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y
o
APPENDIX G
COMMENTS ON THE DRAFT TAMPA BAY BIS
AND EPA'5 RESPONSES TO THOSE COMMENTS
SEPTEMBER, 1983
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r--.«'i.-;^' :- .
TT&^3ti";>^^^
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The Draft EIS (DEIS) was released November, 1982. This Appendix
includes copies of written comments received by EPA on the DEIS. Responses
to comments were addressed in one of three ways:
0 Acknowledgement of comments for those requiring no response.
0 Correction or addition of information incorporated into text as
noted.
0 Specific comments not requiring text changes but requiring a
response are numbered in the margins of letters with responses
following.
EPA appreciates the time and effort taken by those who offered their
comments on the DEIS. Comments, criticisms, and additional information
offered were carefully considered in preparation of the Final EIS.
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FLORIDA DEPARTMErfT OF STATE;l \ \rr-;--
George Firestone
Secretary of State
DIVISION OF ARCHIVES, .
HISTORY AND RECORDS MANAGEMENT
The Capitol, Tallahassee, Florida 32301
(904)488-1480
November 30, 1982 In Reply Refer To:
Mr. Frederick P. Gaske
Historic Sites Specialist
(904)487-2333
Mr. Walter 0. Kolb
Division of State Planning >-••
Department of Administration ^T f i r
Office of the Governor / '
The Capitol
Tallahassee, Florida 32301
Re: Your Memorandum and Attachment of November 19, 1982
Cultural Resource Assessment Request
Draft Environmental Impact Statement for Tampa Harbor
/""""Ocean Dredged Material Disposal Site Designation, ~?
\ Hillsborough County, Florida _ _f
Dear Mr. Kolb:
In accordance with the procedures contained in 36 C.F.R.,
Part 800 ("Procedures for the Protection of Historic and
Cultural Properties"), we have reviewed the above referenced
project for possible impact to archaeological and historical
sites or properties listed, or eligible for listing, in the
National Register of Historic Places. The authorities for
these procedures are the National Historic Preservation Act
of 1966 (Public Law 89-665) as amended by P.L. 91-243, P.L.
93-54, P.L. 94-422, P.L. 94-458 and P.L. 96-515, and Presiden-
tial Executive Order 11593 ("Protection and Enhancement of the
Cultural Environment").
A review of the Florida Master Site File indicates that
no inundated cultural resources are recorded within Shallow-Water
Alternative Site 4. Furthermore, use of the area for disposal of
ocean dredged material is deemed unlikely to affect any cultural
resources which may be present. Therefore, it is the opinion of
this office that the proposed project will have no effect on sites
listed, or eligible for listing, in the National Register of Historic
Places, or otherwise of national, state or local significance.
FUDRIDA-State of the Arts
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V
Mr. Walter O. Kolb
November 30, 1982
Page Two
If you have any questions concerning our comments, please do
not hesitate to contact us.
Your interest and cooperation in helping to protect Florida's
archaeological and historical resources are appreciated.
Sine
George JR, Percy
Deputy State Historic
Preservation Officer
GWP:Geb
cc: U. S. Environmental Protection
Agency
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DEPARTMENT OF HEALTH & HUMAN SERVICES
Public Health Service
Atlanta GA 3C333
(404) 452-4095
December 3, 1982
2-1
2-2
Criteria and Standards Division (WH-585)
Environmental Protection Agency
401 M Street, S.W.
Washington, B.C. 20460
Gentlemen:
We have reviewed the Draft Environmental Impact Statement (SIS) for Tampa
Harbor, Florida, Ocean Dredged Material Disposal Site Designation. We are
responding on behalf of the Public Health Service.
We have reviewed this document for possible health effects and find that
the proposed alternatives have been adequately addressed. We trust that
both the existing site and the proposed disposal site will be monitored for
dispersion of dumped materials and also for adverse impacts on the local
fauna which could cause long-term food-chain effects.
Thank you for the opportunity of reviewing this Draft EIS.
a copy of the -final document when it becomes available.
Sincerely yours,
Please send us
Frank S. Lisella, Ph.D.
Chief, Environmental Affairs .Group
Environmental Health Services Division
Center for Environmental Health
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I
TAMMPOKT
AUTHORITY
Serving America'* Seventh Largest Port
December 6, 1982
3-1
3-2
Mr. T. A. Wastler, Chief
Marine Protection Branch (WH-585)
Environmental Protection Agency
Washington, D.C. 20460
Reference: 40 CFR Part 228
(OW-FRL 2234-8)
Proposed Designation of Ocean Disposal Site; Tampa Harbor
Dear Mr. Wastler:
I am writing in response to the public notice which appeared in the
8 November 1982 Federal Register concerning proposed designation of a per-
manent disposal site for dredged material from the Tampa Harbor Project.
I have reviewed the Draft Environmental Impact Statement issued by your
agency in regard to this proposed action on 29 October 1982. In addition,
I have reviewed all of the ancillary and background material regarding
this and other alternative.sites which is referenced in that document.
In general, we support the proposed designation proposed in the
8 November 1982 public notice. We agree with the conclusion expressed in
the notice and the DEIS that current interim Disposal Sites A and B may
not be the best locations for the disposal of dredged material due to the
presence of sensitive hard-bottom communities to the west and north of
these" areas. Based on the limited information presented in the DEIS and
supporting documents, we agree that alternative Site 4 appears to be a
more acceptable site for the disposal of dredged material.
However, we are concerned that there has not been presented sufficient
evidence to confirm that all of alternative Site 4 is acceptable for
dredged material disposal. The television camera inspection presented by
EPA covers only a small portion of the 4 sq. mile-site. In addition, the
numerous sediment and biological samples collected during the EPA survey
appear to have been conducted using surface-deployed sampling devices.
The use of such devices does not afford information regarding the possible
presence of viable hard-bottom communities in those areas sampled.
cont...
POST OFFICE BOX 2192 •
GEORGE B. HOWEIL MARITIME CENTER
8H WYNKOOP ROAD • TAMPA, FLORIDA 33601
AN EQUAL OPPORTUNITY EMPLOYE*
• 813/248-1924 • TEEX 52441
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N
Mr. T. A. Wastler
December 6, 1982
Page 2
It would be our recommendation that, prior to final designation and use of
this site, additional inspections of the area be conducted utilizing either
divers or the television camera to confirm the absence or limited presence
of hard-bottom communities and predominance of sandy substrates cited in
the DEIS for the entire area included in the proposed action. We are con-
cerned that in the absence of such information this designation, and any
dredging contract conducted pursuant thereto, may be open to the same
challenge and delays which have been experienced in regard to the use of
interim Sites A and B. Delays which might result from such challenges
would have a severe economic impact on the Port of Tampa since the recently
proposed work in Section 38 of the Tampa Harbor Project is the last work
necessary for completion of the present phase of that project.
Respectfully,
~2 /
-&<6****f
William K. Fehring, Ph.D. /
Director of Environmental Xffairs
/
WKF:bw
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3AMBVPOR1
iSUTHOMTY
"-"-i* •-
Serving America's Seventh Largest Port
December 6, 1982
Criteria and Standards Division (WH-585)
401 M Street, Southwest
Environmental Protection Agency
Washington, D.C. 20460
Reference:
Gentlemen:
Draft Environmental Impact Statement
Ocean Dredged Material Disposal Site Designation
Tampa Harbor, Florida
I have reviewed the Draft Environmental Impact Statement published by your
4-1 agency on 29 October 1982 in regard to the proposed permanent designation
of a site for the disposal of dredged material from the Tampa Harbor Pro-
ject. In addition, I have reviewed the supporting documents, video tapes,
studies, and reports which have been presented by your agency to support
this DEIS.
In general, this Authority can support the proposed designation of Site 4
4_2 for dredged material disposal as described in the DEIS. We agree with the
conclusion expressed in the DEIS that interim sites A and B which are cur-
rently being utilized may not be the most appropriate sites for long-term
disposal of dredged material due to the presence of sensitive hard-bottom
communities near those areas. Based on the limited information contained
in the DEIS and associated documents, we agree that alternative Site 4
appears to be more appropriate for use as a long-term dredged material dis-
. posal site.
However, we are concerned that the DEIS and the accompanying documentation
do not contain sufficient evidence to confirm that all of alternative Site
4 is appropriate for the proposed use. We note that the video tape of
Site 4 covers only a very small portion of the 4 sq. mile-proposed site
While the sediment and infaunal analyses described in the DEIS and attached
documentation is certainly complete, the apparent use of surface-deployed
sampling devices makes this data of little use in determining the presence
or absence of sensitive hard-bottom communities within the proposed site.
cont...
POST OFFICE BOX 2192 •
GEORGE B. HOWELL MARITIME CENTER
811 WYNKOOP ROAD • TAMPA, FLORIDA 33601
AN EQUAL OPPORTUNITY EMPLOYER
• 813/248-1924 • TELEX 52441
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Criteria and Standards Division
December 6, 1982
Page 2
We would strongly recommend that additional visual inspections of the pro-
posed disposal site be conducted utilizing either local divers or the
camera equipment utilized previously. We believe that it may be important
to confirm the absence of hard-bottom communities and the predominance of
sandy substrates cited in the DEIS. We are concerned that in the absence
of such additional observations, this designation may be subject to the
same challenges which have been experienced with regard to the use of
interim disposal Sites A and B.
Such challenges may result in delays to the final contract of the Tampa
Harbor Deepening Project and thus may have significant economic cost to
this Authority and to the Port of Tampa.
Should the decision be made to conduct the additional inspections by
divers which we have recommended, I would offer my personal assistance to
such efforts.
Respectfully,
William K. Fehring, Ph.D.
Director of Environmental A/fairs
WKF:bw
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State of Florida
DEPARTMENT OF NATURAL RESOURCES
DR. ELTON J. GiSSENDANNER
Cnanltt DbMMr
3NO COMMONWEALTH BOULEVARD / TALLAHASSEE 3Z303
BOB GRAHAM
Governor
GEORGE FIRESTONE
Secretary of Stale
JIM SMITH
Attorney General
GERALD A. LEWIS
Comptroller
BILL GUNTER
Treasurer
DOYLE CONNER
Commissioner of Agriculture
RALPH D. TURLINGTON
Commissioner of Education
December 8, 1982
5-1
5-2
United States Environmental Protection Agency
Criteria and Standards Division (WH-585)
401 M Street Southwest
Washington, D.C. 20460
Dear Sirs:
The Florida Department of Natural Resources thanks you for the
opportunity to comment on the Draft Environmental Impact Statement
for Tampa Harbor, Florida Ocean Dredged Material Disposal Site
Designation.
Department testimony presented at the Army Corps of Engineers Public
Hearing June 30, 1982 called for the immediate cessation of dumping
at current Interim Site A. The Department continues to be of that
opinion. Further, the Department reiterates its concern regarding
any dredged material disposal offshore and its support for land-based
alternatives.
In regards to the current Draft Environmental Impact Statement, staff
review (attached) has shown it to be a fragmented, poorly developed
document which is both redundant and contradictory. The document is
inadequate for the purposes proposed as it does not explore all alterna-
tives; it does not present a thorough environmental review; and it
proposes a new interim site (Site 4) without adequate survey or investi-
gation of the site.
DIVISIONS /
ADMINISTRATION • LAW ENFORCEMENT * MARINE RESOURCES
RECREATION AND PARKS • RESOURCE MANAGEMENT * STATE LANDS
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Environmental Protection Agency
December 8, 1982
Page Two
It is the Department's request that the Environmental Protection Agency
5-3 withdraw this draft and schedule full public hearings to receive necessary
public and private input to the document and any subsequent designations.
Sincerely,
Elton J. Gissendanner
EJG:ghh
Attachment
cc: Governor Bob Graham
Florida Legislative delegation
Manatee County Commission
Edwin A. Joyce, Jr.
Karen A. Steidinger
George E. Henderson
Walter Jaap " •
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of Natural Resources
-T.ar.zs on Draft environmental Impact Statement
imps. Harbor, Florida Ocean Drsdged Material
Disposal Site Designation
5-4
5-9
These comments ar= referenced by page and line for ease in following the
critique. Since review time was short it can be expected that some
additional comments could be made or expanded especially regarding physical
oceanography and hydrology.
Page x. You have not included certain existing diked dredged disposal
islands that could be used for the ongoing projects. In many cases they
are closer to the dredge projects than offshore disposal sites. In fact,
consideration is only to offshore Gulf sites.
5.5 Page xii, line 4. Should be 82'55'06"W not 83'55'06"W.
Page xiii, line 15. Change hard bottom to "live bottom." Refer to CFR
1978, "Live bottom areas are defined as those areas which contain
biological assemblages consisting of such sessile invertebrates as sea
5_5 fans, sea whips, hydroids, anemones, ascidians, sponges, bryozoans, or
corals living upon and attached to naturally occurring hard or rocky
formations with rough, broken, or smooth topography or whose lithotope
favors the accumulation of turtles and fishes."
Page xiii, lines 19-22. The conclusion that site 4 does not contain live
bottom communities is not based on adequate field reconnaissance. The
5-7 survey relied on incomplete remote data acquisition and box coring using a
symetrical station pattern. Patchy distribution of live bottom requires
intensive in situ observations to insure that the total site of surrounding
areas are sand or sedimentary facies.
Page xv, item 9. The benthic community is composed of two components.
First, infaunal communities in the sediments and secondly, live bottom
5-8 communities superimposed on rock. This includes sessile attached algae,
sponges, corals, bryopzoans, tunicates and mobile invertebrates and
demersal fish populations. Both infaunal and live bottom communities are
composed of subtropical-tropical and temperate species.
Page xvi, lines 25-29. Note that the studies referred to are confined to
"Sandy bottom habitats." Here we are dealing with sandy and live bottom
habitats. Decolonization of a sedimentary habitat cannot be extrapolated
to equate to recolonization of live bottom habitats that occur offshore of
Tampa Bay.
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United States Environmental Protection Agency
Page two
7 December 1982
. Page xvii, line 4. Your statement of "will provide 4 nmi of sand bottom"
5_10 is made on the basis of symetrical sampling stations, using a box core, and
discarding any sample that contained <15 cm of material. This is a poor
technique for reconnaissance of an area suspected to contain contagious
distribution of live bottom. The statement that the alternative site is
"safe" is an unsubstantiated hypothesis at best.
Page xvii, line 22. "Most of the living corals are found shoreward of the
5-11 .10 m isobath, although, some exist to 60 m." Most reef Scleractinian,
Octocorallian, and Milleporarian corals are found in 10 to 40 m, very few
are found in depths <10 m. Beyond 50 m, many ahermatypic corals are found,
see Cairns (1979).
Page xviii, line 28. The most common fish associated with the live bottom
5-12 habitat includes red grouper, white grunt, mangrove snapper, triggerfish,
and belted sand fish.
>
Page xix, line 4. Hard bottom (live bottom) areas are inhabited by algae,
5-13 sponge, corals, bryozoans, tunicates, and a diverse motile fauna of
crustaceans, polychaetes, molluscs, echinoderms, and fish.
Page xix, line 8. Recreational activities are important to the economy,
5-14 they generate a great amount of money through attendant service industries:
dive shops, marinas, ice, fuel, bait, and boating accessories all are
significant.
_ Page xix, line 26r27. Again, similar habitats are not being compared. The
5-15 impact of dredge spoil on a sedimentary habitat cannot be extrapolated to a
live bottom community.
c ,g Page xx, lines 18-22. Sea turtles, especially loggerheads, often remain on
the same outcrop or live bottom site. Burial of the site may be
significant to individuals. This is important during breeding periods
since turtles tend to use the same areas to mate and nest. During
internesting intervals, sea turtles remain in the immediate nearshore
vicinity. Degrading the offshore environment may disrupt reproduction
success.
c 17 Page xx, lines 27 and 28. Your conclusion that long term adverse
biological effects will not occur from contaminants is not supported.
cio Page xxi, line 3-5. Other resources lost due to disposal would include any
live bottom habitat that dredge spoil was dumped on, loss of fish and other
renewable resources from the site.
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United S;«
Page three
7 December
:;::;.*.L3i Protection Agency
5-19
5-20
5-21
5-22
5-23
5-24
5-25
5-26
5-27
5-28
Page xxi, lines 4 £.-d 5. If you cite the benefits of marine commerce you
should also cite the negative aspects of these activities. For example the
the accidents and loss of life (Blackthorn-Capricorn, Sunmet Venture vs the
Skyway Bridge), numerous other accidents; two barges hit the bridge in
November, one was the dredge contractors. Commerce also has other
undesirable attributes i.e., oil spills and resultant environmental
degradation.
Page xxi, line 22-26. The studies to date are insufficient to document
that there is less hard bottom (live bottom) in the site 4 area.
Page 1-7, lines 11 and 12. To date, EPA and the Corps studies are not
adequate to select or designate a most suitable site.
Page 2-1. You dp not evaluate the existing bulkhead spoil disposal islands
in Tampa Bay. Also, abandoned phosphate pits east of Tampa are potential
disposal sites. Only gulf sites are considered.
t
Page 2-2, line 4. Mid-shelf areas are not any more environmentally
sensitive than areas near to shore.
Page 2-3, line 11. It would be better to consistently use Lyons and
Collard (1974) terminology-for benthic community distribution.. The Collard
and D'Asaro (1973) interpretation is not as accurate for offshore areas.
Page 2-3, lines 12 and 13. Chapter 3 of this draft indicates low average
winds and seas at the nearshore sites. Lyons and Collard (1974)
characterization referred to the area as the shallow shelf 10-30 m (30-100
ft). Temperature and substrate are the physical-geological controls.
Occasional severe storms place stress on this area, but it is not a
consistent influence. Freshwater runoff, with the exception of hurricane
generated rains, has little influence on bottom communities 13 to 17 nmi
off the mouth of Tampa Bay.
Page 2-5. Land-based disposal. Why were the spoil islands in Tampa Bay
eliminated from consideration?
Page 2-6, line 22. What are the technical and environmental reasons fot
concluding that ocean disposal of sediments is the most practical method of
disposal? Your site specific studies are inadequate to show that disposal
is not harmful to the adjacent live bottom communities.
Page 2-11, lines 11 and 12. Previous characterization on page xvi, line 3
states "(currents) are generally less than 1 kn." Furthermore, the cited
reference (Holliday 1978) is not relevant, there is nothing in this report
dealing with currents off Tampa Bay.
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United Spates Envir ^n-isr.tal Protection A j . •
Page four
7 December 1982
. Page 2-11. In reference to animal species found in =e region, one should
refer to the many Hourglass monographs. Jaap (in prep.) identified 16
5-29 species of stony corals. There is no attempt to characterize dominant live
bottom flora or fauna in this EIS.
Page 2-13, line 10-12. Was there a rational reason why the May 1982 site
5-30 specific survey did not sample live bottom? There is admission that live
bottom does exist, but failure to sample or study its biota.
Page 2-14, lines 5 and 6. What evidence do you cite to state that "animals
of a shallow-water area must be adapted to periodic burial — ."? You fail
5-31 to cite the range of what "shallow water" is; define your terms. The area
in 16-30 m depth is not a region of high energy. Your contention that
disposal at a mid-shelf site would have longer adverse effect on the biota
is" inadequately supported. The community type is important when
considering sites. There is more live bottom in the nearshore 10-30 m
depths than in 70 m depth off Tampa Bay.
5-32 page 2-15, line 1. Long line fishing does occur in this area.
Page 2-16, lines 22-24. The, Hirsch et al. (1978) statement is irrelevant
5-33 to the area off Tampa Bay in depths of 16-30 m. Live bottom communities
. are not unstable and are not sedimentary.
Page 2-17, lines 1-3. The lack of addressing the effect of fine -silt-like
5-^4 sediment chronically deposited over a long period of time on live bottom
habitat is of more concern than mixing different types of sediments,.
5-35 bottom.
Page 2-19, lines 9 and 10. Interim site A had a considerable amount of
1^ bottom.
Page 2-19, lines 20-24. The video tape was only a small portion of the
entire site. No side scan sonar or seismic survey of the area was made.
Symetrical sampling with box cores is inadequate to discover live bottom.
Page 2-21. Amenity Areas. Egmont Key and Passage Key, at the mouth of
(. ,, Tampa Bay, are National Wildlife Refuges with nesting sites for endangered
species (Loggerhead turtle) and species protected by statute (brown
pelican). Least terns, black skimmers and laughing gulls also nest on
these islands.
5_38 Page 2-21, lines 18 and 19. U.S. Fish and Wildlife Service 1982 identifies
reef (live bottom) areas in the area, with red grouper, cobia, grunts, gag
grouper, and sea bass.
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United States Environmental Protection Agency
Page five
7 December 1982
5-39
5-40
5-41
5-42
5-43
5*44
5-45
Page 2-22, line 2. The survey was inadequate to confirm that major live
bottom areas do not occur within the site.
Page 2-24, paragraph 2. What is the source for this information?
Page 2-24, paragraph 3. Site A has received 4.4 million yd^, site B
received its volume over 5 years and the total was 1,020,000
There is no evidence to insure that the mound at Site A won't remain. Some
of the material is rock 1 ft or more in diameter.
dynamic seas to move it.
It will take very
Page 2-25, paragraph 2. The dredge disposal sites are in 40 ft depth or
greater. This is not a "high energy environment" with the exception of a
hurricane passing closeby.
Page 2-25, paragraph 3. It is not valid to compare eastern Gulf sites
containing live bottom communities with a sedimentary site off Galveston,
Texas. Furthermore, Taylor's (1982) work was largely restricted to
soft-bottom infaunal recovery; he did not quantitatively look at live
bottom or hard bottom communities. The nine-year temporal parameter is not
a valid figure for the live bottom situation. Experience in coral reefs
may be extrapolated for time1estimates. Grigg and Maragos (1974) reported
a time period of 20 to 50 years for recovery following lava flows. Pearson
(1981) reported in reference to reef recovery "The situation is not clear,
following man-made disturbances, where the environment may have undergone
permanent change." Pearson reported that following natural disturbance,
coral communities reguire several decades to recover. '-
Page 2-25, paragraph 4. What research substantiates the claim that "no
major differences In finfish and shellfish species or numbers have been
found between stations within the affected site and control stations."?
