Palm Beach County

REEF RESCUE
P.O. Box 207 Boynton Beach, Florida 33425 (561) 699-8559 Email: etichscuba@aol.com www.reef-rescue.org

August 13, 2013

U.S. Army Corps of Engineers 701 San Marco Blvd., Jacksonville, FL 32207 Via email: Terri.Jordan-Sellers@usace.army.mil Re: Comments and Questions Draft Environmental Impact Statement Port Everglades Expansion

Other than the obvious removal of coral habitat an underlying tenet in the Draft EIS appears to be that if presently existing coral colonies are capable of surviving initial injury from turbidity, suspended solids or direct burial that there will be no lasting impacts to their biology. No consideration is given to long-term or cumulative impacts from this and past projects on the already degraded coral reef ecosystem. In addition, there is little or no focus on the potential impacts to the corals natural biological functions, such as reproduction, larval dispersal, settlement and recruitment. This is particularly disturbing since the project is proposed to take place in federally designated protected Acroporid coral habitat critical to the survival of the species. The Draft EIS fails to assess potential project impacts on coral reproduction and preservation to essential habitat identified by NOAA/NMFS as necessary for the survival of the species. Failure to consider any impact short of total annihilation is a glairing omission and suggests a narrow and archaic view of coral reef biology. The Army Corp of Engineers (ACOE) Draft EIS appears to underestimates the impact to coral reef habitats from the project. The ACOE calculation fails to address impacts to the coral reefs east and west facing slopes below the proposed 57 foot deep channel excavation. Elevated turbidity, sedimentation, mechanical damage and rubble generated from reef-top excavation will very likely result in negative impacts to the deeper reefs zones. Why havent the impacts to the reef zones below 57 feet been taken into consideration in the ACOE loss of coral habitat calculations? The failure to include the added coral loss also results in an underestimation of coral mitigation needed resulting of project impacts.

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To monitor, preserve and protect the coral reef ecosystem of South Florida through

research, education and public awareness

Palm Beach County

REEF RESCUE
The Draft EIS describes secondary impacts to coral habitat up to 150 meters from the channel excavation, but fails to provide any rationale or justification to support this estimate. Was this estimation based on any scientific methodology? Based on observations of coastal dredge and fill projects along the southeast coast of Florida it is our opinion that sediment and turbidity impacts will extend well beyond 150 meters from the channel excavation area. How will any and all negative impacts beyond 150 meters from the channel be documented? Considering the potential for a substantial increase in tidal flushing through the enlarged channel after expansion, has the ACOE evaluated potential interruption of larval coral transport from increased flushing along the reefline? Has the ACOE considered impacts on coral spawning, larval transport and survival? How has sedimentation and turbidity impacts to Acropora coral critical habitat been evaluated? At the July 2012, 12th International Coral Reef Symposium in Cairns, Australia, 2,600 of the worlds most respected coral reef scientists signed a Consensus Statement urging governments to take action for the preservation of coral reefs for the benefit of present and future generations. The Consensus Statement calls on all governments to ensure the future of coral reefs, through global action to reduce the emissions of carbon dioxide and other greenhouse gases, and via improved local protection of coral reefs. Coral reefs are important ecosystems of ecological, economic and cultural value yet they are in decline worldwide due to human activities. Land-based sources of pollution, sedimentation, overfishing and climate change are the major threats, and all of them are expected to increase in severity. The Statement specifically addresses sedimentation stating Coral reef death also occurs because of a set of local problems including excess sedimentation, pollution, habitat destruction, and overfishing. These problems reduce coral growth and vitality, making it more difficult for corals to survive climate changes. Currently, one Endangered Species Act (ESA) protected coral (Acropora cervicornis) occurs within the EIS impact area. The National Marine Fisheries Service (NMFS) is _______________________________________________________________________ _ 2

To monitor, preserve and protect the coral reef ecosystem of South Florida through research, education and public awareness

