Save Our Siesta Sand 2 gets more answers to questions it submitted to the city and the federal agency about potential impacts of the project, but its concerns are not allayed, the chair says
The U.S. Army Corps of Engineers (USACE) is finalizing the seagrass mitigation plan required by the Florida Department of Environmental Protection (FDEP) for the permit application the USACE and the City of Sarasota filed in March 2015 for the proposed $19-million Lido Key Renourishment Project, The Sarasota News Leader has learned.
Lt. Col. Susan J. Jackson (U.S. Army Reserve) told the News Leader last week that the USACE manager for the project, Brandon Burch, reported to her that the team is preparing to submit its responses to FDEP by mid-June.
The seagrass mitigation plan is one of the last elements of the FDEP application process the USACE and the City of Sarasota must complete in an effort to obtain FDEP permits. In March, the FDEP’s manager overseeing that process — Greg Garis — issued a six-month extension to the USACE to complete “a suitable seagrass mitigation plan,” as Michelle R. Pfeiffer, senior project manager with CB&I Coastal Planning & Engineering Inc. in Boca Raton, characterized it in a March 16 email she wrote to Garis. CB&I is a consulting firm working with the USACE on the Lido initiative.
The extension will end on Sept.16.
Additionally, Jackson wrote in a May 26 email to the News Leader, “[A]n [Environmental Impact Statement] is unlikely since we correctly conducted the [National Environmental Policy Act] process.”
Save Our Siesta Sand 2 (SOSS2), a nonprofit organization based on Siesta Key, long has called for the USACE to prepare an Environmental Impact Statement (EIS) that would include a thorough assessment of any potential effects of the planned dredging of Big Sarasota Pass for the Lido project — as well as any other impacts on native habitat and wildlife.
On behalf of the Siesta Key Association (SKA), Robert Luckner, a member of that nonprofit group’s Environmental Committee, also asked the Sarasota County Commission during its March 23 meeting to request an EIS.
SOSS2 representatives have pointed out that Big Pass never has been dredged, and past studies have shown that its ebb shoal is a critical factor both in maintaining the stability of the beach on Siesta Key and as protection for the island during major storms or a hurricane.
Jackson also told the News Leader last week that the former manager of the Lido project for the USACE, Milan Mora, was promoted several months ago to chief of the Water Resources Section.
SOSS2 members stressed in their latest newsletter — issued this week — the inadequacy of responses they received last month from the city to a series of questions. As the News Leader has reported, those answers were for eight questions SOSS2 gave county staff earlier this year. The newsletter calls the responses “simply reiterations” of positions that Atkins —the firm that undertook a peer review of the Lido project for the County Commission — also had questioned.
The newsletter further noted, “There has been no response to [an] additional 39 questions sent in March,” which Peter van Roekens of Siesta Key, chair of SOSS2, characterized during the May 3 meeting of the Siesta Key Village Association as “fundamental questions.”
However, in a June 1 telephone interview with the News Leader, van Roekens said Alexandrea DavisShaw, the City of Sarasota engineer, wrote him in a May 31 email that she had understood the USACE would respond to all queries it had received in connection with the public meetings it and the city had held on the Lido proposal. She added that she would find out when the answers would be provided to SOSS2 and let him know.
On June 2, she provided answers to 19 more questions from SOSS2. The organization, in turn, gave the News Leader a copy of them. They follow:
The latest set
- Why has Mote Marine Laboratory (based in Sarasota) not been consulted to determine the effects of dredging Big Pass on the environment?
The USACE contacted Mote Marine Laboratory. A copy of that email correspondence for information can be provided.
- Given the dynamic nature of barrier islands, why is so much of the morphological data used in the [USACE] plan out of date?
The morphological data is not out of date. The most recent data was used at the commencement of the numerical model. The dates are detailed in the modeling report.
- There is overwhelming evidence that the Intracoastal Waterway, the bays and the area passes interact to affect the tidal flow in each pass. Given this, how can Big Pass dredging be successfully modeled in isolation from this area wide system?
The model was calibrated and verified. Big Sarasota Pass (BSP) was not modeled in isolation from the area wide system. The model reflects the hydrology of the entire system, and does not isolate BSP from Sarasota Bay and the other inlets associated with it.