The 1979b cited report is a EIS for port and crude oil distribution in
Galveston, Texas. It is irrelevant to the Tampa Bay disposal sites.
Page 2-27, last paragraph. Many of the studies cited are not applicable,
they are restricted to Tampa Bay and not the nearshore Gulf (Saloman 1973);
others are not included in the references (Saloman and Saloman et al.
1968). The Smith et al. (1975), Dawes and van Breedveld (1969), through
Huff and Cobb (1979) are not ecological studies of the area in question.
Smith et al. (1975) is a study of Florida Middle Ground fish and Cairns
(1977) is a taxonoraic-systematic account of Caryophyllid-Dendrophyllid
Scleractinia from the Hourglass Cruises.
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United Scares Environmental Protection Age:'-:-
Page six
. 7 December 1982
Page 2-28, paragraph 2. The area also contains liv~ bottom communities.
5_46 *c i-8 noc a high energy environment. The Holliday 1978 report does not
contain any data about Tampa Bay nearshore environments.
Page 2-29, conclusion 4. The studies were insufficient to insure that
5.47 major live bottom assemblages do not occur in the Site 4 area.
Page 2-32, line 14. This 1980 survey must be a typo; this is the first
mention of it, and it is not in the references. Monitoring guidelines fail
to address live bottom biota. This is the most sensitive community. Both
5-48 Courtney et al. (1974) and Griffin (1974) have guidelines for monitoring
and protecting reef type habitats in and around dredging operations that
should be used here.
Page 2-33, line 15. The statement "—(hard and soft corals) are expected
to occur, only to a limited extent, in the selected site; a survey to
assess these species need not be made." is wrong. First, on the basis of
your cursory field study, you have no idea of coral abundance within the
area. Secondly, to write them off is a poor and indefensible option.
5-49 Florida statute (370.114) and proposed federal fishery management plan
regulations (Gulf of Mexico and South Atlantic Fishery Management Councils)
make it illegal to harvest;, sell, or destroy stony corals (orders
Milleporina and Scleractinia) and the sea fan Gorgonia. It would seem
rational that your guidelines reflect Florida law and the Fishery
Management Councils concern regarding the value of coral and its intrinsic
habitat value.
Page 2-34, lines 16, 17. Benthic sessile epifauna is more sensitive than
5-50 the infauna. Attached epifauna is unable to leave the area.
Page 2-34, lines 17, 18. The numerically abundant organisms on live
bottoms can be observed and censused in situ and monitored for change as
5-51 well as infaunal populations.
Page 2-35, paragraph 1. It would appear that several macroinvertebrates
are found in the area that could serve for trace metal accumulation study.
5-52 fhe arc Noetia ponderosa, starfish Astropectin, and Echinaster, and several
Holothurian species are common and remove nutrients from the sediments or
s'ediment water interface.
Page 3-8, paragraph 4. .Sediments of Tampa Bay are from previous time, the
- ct bay at Present " not creating any appreciable sediments (Brooks, 1973 and
3~" Doyle and Sparks 1980).
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United States Environmental Protection Agency
Page seven
7 December 1982
5_54 . Page 3-30, third line from the bottom. Sessile epibenthic organisms are
better indicators than infauna.
Page 3-29 follows page 3-30.
5_55 Page 3-32. Change Gymnodinium breve to Ptychodiscus brevis-, see Steidinger
(1979).
Page 3-43, line 3. The corals are colonial and solitary. These outcrops
5-56 also support a diverse assemblage of sponges, bryozoans, tunicates, all of
which are sessile and provide habitat for many mobile organisms.
Page 3-43, line 27. The corals Cladocora arbuseola and Solenastreas hyades
5-57 are not Alcyonarians, they are Scleractinians.
Page 3-47, paragraph 1. You"should include information on the economics of
5-58 bait, gas, boats, supplies, ice, diving, and other service industries that
are fishing and boating related.
Page 3-47, paragraph 2. Spotted sea trout is not a fish found in the
5-59 dredge spoil area.
Page 3-48. Landing statistics for shrimp are misleading, Tampa-St. Pete
landings include harvest from Tortugas, Ft. Meyers, Texas, and at one time
5-60 Mexico. Vessels fish many areas far from these ports.
' «
Page 3-51, paragraph 3. Egmont Key and Passage Key are U.S. Fish- and
5-oi Wildlife Service Wildlife Refuges.
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17
United S:__. . r-j;-..T->.r.ial Protection Agency
Page eigh'
7 December i?'CZ
LITERATURE CITED
Brooks, H.K.
1973. Geological Oceanography pp. II, El to IIE50, in A summary of
knowledge of the eastern Gulf of Mexico. Coordinated by State
University System of Florida, Institute of Oceanography, St.
Petersburg, FL.
Cairns, S.
1979. The deep-water Scleractinia of the Caribbean Sea and adjacent
waters. Vitgaven Natuurwetenschappelijke Studiekring voor
Suriname en de Nederlandse Antillen 96. 341 pp.
Courtenay, W., D. Herreraa, J. Thompson, W. Azzinaro, and J. van Monfrans.
1974. Ecological monitoring of beach erosion control projects, Broward
County, Florida, and adjacent areas. U.S. Army Corps of Engineers
Coastal Engineering Research Center, Tech. Mem. 41, Ft. Belvior,
VA. 88 pp.
Doyle, L., and T. Sparks.
1980. Sediments of Mississippi, Alabama, and Florida. J. Sed. Petrol.'
50(3): 905-916.
Griffin, G.
1974. Dredging in the Florida Keys. A case history of a typical
. dredge-fill project in the northern Florida Keys—effects on water
quality, sedimentation rates, and biota. Harbor Branch Foundation
Publ. 33. Ft. Pierce, FL. 67 pp. .
Grigg, R., and J. Maragos.
1974. Recolonization of hennatypic corals on submerged lava flows in
Hawaii. Ecology 55: 387-395.
Pearson, R.G.
1981. Recovery and recolonization of coral reefs. Mar. Ecoi. Prog. Ser.
4: 105-122.
Steidinger, K.A.
1979. Collection, enumeration, and identification, of freeliving
Dinoflagellates, pp. 435-442 rn^ D. Taylor and H. Seliger eds.
Toxic dinoflagellate blooms. Elsevier, North Holland, NY.
U.S. Fish and Wildlife Service
1982. Gulf coast ecological inventory. Biological Services Program
FWS/OBS 82/55. 1 User guide, 22 maps.
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I tampo boy
regional
December 13, 1982 / /" xd planning
council
Mr. Jonathan Amson
O. S. Environmental Protection Agency
Criteria and Standards Division (WH-585)
401 M Street, S.W. 9455Koge-Bouievara
Washington, D. C, 20460 St. Petersburg. R.3J702
(813) 577-515 J'Tampa 224-3380
Dear Mr. Amson:
Subject: TBRPC A-95 Clearinghouse Review #218-82; Draft Environmental
Impact Statement (DEIS) for Tampa Harbor, Florida, Ocean Dredged
Material Disposal Site Designation, Hillsborough, Manatee and
Finellas Counties
Pursuant to OMB Circular A-95, the Tampa Bay Regional Planning Council is
conducting a review of the above referenced DEIS and, based upon the
December 13, 1982 required response date, submits the following preliminary
comments as related to the document's specific recommendations regarding
the designation of Alternative Site 4:
• The DEIS lacks sufficiently detailed evaluation and comparisons of all
g_i possible alternatives including diked disposal islands and upland dis-
posal areas.
• The designation of Alternative Site 4 for disposal of dredged material
from the Tampa Bay Area should be based on more detailed studies of this
area. The DEIS lacks site specific studies evaluating the impacts on
g_2 marine environment and economy of the region. The results of the
studies done in other*locations cannot serve as the base for evaluating
the impacts of the proposed dumping of dredged material on the proposed
site.
• The environmental consequences of dumping dredged sediments on sand-
subs tat e habitats also cannot be predicted based on the results of the
6-3 studies from other locations. The ecosystem of shallow-waters in cen-
tral-southwest Florida is different from the continental D. S. waters.
• information pertaining to tidal currents is needed based on records
6-4 obtained from the tide guage station located in Egmont Key.
• The monitoring program has not been specifically designed to determine
whether disposal at the selected site significantly affects areas out-
side the site and to detect long term effects occurring in or around the
g_5 site. It is stated in the DEIS that a monitoring program may be estab-
lished to supplement historical data. Details on what the monitoring
program will entail must be included.
Chairman Jan K. Platt Vice-Chairman George McGough Secretary/Treasurer Saundra Rann W A. Ockunzzi
Commi$sioner, Hillsborough County Mayor. City ol Largo Councilwoman, City ol BraOenton Executive Director
•Brademon « Clearwater • Oade City • Dunedin « Qulfport « Hillsborough County • Largo • Manatee County • New Port Richey « Oldsmar • Palmetto
• Paaco County . Pinedas County * Pinellas Park • Safety Harbor « St. Petersburg • Si. Petersburg Beach * Sarasota * Tampa • Tarpon Springs
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Mr. Jonathan Amson -2- December 13, 1982
• The recreational and commercial fishing values of the surrounding area
should be identified as well as the impacts of ocean disposal on migra-
6~6 tory fishing. •
• It is stated that dispersion of disposal material outside the site
boundaries will be over time and in thin layers, and that such disper-
sion is not expected to have unacceptable adverse environmental impacts.
.._ Specific studies need to be completed to determine whether the thin
layer of siltation adversely impacts the surrounding hard bottoms
(corals).
It is the opinion of the Council staff that the DEIS' is inadequate in
detail on the above issues and should be sufficiently documented prior to
designating the most environmentally and economically acceptable location
for disposal of large volumes of dredged material. The amendments should
include the feasibility of other possible alternatives, including diked
co disposal islands and upland disposal areas. The Council staff does cnot
support the identified ocean disposal areas located offshore due to the.
potential destruction of wetlands. If the revised studies of- viable alter-
natives prove that Alternative Site 4 is the most environmentally and
economically acceptable location, both in the ocean and on land, then it is
the opinion of the Council staff that a very stringent monitoring program
should be established to trace the future changes caused by the disposal
action*
In conclusion, the final recommendation of the DEIS for Tampa Harbor which
designates Shallow-Water Alternative Site 4 as the Tampa Harbor ocean
dredged material disposal site is not consistent with the Council's adopted
g_g policy to support the maintenance of Class III Waters, including bays,
rivers, lakes, estuaries and open waters of the territorial sea, at a
quality sufficient to allow body-contact water sports and propagation of
fish and wildlife. (Future of_ the Region, 2.402)
The above comments by the staff of the Tampa Bay Regional Planning Council
are preliminary and are subject to approval by the Council's Clearinghouse
Review Committee and final approval by the Council's full policy board.
Additional local and regional comments will be forthcoming upon the January
3, 1982 meeting of the Council's Clearinghouse Review Committee. As dis-
cussed, the copy of the draft Clearinghouse report will be submitted to you
prior to the meeting. This format is necessary because, as noted in our
November 19, 1982 letter to you, TBRPC was not included, as required by OMB
Circular A-95, on EPA's initial request for comments, and therefore', did .
not obtain a copy of the document until November 22, 1982. Finally, any
local comments received from interested parties in the Tampa Bay Region
will be forwarded to EPA immediately upon our receipt.
We appreciate the opportunity to review this important DEIS and hope our
comments are helpful to you in preparing the final EIS for the Tampa Harbor
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Mr. Jonathan Amson -3- December 13, 1982
Disposal Site Designation. Should additional clarification be necessary,
please contact Ms. Margaret Guy of the Council's staff.
Sincere,
William A. Ockunzzi
Executive Director .
wao/ j is
cc: Walt Kolb
Jesse Carr
Westwood Fletcher
Jan Platt
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UNITED STATES DEPARTMENT OF COMMERCE
National Oceanic and Atmospheric Administration
Washington. O.C. 20230
OFFICE GF THE
December 16, 1982
Environmental Protection Agency
Criteria and Standards Division (WH-585)
401 » Street, SW, Room 2824
Washington, D.C. 20460
Dear Sir:
This is in reference to your dratft environmental impact statement
entitled "Tampa Harbor, Florida, Ocean Dredged Material Disposal Site
Designation." Enclosed are additional comments from the National Oceanic
and Atmospheric Administration.
Thank you for giving us an opportunity to provide comments.
Sincerely,
royce M. Wood
'Chief
Ecology and Conservation Division
Enclosure
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-------
/v\.
*»»!».. M &
UNITED STATES DEPARTMENT OF COMMERCE
National Oceanic and Atmospheric Administration
OFFICE OF MARINE POLLUTION ASSESSMENT
Rockville, Maryland 20852
To: PP/EC - Joyce Woo«
7-1
From: RD/MP - R. Lawrence Swanson
Subject: DEIS 8211.02,, Tampa Har&or, Flortda, Ocean Dredged Material Disposal
Stte Designation
This DEIS appears to be adequate to support the proposed ocean
disposal of dredged material. The material to be dredged is not severely
contaminated and should not cause any major disruption of the shelf
ecosystem beyond that due to turbidity and burial. The monitoring
program outlined on pp 2-31 to 2-35 is a good one and should be continued
for a least several years after disposal begins. It should include con-
tinued sampling of the dredged material itself to insure that there is
no major change in constituents. On a more general level,. Were should
be extensive coordination within and among the various COE Districts to
insure intercomparibility of monitoring results. The relative suitability
of the many present ocean disposal sites now being designated could then
be assessed, and the results used in the planning of future disposal
actions.
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STATE OF FLORIDA
DEPARTMENT OF ENVIRONMENTAL REGULATION
8-1
8-2
8-3
BOB GRAHAM
GOVERNOR
VICTORIA j, TSCHINKEL
SECRETARY
TWIN TOWERS OFFICE BUILDING
2600 BLAIR STONE ROAD
TALLAHASSEE, FLORIDA 32301-8241
December 17, 1982
Mr. Walt Kolb
Senior Governmental Analyst
Office of Planning and Budgeting
Office of the Governor
415 Carlton Building
Tallahassee, Florida 32301
Dear Walt:
Re: Draft Environmental Impact Statement,
Tampa Harbor, Florida, Ocean Dredged
Material Disposal Site Designation
We have reviewed the referenced document and offer the following comments.
Essentially, the selection of a preferred alternative was based upon the
tangible considerations of distance from shore (transport costs) and
prevalence of hard bottoms. Most of the potential ecological impacts,
particularly long-term-effects, are not weighed as strongly since they
are less quantifiable and less studied. Further, the conclusions presented
in the text are based upon information contained in appendices which
were not included with the DEIS.
The alternatives evaluations are understandably sensitive to the presence
of hard bottoms, but this is not the only important component of live
bottoms. Soft live bottoms are viable and vulnerable components of the
ecosystem, too. The characterizations on p. 2-19 do not discuss the
biological characteristics of the Site 4 bottoms. The only information
given is geophysical, primarily noting fewer areas of hard bottom lithotype
than alternative sites.
While the DEIS asserts that recovery for soft bottoms is certain, many
qualifications must modify these expectations. This is a relatively
unstudied topic with wide variability in results and predictions. One
of the main factors repeatedly mentioned as a facilitator of recolonization
by non-opportunistic species is the similarity between the disposed
"material and bottom sediments. The dredged material proposed for disposal
is a finer material than the. recipient bottoms of Site 4.
AN EQUAL OPPORTUNITY / AFFIRMATIVE ACTION EMPLOYER
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Mr. Walt Kolb
Page Two
December 17, 1932
8-4
8-5
8-6
8-7
8-8
8-9
The distribution of a discharge plume at sea is unpredictable. It is
not unrealistic to consider the possibility of a several mile impact
distance (p. 2-26). Entrainment of pollutants is even less predictable.
Some of these pollutants will be anthropogenic with a greater probability
for persistence in the environment. Dissolution may result in or contribute
to localized high nutrient concentrations, one of the assumed preconditions
for red tide blooms (p. 4-8) .. Dissolved contaminants may also effect
chronic, sublethal damages to biological populations through interference
with chemoreception.
The pile formed on the ocean floor may also spread and slough onto
adjacent bottoms. During the period that affected bottoms are devoid of
benthic organisms, their contributions to water quality, habitat and
bottom stability are lost.
The combined results of all these potential effects of the proposed
disposal will operate on fishery resources dependent upon an intact
ecosystem. Again, the full extent of these effects cannot be quantified
{p. 4-22).
It is a reflection of the complexity of the marine environment that many
of the above impacts are difficult to assess with fixed numbers. It is
also a reflection of the sensitivity of this delicately balanced ecosystem
that some degree of all these impacts can be expected to result from a
perterbation such as dredged material disposal. A difficulty in quantifying
effects should encourage a cautious approach to the use of Gulf coastal
waters for dumping grounds. Also, this activity would only be one of
many degrading~influences operating on area environmental quality. It
is myopic to continue to expect infinite capacity out of a finite waterbody.
Dilution does not solve environmental contamination.
Another long-term consequence of the proposed dumping is the waste of
the material itself. We continually lose upland and nearshore sediments
to erosion to the extent that we should not discard useable material.
We recognize the magnitude and complexity of dredged material disposal,
but cheaper and quicker options are not always better economically or
environmentally. Planning for port development, expansion and maintenance
should include consideration of appropriate, conservative disposal
methodologies. Upland disposal and recycling of previously used sites
should be given the highest priority.
On November 5, 1982, we advised the EPA of the state's concerns for
proceeding with site designation and rule-making without benefit of the
federal consistency review prescribed by the Coastal Zone Management
Act. (see attached correspondence.) To date, we have received no reply
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Mr. Walt Kolb
Page Three
December 17, 1982
or submission of consistency findings. We reiterate our request for
attention to these federal requirements as soon as possible.
Cordially,
Lynn F. Griffin
Environmental Specialist
Intergovernmental Programs
Review Section
LFG/jb
cc: Dave Worley
Terry Cole
Steve Fox
Ann Berger-Blundon
Elton Gissendanner
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November 5, 1982
Mr. T. A. Wastler, Chief
Marine Protection Branch (WH-585)
Environmental Protection Agency
Washington, D.C. 20460
Dear Mr. Wastler:
Re: Proposed Rule for Ocean Dumping, Gulf of Mexico
On review of the Federal Register (Vol. 47, No. 194), we note that the
EPA is proposing certain dredged material disposal site designations
pursuant to 40 CFR Part 228. Specifically, the proposed rule would
extend the interim designation of Site A, which is currently being used
for the Corps of Engineers' Tampa Harbor. Project, Section 2C materials.
Additionally, interim approval of a new site. Site 4, is proposed, which
would accommodate the remaining dredged materials from this project. A
permanent ocean disposal site, not necessarily one of these, will be
designated through an Environmental Impact Statement review.
Adoption and implementation of the proposed rule enables an activity to
be conducted in an area in and surrounded by abundant marine resources
of significant importance to recreational and commercial enterprises in
Florida. Under the federal Coastal Zone Management Act, federal activities
directly affecting the coastal zone of a state must be conducted in a
manner consistent"to the maximum extent practicable with the approved
state coastal management program. The EPA is required under 15 CFR
Section 930.33(c) to evaluate the full extent of these direct effects
and, subsequently, prepare a federal consistency determination for the
state's review and comment.
We, therefore, request that these findings be submitted to the Florida
Department of Environmental Regulation and/or the Governor's Office of
Planning and Budgeting, Natural Resources Policy Unit as soon as possible.
As appropriate, we expect the federal consistency review to precede
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Mr. T. A. Wastier
Page Two
November 5, 1982
final adoption of the proposed rule as specified in Section 930.34 of
the federal regulation. We understand that ample tine is available
under the rulemaking and NEPA processes to accommodate this compliance
requirement.
Sincerely,
Terry Cole
Assistant Secretary
TC/lgb
cc: William Matuszeski
Ann Berger-Blundon
David Worley
Elton Giasendanner
Ton Herndon
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I tompa bay
[ regional
planning
council
X X "XX *
December 22, 1982
9455 Koger Boulevard
St. Petersburg. R. 33702
(813) 577-5iSl/Tampa 224-9380
Mr. Jonathon Amson
U.S. Environmental Protection Agency
Criteria and Standards Division (WH-585)
401 M Street, S.W.
Washington, D.C. 20460
Dear Mr. Amson:
Subject: Tampa Bay Regional Planning Council A-95 Clearinghouse Review No.
218-82; Draft Environmental Impact Statement (DEIS) for Tampa
Harbor, Florida, Ocean Dredged Material Disposal Site
Designation, Hillsborough, Pinelias and Manatee Counties
As referenced in my December 13, 1982 correspondence, enclosed for your
information is a copy of our draft Clearinghouse report and recommendations
concerning the above referenced project. The Tampa Bay Regional Planning
Council's Clearinghouse Review Committee will consider this report at its
January 3, 1983 meeting.
Should additional clarification be necessary, please contact me.
