize and quantify the bottom cover in the specific locations. This mapping must be completed prior to the evaluation of the permit applications.
The applicants have not furnished detailed construction plans and specifications with the application packages. The FDEP is charged to "protect, conserve and manage Florida's environment and natural resources." FDEP should not, and cannot, approve a construction permit without knowing exactly how that work will be carried out. The documents submitted with the applications provide far too little information upon which a decision can be based. The documents fail to detail how the work will be conducted and what techniques will be utilized to minimize impacts.
General overview statements like those contained in the submitted permit applications do not provide assurance that Florida's valuable marine resources will be protected or conserved. The lack of information also prevents organizations such as ReefKeeper International and concerned individuals from adequately commenting on the project prior to FDEP's approval of the project.
Therefore, ReefKeeper International has requested that the FDEP require the applicants to submit detailed construction plans prior to approval or disapproval of the projects.
Past experience shows that physical dredging damage does occur during beach renourishments. In fact, coral reefs are most damaged by dredging. Poorly planned and implemented dredging operations have caused the demise of many reefs. Straughan (1972) condemned dredging for the destruction of some Florida Keys reefs. Poor planning at a beach renourishment dredging project off Hallandale, Florida resulted in reef burial.
Blair and Flynn (1988) documented the destruction by direct dredge impact of 2 acres of coral reef at a previous beach renourishment project in the Sunny Isles area. In 1988, two acres of natural coral reef were damaged or destroyed by a dredge during the rebuilding of Miami's Sunny Isles Beach. The damage was depicted as some of the most severe reef destruction in modern South Florida history, according to Carlos Espinosa, then Chief of the Water Management Division of Dade County's Department of Environmental Resources Management.
The dredging company had orders to draw sand from a strip of sea bottom between two reefs parallel to shore. Round the clock, seven days a week, a huge ship floated along the narrow corridor, sucking up sand.
Even though the dredging zone was established with dredging barge paths no closer than 200 feet to the nearest coral areas, this did not prevent the damage. The dredge strayed off its charted course and plowed as much as 150 feet into coral habitat without the dredge operators' knowledge of it. The dredge was pulled over the reef numerous times, in a path of destruction in some places 350 feet wide (Blair and Flynn, 1988). Even when chunks of broken coral began spewing out of the dredge suction pipe, the barge operators assumed it was relic material buried under the sand pocket they were working.
Errors and accidents do occur. They have in the past. And they will happen again if proper safeguards are not in place. Therefore, ReefKeeper International has requested that adequate dredging buffer zones around coral reefs be required as part of the construction activities.
In 1990, the South Florida Regional Planning Council adopted as regional policy the prohibition of dredging or mining in the vicinity of coral reefs in Dade, Broward and Monroe counties. ReefKeeper International has recommended that, at a minimum, 600 foot wide buffer zones be established to prevent dredging in the vicinity of coral reefs.
For economic and time constraint reasons, dredging is often conducted around the clock for beach renourishment projects. Past projects in South Florida have utilized lighted buoys that are often placed along the hardbottom areas to mark a dredge's path. However, these lighted buoys do not prevent the dredge from entering the coral areas or from damaging them. The lighted buoys give only a visual demarcation of the hardbottom.
ReefKeeper International has requested that dredging activities for these projects be limited to daytime operations only. The risks of the dredge straying off course and impacting hardbottom are too great to allow nighttime dredging to occur.
Dredging is not the only activity conducted during beach renourishments that has the potential to adversely impact coral reefs and hardbottom communities. Construction vessels can run aground or scrape corals as they maneuver to, from, and around the dredge site. Heavy anchors can destroy corals on which they land.
Therefore, ReefKeeper International has requested that reef protection zones be required so that reefs and hardbottom habitats are further protected from non-dredging activities such as construction vessel movement, anchoring, and spudding. All of these non-dredging activities must be prohibited in reef protection zones to protect these fragile resources. The reef protection zones must establish a buffer of at least 200 feet between allowed activities and the coral reefs and hardbottom communities.
The presence of the pipelines used to move the sand on top of corals can damage, if not kill, these fragile marine organisms. Direct physical placement can crush corals and other reef organisms. The continued presence of the pipeline will shade corals, which are dependent upon sunlight for their survival.
ReefKeeper International has requested that the applicants be required to provide specific drawings and details of pipeline placements, including an evaluation of the potential adverse impacts by the pipelines. Quantification and a quality evaluation of any hardbottom habitat that would be covered must be included. If at all physically possible, damage must be avoided by routing the pipelines around corals -- or by using sand from a different source.
The Lake Worth sewer outfall pipe is located in one of the proposed borrow areas. The applicant states that a buffer zone around the sewer outfall will need to be developed (Offshore Sand Source Investigation, page 25). Details of any proposed buffer zone are not provided. No information on the stability or structure of the outfall pipe is provided by the applicant. The applicant also does not provide a vessel operations plan adequate to prevent the dredge from entering any designated buffer zone.