Palm Beach County

REEF RESCUE
now in the process of considering an additional 82 coral species for ESA protections due to their potential extinction risk. Of the 82 corals, seven are found in Broward County and within the footprint of the proposed port expansion. According to NMFS Biological Review Teams findings; of these seven, five topped the list of the 82 corals as most likely to become extinct by the end of the century unless protective measures are instituted. Impacts from turbidity and sedimentation on corals are well documented and range from direct burial, increased metabolic stress to degradation of substrate preventing coral recruitment. Sediment deposition and accumulation affect the overall amount of suitable substrate available for larval settlement, recruitment, and fragment reattachment (Babcock and Davies 1991, Birrell et al. 2005); both sediment composition and deposition affect the survival of juvenile corals reducing available substrate for larval recruitment. Habitat degradation from sediment deposition can disrupt cues for larval settlement, leading to limited or failed recruitment potential and increased larval mortality. Coral reproduction and recruitment are far more sensitive to changes in water quality than adult corals (Fabricius 2005). Accumulation of sediments can be a cause of mortality in coral recruits (Fabricius et al. 2003). Settlement rates for coral larvae and reattachment rates for fragments are near-zero on sediment-covered surfaces (Fabricius 2005). Rogers (1983) investigated the effects of sedimentation on several coral species documenting a single application of 200 mg/cm2 to colonies caused coral tissue death. Hodel and Vargas-ngel (2007) noted degenerative histopathological changes in staghorn coral exposed to sedimentation rates of 200 mg/cm2, indicating sub-lethal damage to the coral and compromised health. Riegl and Branch (1995), documented sedimentation rates greater than 100 mg/cm2 can kill exposed coral tissue within a period of a few days. Sedimentation levels less than 100 mg/cm2 reduce photosynthetic yields in corals (Philipp and Fabricius, 2003), and the removal of settled particles by coral polyps increases metabolic costs (Telesnicki and Goldberg, 1995). In coral colonies, sedimentation stress increases linearly with the duration and amount of sedimentation: for example, a given amount of sediment deposited on the coral for one time unit exerts the same measurable photophysiological stress as twice the amount deposited for half the time (Philipp and Fabricius, 2003). Coral damage appears to not only depend on the amount and duration of sedimentation, but also strongly depends on the sediment type. Tissue damage under a layer of sediment increases with increasing organic content and bacterial activity and with decreasing grain sizes (Hodgson, 1990;

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To monitor, preserve and protect the coral reef ecosystem of South Florida through research, education and public awareness

Palm Beach County

REEF RESCUE
Weber et al., 2004). Low-level sedimentation (12 mg/cm2) when combined with exopolymer particles (possibly polysaccharides exuded by bacteria) kills newly settled coral recruits. These and similar data demonstrate the critical interactions between sediment quality and quantity on coral damage (Fabricius and Wolanski, 2000). They also show that short exposure to sediments (a few days) can cause long-term effects in populations, by removing cohorts of young corals and thus retarding reef recovery after a disturbance. Rogers (1979) simulated sediment shading in a 20 square meter area of reef. Three weeks after shading was initiated, most colonies of staghorn coral were bleached. Shading was terminated after 5 weeks. After six weeks, the growth tips of the staghorn coral were deteriorating or had been grazed away. A few branches recovered; most were dead and covered with algae. After seven weeks, there were more algae on the branches and further disintegration of branch tips. Light affects both reproduction and recruitment, as coral fecundity decreases in low-light conditions, and coral larvae use light quantity and quality to choose their settlement site. At low light levels, corals preferentially settle on upper surfaces, where the risk of sedimentation damage is high, rather than on vertical of downward facing surfaces (Birkeland et al., 1981). At highly turbid conditions, coral recruits may undergo reverse metamorphosis, indicating conditions are unsuitable for continued development and growth (Te, 1992). Sedimentation strongly inhibits successful coral reproduction, especially coral settlement and recruit and juvenile survival. Sedimentation mortality thresholds for coral recruits are an order of magnitude lower than those for larger colonies (loads of tens rather than hundreds of mg/cm2; Fabricius et al., 2003). Few coral larvae settle on sediment covered surfaces, and survival on such surfaces is minimal. Local divers have been observing ever-increasing accumulations of sediment on offshore coral reefs resulting from past coastal construction projects. At many sites the sediment accumulations have obscured resident crustose coralline algae (CCA) populations. Larval corals preferentially colonized CCA sites. Successful coral recruitment involves specific cues that connect planktonic larvae with CCA during settlement (Doropoulos et al 2012). How does the ACOE intend to monitor potential regional large-scale sediment degradation to the Acropora critical habitat substrate as it relates to larval coral recruitment and survival?