Sincerely,
Michael R. McKinley I
Director of Planning^"./
MRM/kh
Enclosure
Chairman Jan K. Platl Vice-Chairman George McGough Secretary/Treasurer Saundra Rahn w.A. Ockunzzi
Commissioner, Hillsborougti County Mayor, City of Largo Councilwoman, City of BraHemon Executive Director
Bradenton • Clearwater • Oade City • Dunedin * Gulfport • Hillsborough County • Largo • Manatee County • New Port Richey • Oldsmar • Palmetto
• Paseo County • Pinellas County • Pinellas Rark « Safety Harbor • St. Petersburg • St. Petersburg Beach • Sarasota « Tampa • Tarpon Springs
-------
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Agenda Item #11A
A-95 #218-82; Draft Environmental Impact Statement (DEIS) for Tampa
Harbor, Florida, Ocean Dredged Material Disposal Site Designation,
Hillsborough, Pine lias and Manatee-Counties-- - -
The U.S. Environmental Protection Agency (EPA) has requested review and
comment on the draft Environmental Impact Statement (EIS) for Tampa Harbor,
Florida which presents information necessary for the designation of a new
Tampa Harbor Dredged Material Disposal Site. The purpose of the action is
to provide the most environmentally and economically acceptable ocean
location for the disposal of material dredged from the Tampa Bay area.
Based on recent surveys of four Shallow-Water Alternative Sites, EPA has
determined that Shallow-Water Alternative Site 4 is the alternative with
the fewest hard-bottom areas which may be affected by the disposal of
dredged material. It is the recommendation of the DEIS that Alternative
Site 4 be designated as the disposal site location for dredged material
from the Tampa Bay area. Agency - EPA; Location - Hillsborough, Pine lias
and Manatee Counties*
Local Comments Received From;
Hillsborough County Environmental Protection Commission: See attached
letter dated December 5, 1982.
Hillsborough County Department of Development Coordination: See attached
memorandum dated December 3, 1982.
Pinellas County Planning Department: No comment received as of December
30, 1982.
City of St. Petersburg Planning Department: See attached letter dated
December 16, 1982. - .
Manatee County Board of County Commissioners: See attached letter dated
December 13,1982
Mote Marine Laboratory: See attached letter dated December 9, 1982.
Gulf of Mexico Fishery Management Council: See attached letter dated
December 10, 1982.
Office of the Governor: See attached letter dated December 22, 1982«
Council Comments and Recommendations
This project has been reviewed for consistency with the Council's Areawide
Water Quality Management Plan and the Council's adopted growth policy, the
Future of the Region. The proposal has not been found to be consistent
with Council policy that a standard of water quality should be achieved
that allows for the protection and propagation of fish, shellfish, and
wildlife and provides for recreation in and on the waters in the region.
tempo bay regional planning council
9455 Koger Boulevard St Petersburg, FL 33702 (813) 577-5151-Tampa 224-9380
-------
This project is regionally significant'and the following local and regional
concerns have been raised during the review:
• The staff of the Tampa Bay Regional Planning Council has reviewed the
Draft Environmental Impact Statement (DEIS) for Tampa Harbor Ocean
Dredged Material Disposal Site Designation and offers the following
commentst
9-1
9-2
9-3
9-4
9-5
9-6
9-7
9-8
General Comments
1. The DEIS lacks sufficiently detailed evaluation and comparisons of
all possible alternatives including diked disposal islands and
upland disposal areas.
2. The designation of Alternative Site 4 for disposal of dredged
material from the Tampa Bay Area should be based on more detailed
studies of this area. The DEIS lacks site specific studies evaluat-
ing the impacts on marine environment and economy of the region.
The results of the studies done in other locations cannot serve as
the base for evaluating the impacts of the proposed dumping of
dredged material on the proposed site.
3. The environmental consequences of dumping dredged sediments on sand-
substate habitats also cannot be predicted based on the results of
the studies from other locations. The ecosystem of shallow-waters
in central-southwest Florida is different from the continental U.S.
waters.
4. Information pertaining to tidal currents is needed based on records
obtained from the tide guage station located in Egraont Key.
5. The monitoring program has not been specifically designed to deter-
mine whether disposal at the selected site significantly affects
areas outside the site and to detect long term effects occurring in
or around the site. It is stated in the DEIS that a monitoring
program may be established to supplement historical data. Details
on what the monitoring program will entail must be included.
6. The recreational and commercial fishing values of the surrounding
area should be identified as well as the impacts of ocean disposal
on migratory fishing.
7. It is stated that dispersion of disposal material outside the site
boundaries will be over time and in thin layers, and that such
dispersion is not expected to have unacceptable adverse environmen-
tal impacts. Specific studies need to be completed to determine
whether the thin layer of siltation adversely impacts the sur-
rounding hard bottoms (corals).
Specific Comments
1. Statements that there are no hard-bottom habitats within or in
proximity to Site 4 are not well-documented. More extensive inspec-
tion of areas both within and around the site is necessary before it
can be known what types of organisms and communities will-be
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9-9
9-10
9-11
9-12
9-13
9-14
9-15
adversely affected by dumping. In-depth surveys to determine the
- nature and extent-of live, hard-bottom habitats in or near the site
should be further conducted.
2. It is stated in DEIS that results of dredged material disposal at
the Tampa Harbor alternative sites are anticipated to be similar to
the results of disposal operations at Calveston, Texas (page 2-28).
However, the West Florida Shelf cannot be compared with other areas
which have no hard-bottom communities. The conclusions that dispo-
sal will not result in any detectable changes in ecology of the area
are inappropriate.
3. An assessment of the siltation and turbidity caused by resuspension
of fine particles by waves, storms and tides has not been completed,
as well as the expected impacts of the siltation on live-bottom
habitats*
4. The long-term effects from the continual resuspension of spoil
material throughout the water column have not been adequately
studied nor documented. The amount and frequency of siltation, the
direction of sediment transport based on site-specific ocean current
information, and the environmental consequences of long-term tur-
bidity should be estimated before final recommendations are made.
5* It is stated in the DEIS that Site 4 is removed from areas of
recreational use, and has no known significant commercial fishery
use (page 2-27). This statement is not based on the detailed survey
of commercial and recreational fishing activities of this area.
Relevant studies should be completed based on public testimony
whether the proposed action affects the recreational activities of
the region and commercial fishing.
6* Cost-benefit analysis, taking into account the direct and indirect
economic benefits generated by the recreational use of this part of
the Gulf of Mexico have not been done at this time.
7. A public hearing should be scheduled to allow full and fair public
'comment in the draft BIS and the overall suitability of dumping in
the Eastern Gulf of Mexico.
The Manatee County Board of County Commissioners has provided extensive
comments which already have been forwarded to EPA and are summarized
below (see attached letter dated December 13, 1982} regarding the Draft
EIS for a permanent ocean disposal site for Tampa Harbor:
1. The EPA survey upon which the EIS relies to recommend Site 4 for
permanent designation, used survey methodologies that are inadequate
for determining the nature and extent of live, hard-bottom habitats
in or near the site; yet, the entire EIS rests on the unproven
assumption that there are no hard-bottom habitats within or in
proximity to Site 4. This is critical because of the well-docu-
mented importance of live-bottom habitats to both commercial and
recreational fishery resources.
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2. Although the EIS notes that significant damage that can occur to
hard-bottom habitats from siltation and turbidity, it completely
fails to describe or assess the siltation and turbidity that will be
9_15 caused by resuspension of fine particles by waves, storms, tides,
and combinations thereof, and it fails to quantify the resulting
siltation problem and its expected impacts to corals, sponges,
algaes, and the like*
3. The EIS recommendation of Site 4 is based on erroneous and under-
stated information concerning the use of the area in and around the
9_17 site, which is actually located in an area that is heavily used by
commercial and recreational fishermen, sport divers, and others.
4. The Site-Designation EIS presumes that ocean dumping is appropriate
in this part of the Gulf of Mexico, disregarding as a general matter
the high potential for damage from burial and siltation to the hard-
9-18 bottom habitats and organisms found scattered throughout this part
of the Gulf, and inadequately considering, the possibility of using
uplands or diked disposal areas on a short-term basis pending
thorough investigation of the suitability of ocean dumping.
5. The BIS also relies on erroneous cost estimates for transporting the
dredged material to various alternative sites, and there is no
comparison of the environmental "pros and cons" of each alternative
9-19 site relative to the economic costs.
6. Finally, with respect to the EJS's cost analyses, the EIS fails to
take any account of the direct or indirect economic benefits gen-
erated by the recreational use of this part of the Gulf of Mexico,
9-20 thereby placing too-heavy emphasis on the immediate costs of spoil
transportation.
Therefore, in light of the many deficiencies of the Draft EIS, including
reliance'on erroneous assumptions, inadequate surveys, and incorrect
infomation, the Board of County Commissioners of Manatee County requests
9-21 that a public hearing be scheduled to discuss the Draft EIS and proposed
site designation, or, in the alternative, that the Draft EIS be with-
drawn and subsequently resubmitted for public comment.
• The staff of the MilIsborough County Environmental Protection Commission
has reviewed the Draft Environmental Impact Statement (EIS) for Tampa
Harbor: Ocean Dredged Material Disposal Site Designation and submits
the following comments and recommendations:
It is recommended that all disposal at the Existing Site A be
stopped because it is too close to shore, too close to produc-
9-22 tiv« reef areas, and within easy reach of divers and small boat
users.
Site 4 is in 85 to 95 feet of water and is not as likely to be
used for recreational purposes such as diving and fishing. All
9-23 material should go to this site until some long range solution
is found.
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Site 4 has no hard-bottom outcrops and would therefore have the
9-24 least impact on fish and other types of life. •
•' The City of St. Petersburg Planning Department has reviewed the Draft
SIS for Tampa Harbor: Ocean Dredged Material Disposal Site Designa-
tion and recommends the following additions to the above referenced
EIS:
Incorporation of any appropriate review criteria
which may be forthcoming from the pending litiga-
tion related to offshore dumping initiated by
Manatee County;
Analysis of upland dumping sites;
Further analysis of Site 4. It appears that
Appendix C. (referenced on Page 2-13 of study) may
provide additional data to substantiate minimal
adverse environmental impacts.
• The Office of the Governor has submitted the following comments and
recommendations regarding the Draft BIS:
An interagency review of the statement has found
that the proposed action would smother the benthos
within the designated area and alter habitat within
the site. The document recognizes that these
adverse impacts at the site are unavoidable. Our
reviewing agencies report that the EIS statement is
inadequate and lacks the necessary information to
be of sufficient value as a decision-making docu-
ment (see attachments).
- We have concerns with this designated site and
EPA's proposed rule for ocean dumping without a
Federal Coastal Zone Management Consistency Evalua-
tion. Recognizing our concerns, the impact of this
designation and its effect on the Tampa Harbor
project, we request that your agency participate in
an interagency meeting at your earliest convenience
to afford us the opportunity to discuss issues of
concern to the State of Florida. It is our desire
to use this initial meeting as a step toward re-
solving our concerns.
Based on the review of this document, it is the opinion of the Tampa Bay
Regional Planning Council that no ocean dumping should be performed
until it is demonstrated that ocean dumping in this part of the Gulf of
Mexico is appropriate and that it is the most suitable method of dispo-
sal. That demonstration should include an actual determination of the
9-2S nature and extent of hard-bottom habitats and fishery resources in site
4 and in surrounding areas. This determination should be based on
further, site-specific surveys, including the direction/ amount, fre-
quency/ and distance of sediment transport and siltation, and a specific
quantification of the damage that will result therefrom. Also, a de--
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*•:
9-26
tailed, careful balancing of the economic versus environmental concerns
for each alternative method should be performed, including consideration
of the many commercial aspects of recreational fishing and diving and
development of a thorough monitoring program to assess the impacts of
any dumping on a long-term basis.
In conclusion, the final recommendation of the DEIS for Tampa Harbor
which designates Shallow-Water Alternative Site 4 as the Tampa Harbor
ocean dredged material disposal site is not consistent with the
Council's adopted policy to support the maintenance of Class III waters,
including bays, rivers, lakes, estuaries and open waters of the terri-
torial sea, at a quality sufficient to allow body-contact water sports
and propagation of fish and wildlife. (Future of_ the^ Region, 2.402)
It is recommended that Alternative Site 4 not be used as an interim
dumping site, and that all concerned parties meet to resolve identified
concerns.
It is therefore recommended that the above local and regional concerns and
recommendations be addressed in the final EI5 for Tampa Harbor. Further,
it is recommended that any additional comments addressing local concern be
considered prior to issuance or approval of the final EIS.
Committee adopted January 3, 1983.
Lu**
/Mayor ({gorge McGough", Chai^fian
Clearinghouse Review Committee
Please note: Unless otherwise notified, action by Clearinghouse Review
Committee is final. Append copy to application to indicate compliance with
clearinghouse requirements. Comments constitute compliance with OMB Circu-
lar A-95 only.
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PEEPLES. EARL, REYNOLDS & BLANK
L. GRANT »«EPLES
WILLIAM I. EARL
ROBERT N, REYNOLDS, P.A.
ROBERT H. BLANK
PAUL M. AMUNDSEN
WILLIAM F. TARR
O. LION
I WILUAM9.P.A.
TALLAHASSEE, FLORIDA
COUNSEL
PROFESSIONAL ASSOCIATION
ATTORNEYS AT LAW
December 14, 1982
ONE BISCAYNE TOWER, SUITE 3638
TWO SOUTH BISCATNE BOULEVARD
MIAMI, FLORIDA 33131
OOS) 358-3OOO
3O6 EAST COLLEGE AVENUE
POST OFFICE SOX US9
TALLAHASSEE, FLORIDA 323O2
REPLY TO:
Miami
Joseph Freedman, Esquire
Office of the General Counsel
U.S. Environmental Protection Agency
Rm. 538, West Tower
401 M. Street, S.W.
Washington, D.C. 20460
Re: Comments on Draft EIS for Tampa Harbor Site Designation
Dear Joe:
This will confirm that you have agreed to a one day extension
within which Manatee County can provide comments to EPA's Draft
EIS for a permanent ocean dump site desigation outside Tampa
Harbor, Florida. Therefore, Manatee County will file the com-
ments 'with EPA on December 14, 1982. I have enclosed a copy of
Manatee County's comments for your convenience.
Thank you very much for your cooperation.
Yours very truly,
PEEPLES, EARL, REYNOLDS & BLANK
:- -• ^ •-•/
William F. Tarr
For the Firm
WFT/yp
cc: Mr. T. A. Wastler
-------
-------
L.GRANT PEEPLES
WILLIAM L.EARL
ROBERT N. REYNOLDS, P.A.
ROBERT H. BLANK
PAUL H. AMUNDSEN
WILLIAM F. TARR
SANTIAGO G. LKOM
MOORS £ WILLIAMS, P. A.
TALLAHASSEE, FLORIDA
COUNSEL
PEEPLES, EARL, REYNOI-DS & BI-AJOC
PROFESSIONAL. ASSOCIATION
ATTORNEYS AT LAW
December 13, 1982
ONE 3ISCAYNE TOWER, SUITE 3636
TWO SOUTH BISCAYNE BOULEVAHP
MIAMI, FLORIDA 33131
OOS) 3S6-3OOO
3O6 EAST COLLEGE AVENUE
POST OFFICE BOX 1189
TALLAHASSEE, FLORIDA 323O2
) 22S-2IS6
REPLY TO:
Miami
Mr. T. A. Wastler
Chief, Marine Protection
Branch (WH-585)
Environmental Protection Agency
401 M. Street S.W., Room 2709
Washington, D.C. 20460
Re: Comments on Draft BIS No. 820697, Tampa Harbor Ocean
Dump Site Designation; Request for Public Hearing and
for Withdrawal ofr BIS.
Dear Mr. Wastler:
This letter is furnished on behalf and under express
authority of the Board of County Commissioners of Manatee County,
Florida, to provide comments to the Environmental Protection
Agency (EPA) on its Draft Site-Designation EIS for a permanent
ocean dump site outside Tampa Harbor. This letter is also
provided to request a public hearing concerning the EIS and the
site-designation and, because of the many deficiencies in the
BIS, to suggest that it be withdrawn and resubmitted after
development of more accurate information.
Because of the County's proximity to the dump sites proposed
in the EIS and the heavy use of the Gulf of Mexico by its
citizens and tourists, Manatee County is vitally interested in
assuring that the most suitable ocean dump site is selected (if
dumping in this part of the Gulf is, in fact, appropriate) in
order to protect commercial and recreational activities in the
marine environment and the public health, safety, and welfare.
In pursuit of those goals, Manatee County recently filed a
lawsuit against EPA and the Army Corps of Engineers, which was
joined in by the cities of Anna Maria and Holmes Beach, seeking
to enjoin the use of the existing Gulf dump site approximately
thirteen miles offshore. An order from the Court in. this
lawsuit, styled Manatee County et al. v. Ggrsuch et al., Case No.
-------
Mr. T. A. Wastier
December 13, 1982
Page -2-
82-248-Civ-T-GC (M.D. Fla.), is expected in the very near future.
As a result of that litigation, a great deal of information has
been developed that reveals numerous deficiencies in the Draft
EIS and militates in favor of withdrawing it for further
consideration. As you know from the taking of your deposition in
June of 1982, the federal government at all times had at least
four attorneys working on the case, and the same four people
(including Joseph Freedman, Esq., of EPA) were actively involved
all the way through trial. It is suggested that you consult with
your legal counsel to take advantage of their knowledge of these
matters.
To summarize what is amply demonstrated by the below-
enumerated specific comments, the Draft Site-Designation EIS is
either wrong or inadequate in at least six general respects:
(1) The EPA survey upon which the EIS relies to recommend
Site 4 for permanent designation, used survey methodologies that
are inadequate for determining the nature and extent of live,
hard-bottom habitats in or near the site; yet, the entire EIS
rests on the unproven assumption that thertre are no hard-bottom
10-1 habitats within or in proximity to Site 4. This is critical
because"of the well-documented importance of live-bottom habitats
to both commercial and recreational fishery resources.
(2) Although the EIS notes that significant damage that can
occur to hard-bottom habitats from siltation and turbidity, it
completely fails to describe or assess the siltation and
turbidity that will be caused by resuspension of fine particles
by waves, storms, tides, and combinations thereof, and it fails
10-2 to quantify the resulting siltation problem and its expected
impacts to corals, sponges, algaes, and the like.
(3) The EIS recommendation of Site 4 is based on erroneous
and understated information concerning the use of the area in and
around the Site, which is actually located in an area that is
heavily used by commercial and recreational fishermen, sport
10-3 divers, and others.
(4) The Site-Designation EIS presumes that ocean dumping is
appropriate in this part of the Gulf of Mexico, disregarding as a
general matter the high potential for damage from burial and
siltation to the hard-bottom habitats and organisms found
scattered throughout this part of the Gulf, and inadequately
considering the possibility of using uplands or diked disposal
10-4 areas on a short-term basis pending thorough investigation of the
suitability of ocean dumping.
PEEFUBS, HARJ., RBTTNX>U>S &
PROFESSIONAL ASSOCIATION
ATTORNEYS AT LAW
-------
Mr. T. A. Wastler
December 13, 1982
Page -3-
(5) The EIS also relies on erroneous cost estimates for
transporting the dredged' material to various alternative sites,
10 s and there is no comparison of the environmental "pros and cons"
of each alternative site relative to the economic costs.
(6) Finally, with respect to the EIS's cost analyses, the EIS
fails to take any account of the direct or indirect economic
benefits generated by the recreational use of this part of the
Gulf of Mexico, thereby placing too-heavy emphasis on the
10_6 immediate costs of spoil transportation.
Therefore, in light of the many deficiencies of the Draft
EIS, including reliance on erroneous assumptions, inadequate
surveys, and incorrect information, the Board of County
Commissioners of Manatee County requests that a public hearing be
scheduled to discuss the Draft EIS and proposed site designation,
or, in the alternative, that the Draft EIS be withdrawn and
subsequently resubmitted for public comment.
The following comments are directed toward specific portions
of the EIS: >
COMMENT No. 1 — page x, 1f 1;
Non-ocean disposal methods were considered by
the U.S. Army Corps of Engineers (C.E., 1974)
(while evalutating the need for ocean
disposal) to be less desirable than disposal
in the ocean because of the quantity of
sediments to be dredged, the limited receiving
capacity of land disposal sites, and economic
and environmental concerns.
That statement is erroneous. In fact, the Corps of Engineers
expressly and unequivocally rejected ocean dumping as an
1Q_7 alternative:
6.05 Consideration was given to disposal in
the Gulf of Mexico. This would entail
covering 6.1 square miles of Gulf bottom with
an average of ten feet of fill. This plan
produced the highest costs of all alternatives
considered. (Final EIS at 142).
* * * *
Gulf disposal was ruled out because of
prohibitive costs. (Final EIS at page v).
PEEFUBS, EAKL, REYNOLDS &
PROFESSIONAL ASSOCIATION
ATTORNEYS AT LAW
-------
Mr. T. A. Wastler
December 13, 1982
Page -4-
The statement in EPA's Draft EIS implies that the Corps of
Engineers carefully examined several types of dumping but choose
ocean dumping. That clearly was not the case. in addition, the
10-8 adequacy of the Corps's discussion of alternatives is now subject
to challenge in the above-described lawsuit. Further comment in
this regard is provided below.
COMMENT No. 2 — page 2-3, fl 2;
However, using Shallow-Water Alternative Sites
one or four would add only 4-5 nmi to the
present round-trip distance to the Outer
Existing Site ....
The round trip calculation has apparently been cut in half
through a clerical or typographical error. Testimony by the
Corps at trial indicated that the additional distance to Site 4
(above and beyond Site A) was 5.6 nmi one way, so the round trip
10-9 distance would actually be approximately 11 nmi.
COMMENT No. 3 — page 2-4, H 2;
By taking no action, the present ODMDS's
would not receive permanent designation, nor
would an alternate ocean disposal site be
permanently designated. Therefore, the CE
would be required to: (1) justify an
acceptable alternative disposal method (e.g.,
land-based); (2) develop information
sufficient to select an acceptable site for
disposal in the ocean; or (3) modify or cancel
a proposed dredging project that depends on
disposal in the ocean as the only feasible
method for the disposal of dredged material.