The potential for large-scale damage to the Palm Beach ocean resources should the dredging operations damage or break this sewer pipe is tremendous. The widespread release of sewage in the nearshore waters would have dramatic ecological and human health effects. The applicant fails to detail safety measures and offers no assurances that this sewer pipe will not be damaged during the dredging.
Therefore, ReefKeeper International has requested that dredging not be allowed within 300 feet of any outfall pipe. Additionally, analysis of the outfall pipe, including its expected stability after the dredging is completed, must be conducted prior to the approval or disapproval of this permit. If the results indicate a buffer zone wider than 300 feet is necessary, then one must be established as part of the permit requirements.
To ensure that the dredge does not stray near the outfall pipe, ReefKeeper International has requested that a vessel operations plan be developed that will ensure that the dredge does not enter the designated buffer zone.
As proposed, the projects include a number of irregularly-shaped borrow areas, with as many as 12 corners or turns. There should be no more than four corners or turns required in any one borrow area to ensure that the dredge stays on its path. If the dredge operator were to misjudge just one of these turns, the dredge could collide with the reefs. The impact to the reefs could be catastrophic.
Therefore, ReefKeeper International has requested that the borrow areas be redesigned to minimize the number of turns and corners required. The areas should be easily marked squares and rectangles to minimize the potential for dredging to occur outside of the borrow areas.
Hard corals in particular are susceptible to the effects of elevated levels of turbidity due to dredging (Dodge et al., 1974; Loya, 1976; Dodge and Vaisnys, 1977; Bak, 1978; Lasker, 1980; Marszalek, 1981; Rogers, 1983). High turbidity resulting from fine suspended particles generated by dredging decreases the amount of light -- a vital source of energy -- available to corals for the photosynthetic fixation of calcium carbonate (Johannes, 1975), thus reducing coral calcification (growth) rates (Lasker, 1980).
Turbidity also clogs the filter feeding mechanisms of coral polyps and causes continual energy losses by the necessity of continuous shedding of the protective mucus layer secreted by coral polyps (Lasker, 1980; Dallmayer et al., 1982).
Silt created by dredging remains in the local area for long periods and is resuspended during storms. Natural resuspension can also be compounded by the presence of silt fill discharged at the dredge site.
Moreover, sediments excavated by dredging are often anaerobic and bind up available dissolved oxygen. This forces reef organisms to increase respiration to remove silt, further lowering dissolved oxygen levels. Coupled with this increased respiration is reduced photosynthesis and oxygen production due to lowered light levels.
The usual result of chronic sedimentation is stressed corals susceptible to disease. The quantity of turbidity and the length of time required for exertion of its maximum stress effect is not known, but corals that are stressed expel essential symbiotic zooxanthellae and take on a pallid appearance prior to mortality (Goreau, 1964; Rogers, 1979; Glynn et al., 1984). Generally, mortality ensues within six weeks of such reactions.
Therefore, ReefKeeper International has requested that criteria specifically responsive to coral reef water quality requirements be included as a specific permit requirement. Consideration of water quality requirements for corals will help prevent "unforeseen" negative impacts and will allow for the establishment of water quality criteria that are appropriate for the ecosystem.
Poor planning at a beach renourishment dredging project off Hallandale, Florida resulted in reef burial and water quality problems (Courtenay et. al. 1974). The 1990 beach renourishment project at Bal Harbour resulted in catastrophic sedimentation burial of coral reef areas near the dredging site (Blair et. al., 1990). Similar destruction may occur as a result of these proposed projects.
Given the history of adverse turbidity impacts during dredging projects and the severe damage to corals that results from poor water quality, ReefKeeper International requests that FDEP require that turbidity levels not exceed applicable standards more than 150 meters from the discharge point.
ReefKeeper International has further requested that the use of turbidity buffer zones and turbidity barriers be required both along the shoreline and at the borrow sites These measures must be incorporated into the project to minimize and monitor turbidity loads over the coral reefs and hardbottom communities and to prevent fatal turbidity impacts to those coral reefs. Researchers have recommended buffer zones of up to half-a-nautical-mile to protect coral reefs from dredging siltation (Griffin 1974; Courtenay et al. 1974).
Upland sources of sand in Florida can provide medium to fine grained quartz sand. Upland sources have the benefits of not requiring the separation and disposal of larger-sized particles, reducing overfill and improving turbidity conditions at the deposition site due to its lower silt content, eliminating any environmental risks and impacts to offshore coral reef areas from dredging, and eliminating the need to mitigate.
ReefKeeper International has requested that the applicants fully evaluate the availability and economic feasibility of using sand from upland sources. There must be a full presentation, comparative analysis and accounting that equitably compares the use of these upland sand sources with the use of the high-risk offshore borrow areas. Such a comparison must clearly show and take into account all the operational savings attributable to the use of the upland sand source -- such as no mitigation cost and no offshore rock disposal cost -- as well as the added values accruing from higher quality sand, eliminated risks to reefs, and more.
Damage to coral reefs and hardbottom communities can only be detected if an adequate monitoring program is in place. Monitoring must be conducted before any dredging activities are initiated to determine the "baseline" conditions. Monitoring during the dredging is critical to identify problems and prevent additional damage. Monitoring after the dredging is complete is important in determining long-term impacts of the project.