- Since the last area wide inlet management plan was judged to be non-implementable by its peer reviewers, why is there no current inlet management plan?
In the USACE’s review of the process for the development of the Inlet Management Plan done by Sarasota County, we haven’t found any evidence that the plan was judged “non-implementable.” When the draft of the inlet Plan was first released for peer review, a number of engineers had comments. In response to these comments, the study was revised. The revised plan was then completed and presented to the County Commission. It is the final, revised plan the USACE reviewed and built off of when developing the present plan. It is important to point out that the Inlet Management Plan (IMP) is just a draft IMP, not yet adopted by the FDEP. The USACE’s work would add to the IMP.
- Almost 1,000 petitions have been submitted online and in hard copy by SOSS2 members asking for an area wide Environment Impact Statement to be generated. Why has this not been done?
The National Environmental Policy Act requires federal agencies to assess the environmental effects of their proposed actions prior to making decisions. If an action may have environmental effects, the first step in the process is to prepare an Environmental Assessment to identify whether or not the federal action has the potential to cause significant environmental effects. If there is the potential for significant effects, USACE may choose to simply draft an EIS rather than first drafting an EA. USACE sent a scoping letter to resource agencies, [nongovernmental organizations], and the public to allow them the opportunity to comment on the project, and also held public scoping meetings on July 23, 2014 to request their input prior to making the decision to first draft an EA rather than an EIS. As no significant concerns were presented during the scoping period, USACE followed the NEPA process and prepared the Draft EA. The Draft EA was made available for public review and comment from March 30, 2015, through May 14, 2015. While USACE is still reviewing and responding to comments received on the Draft EA, no significant impacts on the quality of the human environment that cannot be mitigated have been identified.
- By dredging all this sand [the USACE proposal calls for 775,000 cubic yards to come from Big Pass in the initial renourishment] how can there only be a benefit to Lido Key without having an impact elsewhere in the system?
The results of the … model [used by the USACE] have shown no impact elsewhere in the system.
- Why is sand being placed on Lido in areas that do not need sand?
The project doesn’t propose to place sand where it is not needed. The fill template is designed to provide an [80-foot] buffer for shoreline projection. If sand accumulates so the full 80’ isn’t needed at the time of construction, only the amount of sand needed to provide for the protection buffer and advanced fill is placed. The width of sand placed is dependent on the condition of the beach at the time of construction.
- Why hasn’t [the USACE] been willing to discuss a smaller project similar to the previous Lido renourishment?
While the City of Sarasota may design a project just for tourist or recreational reasons, allowing for construction of smaller, shorter-lived projects, the USACE’s focus is on shoreline protection. The main objective is to construct a project that will protect the area from storm events. Based on the erosion rate at which the sand left after the 2015 renourishment following just minor storms, the need for a more robust shoreline projection effort is apparent.
- Why it that the Army Corps originally said three groins were absolutely required to retain the sand and now only two are required? And why was GENESIS selected to model the groins?
The third groin is not needed at present as the most southerly end of Lido Key has grown. Should the third groin be necessary, it will be built in the future. GENESIS is the model used by the USACE to design groins and it is the model of acceptance by the FDEP and by the engineering community as a whole.
- How will [the county-owned] Ted Sperling Park [on South Lido Key] be spared the erosion that happens downdrift of groins?
The project consists of both the addition of groins and the placement of sand. It is the combination of both elements that help to preserve the Park. However, we will include adaptive management planning options so we can modify the design if ever needed. The elimination of the sheet pile from the groin design is part of this adaptive planning as it allows for modification of the groins, if needed in the future.
- New Pass and Longboat Pass require dredging every year or two to remain navigable to boats with [drafts greater than 3 feet]. Since this has never happened in a timely manner, why won’t that same problem occur in Big Pass if it is dredged?
As this is a renourishment project, dredging would occur when renourishment is needed. If an inlet management plan is desired, we would be happy to work with the County, [the West Coast Inland Navigation District] and the Corps to develop one. Numerical model has shown that dredging the shoal at BSP does, in fact, create an alternative depositional region for sediments as opposed to the location into which they are presently deposited, namely, the ebb channel which is typically used as a navigation channel.
- Several reports say that there will be a loss of sand transported to Siesta Beach. Why won’t this happen?