The next sentence of the Draft EIS then summarily states that
the "No-Action Alternative" in therefore unacceptable. No
analysis of the reasoning used to discount the three cited
factors is provided, and this passage suggests that the Corps
should not be burdened with environmental considerations. Please
explain why it is unreasonable for the Corps to "justify an
10-10 acceptable alternative disposal method (e.g., land-based)," which
would present less environmental damage than that caused to
sensitive marine habitats from burial and siltation. Equally
important, explain how it would be unacceptable to ask the Corps
"to develop information sufficient to select an acceptable site"
PEEBLES, EARL, REYNOLDS &
PROFESSIONAL ASSOCIATION
ATTORNEYS AT LAW
-------
Mr. T. A. Wastler
December 13, 1982
Page -5-
for ocean dumping. Finally, please clarify why the proposed
dredging project (apparently Section 3B) depends on ocean dumping
as "the only feasible method," when testimony as trial clearly
demonstrated that the diked disposal areas in upper Hillsborough
Bay are closer to Section 3B than the Gulf dump sites; that the
use of the diked disposal areas would not have unacceptable
adverse impacts to the environment, in stark contrast to dumping
in the ocean; that the diked disposal areas have ample capacity
for handling the dumping from Section 3B and other projects; and
that the cost of disposing materials at the diked disposal areas
would be approximately the same as the costs of ocean dumping.
COMMENT No. 4 — pages 2-5 to 2-6;
[See Block-indented quotation of Corps of Engineers
concerning land-based disposal, dated 1974.]
Reliance on this passage from the Corps of Engineers' Final
EIS for the Tampa Harbor Project is flawed for several reasons.
First, the Corps quotation was dated 1974, fully eight years ago,
and conditions may well have changed drastically since that time.
Please specifically reexamine the feasibility of upland disposal
10-11 as °f today, describe potential upland sites (and other
locations} in the area, and explain why each is less appropriate
than ocean dumping.
Second, the 1974 decision regarding land-based disposal was
based on the dumping of 72.8 million cubic yards of material to
be dredged from the Tampa Harbor Deepening Project. Nothing in
EPA's Draft EIS suggests that like-quantities are proposed for
dumping in the near future, so that the feasibility of the use of
uplands, diked disposal areas, etc., in the near future should be
reconsidered. Please describe the location of all possible
upland disposal areas and assess the costs and enviromental
10-12 benefits of -transporting dredged materials to each upland
location versus ocean sites and the diked disposal areas. Also,
please discuss currently proposed dredging projects in the Tampa
area and their current, projected scheduling so the actual need
for ocean dumping can be better determined in the EIS.
Finally, as noted above, two diked disposal areas exist in
upper Hillsborough Bay that are stated by the Corps of Engineers
to contain 15 million cubic yards of capacity. Although-they are
purportedly slated to be used for dumping from maintenance
10-13 dredging over the next twenty-five to fifty years, please explain
why they could not be used on a short-term basis as an
alternative to ocean dumping pending completion of complete and
careful studies of the feasibility and suitability of particular
ocean dump sites or other methods of disposal.
PBEPX.ES, EAKL, RETTNTOLUS &
PROFESSIONAL ASSOCIATION
ATTORNEYS AT LAW
-------
Mr. T. A. Wastier
December 13, 1982
Page -6-
COMMENT No. 5 — page 2-8, H 1;
It was determined during the initial screening
that areas immediately north and west of the
Existing Sites should be eliminated from
consideration because of the presence of hard-
bottom areas and artificial reefs.
That statement is misleading and inaccurate. As a result of
its September/October 1979 and January 1980 surveys, Interstate
Electro'nics Corporation actually "strongly recommend[ed] that the
Existing Sites not be used or designated." Nevertheless, the
Corps and EPA authorized the dumping of several million cubic
yards of dredged spoils at Site A in spite of the express
recommendation of EPA's contractor to the contrary. Please
10-14 furnish the documentation showing that IEC recommended that the
areas north and west of the existing sites, as opposed to the
existing sites themselves, should be eliminated. Most important
explain why the Corps and EPA used Site A in spite of lEC's
recommendation against it.
COMMENT No. 6 — page 2-8, T 2, 2nd circlet
At this point, based on evalutation of the
historical and survey data and information, it
was concluded that:
* * * *
Suggested Shallow-Water Site 2 and the
Existing Sites are the most economical;
however, Shallow-Water Alternative Sites 1 and
3 are probably more environmentally acceptable
locations for dredged material disposal.
That block-indented material is similarly erroneous and
demonstrates a misunderstanding of the factual history of EPA's
own site-designation process. The quoted material refers to
10_15 lEC's 1979/1980 survey, but states that conclusions were made at
that time concerning Alternative Sites 1, 2, and 3. IEC,
however, did not even survey Sites 1 through 3 at that time: the
first survey of those sites did not occur until the Reconaissance
Survey of October, 1981.
COMMENT No. 7 — page 2-9, I 3 (last line) and 11 4;
Alternative Site 3 appeared to be sandy- ..
bottomed over its entire area.
PEBPXJBS, EARL, REYKOIJDS & BLANK
PROFESSIONAL ASSOCIATION
ATTORNEYS AT LAW
-------
Mr. T. A. Wastler
December 13, 1982
Page -7-
Based on results of the Reconaissance
Survey, more in-depth surveys were planned.
Please explain the difference in the results of the
Reconaissance Survey in October of 1981 and the EPA Survey of
Site 4 in May of 1982. During the Reconaissance Survey, actual
diver observations were made, which is (from a scientific
standpoint) the most appropriate way of identifying the nature
and extent of hard-bottom areas at a particular site. In the May
1982 survey of Site 4, however, no diver observations were made;
rather, one videotaped transect and two otter trawls were run
across the site, along with nine box cores, all of which are
10-16 incapable of accurately determining whether or not hard-bottom
habitats exist in or near the Site. Since in-depth surveys were
planned to .follow up the Reconaissance Survey of 1981, please
explain why an in-depth survey is not now planned to follow up
the preliminary survey that has been performed of Site 4.
COMMENT No. 8 — page 2-10, H 3;
Examination of the videotape of Alternative
Site 3 revealed much more hard-bottom areas
than was revealed by the results of the
Reconaissance Survey of October, 1981. These
new results led to the elimination of '
Alternative Site 3 from, further detailed
consideration'.
Actually, the Reconaissance Survey report described Site 3 as
being mostly sandy bottomed but having sparce hard-bottom
communities appearing at five out of ten stations at the site.
That description of Site 3, based on diver observations, does not
appear to differ significantly from the description now provided
• as a result of the EPA's 1982 videotape. Please explain this
10-17 perceived discrepancy between the two surveys and the differing
conclusions reached as a result of different methodologies.
COMMENT No. 9 — page 2-12, 1? 2;
Disposal of large quantities of additional
dredged material may result in an adverse
impact due to burial or siltation of nearby
hard-bottoms and artificial reefs. However,
these possibilites are dependent on the amount
of material and on the ultimate direction of
mass transport of dumped material. The
limited knowledge of water current phenomena
PEEPI.ES, EASL, RETTXOUOS & BLANK
PROFESSIONAL ASSOCIATION
ATTORNEYS AT LAW
-------
Mr. T. A. Wastler
December 13, 1982
Page -8-
in this region suggest that
This passage highlights a striking omission from the Draft
EIS. Although the EIS expressly recognizes the adverse impacts
from burial and, importantly, siltation, it stops short of
quantifying such damage because of a lack of information
concerning water currents. This, it seems, is precisely the
purpose of an environmental impact statement. Since knowledge of
water current phenomena is "limited," and siltation is a widely
recognized threat to hard-bottom habitats, please explain why EPA
has yet to perform an ocean current survey to determine current
direction and speed at Site 4 in order to accurately predict the
amount of siltation that will occur and the distance from the
10-13 . Site that it will cause problems. Also, please explain why the
Environmental Protection Agency is proposing permanent ocean
dumping in the face of admitted environmental damage, especially
when EPA has yet to assess the extent of that damage.
COMMENT NO. 10 — paq 2-13/ 1f 1;
A distance of several miles between a disposal
site and a potentially affected area will
provide for extensive dilution of a turbidity
plume and dispersion of deposited materials
transported away from a Site by water
currents. Thus, artificial reefs (5 nmi NE)
are less likely to be adversely affected, but
hard-bottom areas within one mile of the Outer
Existing Site may be adversely affected.
Please provide site-specific data concerning the rates of
dilution of the turbidity plume and the distance the deposited
materials will be tranported from the site by water currents. In
addition, please specifically address the siltation that will be
caused by resuspension of the dredged material throughout the
water column by subsequent wave, storm, and tidal action.
Finally, once those amounts of turbidity and siltation have been
10-19 quantified, please provide documented information describing the
specific effects of expected siltation and turbidity on hard-
bottom organisms such as corals, sponges, and algaes. If such
environmental damage to these important marine habitats can not
be quantified, please explain EPA's rationale in authorizing
long-term dumping in this.area instead of actively searching for
less-environmentally damaging methods of disposal.
PEE PIES. EARX., REYNOIJDS 8e BLANK
PROFESSIONAL ASSOCIATION
ATTORNEYS AT LAW
-------
Mr. T. A. Wastler
December 13, 1982
Page -9-
COMMENT No. 11 — page 2-13, II 3;
No dumping has occurred and no environmental
studies have been conducted at this [Mid-Shelf
Alternative] site ....
If no environmental studies have been performed regarding the
Mid-Shelf Alternative Site, please explain how EPA has balanced
the environmental pros and cons of dumping at that site relative
to the economic costs of transporting the materials that far in
the ocean. In addition, please explain why the site proposed for
the mid-shelf, which runs from 25 to 75 nmi offshore (see page
x), was selected at the most distant portion of the mid-shelf
10-20 (i.e., 70 miles offshore), as opposed to the closer side {e.g.,
25 or 30 miles offshore). Obviously, selection of a potential
alternative mid-shelf site 30 miles offshore would be much less
expensive than one 70 miles offshore. Since no environmental
studies were performed of the seventy-mile Mid-shelf site, the
selection of that particular site for inclusion in the EIS would
seem arbitrary and capricious in the absence of a specific
rationale for such selection.
COMMENT NO. 12 — page 2-14, If 1;
According to Oliver et al, (1977) shallow-
water, high-energy benthic communities recover
more quickly - from disturbances, such as the
disposal of dredged material, than communities
in deeper water.
This conclusion from Oliver's report has been taken out of
context and is quite misleading. It is certainly not true that
Oliver recommended ocean dumping in hard-bottom habitat areas
rather than deep water areas. Instead, any reliance on Oliver's
report must be restricted to discussion of ocean dumping on soft-
bottom organisms that are actually adaptable to periodic burial.
10-21 On fc^e otner hand, in comparing the adverse impacts from burial
and siltation on shallow-water, hard-bottom organisms vis-a-vis
the relatively sparce populations of organisms at deep water
sites, it is clear that Oliver's work would not apply. Please
discuss the Oliver report in more detail and carefully examine
the applicability of his findings to hard-bottom areas such as
those found off the coast of Manatee County.
COMMENT No. 13 — page 2-14, 1f 2;
It is estimated that the increased distance
PEEFLES, EAROL, RETTM-OLDS & BI«ASTK
PROFESSIONAL ASSOCIATION
ATTORNEYS AT. LAW
-------
Mr. T. A. Wastier
December 13, 1982
Page -10-
would add approximately.$.15/ cubic yard/mi to
disposal operations (J. Hendry, personal
communication), or $102,600.00 per hopper
vessel load.
The quoted cost figure is erroneous. Testimony at trial by
Mr. Hendry and others revealed a lower cost figure, which, by
Court Order and agreement of the parties, is to be kept
confidential. Nevertheless, because the Draft EIS relies on the
higher, incorrect cost estimate, all of its cost estimates are
10-22 exaggerated, if the real cost figures are not used in the Draft
EIS, it should be made clear that all cost figures are
hypothetical and used merely for comparison.
In addition, the MPRSA regulations require a quantitative
analysis of the percentage of a resource lost, reduction in user
days of recreational areas, dollars lost in commercial fishery
profits, and the profitability of other commercial enterprises.
See 33 C.F.R. § 227.19. Because Site 4 is in an area of high
commercial and recreational activity, any consideration of the
economic disadvantages of using the Mid-Shelf Site in comparison
with Site 4 must include balancing a consideration of the
environmental and commercial advantages of using the Mid-Shelf
10-23 Site vis-a-vis Site 4. This is especially so in light of the
inappropriatness of relying on the Oliver study to determine the
environmental consequences of dumping in mid-shelf areas as
opposed to hard-bottom habitat areas. Please provide a detailed
assessment comparing the economic costs of going to the Mid-Shelf
Site with the commercial and environmental advantages of not
going to the heavily used Site 4 area. Also, describe how that
assessment would change if a Mid-Shelf Site closer to shore (say,
30 to 35 miles offshore) were chosen instead of one 70 miles
offshore.
Lastly, it must be noted that ocean dump sites much farther
out than that proposed for the Mid-Shelf Alternative Site have
been established for receipt of disposal materials. For example,
on NOAA Chart No. 13003, a dump site used for the disposal of
industrial wastes has been designated approximately 125 miles
from nearest landfall, with center coordinates at approximately
10-24 ^° ^' w an(^ ^° ^' ^' There are also two dump sites about 40
and 50 miles offshore of Cape May, New Jersey, respectively.
Please explain why it is economically feasible to use a dump site
125 miles off the coast of New York but it is infeasible to use a
dump site 30 to 75 miles off the coast of Florida.
PEEPUBS, EARX,, REYITOIJJS &
PROFESSIONAL ASSOCIATION
ATTORNEYS AT LAW
-------
Mr. T. A. Wastler
December 13, 1982
Page -11-
10-25
10-26
10-27
10-28
COMMENT No. 14 — page 2-16, 11 2;
Although the Deep Water Alternative Site
supports a lower density of organisms, these
organisms would be more sensitive to adverse
effects from disposal.
Please identify the study that specifically quantifies the
adverse effects from both burial and siltation to hard-bottom
organisms such as corals, algaes, and sponges. If there is no
such study that specifically describes the nature and extent of
damage to hard-bottom organisms from particular amounts and
frequencies of burial and siltation, explain how you arrived at
the conclusion that deep water organisms would be more sensitive
to dumping than shallow-water organisms, especially in light of
the fact that EPA conducted no environmental studies of the deep
water site and ostensibly does not know what organisms exist as
the site.
Additionally, please consider the comments and questions
posed regarding the Mid-Shelf Site and explain in each instance
how your response would differ with respect to the Deep Water
Site.
COMMENT No. 15 — page 2-16, f 2;
According to Slobodkin and Saunders (1969) a
perturbation (such as dredged material
disposal) which would have a small effect on
groups of organisms in stressful environments
(e.g., a shallow-water environment) "may be
catastrophic, when applied" to groups of
organisms in relatively constant environment,
e.g., a deep water environment.
First, please clarify the meaning of the term "small effect"
in relation to the impacts to hard-bottom organisms in and around
a dump site, from burial and siltation caused by dumping. If EPA
cannot quantify the effects to hard-bottom habitats from burial,
siltation, resuspension, etc., how can comparisons such as that
in the above passage be made?
Second, once again, the findings of the report relied on in
the EIS have been taken out of context. (See discussion of Oliver
above.) Please explain, with specific textual references, how
the Slobodkin and Saunders report can be meaningfully applied to
the long-term dumping of massive quantities of dredged spoils
PEEPLES, EARL, RETTKTOLDS &
PROTESSIONAL ASSOCIATION
ATTORNEYS AT LAW
-------
Mr. T. A. Wastler
December 13, 1982
Page -12-
(and the associated sediment transport and siltation) at an ocean
dump site in or near productive hard-bottom areas.
COMMENT No. 16 — page 2-16, II 3;
Shallow-water, high-energy communities
recover more quickly from disturbances, such
as the disposal of dredged material, than
communities in deep water (Oliver et al.
1977).
The passage is extremely misleading and totally disregards
the recovery potential for hard-bottom habitats and organisms.
Although a soft-bottom community may recolonize a site soon after
dumping, hard-bottom communities will be killed by dumping and
will not be capable of recolonizing the dump site until all the
dumped spoils have been transported away from the site leaving a
hard substrate. Even after a hard substrate reappears,
scientific literature clearly demonstrates that the hard-bottom
10 29 communities themselves will not recover to their pre-dumping
state for 25 to 50 years. In light of these facts, please
explain your conclusion that the communities discussed in the EIS
will "recover more quickly" than deep water communities.
Further, please compare the amount of environmental damage at
shallow-water versus deep-watersites (i.e., will as much be
damaged by dumping in deep water?).
COMMENT No. 17 — page 2-17, 1} 1;
Thus, dredged material sediments are likely to
differ from Deep Water Disposal Site
sediments, and this difference increases the
adverse effects of disposal on deep water
benthos.
The quoted material, along with other portions of the EIS,
erroneously implies that the dredged spoils being dumped outside
Tampa Harbor are in fact similar to the sediments found naturally
in and around Site 4. The evidence at trial, including I.B.C.
findings and expert testimony, showed that natural silt in this
1Q--30 area off Tampa-Bay ranges from II to possibly 10%.- However, the
evidence also showed that materials that have actually been
dumped from Tampa Harbor to date have averaged almost 60% silt
and have sometimes contained as much as 100% silt. Thus, these
two sets of sediments cannot be considered similar. In light of
such differences, please explain whether the "increase[d] adverse
PEEPLBS, EARL, REYNOLDS & BLANK
PROFESSIONAL ASSOCIATION
ATTORNEYS AT LAW
-------
Mr. T. A. Wastier
December 13, 1982
Page -13-
10-31
10-32
effects of disposal on deep water benthos" would likewise be
applicable to dumping at Site 4.
COMMENT No. 18 — page 2-17, H 2;
[Paragraph regarding the additional costs of transporting to
the Deep Water Site.]
With regard to the Deep Water Site, please address the same
considerations noted in Comment No. 13, above, concerning the
mid-shelf alternative site.
COMMENT No. 19 — page 2-19, H 4t
Shallow-Water Alternative Site 4 has
never been used for dredged material disposal
and is devoid of major typographic features.
A videotape taken of this area revealed no
rock or hard-bottom outcroppings and low
vertical relief. A recent EPA survey
determined that the site is predominately
characterized by the presence of fine sands
and coarse silts and plains of shell hash.
This entire passage highlights the unfounded assumptions that
run throughout the Draft EIS, i.e., that Site 4 and surrounding
areas contain no hard-bottom habitats and are unimportant to
commercial and recreational activities. As is clear from
discussion with several scientists, however, the methodologies
used in the EPA survey of Site 4 in May of 1982 were completely
inadequate for identifying the nature and extent of hard-bottom
habitats both within and without the Site. The survey consisted
solely of one videotape run across part or possibly all of the
site, two otter trawls that did not run across the whole site,
and nine box cores. No diver observations were made. Based on
that survey, it cannot be known what exists in the unseen and
unstudies 95% or more of the Site. Equally important, EPA cannot
possibly know what exists anywhere outside the boundaries of the
site because those areas were not studied (except for the four
small box core locations). Thus, the survey of Site 4 can be
considered preliminary at best, and a more extensive inspection
of areas both within and without the Site is necessary before it
can be known what types of organisms and communities in the area
will be adversely affected by dumping. Actually, observation by
divers and fisherman with many, many years of experience, in this
part of the Gulf demonstrates that Site 4 itself contains hard
bottoms and possibly ledges (and EPA found live-bottom
PEEPIJES, EART, RETNOUOS & BLANK
PROFESSIONAL ASSOCIATION
ATTORNEYS AT LAW
-------
Mr. T. A. Wastler
December 13, 1982
Page -14-
10-33
10-34
communities at the Site); and that the areas surrounding Site 4
contain hard-bottom habitats, ledges, wrecked vessels, and
valuable shrimping and fishing grounds.
EPA's unfounded assumption is rendered all the more
questionable by the high likelihood of encountering hard-bottom
habitats in this general area of the Gulf of Mexico. Sites 1, 2,
and 3 all were found to contain productive hard-bottom habitats,
and I.E.G. recommended against using or designating Sites A and 8
in 1980 because of the existence of such hard-bottom areas. This
highlights the need for further study of Site 4 before it can be
reasonably recommended as a permanent Site for ocean dumping.
COMMENT No. 20 — page 2-21, Hi;
Use of Shallow-Water Alternative Site 4
is not anticipated to affect any biologically
unique habitats or interfere with spawning or
migration activities. The site was selected
on the basis of its remoteness from known
hard-bottoms. A recent EPA survey determined
that this site apparently contains fewer hard-
bottom areas than any of the other shallow-
water alternative sites.
The reliability of those conclusions is extremely
questionable because they are based solely on the preliminary EPA
survey of May 1982. (Refer to preceding comment.) Actually,
local divers and fishermen have stated unequivocally that Site 4
is not remote from known hard bottoms and have countless Lor an
numbers demonstrating the presence of hard bottoms, ledges, and
the like. Additionally, Site 4 is in an area that is heavily
relied on for shrimping, recreational fishing, by charter boats,
party boats, and individuals, and scuba divers.
In light of the above, it would appear Site 4 does not meet
the second of the eleven factors found in EPA's Criteria. Please
reevaluate Site 4 for the suitability of its use "in relation to
breeding, spawning" grounds under 40 C.F.R. § 228.6 (a)(2).
COMMENT No. 21 — page 2-21, fl 4:
Recreational fishing and diving may occur
anywhere in the near shore waters. However,
most of these activities are limited to high-
relief hard-bottom areas, artificial reefs,
and sunken vessels, all of which are removed
PEEPLES, EARL, REYNOLDS &
PROFESSIONAL ASSOCIATION
ATTORNEYS AT LAW
-------
Mr. T. A. Wastler
December 13, 1982
Page -15-
from the site. Some scuba diving and fishing
activities may occur in the site vicinty,
although these activities are probably less
frequent in similar use in the vicinty of the
existing sites.
