The more expansive review of the City of Sarasota/Army Corps of Engineers plan would provide analyses of alternative designs that could spare Big Pass from dredging, the SKA says
The Siesta Key Association (SKA) this week formally requested that the Sarasota County Commission call for an Environmental Impact Statement (EIS) of the City of Sarasota/U.S. Army Corps of Engineers (USACE) proposed Lido Renourishment Project, The Sarasota News Leader has learned.
The letter, which was sent to the commissioners on the morning of July 14, asks that they approve a resolution calling for the withdrawal of the Finding of No Significant Impact (FONSI) in the Environmental Assessment (EA) the USACE filed with the Florida Department of Environmental Protection (FDEP) in March 2015. The $19-million city/USACE plan calls for dredging about 775,000 cubic yards of sand from Big Sarasota Pass to renourish the critically eroded Lido Beach.
“The EIS would formally update and document the principal design and provide analyses of alternative designs,” the letter says. (The emphasis is in the letter.) “An EIS is essential given the significance of this project to the shorelines of Lido and Siesta Key [and] potential impacts to Big Sarasota Pass and Ted Sperling County Park.”
The park is on the southern part of Lido.
The letter further points out that during the March 23 County Commission discussion of the Atkins’ firm peer review of the project, “many questions went unanswered as the models used by USACE were not considered ‘best practices’ for this project. The answers could be obtained through an alternative model, described by Atkins, well known in similar Coastal erosion circumstances.” The peer review was requested by the County Commission in August 2014.
The USACE modeling “was not designed for tidal inlets such as Sarasota Big Pass,” the letter notes. “The environmental descriptions in the [Environmental Assessment], upon which impacts were to be assessed, were also significantly out of date. Additionally, USACE arbitrarily dismissed reasonable alternatives to the sand source and groin design,” the letter continues.
The project originally called for three groins to be constructed on Lido Key to keep sand in place between renourishments spread over a 50-year period. However, when the USACE submitted its permit application to the Florida Department of Environmental Protection in March 2015, the proposal called for just two groins.
The News Leader left messages for county commissioners on July 14, asking whether they had received the letter and whether they had any comments. Only Commissioner Christine Robinson responded. “I did read it,” she said, “[but] I have questions.” She added that she would like to have county staff provide information about what an EIS entails.
The board conducted its final meetings this week before beginning its traditional summer recess at the end of this week. The first session it will hold after that break will be on Aug. 22, which will be a budget workshop.
The SKA letter further explains that an EIS “would evaluate and rank alternatives” such as the following:
- Removal of the existing rock groin north of the eroded beach, “which threatens condos.” The letter notes that that structure has been acknowledged as a model demonstrating how groins can have a negative impact on the natural flow of sand from north to south on the west coast of Florida.
- The utilization of permeable adjustable groins, which the Town of Longboat Key has constructed. As a guest during the SKA’s May meeting, Longboat Town Manager Dave Bullock talked of the success the community has achieved in keeping sand on its beaches, thanks to having those groins in place. The fact that this alternative design “was arbitrarily ignored” in planning the Lido project, the SKA letter says, “should provide a legal challenge to the draft FONSI.”
- A smaller project “focused on protecting the most eroded portion of the Lido Key beach” rather than the approximately 1.6-mile expanse targeted by the city and the USACE.
SKA Second Vice President Catherine Luckner pointed out to the News Leader on July 14 that she has said for years, “It doesn’t have to be all or nothing.”
- Disclosure and ranking of cost of alternative sand sources, including sand brought in by truck. “Cost should be compared using the most recent reduction in proposed sand volume,” the letter notes. The original USACE project manager initially announced that between 1.2 million and 1.3 million cubic yards of sand would be needed from Big Pass; the figure was reduced twice in documents provided to FDEP, with 775,000 cubic yards cited as the most recent number.
- Restoring to the project means of protecting Ted Sperling Park from any adverse consequences. “Costs and permits for this were eliminated by USACE through modeling that indicated that [they] might not be needed,” the letter says. “While the modeling may be correct,” the letter continues, “the design of the third groin, including all the required permits [from FDEP, plus a county lease allowing the city’s use of property for that groin] should be included as part of an Adaptive Management Plan with funds dedicated should [the groin] be needed.”
The letter also points out that SKA officers recently learned from FDEP that the department could issue a permit to the city and the USACE without a complete Biological Opinion. The permit should not be granted without that opinion, the letter adds.