The reviewer should refer to the USACE CMS modeling report, available on the USACE website at http://www.saj.usace.army.mil/Portals/44/docs/Planning/EnvironmentalBranch/EnvironmentalDocs/SarasotaLidoBigSarasotaPassStudy.pdf. The answer to this question is clearly outlined in the report and it is too voluminous to repeat here.
- The recent peer review by [the] Atkins [team members] noted that there were not enough details so that they could provide an opinion about the conclusions the Army Corps reached. Are those details available and if so why didn’t Atkins receive them?
This information is available through the USACE or on the FDEP website. Atkins needs to access the website provided and review the reports. The data has been available publicly. Should Atkins need additional information, USACE is willing and able to provide requested data. It is important to point out that Atkins contacted the Corp’s [project manager] early on their review. The USACE advised Atkins to send a request on needed data, but such request was not [sent]/received by the Jacksonville District.
- The Army Corps models have been shown by [the USACE’s] own studies to be very inaccurate with an average error rate of over 100% between the sediment transport the model predicted and the actual results that occurred. Why should we have confidence in them now?
This is an erroneous statement which is completely unsubstantiated. The reviewer should provide [a] peer-reviewed periodical to substantiate statement.
(In response to this answer, van Roekens told the News Leader, “We cited their own study and have provided pointers to it many times …” He added that he raised it during a public hearing held on the Lido proposal, and the modeler for the USACE, Kelly Legault, “said she had never heard of [this].”
- Part of the Big Pass dredging plan calls for what is euphemistically called a “Borrow” area. The notion is that the sand that is removed will be replenished so that it can be removed again and again every five years. But when [the USACE] dredged a similar “Borrow” area off Longboat Key in 1993 only 10% of the sand was replenished 14 year later. Why will it be different at the Big Pass “Borrow” area?
The two Passes have completely different dynamics. The models used to predict sediment transport have improved substantially since the early 1990s, and the calibrated and verified model shows the expected transport pathways which indicate replenishment.
- When they dredged the “Borrow” area off Longboat Key there was a significant increase in wave height resulting in major shoreline erosion. Why should we expect anything different at the Big Pass “Borrow” area?
The model showed no increase in wave energy (proportional to H^2) and again, the dynamics of both Passes are different and cannot be compared in such a simplistic way.
- Why has there never been a Public Hearing held by [the City or County] Commission on the largest and longest project ever proposed in the area?
There have been Public Hearings held on various element of this project by the City of Sarasota and also by the USACE. A list of the meeting dates and locations can be provided.
- If unexpected consequences occurred either because the groins were installed or because Big Pass was dredged, what is the remediation plan and how soon could it be implemented? Would this remediation be a one-time event or a recurring event as in Venice? And given [that] remediation is even possible, where are the dedicated funds for this work?
If the groins did not perform as intended, remediation options would be available to modify or remove them. In addition, the project includes an extensive monitoring plan to identify how the project is performing. Future construction events can be modified based on the results of the surveys conducted to address any concerns that develop (otherwise known as “adaptive management”).
- If there are damages caused by this project, who is liable?
A better question may be, as we know that Lido Beach is eroding, and homes, habituate and infrastructure [are] known to be vulnerable, what is the responsibility the City and County governments have to provide protection for these known erosional issues?
Concerns not allayed
Since the former USACE project manager, Mora, unveiled the Lido plans during a Sarasota County Coastal Advisory Committee meeting in September 2013, the USACE has maintained that no adverse effects would result from the dredging of Big Pass and the installation of the groins on Lido Key. However, SOSS2 notes in its newsletter, “[A] number of books have been written about the disasters that the [USACE] has created or at least to which [it] contributed.” The latest example, the newsletter points out, is a project in Miami that resulted in “significant damage to the coral reefs.”
The New York Times reported on May 1 that a document based on a December 2015 survey undertaken by scientists for the National Marine Fisheries Service “found that as much as 81 percent of the reef” was buried in sediment near the site where the USACE undertook a large-scale dredging of Miami’s port. Further, the article says a USACE contractor’s report dated August 2015 “shows up to 93 percent partial coral death because of sediment, despite a plan by the [USACE] to minimize the damage.”
The article adds, “The damage is particularly alarming because the world is rapidly losing its reefs, partly because of global warming, experts say.” The article notes, “South Florida has the only coral reef in the continental United States ….”