With the exception of the first sentence and part of the
third, the above passages are mistaken and misleading. As stated
above, Site 4 is located in an area of the Gulf that is heavily
used for shrimping, recreational fishing, and scuba diving, and
the Site is not^ far removed from hard-bottom areas, artificial
reefs, and sunken vessels; in fact, the "gunsmoke" is a 65 foot
vessel approximately one mile to the north of Site 4 that is very
10-35 important to fishing and diving interests. Further, scuba diving
and fishing activities are actually more frequent around Site 4
than around the existing sites, because the dumping at the
existing sites has ruined those areas by burial and recurrent
s.iltation.
Therefore, Site 4 fails to meet the requirements concerning
its location relative to beaches and other amenity areas under 40
C.F.R. § 228.6(a)(3).
COMMENT NO. 22 — pages 2-23 to 2-24;
[Dispersal, horizontal transport, and vertical
mixing characteristics of the area including
prevailing current direction and velocity, if
any. ]
This entire discussion in the Draft EIS is too speculative.
Testimony of two experts at trial demonstrated that the direction
and ultimate distance of sediment transport could not be
predicted accurately without a site-specific ocean current study,
and that combinations of tides, wave action, storms, and bottom
currents create variable current directions and velocities. No
10-36 investigation of the currents at Site 4 has been performed.
Therefore, please explain how the Site-Designation EIS has
satisfied the requirements of 40 C.F.R. § 228.6(a)(6) concerning
movement of the dredged spoils.
COMMENT No. 23 — page 2-25, 11 3;
Although dredged material disposal causes some
localized decreases in the abundance of
benthic fauna, fairly rapid recollinization
has been observed at similarly affected areas
PEEPUBS, EAKL, RBTHSTOUDS &
PROFESSIONAL ASSOCIATION
ATTORNEYS AT LAW
-------
Mr. T. A. Wastler
December 13, 1982
Page -16-
within three months after disposal operations
ceased. At the Galveston, Texas ODMDS,
organisms which colonized the affected areas
were members of the surrounding unaffected
areas and no nuisance species were recruited.
The implication that the Galveston dump site is analogous to
the sites off Tampa Harbor is erroneous because it disregards the
numerous hard-bottom areas found off the coast of Florida that
in ,? are not found off the coast of Texas. Thus, recolonization of
u soft bottom organisms at Texas would be quite different from
recolonization by corals, sponges, and algae.
COMMENT No. 24 — page 2-26, fl It
[Unacceptable adverse effects could result
within several miles of the disposal site due
to deposition of suspended particulate matter
and dispersion of accumulated sediments
following disposal operations.
The passage is undeniably true, but the EIS consistently
fails to adequately address resuspension of particulate matter
and to quantify both the amount and frequency of re-suspension
and the impacts to hard-bottom habitats and organisms. Because,
as was demonstrated at trial, hydrodynamic energies in this part
of the Gulf of Mexico are sufficient to continually resuspend
10-38 fine materials, siltation and turbidity are problems that must be
described before a permanent dump site should be designated.
Please quantify these impacts with specific reference to Site 4,
and include ocean current data relied on in such quantifications.
In the absence of such information, the requirements of 40 C.F.R.
§ 228.6{a)(7) cannot be considered to have been fulfilled.
COMMENT NO. 25 — page 2-27, H 3;
This site is removed from areas of
recreational use, and has no known significant
commercial fishery use.
As stated above in several comments, that conclusion
concerning Site 4 is plainly incorrect. Site 4 is located within
1Q -g an area that is heavily used for both commercial and recreational
use, including sport fishing, shrimping, party and charter boat
fishing, and scuba diving. Therefore, Site 4 also fails to meet
the requirements of 40 C.F.R. § 228.6 (a)(8).
PBEFUBS, EASX,, REYTTOUOS &
PROFESSIONAL ASSOCIATION
ATTORNEYS AT LAW
-------
.*
Mr. T. A. Wastler
December 13, 1982
Page -17-
COMMENT No. 26 -- page 2-28 1f 3;
[Reference dumping operations in other regions].
Because the numerous hard-bottom habitats scattered
throughout this part of the Gulf of Mexico make this a unique
area, reliance upon studies of dumping operations near Texas and
other dissimiliar areas is inadequate. Adequate site-specific
10-40 studies of Site 4 and of the effects of burial and siltation on
hard-bottom habitats is necessary before ocean dumping off the
coast of Manatee County can be reasonably authorized.
COMMENT No. — page 2-29, conclusion no. It
A limestone shelf is believed to occur 0.5 nmi
northwest of the outer existing site, and
small outcrops are suspected to occur within
the site. An artificial reef has been
constructed within 3 NMI of the inner existing
site.
The quoted passage, which is relied on to recommend the use
of Site 4, fails to note the existence of numerous hard-bottom
areas and ledges in proximity to Site 4 and the wreck of the
"Gunsmoke" one mile to the north of the site. The existence of
10-41 these would militate against the use of Site 4 for permanent
ocean dumping.
COMMENT No. 28 — page2-29, conclusion no. 4;
These surveys indicated that disposal of
dredged material at alternate Site 4 would
affect the fewest hard bottoms since this area
is sandy bottomed.
For the reasons indicated in comments above, the preliminary
nature of the EPA survey of Site 4 in May of 1982 makes it
unreasonably speculative to presume that there are no hard-
10-42 bottoms, ledges, or other important habitat areas within or near
Site 4.
COMMENT No. 29 — page 2-30, H 2;
All dredged material scheduled for disposal
must comply with the Ocean Dumping
Regulations' elutriate, bioassay, and
bioaccumulation test procedures. Disposal of
PEEPXJES, EARL, REYNOUOS & BLANK
PROFESSIONAL ASSOCIATION
ATTORNEYS AT LAW-
-------
Mr. T. A. Wastler
December 13, 1982
Page -18-
th is material should not cause unacceptable
and adverse effects outside the designated
dump site nor should this material cause long-
term adverse/chronic effects at a site.
The first sentence of that paragraph fails to mention that
bioassay tests are regularly performed on worms, clams, and fish,
10-43 rather than on corals, sponges, and algaes. Please explain how
elutriate, bioassay, and bioaccumulation testing accurately
predicts the impact of burial and siltation on such hard-bottom
organisms.
In addition, the second sentence of the passage disregards
the impact to hard-bottom organisms from siltation and continual
resuspension of the dredged spoils throughout the water column.
Because this resuspension will occur on a continual basis for as
10-44 long as the dump site is being used (permanently), these impacts
will be long-term and, as stated in the EIS> adverse.
COMMENT No. 30 — page 2-33, 1? 3;
However-, in the event that the selected site
is determined to have hard-bottom outcrops
within 0.5 nmi, pollution-sensitive species
outside the site should be surveyed.
That passage emphasizes the importance of identifying the
nature and extent of hard-bottom outcrops both in and near the
dump site, which was not adequately accomplished by the EPA 1982
survey. The sentence preceding, the quoted passage once again
erroneously presumes that hard and soft corals do not occur near
10-45 the site. In light of the admitted importance of monitoring for
pollution-sensitive species within one-half mile of the site,
please explain why it is unnecessary to conduct an examination of
Site 4 that better identifies hard and soft corals in and near
the site.
COMMENT No. 31 — pages. 3-47 to 3-48;
[Re: Recreational and commercial fisheries]
As stated above in numerous other comments the EIS's findings
' regarding commercial and recreational fishing in the area of Site
4 are inaccurate, in light of the EIS's reliance on a study that
10-46 is nearly 20 years old (see Figure 3(18)), this error is
understandable. The drafters of the EIS should discuss the
current, actual use of the area around Site 4 with local
PEEFLES, EART, REYNOLDS & BLAJTK
PROFESSIONAL ASSOCIATION
ATTORNEYS AT I_AW
-------
Mr. T. A. Wastler
December 13, 1982
Page -19-
governmental agencies and interested persons. After such
discussions and resort to more recent studies, please report the
findings and reevaluate the EIS's conclusions.
COMMENT No. 32 — page 4-4 1f 4;
[Re: characteristics of dumping after release into the water]
The EIS has failed to mention the fourth characteristic of
post-release dumping, i.e., the resuspension of find particle by
wave action, tides, storms, and ocean currents. Please describe
n -7 these characteristics with specific reference to data collected
u from Site 4 and identify the potential impacts to hard-bottom
habitats and organisms in and near Site 4.
COMMENT No. 33 — page 4-8 H 1;
[Discusses the short-term turbidity effects on coral-type
organisms.]
Although the severe adverse impacts from short-term turbidity
are described, the EIS makes no attempt to quantify the long-term
effects from the continual resuspension of the material
._ throughout the water column. Please quantify the amount and
IU-4S frequency of siltation, the direction of sediment transport based
on site-specific ocean current information, and the environmental
consequences of long-term turbidity.
COMMENT NO. 34 — page 4-19 fl 4;
Short-term avoidance of locally high turbidity
may be the only significant environmental
effect on fisheries.
The paragraph is erroneous. Testimony by a scientist with
the •*• National Marine Fisheries Service clearly demonstrated that
high turbidity will cause significant adverse impacts to live,
hard-bottom habitats and resulting adverse impacts to fishery
10-49 resources. Please explain the discrepancy between the statements
in the EIS and those of the NMPS scientist regarding the adverse
impacts on fisheries due to turbidity and siltation, especially
in light of the unquestionable relationship between hard-bottom
habitats and fishery resources.
COMMENT No. 35 — page 4-21, 1 4;
[Reference to lack of recreational fishing and diving
activities at site 4, and to nature of the bottom.]
PBEPLBS, EART,, REYITOUDS &
PROFESSIONAL ASSOCIATION
ATTORNEYS AT I_AW
-------
Mr. T. A. wastler
December 13, 1982
Page -20-
The paragraph is incorrect for the reasons stated several
times previously.
COMMENT No. 36 — pages 4-21 to 4-22;
[Discussion regarding effects on economics.]
This entire section fails to take account of the commercial
aspects of recreational fishing, which are clearly recognized
under the MPRSA regulations. See 40 C.F.R. § 227.19. In fact,
the EIS notes that the "full extent to which fisheries may be
10-50 affected, including damage to spawning grounds or juvenile fish,
is unknown." In light of the admitted lack of knowledge
concerning impacts to fisheries in the area, the necessity of
further study is obvious. Please explain the rationale
underlying EPA's recommendation of designating an ocean dump site
on a permanent basis in the absence of knowledge concerning
impacts to fisheries.
COMMENT No. 37 — page 4-22, IT 3;
Disposal of dredged material will result in a
turbid plume that will reduce water cleary at
the site. Because all sites are located at
least 9 nmi offshore adverse impacts on visual
aesthetics from shore will be non-existent.
The quotes passage ignores two important factors: (!) It
unreasonably ignores the effects of turbidity on sport diving,
the enjoyment of which is substantially dependent upon visibility
10-51 and aesthetics. ,{2) It fails to take account of the fact that
there will be continual resuspension of the materials as tides,
storms, etc., act on the dredged spoils.
The above comments make it pellucidly clear that the Draft
Site-Designation EIS is critically flawed. It should be
withdrawn and substantially revised for further public comment.
Because of the extreme significance of the marine habitats and
10-52 fishery resources in this part of the Gulf of Mexico to the
people of Manatee County and the general area, EPA should
schedule a public hearing to allow full and fair public comment
on the revised EIS and the overall suitability of dumping in the
eastern Gulf' of Mexico.
In addition, the Environmental Protection Agency must not
10-53 allow further ocean dumping and the concommitant damages to the
environment and natural resources unitl it has been affirmatively
PEEPJLES, EARL, REYNOLDS & BLANTK
PROFESSIONAL ASSOCIATION
ATTORNEYS AT LAW
-------
Mr. T. A. Wastler
December 13, 1982
Page -21-
demonstrated that ocean dumping in this part of the Gulf of
Mexico is appropriate and that it is the most suitable method of
disposal. That demonstration should include an actual
determination of the nature and extent of hard-bottom habitats
and fishery resources in Site 4 and in surrounding areas, which
must be based on further, site-specific surveys; a determination
of the direction, amount, frequency, and distance of sediment
transport and siltation and a specific quantification of the
damage that will result therefrom; a detailed, careful balancing
of the economic versus environmental concerns involved in using
each alternative method and location for dumping, including
consideration of the many commercial aspects of recreational
fishing and diving; and development of a thorough monitoring
program to assess the impacts of any dumping on a long-term
basis.
pending completion of necessary studies, no ocean dumping
should be allowed — especially on another "interim" basis. Any
consequential delays in important dredging projects can be
avoided by using the massive diked disposal areas in Hillsborough
Bay in the meantime.
Yours faithfully,
William F. Tarr
On behalf and under
authority of the Board of
County Commissioners of
Manatee County, Florida
WFT/yp
cc: Honorable Charlotte Long, Holmes Beach, Fla.
Honorable Ernest Cagnina, Anna Maria, Fla.
Gulf of Mexico Fishery Management Council
Dr. Elton Gissendanner , Florida DNR
National Marine Fisheries Service, Reg'l Dir.
U.S. Fish and Wildlife Service, Reg'l Dir.
Col. Alfred Devereaux, District Engineer
Florida DER
Tampa Bay Regional Planning Council
Joseph* Freedman, Esquire
PBBPXES, EARI., REYNOLDS 8c BLAITK
PROFESSIONAL ASSOCIATION
ATTORNEYS AT LAW
-------
-------
11-1
11-2
GULF OP MEXICO FISHERY MANAGEMENT COUNCIL
Lincoln Center, Suite 881 • 5401 W. Kennedy Blvd.
Tampa, Florida 33609 • Phone: 813/228-2815
December 10, 1982
OO.OEC.32*G02229
Environmental Protection Agency
Criteria and Standards Division (WH-585)
401 M Street, S.W.
Washington, D.C. 20460
Dear Sir:
The Gulf Council has reviewed the DEIS for Tampa Harbor Ocean Dredged
Material Disposal Site Designation. I would like to take this oppor-
tunity to express the Council's position with the following comments
and recommendations:
GENERAL COMMENTS
The Council is a federally funded entity charged with insuring that
the United States obtains the best possible use of fishery resources
in the Fishery Conservation Zone (FCZ), out to the 200 miles offshore.
Fishery management plans developed by the Council for shrimp, reef
fish, and coral reef resources place great importance on habitat pro-
tection. Spoil disposal in or near productive hard-bottom habitat is
a significant threat to fisheries dependent on these habitats. This
threat is not adequately analyzed in the DEIS nor are alternative-
disposal sites adequately explored. We find the DEIS to have serious
deficiencies in content and scope. Our comments of June 4, 1982 (copy
attached), have not been addressed. The survey of offshore sites and
disposal impacts is totally inadequate. The DEIS does not seriously
address disposal alternatives other than the Gulf, nor does it con-
sider the economic and social cost to recreational and commercial
fishermen dependent on fishery populations in and near the dump sites.
We are particularly concerned that offshore disposal of maintenance
material on a continuing basis (1.1 million cubic yards per year, DEIS
page 1-6) will permanently destroy or degrade hard—bottom corrmun i 11 es
and associated fishery values for several miles surrounding the site.
SPECIFIC COMMENTS
1. The site survey on which designation of disposal site 4 is based
is inadequate. Although the site survey is not clearly described
in the DEIS, our staff has obtained additional documents which
detail the survey. It consisted of one transect with an under-
water camera approximately one-half way across site 4, two otter
trawl samples of unknown duration in or near the site and an
unspecified, but apparently small number of box cores and sediment
samples. This is not an adequate base on which to conclude that a
A council authorized by the Magnuson Fishery Conservation & Management Act
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Environmental Protect ion Agency
December 10, 1982
Page Two
site of approximately 3,000 acres contains no hard-bottom com-
munities or that the thousands of acres immediately surrounding
the site are equally barren. According to published information
there are two artificial reefs nearby, one less than one mite
north of site 4 (loran coordinates 14138.5, 44789.6 and 14143.6,
44762.4). Personal communications from divers and fishermen that
use these areas indicate that there are several areas of hard-
bottom habitat within site 4, including at least one ledge. In
addition, hard-bottom areas with ledges have been found on the
northwest, northeast, and southeast corners of the site. There is
a large concentration of hard bottom within 1.5 miles of the
southern boundary of the site, a large concentration of ledges
approximately one mile east of the site, a ledge one-half mile
south of the site, and another area with several ledges less than
one mile north of the site.
11-3
11-4
11-5
The DEIS states that site 4 is removed from areas of recreational
and commercial use (page 2-27). This is in error. The artificial
reefs and hard-bottom areas surrounding the site are well known
and very popular with divers and recreational fishermen and are a
major fishing ground for the charter and head boat fleet operating
out of Manatee County. •
The EPA field survey conducted to look for alternative disposal
s i tes, cons i s ted of two camera transects, one from site 2 approxi-
mately six mi les to the southwest and another west from site A
through site 3, approximately ten miles. ft is difficult for us
to understand how this could be considered an adequate search or
survey.
DEIS does not consider the long-term, essentially permanent effect
of siltaticn resulting from disposal of maintenance material. The
DEIS indicates that a total maintenance budget of 1.0 million
cubic yards per year. An earlier document indicated 0.5 million
cubic yards per year would be disposed of off-shore. This
material will be primarily soft, silty sediments, highly suscep-
tible to movement by current and wave action. It is anticipated
that this mater ial will spread out in a thin layer for many mi 1 es
surrounding the site, as indicated in the DEIS, pages XVI1 and
2-11. This recurring, essentially p.ermanent siltation can be
expected to severely stress hard-bottom communities, decrease the
habitat's ability to support valuable fish stocks and their
aesthetic value for scuba divers.
11-6
The DEIS suggests on page 2-28 that disposal will not result in
any detectable changes in ecology of the area. However, the
studies used to back up this conclusion were all from areas which
have no hard-bottom communities. The animal and plant communities
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Environmental Protection Agency
December 10, 1982
Page Three
in those areas are al
t ion and turbi dity.
use in making conclus
is characterized by I
..levels, and low level
from divers indicate
since offshore dispos
sponges and spiny oys
around the present di
manent stress result!
a very serious threat
dependent on it.
ready adapted to soft sediments, high silta-
Those studies are totally inappropriate to
ions about the west Florida shelf. This area
ow freshwater inflow, clear water, high light
s of silt and turbidity. Personal reports
substantial changes in hard-bottom habitat
al began. Many species, including basket
tors, have disappeared from ledges in and
sposal site. The Council regards the per-
ng from maintenance disposal siltation to be
to the offshore habitat and human activities
3. The DEIS does not make any attempt to analyze the effect which the
proposed disposal will have on fisheries and the economic damage
which will result in the Florida economy. Recreational and com-
mercial fishing is a multibillion dollar business in Florida. A
large fraction of this value is derived from the west Florida
11-7 shelf and will be directly affected by degradation of the habitat
on which these fishery resources are dependent. The values given
in the DEIS are very much out of date and grossly underestimate
the actual value of this activity.
4. The DEIS does not seriously consider alternatives to open Gulf
disposal. Upland disposal is mentioned but rejected because con-
demnation pr oceed i ngs by the sponsor wilt be necessary. However,
it is the legal responsibility of the sponsor to find environmen-
tally acceptable sites. Condemnation is a viable alternative and
is not a particularly lengthy process. As an example, the Alabama
11-8 State Docks recently used condemnation to acquire an industrial
site for port expansion.
An environmentally acceptable alternative exists which has not
been addressed. Two diked enclosures exist today in upper
Hillsborough Bay which have tremendous capacity. These sites are
not mentioned in the DEIS. Although no official estimates were
available to our staff, the diagrams in the 1977 Supplemental EtS
for the Tampa Harbor Project indicate a capacity of roughly 39
11-9 million cubic yards, assuming a six* foot elevation. If existing
dewatering technology was used and the dikes increased in height,
the capacity could be increased many fold. This appears to us to
be sufficient to hold all material scheduled for offshore disposal
for many years to come.
5. The DEIS considers the possible adverse affects of heavy metals
and other toxic substances which may be contained in dredged
spoil. It cites bioassay testing by Jones, Edmonds and
Associates, to support a conclusion that no human health hazards
11-10 are indicated. We have examined sworn affidavits by two former
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Environmental Protection Agency
December 10, 1982
Page Four
employees of that firm which allege that some sediment samples
failed bioassay tests. However, only favorable results were
reported. This casts serious doubt on the reliability of any
conclusions based on the Jones, Edmonds and Associates report.
Another study by Mote Marine Laboratory found extremely high
levels of heavy metals at the existing disposal site. This infor-
mation indicates to us that dangerously contaminated sediments
were dumped offshore and may be dumped again as a result of main-
tenance dredging activity.
6. The DEIS ignores the fact that spoil is being dumped outside the
site. Several individuals have observed dumping outside the site.
A large pile of spoil material was found by a member of our staff
one mile outside the site. Dr. Blake Edwards of the University of
11-11 South Florida observed five disposal trips. In two of the five
trips, disposal occurred outside the site. This dumping greatly
increases the area affected and the potential damage to U.S.
fisher ies.
The Council would like to make the following requests and recommen-
dations:
1} Immediately cease all.offshore disposal until the following is
comple ted -
a. Adequate studies are made of the offshore environment. This
should include a well planned series of transects with an
underwater camera or high resolution fathometer. Transects
H-12 should be run from near shore to beyond 100-foot depths.
Transects should be spaced no more than one-half mile apart.
The area of coverage should extend from at least 15 miles
south of the harbor entrance to ten miles north of It.
t
b. A careful study is made of the present disposal site and
surrounding area to determine how far the .material already
dumped has spread and what effect siltation is having on hard-
1]__13 bottom communities. Observations from local divers indicate
that siltation from the present disposal site has spread at
least seven to eight miles beyond the site. This should be
confirmed and its effect determined.