In the FDEP’s first Request for Additional Information (RAI1) regarding the City of Sarasota/USACE Lido project — dated April 15, 2015 — the FDEP staff wrote, “Please provide an updated Incidental Take and Biological Opinions from both the U.S. Fish & Wildlife Service and the National Marine Fisheries Service. The incidental take authorization should assess take [killing of wildlife] due to construction of the [proposed groins] as well as potential impacts to nesting and nearshore foraging sea turtles. This Opinion should include potential impacts to nearshore hard bottom habitats as well as impacts due to fill placement.”
In a Sept. 4 letter responding to the RAI1, CB&I Coastal Planning & Engineering Inc. of Boca Raton — the consulting firm working with the USACE on the Lido project — wrote to the FDEP that it acknowledged the need for those documents. “Copies of the Biological Opinions and consultation letters will be provided to FDEP,” CB&I added.
The SKA letter concludes, “We have consistently worked toward a ‘no harm’ solution on this issue. While our request may seem atypical, many corporations and government entities begin (emphasis in the letter) with an EIS to more efficiently address complex issues and achieve the best outcomes.”
The letter is signed by Luckner and Vice President Robert Stein.
Copies also were sent to County Administrator Tom Harmer; Matt Osterhoudt, senior manager of the county’s Planning and Development Services Department; Carolyn Brown, director of the county’s Parks, Recreation and Natural Resources Department; and Laird Wreford, the county’s coastal initiatives manager.
Two sides of the issue
During a July 14 telephone interview, Luckner emphasized to the News Leader that the SKA never has opposed the renourishment of Lido Key. The nonprofit organization’s focus, she said, has been on how best to pursue that work without damaging parts of the county’s environment. “This is a highly developed coastal community,” she pointed out. Yet, Sarasota County has a long history of preserving its “rich environmental qualities. … That speaks volumes for us.”
A Frequently Asked Questions document on the U.S. Department of Energy website explains that the National Environmental Policy Act (NEPA) requires an EIS for “Federal actions significantly affecting the quality of the human environment.”
Among the criteria used to determine whether an EIS is needed are whether a project “presents unique or unknown environmental risks” and whether “[t]here is any controversy over the degree of environmental effects of the project.”
Big Pass never has been dredged, Siesta residents long have pointed out. Past scientific studies have cited significant concerns about the potential impacts of such an undertaking.
However, from the outset, the USACE has maintained that the draft Environmental Assessment it conducted for the Lido Renourishment Project was all that was necessary. The USACE and city representatives have said in public meetings that they never would undertake a project that could harm Big Pass.
Furthermore, in a December 2015 email to the News Leader, Lt. Col. Susan J. Jackson (U.S. Army Reserve), a USACE spokeswoman for the Jacksonville District, wrote, “[U]sing Big Pass sand for Lido Key was thoroughly studied for a Sarasota County management plan … The Comprehensive Inlet Management Plan, Big Sarasota Pass and New Pass System, published in May 2010 by Sarasota County, concluded that Big Sarasota Pass is a viable and renewable source of sand for the eroded portions of Lido Key and that sand could be removed from the shoal without negatively impacting Siesta Key. This study was a joint effort of two highly-qualified coastal engineering firms and University of South Florida experts, and it went through three separate independent peer reviews, which all found the study to be fundamentally sound in its conclusion that sand could be dredged from Big Sarasota Pass for placement on Lido Key without causing adverse impacts. Additionally, in June 2015, the State of Florida updated its Strategic Beach Management Plan, which recognizes Big Sarasota Pass as a viable source of sediment.”
During the July 14 telephone interview, Luckner said she had learned about alternatives the USACE is employing in renourishment projects on the East Coast. Further, she has read about USACE meetings on “Living Shorelines” — what a USACE document refers to as “Nature and Nature-Based Approaches to Support Coastal Resilience and Risk Reduction.”
“These other options are not unknown to them,” she said of the USACE staff involved in the Lido project, “and [Sarasota County residents] deserve the best.”
A permit arriving soon?
Just last week, Carl Shoffstall, president of the Lido Key Residents Association, joined City Manager Tom Barwin in pointing out to the Sarasota City Commission the severity of erosion on Lido Key, especially in the aftermath of Tropical Storm Colin’s wind and waves in early June. “There is no beach,” Shoffstall said during the July 5 City Commission meeting.
He had heard, though, that the FDEP is expected to issue the project permit this fall, he added.
FDEP staff is awaiting a seagrass mitigation plan from the USACE and its consultant, CB&I. Luckner has told the News Leader that, based on her discussions with the FDEP manager overseeing the application process, that plan appears to be the final, key piece of documentation the department wants before considering whether to issue the permit.
USACE spokeswoman Jackson said in a July 14 telephone interview with the News Leader that although the most recent timeline from USACE staff indicated the seagrass plan would be submitted by the end of this week, that will not be the case. She added that no new date was available.