ReefKeeper International has requested that a monitoring program for the coral reefs and hardbottom communities be required. Monitoring must be conducted before, during, and after the project to adequately determine the impacts.
Some of the applicants propose a 1:1 mitigation of lost hardbottom and coral reefs with clean concrete structures. Clean concrete structures are, by definition, devoid of life. They do not replace the valuable coral reefs and hardbottoms that will be destroyed by the proposed project, especially the destruction of Breakers Reef. Burial of this ecosystem is unacceptable. Replacement with uninhabited concrete modules will not provide the same ecological or aesthetic benefits as the existing coral reefs and hardbottom communities.
One also cannot assume that any dredging project will be conducted perfectly as planned and without a hitch. It is likely that the current nearshore area contains corals that will be covered during the renourishment activities. It is also likely that some corals will be adversely impacted during the dredging.
Therefore, ReefKeeper International has requested that an adequate evaluation of possible mitigation measures to compensate for errors, unforeseen circumstances, and lost habitat be required prior to the initiation of the projects. ReefKeeper International has requested that this include an evaluation of the feasibility of relocating coral colonies that will be buried, may be covered by the pipeline or are within buffer zone areas.
To mitigate for stony coral mortality from coral relocation, and for general destruction of benthic biota, the proposed limestone modules must be deployed on more than a 1:1 basis at locations where the deployment would provide new hard substrate for the settlement of new corals and other benthic organisms.
ReefKeeper International also has requested that monitoring of the artificial reef and the mitigation reef be conducted quarterly for a period of at least five years. At the conclusion of the monitoring, the effectiveness of the artificial reef should be evaluated to determine if additional mitigation is necessary.
The fragile coral reefs and hardbottom communities of South Florida must be adequately protected before any of these beach renourishment projects are allowed to proceed.
References Bak, R.P. M. 1978. Lethal and sublethal effects of dredging on reef corals. Mar. Poll. Bull. 9:14-16. Blair S. and B. Flynn. 1988. Sunny Isles Beach Restoration Project: Mechanical Damage to the Reefs Adjacent to the Borrow Area. Metro-Dade DERM Technical Report 88-14. 17pp. Blair S. B. Flynn, T. McIntosh, L. Hefty. 1990. Environmental Impacts of the 1990 Bal Harbor Beach Renourishment Project: Mechanical and Sedimentation Impact on Hard-Bottom Areas Adjacent to the Borrow Area. Metro-Dade DERM Technical Report 90-15. Courtenay, W.R., D.J. Herrema, M.J. Thompson, W.P. Azzinaro, and J. van Montfrans. 1974. Ecological monitoring of beach erosion control projects, Broward County, Florida, and adjacent areas. U.S. Army Corps of Engineers, Coastal Engineering Research Center, Fort Belvoir, Va. Tech. Memo. 41. 88pp Dallmayer, D.G., J.W. Porter, J.J. Smith. 1982. Effects of particulate peat on behavior and physiological of Jamaican reef-building coral Montastrea annularis. Mar. Biol. 68:229-233. Dodge, R.E., R.C. Aller, and J. Thomson. 1974. Coral growth related to resuspension of bottom sediments. Nature 247(5442):574-577. Dodge, R.E., and J.R. Vaisnys. 1977. Coral populations and growth patterns responses to sedimentation and turbidity associated with dredging. J. Mar. Res. 35(4):715-730. Glynn, P.W., L.S. Howard, E. Corcoran and A.D. Freay. 1984. The occurrence and toxicity of herbicides in reef building corals. Mar. Poll. Bull. 15:370-374. Goreau, T.F. 1964. Mass expulsion of zooxanthellae from Jamaican reef communities after hurricane Flora. Science 145:383-386. Griffin, G. 1974. Case history of a typical dredge-fill project in the northern Florida Keys - effects on water clarity, sedimentation rates and biota. Publ. 33, Harbor Branch Foundation. 67pp Johannes, R.E. 1975. Pollution and degradation of coral reef communities. Pages 13-51 in R.E. Johannes and E.J. Ferguson Wood, eds. Tropical marine pollution. Elsevier Scientific Publishing Co., Amsterdam, Netherlands. Lasker, H.R. 1980. Sediment rejection by reef corals: The roles of behavior and morphology in Montastrea cavernosa (Linnaeus). J. exp. mar. Biol. Ecol. 47:77-87. Loya, Y. 1976. Effect of water turbidity and sedimentation on the community structure of Puerto Rico corals. Bull. mar. Sci. 26:450-466. Marszalek, D.S. 1981. Impact of dredging on a subtropical reef community, southeast Florida, U.S.A. Proc. 4th Intern. Coral Reef Symp. Manila 1:147-153. Rogers, C.S. 1979. The effect of shading on coral reef structure and function. J. Exp. Mar. Biol. Ecol. 41:269-288. Rogers, C.S. 1983. Sublethal and lethal effects of sediments applied to common Caribbean reef corals in the field. Mar. Poll. Bull. 14:378-382.