H-14 c. A good economic analysis of potential damage to fisheries is
produc ed.
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frl
Environmental Protect ion Agency
December 10, 1982
Page Five
11-15
d. A detailed analysis is made on how the capacity of the
existing diked disposal areas could be increased. We suspect
that a carefully planned program of de-watering, increasing
dike height, and reusing spoil material could extend the life
of existing site far into the future, perhaps permanently.
2) Until the above are accomplished, the existing diked disposal
areas should be used for disposal of material proposed to be
dumped rn the Gulf.
11-16
3) We request that a public hearing be held to allow full and complete public
comment. As indicated above, our preliminary review of this project indica-
tes that it is a serious threat to fishery resources for which the Council
is responsible. It may also represent a serious health hazard to the human
population in the area.
Si ncerely,
H
John M. Green
Ch a i rma n
JMG:JCD:lod
At tachments
cc: Gulf Council
Di rector, FlorIda DNR
Secretary, Florida DER
District Engineer, JacksonviI Ie COE
Regional Director, National Marine Fisheries Service
Regional Administrator, Fish & Wildlife Service
Staff
-------
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1600 CITY ISLAND PARK
SARASOTA. FLORIDA 33577
PHONE: (813) 388-4441
WILLIAM R. MOTE WILLIAM H. TAFT. Ph.D.
CHAIRMAN OF THE BOARD PRESIDENT
December 9, 1982
Mr. Michael R. McKinley
Director of Planning
Tampa Bay Regional Planning Council
9455 Koger Boulevard
St. Petersburg, PL 33702
Dear Mr. McKinley:
Enclosed please find a copy of the Mote Marine Laboratory's
comments on the Draft EIS for Tampa Harbor, Florida Ocean Dredged
Material Disposal Site Designation, dated November 1982. These
same comments have been sent: 'to the EPA Criteria. and Standards
Division.
I hope that these comments are of use to you in evaluating the
offshore dumping issue as it relates to the plans and goals of
your organization.
Sincerely,
H. fU^f
Stanley A. Rice, Ph.D.
Staff Scientist
SAR: lef
Enclosure
-------
-------
1600 CITY
SARASOTA,
ISLAND
= L O R I D A
PARK
33577
PHONE: (813) 388-4441
WILLIAM R. MOTS
CMAIPMAN OF THE BOARD
WILLIAM H. TAFT, Ph.D.
PRESIDENT
Comments on the Draft Environmental Impact Statement
For Tampa harbor, Florida
Ocean Dredged Material Disposal Site Designation.
Dated November, 1982
12-1
12-2
I have thoroughly reviewed the above draft EIS and the associated
appendices and would like to register the following comments.
The proposal to designate Site 4 (located 18 n mi southwest of
the mouth of Tampa Bayl as a permanent disposal site, for dredged material
is unjustified for two major reasons. First, insufficient information is
available concerning the physical and biological characteristics of Site A
and the Surrounding area to predict the impact of ocean disposal of dredged
material. Second, site specific monitoring studies of post-disposal impacts
have been incomplete and insufficient to evaluate the impact of ongoing dis-
posal operations on the nearshore Sulf of Mexico environment. Attempts are
made in the EIS to draw conclusions about potential impacts at Site 4 based
upon studies conducted in other paz-;s of the U.S. and under very different
environmental conditions. The Gulf of Mexico off Tampa Bay constitutes a
unique ecological system containing hard-bottom as well as soft-bottom
habitats, tropical and subtropical species, and productive commercial and
recreational resources. For these reasons, site specific studies are
essential to any evaluation or prediction of disposal impacts within -his
area,
A review of environmental studies conducted in the Gulf of Mexico
near Tampa Bay as part of the EIS process reveals that Site 4 has only
recently been considered and that little more is known about Site 4 than
was known about Site A when it was first designated as an interim disposal
site. Of the eight major site-specific environmental studies that have been
conducted since 1979 (Taylor, 1979; IEC, 1979; IEC, 1980; >C-1L, 1981; EPA,
1981? CCI, 1982; Taylor, 1982; EPA, 1982), only the last study considered
Site 4. The latest EPA survey (Appendix C of EIS) collected certain physi-
cal, chemical and biological information from Sites A, B, 3 and 4. In this
study, the sediment grain size analyses, sediment chemical analyses and
water column chemistry would appear to be sufficient to characterize the
existing and proposed sites; however, the biological sampling, habitat
descriptions and tissue chemical analyses fall far short of being adequate.
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-2-
Biological sampling during the EPA, 1982 survey was carried out
with a box core ar.d an otter trawl. As stated on page A-4 of EIS
Appendix C, with reference to box core samples, "All samples obtained
with less thar. IS cm penetration depth were rejected." This type of
sampling methodology would automatically exclude any samples collected
from hard-bottom habitats since a box core .would not penetrate 15 cm. into
12-2 hard substratum. Since no hard-bottom habitat samples were retained or
analyzed and since no record is given on the number of times that box
core samples were rejected, absolutely no conclusions can be drawn from
these benthic samples with regard to presence or absence of hard-bottom
habitats and organisms.
The only other data from the Site 4 study that aight be used to
estimate bottom habitat coverage are the video tape records mentioned
on page 2-10 of the EIS. These videotapes, however, represent only
12-3 one partial transect of the site and do not cover enough terrain to
justify conclusions about the entire site or surrounding area.
Local fishermen and divers frequent the area within and around
Site 4 and hard-bottom habitats s*re known to exist within ths site. Unless
more detailed habitat studies are completed at Site 4, the ETA will be
running the risk of repeating the. same mistake it made with regard to
12-4 Site A, that is, designating an environmentally unacceptable site for
dredged material disposal because of inadequate site-specific studies.
Since insufficient data presently exists with regard to benthic
habitats within and around Sire 4, several conclusions in the EIS cannot
be substantiated since they ars based uron the assumption that hard-bottom
habitats are rare or non-existent at Site 4. These conclusions induce:
12-5 EIS page 2-21, first paragraph; page 4-13, second paragraph; page 4-19,
third paragraph; page 4-21, fourth paragraph.
Table S-l on pages xiv-xv of the EIS lists eleven specific cri-
teria to be considered in selec.ticn of an offshore disposal site and
compares the existing sites with Site 4. Ir. light of the aiove discussion
12-6 ' criteria si, 3, 8, and 9 cannot be adequately evaluated with respect to
Site 4 due to insufficient environmental characterization cf that site.
The prediction of environmental impacts due to dredged material
disposal and the success of environmental monitoring program rests
heavily upon having a thorough knowledge of the composition of poten-
tially affected habitats. The Gulf of Mexico off Tarrpa Bay is unique in
12-7 that it contains highly productive and diverse hard-bottom habitats inter-
spersed among sandy substrata. With the exception of studies by Jaap (1981),
Mote Marine Laboratory (1981) and scattered observations by Taylor (1982),
no studies have considered the impact of dredged material disposal upon
hard-bottom attached organisms. The importance of th&ise hard-bottom
habitats and their associated flora and fauna has beer adequately stressed
in the literature (see EIS for OCS Sale 365, 1978; ar.d Fed. Regist. Vol.
45, No. 194, pg. 55945) and even the present EIS states on cage 2-25,
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"To further minimize adverse inpacts, disruption of hard-bottom
ccnnunities should be avoided to the greatest extent possible." Hard-
bottom ccnmmnities have been identified within all of the existing and
shallow water alternative sites yet no studies have been undertaken
to determine the sensitivity of these organisms to disposal operations.
The effects of disposal operations upon soft-bottom conmunities are not
transferable to hard-bottoms.
In order to predict potential short-term impacts upon hard-
bottom communities, it will be necessary to determine: (1) the species
composition of site-specific hard-bottom habitats; (2) the sensitivity
of .selected representative hard-bottom organisas to siltation and burial;
k, and (3) the potential for bioaccumulation or biomagnification of toxic
chemicals in hard-bottom organisms and food webs. In addition, long-term
monitoring programs should include studies on colonization, growth, and
12-8 reproduction of attached hard-bottom organisms in the vicinity of any
active dump site. At the present time, none of the above information is
available for the existing or alternative sites and thus no predictions
can be substantiated with regard to acute nor chronic impacts upon hard-
bottom habitats. +
In addition to the above comments, the Draft EIS is incomplete
with respect to the following points:
1) Bacteriological studies reported in EIS Appendix C considered
only total and fecal cpliforra with no tests made for vibrio-type bacteria
12-9 that have been identified in Tampa Bay sediments and pose a human health
threat.
2) Data contained within the EIS and Appendices indicate that
Tampa Bay sediments are not compatible or comparable to dump site sedi-
ments. For example: Table 3-5 on page 3-30 and Table 3-2 on page 4-5
report very-low background values for heavy metals like cadmium, lead,
and mercury, yet Tampa Bay sediments contain significantly higher concen-
trations of-these metals. How can these sediments be assumed to have r.o
12-10 significant impact? Sediment grain size analyses reported for Site A
and vicinity prior to disposal operations (Appendix A, page A-143 indi-
cated a silt/clay fraction of less than 2%, whereas post disposal'samples
reported silt/clay fractions as high as 11-42% at the same site-(Appendix
C, page A-33). These are obviously not similar sediments and would
definitely be expected to cause a significant impact upon endemic organisas.
3) The EIS sections concerning endangered species (pages 3-46
and 4-19} fail to consider any of the invertebrate species that are
listed as threatened or endangered by the State of Florida Game and
12-11 Freshwater Fish Commission and that have been reported in the vicinity
of the dump sites.
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-4-
4) Site-specific studies are lacking which address the poten-
tial for toxic chemical release from dumped sediments in spite of the
12-12 fact that potentially toxic concentrations of heavy metals have been
found in Site A post-disposal sediments (SIS Appendix C, page A-54;
Appendix E, page 17) and tissue samples (Appendix C, page A-68).
5} Bioassay studies conducted by Jones, Edmunds and Associates,
Inc. (1979) (EIS page 2-25} on pre-disposal sediments did not employ
12-13 endemic species and are further invalidated by pre-exposure of test
organisms to significantly high concentrations of toxic chemicals in
control water. Thus, these studies have no predictive value.
6) The possibility and economic feasibility of other than ocean
disposal has not been adequately treated in the EIS. Serious consi-
deration should be given to using diked disposal areas within Hillsborough
Bay, at least until a suitable permanent disposal area can be found.
12-14 Further studies, as listed above, are needed before the impact of ocean
disposal in the Gulf of Mexico can be predicted or evaluated. These
studies must be designed, executed and reviewed by competent scientists
to ensure that reliable information is obtained and that the results
address the appropriate concerns. Additional studies should be undertaken
immediately at Site 4 (as suggested in EIS Appendix C, page A-153) to
ensure that another inappropriate disposal site is not authorized pre-
maturely.
Stanley A. Rice, Ph.D.
Staff Scientist
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' HILLSBOROUQH COUNTY
ENVIRONMENTAL PROTECTION
COMMISSION
FftEO A. ANOEASON
JEJWV M. BOWMEfl
FRAN OAVIH
JOE KOTVAS
JAM KAMIMS PLATT
STEWAflT
DIRECTOR
1900 - Ml AVE.
TAMPA. FUWIDA 3MOS
TELEPHONE (813) m-SHO
December 5, 1982
Ms. Margaret Guy
A-95 Coordinator
Tampa Bay Regional Planning Council
9455 Roger Boulevard
St. Petersburg, FL 33702
Dear Ms. Guy:
The staff of the Environmental Protection Commission has reviewed the
Environmental Impact Statement for Tampa Harbor, Florida: Ocean
Dredged Material Disposal Site Designation. The attached memo defines
our concerns and recommendations of the project.
If you have any questions concerning our comments, please contact me.
Sincerely,
Michael Heerschap
Environmental Specialist
Hillsborough County Environmental
Protection Commission
MH/rr
w/Attachment
An AWrnwlM* Action • Equal Onpoiuwy Employer
-------
OUNTY
OF HILLSBOROUGF
To.
MEMORANDUM
November 18. 1932
Mike Heerschap, Assessment
From Tom Cardinale, Laboratory
<•£•
S fa cr
~ Ocean Dredged Disposal Site
14-2
14-2
I would recommend that al 1 disposal at the Existing Site A be stopped because
it is too close to shore, too close to productive reef-areas, and within
easy reach of divers and small boat users.
Site k is in 85 to 95 feet of water and is not as likely to be used for
recreational purposes such as diving and fishing. All material should go to this
site until some long range solution is found.
Site k has no hard-bottom outcrops and would therefore have the least impact
on fish and other types of life.
-------
COUNTY
Be
OF HILLSBOROCIGH
15-1
MEMORANDUM
Dote December 3. 1982
To
From
s*«,.
Maroaret F. Guv. A-9S Coordinator. TBRPC
Christy SuppXSenior Planner, Department of- Development Coordination
TBRPC A-95 Clearinghouse Review No. 218-82; Draft Environmental Impact Statement
for Tampa Harbor, Florida, Ocean Dredged Material Disposal Site Designation,
Hi 11s borough, Manatee and Pinellas Counties
We have no comment on the above-stated project proposal. Offshore impacts
related to water quality are within the jurisdiction of the Environmental
Protection Commission. It is understood that you have already sent, under
separate cover, a copy of the Draft to the Environmental Protection Commission
and the Planning Commission for review and comment as appropriate.
Thank you for informing us of the project.
CS:pkh
-------
-------
BOB GRAHAM
GOVERNOR
STATE OF FLORIDA
©Hire of dcfcmwr
THE CAPITOL
TALLAHASSEE 323O1
December 22, 1982
16-1
Mr. Chris Schilling
U.S. Environmental Protection Agency
Criteria and Standards Division (WH-585)
401 North Street, Southwest
Washington, D.C. 20460
Dear Mr. Schilling:
This Office reviewed and coordinated a state agency
review of your Draft Environmental Impact Statement for Tampa
Harbor Florida, Ocean Dredged Material Disposal Site
Designation for Hillsborough, Manatee and Pinellas Counties.
The document describes a proposed action designating a
dredge material disposal site for Tampa Harbor. The site will
be managed by the U.S. Environmental Protection Agency, Region
IV. The proposed recommended site is approximately 18 miles
southwest of the mouth of Tampa Bay and covers a four-mile
area. It is intended that the site be permanently designated
for the disposal of dredge material resulting from the dredging
of the Tampa Harbor area.
An interagency review of the statement has found that
the proposed action would smother.the benthos within the
designated area and alter habitat within the site. The document
recognizes that these adverse impacts at the site are unavoid-
able. Our reviewing agencies report that the EIS statement is
inadequate and lacks the necessary information to be of sufficient
value as a decision-making document (see attachments).
We have concerns with this_d_e^ignate_d_.s.ite__and EPA's
pjcoposed rule fojr ocean dumping without a Federal Coastal Zone
Management Consistency Evaluation. Recognizing our concerns.
the impact of this designation and its effect r»n +T-IQ
Harbor project, we request that your agency participate in an
interagency jneetinq at your earliest convenience to afford us
the opportunity to discuss issues of concern to the State
Florida. m It is our desire to use this initial meeting as
step toward resolving our concerns.
An Affirmative Action/Equal Opportunity Employer
-------
II
Mr. Chris Schilling
December 22, 1982
Page 2
Please contact Walt Kolb of my office at (904) 488-5551
concerning arrangements for this meeting. Thank you for your
cooperation.
Sincerely,
JTH/mkq
cc: Ms. Victoria Tschinkel
Dr. Elton Gissendanner
Mr. L. Ross Morrell
Mr. William A. Ockunzzie
hn T. Herndon, Director
fice of Planning and Budgeting
-------
A vary H. Gould
9907 Spoonbill Road East
Flamingo Cay
Bradenton, FL 33529
^j^m^e.
chy,
5-7 // -- ^^^f**S/^J£
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.7-3
-------
A very H. Gould
9907 Spoonbill Road East
Flamingo Cay
Bradenton, Ft 33529
7?
/ /
£&fstt(_S> -> &-*~*M£_^.
^j£^/^-2^J^A^^£ JSWc^^^^e^L^^^^^Ui^ -'
7-6 s%£^&t!^£&a^t<^ -'- ~ -
~mj\*L ^ \4TlA*-S& IA £ *± ** J^ J^t £^
7-7
7-8
-------
Awry H. Gould
9907 Spoonbill Road East
Ramingo Cay
Sradenton, FL 33529
%rt**~*.
-------
-------
OFFICE OF THE
ASSISTANT DIRECTOR
FOR ASTRONOMICAL.
ATMOSPHERIC. EARTH.
AND OCEAN SCIENCES
\
RATIONAL SCIENCE FOUNDATION
WASHINGTON. O.C. 2O55O
October 28, 1982
19-1
Environmental Protection Agency
Criteria and Standards Division (WH-585)
401 M Street, SW
Washington, DC 20460
Dear Sir:
The National Science Foundation has ..no comment on the DEIS for
Tampa Harbor, Florida Ocean Dredged Material Disposal Site
Designation.
Sincerely yours,
Barbara E. Onestak
Acting Chairman
Committee on Environmental
Matters
-------
18-1
££*e leds damp the nwtenal at
islands. -
-^^U '
*9&
T^X/-
•__ st.'L'L*.
^i-t^i.-.^yf^^-^'^if^- £f
-------
FLORIDA COOPERATIVE EXTENSION SERVICE
UNIVERSITY OF FLORIDA
FOR SEA GRANT PROGRAM OF STATE UNIVERSITY SYSTEM OF FLORIDA
November 29, 1982
MARINE ADVISORY PROGRAM
R.CPLV TO 1303 17th St. W.
Palmetto, Fl. 33561 2998
(813) 722-4524
Criteria and Standards Division
401 M Sheet SW
Environmental Protection Agency
Washington, B.C. 20460
I have reviewed the draft Environmental Impact Statement
for Tampa Harbor, Florida Ocean Dredged Material Disposal Site
Selection, and have some questions and comments.
1. In the report it is clearly and repeatedly stated that
existing dump sites are located near areas of hard bottom and
charter boat operations. Also, that since this area is a "high
energy" environment there is the po^ssibilty that dredge material
could drift back into the Tampa Bay channel entrance (approx.
2Q-1 1.25 nm south of the existing sites). To me this suggests that
the orginal site selection was conducted in a hasty and arbitary
matter.
I applaud the efforts to find a more suitable disposal site
but question whether damage has already occoured. It will soon
20-2 be six years since the initial dump site- selection. To me the
information presented would argue against permitting any additional
dumping I.e. 1.7 million cubic yards at the present dump location.
2. On page 4-7 the report states: "Dilution and dispersion
will reduce suspended particulate levels relatively quickly".
20-3 What does "relatively quickly" mean, (hours, days, weeks,?).
3. On page 4-19 the report states: "Short-term avoidence of
locally high turbidity may be the only significant environmental
effects on fisheries". If this short term avoidence were to occur
concurrently with the short-term seasonal migrations of mackerel
20-4 and mullet, the effect would be greatly increased. Therefore it
would seem to be advisable to consider seasonal restrictions on
dumping activity.
4. On page 4-22 the report indicates that since the sites are
20-5 a least 9 nmi from shore, a turbid plume would have non-existent
adverse impacts on visual aesthetics from shore. What about for
sport diving?
EQUAL OPPORTUNITY EMPLOYER
COOPERATIVE EXTENSION WORK IN AGRICULTURE. HOME ECONOMICS AND MARINE SCIENCES. STATE Of FUORIDA.
W. S. DCF»AATMCNT OF1 AGRICULTURE. U. S. DEPARTMENT or COMMERCE. AND BOARDS OF COUNTV COMMISSIONERS. COOPERATING
-------
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
3KC. 1982
OFFICE OF
WATER
Mr. Richard E. Pease, President
Florida Skin Divers Association
3901 Lynwood Avenue
Tampa, Florida 33611
Dear Mr. Pease:
Thank you for your letter of November 1, 1982, containing
comments on the Draft Environmental Impact Statement (DEIS) for
the Tampa Harbor Ocean Dredged Material Disposal Site Designa-
tion. Comments on this DEIS should be addressed to Mr. W. C.
Shilling, Criteria and Standards Division (WH-585), EPA, Washington,
DC, 20460. I have taken the liberty of forwarding your comments to
Mr. Shilling.
The notice of availability of this DEIS was published in the
Federal Register, on Friday, October 29; the comment period does
n ot close until December 13.
Sincerely yours,
T. A. Wastler, Chief
Marine Protection Branch (WH-585)
-------
Florida
5
November 1, 198
21-1
21-2
Mr. T. A. Wastler
Chief, Marine Protection Branch
(WH 535 > EPA
Washington, D.C. 20460
Dear Mr. Wastler
As a representative of the Florida Skin Divers Association, I
would like to submit the -following comments on the DEIS -for the
Tampa Ocean Disposal Site Designation.
We have not been afforded an adequate opportunity to comment.
We recieved a copy of the document on October 29, 23 days after
the beginning of the comment period. After allowing time for
our comments to reach you by mail, we had less than 72 hours in
which to review and draft comments. Therefore please understand
that this letter does not contain all of our objections. There
appear to be many errors in the text which we have not had time
to analyze. .Your agency is very strict in requiring other
branches of government to provide DEISs to reviewers on or
before the beginning of the comment period. Are you exempt from
your own rules?
The document addresses only offshore disposal, claiming that a
previous study by the Corps of Engineers had determined that
offshore disposal was preferable to upland or within bay
disposal. However, previous studies by the Corps have never
made any significant attempt to compare the environmental and
economic effects of offshore disposal with other sites. Without
such a comprehensive treatment of the disposal problem, both EPA
and the Corps remain in violation of the spirit and letter of
NEPA.