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To monitor, preserve and protect the coral reef ecosystem of South Florida through research, education and public awareness

Palm Beach County

REEF RESCUE
How will the turbidity monitoring protocol employed to protect the surrounding Acropora critical habitat from immediate and long-term post-project impacts ensure there will be no loss or negative impact to the federally protected critical habitat substrate? Will there be penalties for permit turbidity violations? What methodology will be employed to assess sediment accumulation during and after project construction as it relates to protecting substrate to ensure successful larval coral settlement and survival? What sediment accumulation value will be considered as protective to the reef substrate to ensure future successful coral recruitment and larval survival? Impacts from the proposed project on coral spawning, larval settlement and recruit survival have not been adequately addressed in the Draft EIS. The Draft EIS fails to take into consideration the chemical nature of the suspended solids impacting the receiving environment during excavation of sediments within the port. Results of sediment analysis published by the Florida Department of Environmental Protection (Florida coastal sediment contaminants atlas a summary of coastal sediment quality surveys, 1994) found both metal and organic contamination are ubiquitous in intracoastal sediments (http://ufdc.ufl.edu/UF00099283/00001/2x) Ports, marinas and boatyards are notorious for containing contaminated sediments, including Polycyclic Aromatic Hydrocarbons (PAHs), organic contaminants, heavy metals and most notably tributyltin (TBT). TBT, a component of marine antifouling paints, is toxic to aquatic organisms such as mussels, clams, and oysters. At low levels, TBT can cause structural changes and growth retardation. TBT binds strongly to suspended particles such as minute organic material or inorganic sediments, it is well documented that TBT persists in marina/boatyard sediments. Liberation and suspension of entombed TBT and other hazardous material can have a devastating impact on invertebrate reproduction. In addition to the above listed shipyard related contaminants, there is a high likelihood agricultural and urban runoff pollutants may be present in sediments within the proposed port expansion footprint. The Port Everglades receives runoff from the Everglades Agricultural Area (EAA). Contaminates present in EAA sediments can include arsenic,

pesticides, herbicides, DDT and its degradation products. The South Florida Water Management District, Ambient Pesticide Monitoring Network Technical Publication 105 _______________________________________________________________________ _
To monitor, preserve and protect the coral reef ecosystem of South Florida through research, education and public awareness

Palm Beach County

REEF RESCUE
(October 2009) lists the following 21 most frequently detected pesticides, herbicides, Aroclors and degradation products found in EAA drainage sediments: aldrin, alpha endosulfan, ametryn, atrazine, bromacil, beta endosulfan, chlordane, dicofol, dieldrin, diquat, diuron, p,p-DDD p,p-DDE, p,p-DDT, endosulfan sulfate, ethion, norflurazon, PCB-1016, PCB-1242, PCB-1254, PCB-1260. (http://my.sfwmd.gov/portal/page/portal/pg_grp_tech_pubs/PORTLET_tech_pubs/sfwmd _105.pdf, Table 7) What chemical and physical analysis of port sediments was performed/reviewed in preparation of the Draft EIS? What are the anticipated impacts from suspension of contaminated sediments, routes of exposure and long-term effects on the public health, flora and fauna during and post-project? Sincerely, Palm Beach County Reef Rescue, submitted by Ed Tichenor, Director on behalf of Palm Beach County Reef Rescue

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To monitor, preserve and protect the coral reef ecosystem of South Florida through research, education and public awareness