The document strongly suggests that impacts of dumping are
limited to the site and areas immediately adjacent to it and
that turbidity and siltation effects disappear after a few hours
or days. The experience of our members indicates that this is
false. Since large scale dumping began at the present site, we
have experianced. tubidity and siltation problems over a very
wide and steadily increasing area. These problems became severe
during 1981 and 1982. During the summer of 1982 and continuing
up to the present in an area extending for at least 10 miles
south of the site, a thin layer of silt has been present.
Sponges and soft corals in this area are frequently coated with
this material. It does not take a coral biologist to know that
this is not a healthy situation.- Visibility in this area has
Membership in: UNDERWATER SOCIETY OF AMERICA AND FLORIDA WILDLIFE FEDERATION
-------
been greatly reduced, reducing penetration of light and
productivity of the bottom community. As a side effect, it has
become impossible to dive in much o-f this area, and greatly
reduced the receational value o-f the rest. In our experiance,
turbidity and siltation -from dumping continue to disrupt the
system for months or years, not days.
The DEIS Does not differeniate between the likely environmental
effects of spoil from harbor deepening versus maintenance. In
our opinion, the difference will be radical. Large grain
material, rock, sand,etc from channel deepening will probably
stay within the site. Longterm adverse impacts outside the site
21_3 may not be too serious. Maintenance dreding will produce
primarily silt and other fine grain material. This material
will inevitably be distributed for miles surrounding the site.
If the effects of the material are evident for months or years,
and maintenance dreding is conducted annually or bi-annually, we
have a permanent problem. longterm chronic damage to thousands
of acres of. coral habitat is likely. The DEIS gives no
suggestion that this problem might exist.
The DEIS ignores the effect on the human environment. TWere'has
already been and will continue to be a sustantial loss of
esthetic value to divers. This will inevitably translate into
economic loss for diving related businesses. The same i.s true
21-4 for recreational and charter fishing. The values for
recreational fishing given in the document are ridiculously
understated and 8 years out of date. Economic value of diving
is not even mentioned. Recreational fishing and diving is a
multi-bi11 ion dollar industry in Florida.
The DEIS ignores the effect of illegal dumping outside the site.
As you are aware, from previous correspondence with us, dumping
is now occuring outside the site. A spoil pile can be found at
loran coordinates 1416S.2, 44327.5. This is about one mile east
2l_5 of the present site. When found, it was obviously fresh, with
little growth on the rocks. Some of our members have reported
other instances where hopper dredges appeared to be dumping
outside the site. This may be a common occurance. If so, it's
environmental effects should be considered.
FSDA is strongly opposed to offshore disposal of spoil,
particularly maintenance material. We reccommend that dumping
21-6 cease, at least until the following is completed:
1. The DEIS should be modified to fully examine all disposal
alternatives, including upland disposal. Economic values for
fishery and recreational losses should be included.
Proper management of existing disposal sites could solve most or
2J_7 all of our problems and eliminate the need for offshore
disposal. Most material from channel deepening is good quality
-------
fill, for which there is a ready market in this area. Presently
available techiques for de-watering and compacting soft material
could greatly expand the capacity of existing sites in upper
Hiilsborough Bay.
2. If offshore disposal is inevitable, a serious study of
the offshore area should be completed. Work to date has been
piece meal and totally inadequate. A complete mapping study of
the entire area is needed along with current and wave energy
studies to determine exactly where spoil material will end up.
Thank you for this opportunity to comment.
Sincerel y
Richard E. Pease, President
Florida Skin Divers Association
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Captain L. F. Borden
5301 35th Avenue West
Bradenton, Florida 33529
December 8, 1982
Criteria and Standards Division (WH-585)
401 M Street, S.W.
Environmental Protection Agency
Washington, D. C. 20460
RE: Draft Environmental Impact Statement 11/82
Dear Sirs:
Page 10 of the summary. The Corps stated that non-ocean disposal methods were
considered in 1974. We see nothing in the 1982 draft that compares the cost
benefit ratio of offshore dumping with any other alternatives such as upland
disposal of dredged material. The Federal Register 40CFR, Subpart C227.15,
Paragraph C states that in the factors considered, the need for dumping will be
determined by evaluating the relative environmental risk impact and cost for
22-1 ocean dumping as opposed to other feasible alternatives: including, but not
limited to, landfill, well injection, consideration of spreading the material
over open ground, recycling material, storage, etc. Again, the Corps has not
dealt with the cost-ratio benefits between ocean dumping and upland containment
as they must according to-EPA1s Federal Register.
Page 13, paragraph 4. States "the shallow water Alternative Site 4 will provide
a sandy bottom environment that is further removed from the hard bottom areas
and of sufficient size to permit the disposal of dredge material without unaccept-
22-c a^e adverse affects." There is quite a lot of sand in Site 4. However, this
site also contains many highly productive, low relif, hard bottom areas. There-
fore Site 4 is not an entirely sand bottom as so specified.
Page 16, first paragraph. States "the tropical storms and hurricanes produce
strong bottom currents of 3 to 4 knots which can profoundly affect dumped material.1
This is true, however, every northwestern blow that commonly occurs with the
22-3 winter fronts causes considerabledrifting of the dumped material. These prevail-
ing winds will disperse the material towards the southeast, a very sensitive area
located off Sarasota.
Page 16, paragraph 2. EPA states "dispersal of dumped sediments, particularly
the large volume projects from the Tampa Bay Harbor Deepening Project may
adversely affect hard bottom outcrops near the existing site". Again they are
22-4 stating that migitation of the silt is probable. "Relocation of the disposal
site to an area containing fewer or no hard bottom outcrops will present less
conflict with the environmental characteristics of the area and the commercial
fishing, diving and recreational use of the area." One mile north of Alternative
Site 4 lies one of the best dove areas in the West Coast of Florida; the wreck
-------
Criteria and Standards Division
December 8, 1982
Page 2
of the Gunsmoke in 80 feet of water. The Gunsmoke is a 65-70 foot fishing
vessel sunk some 6-7 years ago. Without a doubt the siltation will affect that
dive site. The Draft goes on to say "in addition continued use of existing
sites or use of Alternative Site 2 may result in repositioning of dump sediments
into the entrance of the channel". Again they are stating that migration is
probable. The last portion of that paragraph states that shallow water Alternative
Site 4 will provide a large sandy bottom area for disposal of dredged material.
Again, they stated that is is all sandy bottom. It is not.
Page 17, paragraph 2. States "dispersal of material outside the site boundaries
will be over time and in thin layers. Such dispersion is not expected to have
unacceptable adverse environmental affects." It is my belief that a thin layer
over a period of time is what is doing the damage to the limestone ledge forma-
22-5 tions, particularly the low relief hard bottom outcrops in the Gulf of Mexico.
This thin layer that the draft is discussing unnaturally resuspends and smothers
every little section of outcropping in the area, destroying the chain of life.
Page 19, summary Environmental Consequences. EPA states "previous disposal of
dredged materials at existing sites has not been monitored to determine specific
environmental effects". It goes on to say that "studies of dredged material
disposal in other operations conducted in other areas of the continental waters
had determined no significant long term adverse affects resulted in the dumping
of dredged material on sandy bottoms". The West Coast of Florida is not tfke
other locations throughout, the continental U.S.A. The flushing patterns are
22-6 completely different than the East Coast of Florida or the northeast coast of
the continent. Flushing patterns and dispersal patterns cannot be compared to
other areas of the United States. Again, they have stated in the summary that
dispersal is evident. The problem is that it does not collect on the sandy
areas, it collects in the limestone pockets, the habitat for the fish.
Page 20. States "that mounds of dredged material may persist several months.
The physical characteristics of the dredged sediment may be dissimilar to the
existing sediments resulting in changes to the bathynic biological characteris-
"•-7 tics of the affected site." The Draft summary states "the marine organisms are
not adapatable for burial or the high level of silt, therefore the dredged
material and disposal at the existing site may result in a more significant
environmental consequence than at an alternative site, such as Site 4." The
problem with this statement is that the quality of the water is much better
at Site 4 in 80 feet of water. The corals are in better shape, the spiny oysters
are surviving and the general quality of the water is much better and much
clearer. Therefore there would be more environmental consequences due to the
siltation at Site 4.
Page 20, paragraph 2. States that "based on analysis of the samples, certain
trace elements would be released in the water during disposal. Some of these
materials contain heavy metals, organic compounds, nitrogen compounds, and
phosphorous compounds. It states however the estimated volume release and
22-8 calculated dilution of this mater indicated that there would be reduced back-
ground levels after the permitted 4 hour period of initial dilution. The problem
seems to be that the samples and the 4 hour periods of initial dilution are not
actual paramenters, but in fact samples. - Samples of silt removed from the actual
dump site.
22_Q Page20, paragraph 3. States "the proposed action is expected to have minimal
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Criteria and Standards Division
December 8, 1982
Page 3
22-10
22-11
impact on threatened and endangered species occuring in the region." Turtles
inhabiting the area are predominantly loggerhead. The last portion of that
paragraph states "that the general area of the site under consideration, Site 4,
do not contain unique feeding or breeding grounds for any specie of turtle and
the site used is not anticipated to affect their survival." Perhaps the bottom
within Site 4 is not unique in that it does not have the high relief that the
loggerheads seem to stay around and feed, however the scope of the siltation
will affect the loggerhead feeding. Silt migration is evident to other areas
that the loggerhead will be feeding and living. There are loggerheads in the
area of Site 4. I feel that siltation will definitely affect the feeding
pattern and perhaps the breeding pattern as well.
Page 21. paragraph 1. States that "disposal operations on Alternative Site 4
would not interfere with long term use of the resource". I disagree with that.
It goes on to say that, adverse environmental effects of the proposed action
include smothering of the bottom within the designated site to possible habitat
alteration of the site and states adverse impacts within the site are unavoid-
able, but the disposal operations will be regulated to prevent unacceptable and
environmental degration outside the boundaries". Regulation seems to be the key
would here. The EPA has proven to the residents of Manatee County that it does
not intend to abide by it's own regulations set up in the Federal Register.
Page 21. paragrapir 2. States "the CE District Engineer or EPA may_ establish a
monitoring program to supplement historical data. The primary purpose of the
monitoring program is to determine whether disposal at the selected site signifi-
cantly affects areas outside the site, and to detect long-term effects occurring
in or around the site." This monitoring plan will no doubt be as incomplete as
Mr. Amson's site survey of Site 4. Retrospective monitoring serves no purpose
after the damage is done and the habitat is destroyed. As in the case of Site A.
Bataymetric studies must be conducted before the ocean disposal if adverse im-
pacts are expected.
orden
cc: Alfred B. Devereaux, Jr.
Charles Hunsicker
Bob Reynolds.
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DEPARTMENT OF THE ARMY
WATER RESOURCES SUPPORT CENTER. CORPS OF ENGINEERS
KINGMAN BUILDING
FORT BELVOIR, VIRGINIA 22060
REPL.Y TO
ATTENTION OF:
WRSC-D
9 DEC 1982
Mr. Jonathan Amson
Criteria and Standards Division
U. S. Environmental Protection Agency
401 M Street, S. W.
Washington, D. C. 20460
23-1
Dear Mr. Amson:
The Draft Environmental Impact Statement for the Tampa Harbor, Florida, Ocean
Dredged Material Disposal Site Designation, dated November, 1932, has been
reviewed by the U. S. Army Corps of Engineers. The Corps' general and specific
comments are inclosed, Incl 1.
The Corps concurs with EPA's recommendation that the ocean site at center
coordinates 27° 31* 27"N, 83° 04• 54«W, is environmentally acceptable for the
ocean disposal of dredged material and should receive permanent designation for
the disposal of dredged materials from the Tampa Bay area that are in
compliance with the criteria and requirements of EPA and Corps regulations.
Sincerely,
1 Incl
As stated
Chief, Dredging Division
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-R 1 December 1982
SAD Comments on EPA DEIS (November 1982)
for Tampa Ocean Dredged Material Disposal Site Designation
1. General.
a. While the EIS recommends the designation of a new ocean disposal site,
it does not clearly show the trade-offs involved in changing sites. That is,
the additional economic costs of utilizing Site 4 are not weighed-against the
environmental damages to the existing site and adjacent areas. Furthermore,
the significance of the hard bottom areas in Site A to the hard bottom in the
geographic region is not discussed or demonstrated.
b. The EIS should clarify the concept that previous studies "showed no
significant environmental degradation outside Site A, and, in EPA's best
professional judgment, the balance of the dredged material from Section 2C
(portion) will remain within the site without causing unacceptable adverse impact
beyond the site boundary." (Federal Register, October 6, 1982). The EIS does not
appear to be totally consistent with the concept as indicated by paragraph 1,
page 2-26 and paragraph 1, page 4-2.
c. Recovery of Site A after completion of disposal should be disc-.-sed.
2- Page VI. first sentence, item(2). "possible" should be deleted.
3, Pages X, 10thlineand 2-4, llth line, "justify an acceptable"... suggest
replace "justify" with "develop," and method needs to be pluralized.
*• Page 1-6. The second paragraph needs to be revised to reflect the comple-
tion~~5rrecent maintenance dredging of St. Petersburg Harbor and Port Tampa
Channel, St. Petersburg Harbor dredging was completed on May 1981; 362,652
cubic years of dredged material was taken from St. Petersburg Harbor and
deposited in the Gulf d/a (Site A). Dredging at Port Tampa Channel (Cut 6)
was completed on March 1982; 662,897 cubic yards of dredged material from
the Port Tampa Channel was deposited at the Gulf d/a (Site A).
5. Page 2-3,_ f1rst^ful1 paragraph. Freshwater runoff from upland is not
considered a significant influence at the subject disposal areas. It is
recommended that "freshwater runoff11 should be deleted.
6. Page 2-3, last paragraph. Site 4 is 5.6 statute miles farther hauling distance
than existing site.A round trip would therefore be 11.2 statute miles (9.7 nautical
mi 1es).
7. Page 2-5. A total land-based operation is not expressed on this page. The
alternative should be identified as a land and water-based disposal area. In
addition, the mention of dike locations is confusing. During successive
dredging operations, dredged material will be placed landward of temporary dike
structures located above the waterline. This will confine unconsolidated material
and control the runoff from the disposal area.
Incl. 1
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UNITED STATES DEPARTMENT OF COMMERCE
National Oceanic and Atmospheric Administration
Washington. D.C. 20235
OFFICE OF THE ADMINISTRATOR
December 13, 1982
24-1
Environmental Protection Agency
Criteria and Standards Division (WH-585)
401 M Street, SW, Room 2824
Washington, D.C. 20460
Dear Sir:
This is in reference to your draft environmental impact statement
entitled "Tampa Harbor, Florida, Ocean Dredged Material Disposal Site
Designation." The enclosed comments from the National Oceanic and Atmospheric
Administration are forwarded for your consideration.
Thank you.for giving us an opportunity to provide comments. We would
appreciate receiving four copies of the final environmental impact statement.
Sincerely,
yce !"f Wood
ief
Ecology and Conservation Division
Enclosure
10TH ANNIVERSARY 1970-1SSO
National Oceanic and Atmospheric Administration
A young agency with a historic
tradition of service to che Nation
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UNITED STATES DEPARTMENT OF COMMERCE
National Oceanic and Atmospheric Administration
NATIONAL MARINE FISHERIES SERVICE
,,.....„.
Southeast Region
9450 Roger Boulevard
St. Petersburg, FL 33702
November 4, 1982
PP/EC - Dave Cgttingham
F/SER64 - And'reas
TO:
FROM:
SUBJECT: Review of the November 1982 Draft Environmental
Impact Statement for Tampa Harbor, Florida Ocean
Dredged Material Disposal Site Designation by the
United States Environmental Protection Agency
The subject DEIS has been received for review by the Marine Mammals
and Endangered Species Branch of the National Marine Fisheries Service,
Southeast Region.
The statement has been reviewed relative to information provided
on marine mammals and endangered species. The following comments
are offered for your consideration.
3 Affected Environments
Rare and Endangered Species (Page 3-46)
The information provided regarding whales should be revised. No
data is available on the life histories of the six whale species discussed.
Accordingly, it cannot be unequivocally stated that the Gulf serves as
a winter feeding, mating, and calving ground, or that most whales
stay beyond the continental shelf. The following information on
whales should be considered. This information was obtained from
Schmidly, D.J. 1981. Marine Mammals of the Southeastern United States
Coast and the Gulf of Mexico. U.S. Fish and Wildlife Service, Office
of Biological Services, Washington,.D.C. FWS/OBS - 80/41 163p.
Sei Whale (Balaenoptera borealis) - -These whales are known from
the Gulf of Mexico based on three strandings; one at Gulfport Harbor,
Mississippi, one near Fort Bayou, Louisiana, and one at Campeche, Mexico.
Three stocks are believed to exist, one of these may be a Caribbean/Gulf
of Mexico stock. These whales are distributed inshore as well as offshore.
No data is available on life history in the Gulf of Mexico.
Fin Whale (Balaenoptera physa_l_u8_) - These whales are known from
the Gulf of Mexico based on four sightings and six strandings. They
are present in the Gulf of Mexico apparently throughout the year,
possibly indicating an isolated stock. Two sightings have occurred
inshore; one in Florida Bay near Boot Key and the other off Destin, Florida,
Accordingly, an inshore as well as offshore distribution is indicated.
No life history data is available for fin whales in the Gulf of Mexico.
-------
Blue Whale (Balaenoptera musculus) - Blue whales are known
from the Gulf of Mexico based only on two strandings. The
identification of one of these strandings may be suspect. No other
data is available for this species in the Gulf of Mexico, but blue
whales seem to prefer cold water and avoid warm waters.
Humpback Whale (Megaptera novaeang1i ae) - This species is known
from the Gulf of Mexico based mainly on three sightings, one of these
was off the mouth of Tampa Bay within 40 miles of the coast. Captures
are also reported from the Gulf of Mexico. Humpback whales are a
coastal species and are likely to be found inshore. Breeding and
calving are known to occur in Caribbean waters from January to March,
but no life history data is available for the species in the Gulf of
Mexico.
Right Whale (Eubalaena glacialis) - One sighting and one stranding
of this species are reported from the Gulf of Mexico. The sighting
occurred off New Pass, Manatee County, Florida. These whales are
primarily coastal, occurring very close to shore. Therefore, they
are threatened by pollution, habitat destruction, and ship traffic,
especially since they are near extinction. No life history data is
available for the right whale in the Gulf of Mexico.
Sperm Whale (Physeter catodon) - A number of captures, strandings,
and sightings have been reported for this species in the Gulf of Mexico.
Sperm whales occur primarily in deep water off the continental shelf.
'The sperm whale was once numerous in the Gulf, but is now considered
to be uncommon. No life history data is available in the Gulf of Mexico.
The information in the DEIS on sea turtles is also not accurate.
Specifically, we disagree that the five endangered turtles migrate from
the Caribbean to nest along the Gulf coast of Florida and that the
turtles range from Cedar Keys south to the Dry Tortugas. Moreover,
the loggerhead sea turtle is listed as threatened, not endangered.
The five species of sea turtles mentioned are distributed through-
out the Gulf of Mexico and not only from the Cedar Keys to the Dry Tortugas,
Also, the reference used to document that sea turtles migrate from the
Caribbean to the Gulf of Mexico should be provided. The loggerhead is
the only sea turtle that nests with any frequency along the Gulf coast
of Florida. Nesting here by other sea turtles would be very rare to
non-existent.
-------
In view of the above, the information in the DEIS on sea turtles
and marine mammals should be upgraded. Also, the discussion of project
impacts on endangered and threatened species (page 4-40) should
be re-examined in the light of new information obtained.
The DEIS would also be more complete if it contained the results
of the Section 7 Consultation required by the Endangered Species Act.
This could perhaps be included in Chapter 5 - Coordination.
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December 17, 1982
tempo bou
regional
planning
council
9455 Koger Boulevard
M_ m a waa*1»f SI Petersbwg.FL 33702
ax, A. A. was^xer (813) 577-515 VTampa 224-9380
Chief, Marine Protection Branch (WH-585)
Environmental Protection Agency
402 H Street S.W.,
Washington, D.C. 20460
Dear Mr. Wastier:
Subject: Capacity of an Ocean Disposal Site to Contain Dredged Material
with Special Reference to Outer Site A, Tampa, Florida
The staff of the Tampa Bay Regional Planning Council has reviewed the
above referenced report prepared to support the extended area of Site A
for the disposal of dredged material from the Army Corps of Engineers
Tampa Harbor Deepening Project* Based on the limited information in the
report and minimal review time frame, a determination cannot be made
until detailed evaluation of the proposed action on the human health,
welfare, amenities, marine environment, ecological system, and economic
potentialities are completed and public hearing is held.
The report contains some valuable scientific information assessing the
impact of disposing dredged material on sites located on the Atlantic
Continental Shelf. However; as it is stated in this report, the number
of conducted studies is relatively small and there is not yet a
generalized model that is widely accepted and available to describe all
the relevant processes.
Further disposal of dredged material at Site A may result in more signi-
ficant environmental consequences than at other locations. Since May
25-1 1981, about 4.68 million cubic yards of dredged sediment have been
discharged at Site A; about 59 percent of this material was mud, 39 '
percent was sand, and 2 percent was rock. The additional dumping may
cause irreversible negative impacts on the marine environment.
Therefore, the Council staff recommends that a public hearing be held to '
evaluate the impact of the continued disposal of dredged material of the
25-2 designated site. The public hearing should be held in order to receive
this public testimony on the following issues:
Chairman Jan K. Platl Vice-Chairman George McGough Secretary/Treasurer SaundraRahn WA Ockunzzi
Commissioner. HiltsDorough County Mayor. City ol Largo Councilwoman. City ot Bradenton Executive Director
Bradenton • Clearwater . Oade City * Ounedm • Guifport • Millsborough County • Largo « Manatee County • New Port Richey * Oldsmar « Palmetto
• Pasco County • Pinedas County « Pinellas Park • Safety Harbor « Si. Petersburg « St. Petersburg Beach • Sarasota • Tampa « Tarpon Springs
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Mr.T. A. Wastler -2- December 17, 1982
;/ ' •
25-3 o Evaluate other alternatives than ocean disposal like diked disposal
islands and upland disposal areas.
25-4 o Evaluate the Impacts of the proposed action on marine environment
and economy of the region.
2,5-5 o To further review the EPA proposal for extension of Site A for the
disposal.
Determine whether the proposed action affects the recreational
activities of the region and commercial fishing.
The possible impact on migratory fishing, should be identified*
Contribute to the knowledge of the environmental features of this
area based on the previous activities in/around the site.
Determine what studies' and monitoring should be done in this area in
order to detect long term adverse impacts.
We appreciate the opportunity to review this important project and hope
the above comments are helpful to you in reaching a decision on a public
hearing. Should additional clarification be necessary, please contact
me or Mr* Michael McKinley of the Council's staff.
Sincerely
2.5-6 o
25-7 o
25-8 o
25-9 o
'William AT
Executive Director
WAO/rbm
cc: Jan Platt
Westwood Fletcher
Jesse Carr
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Florida Skin Divers Association, Inc.
December 9,1982
Environmental Protection Agency
Criteria and Standards Division (WH-5B5)
401 M Street, S.W.
Washington, D.C. 20460
Dear Sir:
As a representative of the Florida Skin Divers Association, I
would like to add to our previous comments on the DEIS for Tampa
Harbor Ocean Dredged Material Disposal Site Designation.
The data base of the DEIS is badly flawed. The "survey" used to
define site 4 was unbelievably inadequate. It consisted of
towing an underwater camera along a straight line track for a
26-1 total of two hours. According to the distances given in the log
of the survey supervisor, the camera track only extended about
half way across the site.
The DEIS concludes that site 4 is "sandy bottomed" and is
"removed from areas of recreational diving". It further- states
that there are no wreaks or artificial reefs near the site. All
of these statements are false. Two very popular wreaks are
located just north of the site. One, the Bunsmoke, is less than
one mile from the site and is plainly marked on navigational
charts. There are numerous productive fishing and diving areas
in and around site 4. To our knowledge, three productive areas
exist within the site, including one ledge. At least three
26-2 other ledges can be found within one third mile of the site and
dozens, if not hundreds, of ledges lie within two or three
miles. Numerous hard bottom areas can be found within and on
all sides of the site. All of these areas are popular and
productive diving and fishing areas. We can provide exact loran
coordinates for these areas if the EPA or some other agency is
willing to conduct a comprehensive and unbiased study.
The DEIS is legally insufficient, because all alternatives are
not considered. The DEIS implies that it was not necessary to
consider non-ocean disposal because the Corps of Engineers had
previously compared those alternatives to ocean disposal.
Hovever, we examined the 1974 FEIS and the 1977 supplemental EIS
2g_3 and found no significant analysis of potential damage to
offshore habitats, no studies of offshore sites, no estimates of
damage to fishing and diving values , either economic or social.
We conclude that the previous "analysis by the Corps was not
sufficient to assess the relative merits of ocean versus other
Membership in: UNDERWATER SOCIETY OF AMERICA AND FLORIDA WILDLIFE FEDERATION
agt^^
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N
types of disposal alternatives.
A practical, environmentally safe alternative to offshore
disposal does exist. Two diked disposal areas are available in
upper Hillsborough Bay. These areas cover several square miles
and have tremendous capacity. That capacity could be
26-4 sustantially increased by increasing dike heights and
de-watering the spoil material. There is no need for any
offshore disposal for many years to come, probably never.
Failure to consider this alternative is a serious legal
deficiency in the DEIS.
We request that a public hearing be held in the Tampa Bay area
to allow full and complete public comment on this issue.
Please be aware that we are considering legal action against the
26;-.5 EPA and Corps of Engineers if offshore disposal continues.
Thank you for this opportunity to comment.
Sincerely
Richard E. Pease, President
Florida Skin Divers Association
\
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tempo bay
regional
January 14, 1983
Mr. Jonathon Amson
U.S. Environmental Protection Agency
Criteria and Standards Division (WH-585)
401 M Street, S.W. {8i3)577.5l5i.'TanDa22-»-9380
Washington, D.C. 20460
Dear Mr. Amson:
Subject: Tampa Bay Regional Planning Council A-95 Clearinghouse Review No*
218-82; Draft Environmental Impact Statement (DEIS) for Tampa
Harbor, Florida, Ocean Dredged Material Disposal Site
Designation, Hillsborough, Pinellas and Manatee Counties
27-1 Enclosed please find a copy of the Council's Clearinghouse Review report
for the above referenced project adopted by the full Council on January 14,
1983.
Should additional clarification be needed, please feel free to contact me.
We appreciate the opportunity to review the proposal.
Sincerely,
Platt
Chairman - TBRPC
Hillsborough County Commissioner
MRM/kn
Enclosure
cc: Walt O. Kolb, Governor's Office
Westwood Fletcher, TBRPC
Jesse Carr, TBRPC
Chairman Jan K Plan Vice-Criairman George McGougn SecreiaryfTreaSU'er Saundra Rann WA
Commissioner. HillsOorougn County Vice-Mayor. City ol Largo Counc/'woma/r Cify ol Sradenton Etecuiive Queer
B'acenton • Oearwater • Dade City » Ounedm • Gulloon • HillsDorough County • Largo • Manatee County • New Pori Ricnev • Oldsmar • Palmetto
• Pasco County • Pinellas County • Pinellas ParX • Safety Harbor • St. PetersOurg • Si. PetersDutq BeacM * Sarasota • Tamoa « Tarpon Sonngs
-------
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Agenda Item
1/14/83
A-95 #218-82; Draft Environmental Impact Statement (DEIS) for Tampa
Harbor, Florida, Ocean Dredged Material Disposal Site Designation,
Hillsborough, Pinellas and Manatee Counties
The U.S. Environmental Protection Agency (EPA) has requested review and
comment on the draft Environmental Impact Statement (BIS) for Tampa Harbor,
Florida which presents information necessary for the designation of a new
Tampa Harbor Dredged Material Disposal Site. The purpose of the action is
to provide the most environmentally and economically acceptable ocean
location for the disposal of material dredged from the Tampa Bay area.
Based on recent surveys of four Shallow-Water Alternative Sites, EPA has
determined that Shallow-Water Alternative Site 4 is the alternative with
the fewest hard-bottom areas which may be affected by the disposal of
dredged material. It is the recommendation of the DEIS that Alternative
Site 4 be designated as the disposal site location for dredged material
from the Tampa Bay area* Agency - EPA; Location - Hillsborough, Pinellas
and Manatee Counties.
Local Comments Received From;
Hillsborough County Environmental Protection Commission: See attached
letter dated December 5, 1982.
Hillsborough County Department of Development Coordination: See attached
memorandum dated December 3, 1982. .
Pinellas County Planning Department: No comment received as of December
30, 1982.
City of St. Petersburg Planning Department: See attached letter dated
December 16, 1982. * *
Manatee County Board of County Commissioners: See attached letter dated
December 13,1982
Mote Marine Laboratory: See attached letter dated December 9, '1982.
Gulf of Mexico Fishery Management Council: See attached letter dated
December 10, 1982.
Office of the Governor: See attached letter dated December 22, 1982*
Council Comments and Recommendations
This project has been reviewed for consistency with the Council's Areawide
Water Quality Management Plan and the Council's adopted growth policy, the
Future of the Region. The proposal has not been found to be consistent
with Council policy that a standard of water quality should be achieved
that allows for the protection and propagation of fish, shellfish, and
wildlife and provides for recreation in and on the waters in the region.
tempo bay regional planning council
9455 Koger Boulevard St Petersburg, F|_ 33702 (813) 577-515 Mampa 22-1-9380
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This project is regionally significant and the following local and regional
concerns have been raised during the review:
• The staff of the Tampa Bay Regional Planning Council has reviewed the.
Draft Environmental Impact Statement (DEIS) for Tampa Harbor Ocean
Dredged Material Disposal Site Designation and offers the following
comments:
General Comments
1 . The DEIS lades sufficiently detailed evaluation and comparisons of
all possible alternatives including diked disposal islands and
upland disposal areas.
2. The designation of Alternative Site 4 for disposal of dredged
material from the Tampa Bay Area should be based on more detailed
studies of this area. The DEIS lacks site specific studies evaluat-
ing the impacts on marine environment and economy of the region.
The results of the studies done in other locations cannot serve as
the base for evaluating the impacts of the proposed dumping of
dredged material on the proposed site.
3. The environmental consequences of dumping dredged sediments on sand-
subs tate habitats also cannot be predicted based on the results of
the studies from other locations. The ecosystem of shallow-waters
in central-southwest Florida is different from the continental U.S.
waters.
.4. Information pertaining to tidal currents is needed based on records
obtained from the tide guage station located in Egmont Key.
5. The monitoring program has not been specifically designed to deter-
mine whether disposal at the selected site significantly affects
areas outside the site and to detect long term effects occurring in
or around the site. It is stated in the DEIS that a monitoring
program may be established to supplement historical data. Details
on what the monitoring program will entail must be included.
6. The recreational and commercial fishing values of the surrounding
area should be identified as well as the impacts of ocean disposal
on migratory fishing.
7. It is stated that dispersion of disposal material outside the site
boundaries will be over time and in thin layers, and that such
dispersion is not expected to have unacceptable adverse environmen-
tal impacts. Specific studies need to be completed to determine
whether the thin layer of siltation adversely impacts the sur-
rounding hard bottoms (corals}.
Specific Comments
1. Statements that there are no hard-bottom habitats within or' in
proximity to Site 4 are not well-documented. More extensive inspec-
tion of areas both within and around the site is necessary before it
can be known what types of organisms and communities will be
-------
adversely affected by dumping. In-depth surveys to determine the
nature and extent of live, hard-bottom habitats in or near the site
should be further conducted.
2. It is stated in DEIS that results of dredged material disposal at
the Tampa Harbor alternative sites are anticipated to be similar to
the results of disposal operations at Calveston, Texas (page 2-28).
However, the West Florida Shelf cannot be compared with other areas
which have no hard-bottom communities. The conclusions that dispo-
sal will not result in any detectable changes in ecology of the area
are inappropriate*
3. An assessment of the siltation and turbidity caused by resuspension
of fine particles by waves, storms and tides has not been completed,
as well as the expected impacts of the siltation on live-bottom
habitats.
4. The long-term effects from the continual resuspension of spoil
material throughout the water column have not been adequately
studied nor documented. The amount and frequency of siltation, the
direction of sediment transport based on site-specific ocean current
information, and the environmental consequences of long-term tur-
bidity should be estimated before final recommendations are made.
5. It is stated in the DEIS that Site 4 is removed from areas of
recreational use, and has no known significant commercial fishery
use (page 2-27). This statement is not based on the detailed survey
of commercial and recreational fishing activities of this area.
Relevant studies should be completed based on public testimony
whether the proposed action affects the recreational activities of
the region and commercial fishing.
6. Cost-benefit analysis, taking into account the direct and indirect
economic benefits generated by the recreational use of this part of
the Gulf of Mexico have not been done at this time.
7. A public hearing should be scheduled to allow full and fair public
comment in the draft EIS and the overall suitability of dumping in
the Eastern Gulf of Mexico.
The Manatee County Board of County Commissioners has provided extensive
comments which already have been forwarded .to EPA and are summarized
"below (see attached letter dated December 13, T982) regarding the Draft
EIS for a permanent ocean disposal site for Tampa Harbor:
1 . The EPA survey upon which the EIS relies to recommend Site 4 for
permanent designation, used survey methodologies that are inadequate
for determining the nature and extent of live, hard-bottom habitats
in or near the site; yet, the entire EIS rests on the unproven
assumption that there are no hard-bottom habitats within or in
proximity to Site 4. This is critical because of the well-docu-
mented importance of live-bottom habitats to both commercial and
recreational fishery resources.
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2. Although the BIS notes that significant damage that can occur to
hard-bottom habitats from siltation and turbidity, it completely
fails to describe or assess the siltation and turbidity that will be
caused by resuspension of fine particles by waves, storms, tides,
and combinations thereof, and it fails to quantify the resulting
siltation problem and its expected impacts to corals, sponges,
algaes, and the like.
3. The EIS recommendation of Site 4 is based on erroneous and under-
stated information concerning the use of the area in and around the
site, which is actually located in an area that is heavily used by
commercial and recreational fishermen, sport divers, and others.
4. The Site-Designation EIS presumes that ocean dumping is appropriate
in this part of the Gulf of Mexico, disregarding as a general matter
the high potential for damage from burial and siltation to the hard-
bottom habitats and organisms found scattered throughout this part
of the Gulf, and inadequately considering the possibility of using
uplands or diked disposal areas on a short-term basis pending
thorough investigation of the suitability of ocean dumping.
5. The EIS also relies on erroneous cost estimates for transporting the
dredged material to various alternative sites, and there is no
comparison of the environmental "pros and cons" of each alternative
site relative to the economic costs.
6. Finally, with respect to the EIS's cost analyses, the BIS fails to
take any account of the direct or indirect economic benefits gen-
erated by the recreational use of this part of the Gulf of Mexico,
thereby placing too-heavy emphasis on the immediate costs of spoil
transportation.
Therefore, in light of the many deficiencies of the Draft EIS, including
reliance on erroneous assumptions, inadequate surveys, and incorrect
infomation, the Board of County Commissioners of Manatee County requests
that a public hearing be scheduled to discuss the Draft BIS and proposed
site designation, or, in the alternative, that the Draft EIS be with-
drawn and subsequently resubmitted for public comment.
The staff of the Hillsborough County Environmental Protection Commission
has reviewed the Draft Environmental Impact Statement (EIS) for Tampa
Harbor: Ocean Dredged Material Disposal Site Designation and submits
the following comments and recommendations:
It is recommended that all disposal at the Existing Site A be
stopped because it is too close to shore, too close to produc-
tive reef areas, and within easy reach of divers and small boat
users.
Site 4 is in 85 to 95 feet of water and is not as likely to be
used for recreational purposes such as diving and fishing. All
material should go to this site until some long range solution
is found.
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/of
Site 4 has no hard-bottom outcrops and would therefore have the
least impact on fish and other types of life.
* The City of St. Petersburg Planning Department has reviewed the Draft
EIS for Tampa Harbor: Ocean Dredged Material Disposal Site Designa-
tion and recommends the following additions to the above referenced
BIS:
Incorporation of any appropriate review criteria
which may be forthcoming from the pending litiga-
tion related to offshore dumping initiated by
Manatee County;
Analysis of upland dumping sites;
Further analysis of Site 4. It appears that
Appendix C. (referenced on Page 2-13 of study) may
provide additional data to substantiate minimal
adverse environmental impacts.
• The Office of the Governor has submitted the following comments and
recommendations regarding the Draft EIS:
An interagency review of the statement has found
that the proposed action would smother the benthos
within the designated area and alter habitat within
the site. The document recognizes that these
adverse impacts at the site are unavoidable. Our
reviewing agencies report that the EIS statement is
inadequate and lacks the necessary information to
be of sufficient value as a decision-making docu-
ment (see attachments).
We have concerns with this designated site and
EPA's proposed rule for ocean dumping without a
Federal Coastal Zone Management Consistency Evalua-
tion. Recognizing our concerns, the impact of this
designation and its effect on the Tampa Harbor
project, we request that your agency participate in
an interagency meeting at your earliest convenience
to afford us the opportunity to discuss issues of
concern to the State of Florida. It is our desire
to use this initial meeting as a step toward re-
solving our concerns.
Based on the review of this document, it is the opinion of the Tampa Bay
Regional Planning Council that no ocean dumping should be performed
until it is demonstrated that ocean dumping in this part of the Gulf of
Mexico is appropriate and that it is the most suitable method of dispo-
sal. That demonstration should include an actual determination of the
nature and extent of hard-bottom habitats and fishery resources in site
4 and in surrounding areas. This determination should be based on
further, site-specific surveys, including the direction, amount, fre-
quency, and distance of sediment transport and siltation, and a specific
quantification of the damage that will result therefrom. Also, a de-
-------
tailed, careful balancing of the economic versus environmental concerns
for each alternative method should be performed, including consideration
of the many commercial aspects of recreational fishing and diving and
development of a thorough monitoring program to assess the impacts of
any dumping on a long-term basis.
In conclusion, the final recommendation of the DEIS for Tampa Harbor
which designates Shallow-Hater Alternative Site 4 as the Tampa Harbor
ocean dredged material disposal site is not consistent with the
Council's adopted policy to support the maintenance of Class III waters,
including bays, rivers, lakes, estuaries and open waters of the terri-
torial sea, at a quality sufficient to allow body-contact water sports
and propagation of fish and wildlife. (Future of the Region, 2.402)
It is recommended that Alternative Site 4 not be used as an interim
dumping site, and that all concerned parties meet to resolve identified
concerns.
It is therefore recommended that the above local and regional concerns and
recommendations be addressed in the final BIS for Tampa Harbor. Further,
it is recommended that any additional comments addressing local concern be
considered prior to issuance or approval of the final EIS.
Committee adopted January 3, 1983.
&*«**,
-------
United States Department of the Interior
OFFICE OF THE SECRETARY
WASHINGTON, B.C. 20240
ER-82/1689
'JAN
5 '.983
28-1
28-2
28-3
Mr. T. A. Wastler, Chief
Marine Protection Branch (WH-585)
Environmental Protection Agency
Washington, D.C. 20460
Dear Mr. Wastler:
We have reviewed the draft environmental statement for Tampa Harbor, Florida, Ocean
Dredge Material Disposal Site Designation, and have the following general and specific
comments.
General Comment
It is our understanding that present and alternate Tampa Bay disposal sites have been
selected without the benefit of intensive and thorough underwater surveys. A fairly
comprehensive analysis of impacts at Site A disclosed that severe environmental damage
was occurring. However, the same degree of analysis was not devoted to any of the
alternate spoil sites suggested. The preferred alternative (Site 4) may not have highly
productive or unique bottom communities, but this document does not provide the
information to make that choice.
Specific Comments
Page 2-2. 203: The so-called "11 criteria analysis" has been restricted just to the two
existing spoil disposal sites and Site 4. It would seem appropriate to consider the same
factors for Site 3, the mid-shelf site, and any other alternative which is not infeasible.
Page 2-4; In considering the no action alternative, it is stated that the Corps would be
required to: 1) justify an acceptable alternative disposal method; 2) develop information
sufficient to select an acceptable site for ocean disposal; or 3) modify or cancel a
proposed dredging project that depends on disposal in the ocean. Apparently each of
these is considered an unacceptable alternative to the proposed action. The EIS fails to
explain how Alternative 2 (developing information sufficient to select an acceptable site
for disposal in the ocean) is unacceptable. In fact, this is the major problem with the
spoil disposal sites which have been proposed to date and with the draft EIS itself. It is
apparent that no source has developed sufficient information for selecting an acceptable
site for ocean disposal. Even proposed Site 4 is supported only with minimal data: a
single photographic transect did not disclose large quantities of productive hard bottom.
It is fully possible that Site 4 may indeed be an ideal spoil disposal site, but this
environmental impact statement does not offer sufficient evidence for a rational
selection.
-------
r
Mr. T. A. Wastler, Chief
Page 2-5; A Corps of Engineers 1974 document is used to explain the review of land-
based spoil disposal alternatives. The EIS does not describe how the construction of spoil
retention berms in shallow waters of Tampa Bay and backfilling of wetlands can be
28-4 considered a "land-based*1 scheme. If this "CE proposal" is to be described in the final
document, it should simply be considered another form of open water disposal.
Page 2-19; It appears that the entire justification for selection of site 4 is stated in two
sentences: 1) "A video tape taken of this area revealed no rock or hard bottom
outcroppings and low vertical relief." and 2) "A recent EPA survey determined that the
site is predominately characterized by the presence of fine sands and coarse silts and
plains of shell hash." Considering the number of alternative sites that have been
proposed by various parties, and their later rejection upon the finding that they contained
28-5 environmentally sensitive areas, the reader surely must question whether those two
statements are sufficient to justify the permanent designation of four square miles of
shallow ocean bottom to receive millions of cubic yards of silt and other materials both
during this project and annually for maintenance dredging.
Page 3-21; The analysis of Site 4 is further detailed on this page. A camera was towed
across part of the spoil site and noted "flat, featureless sandy bottom". A "few" soft
coral communities were noted during the video tape transect, but no hard corals.
Presuming that this transect consisted of a single 2.8 mile line, and the width of bottom
28-6 scanned was about 50 feet, then this analysis was based upon examining about one-half of
one percent of the area proposed for spoiL The document should state whether this is
statistically valid or significant.
Page 3-29; The EIS provides few bits of data which are directly comparable between the
existing and proposed spoil site. However, here it is stated that dissolved oxygen levels
in the area currently receiving spoil are lower than dissolved oxygen levels over proposed
23-7 spoil Site 4. In fact, dissolved oxygen levels actually dip below minimum State standards
in area currently receiving spoil. The EIS should explain the significance of these data, if
any.
Page 4-13; The EIS states "a stress reaction or death may have greater environmental
consequences to the surrounding benthic community than to the organism in question."
The average reviewer may find it difficult to conceive of circumstances in which death
28-8 would not be considered a primary or major consequence to an organism. Additional
information should be provided.
-------
Mr. T. A. Wastler, Chief
Concluding Comment
It is our opinion that the draft environmental statement contains insufficient information
and impact analyses to support a decision to designate the proposed ocean dredge
material disposal sites.
Sincerely,
fa tJLs'
/
Blanchard, Director
Environmental Project Review
-------
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•jpoionerit of Natural Resources^
DATED: 6 October 1981
TO: Bill Lyons, <£l T*'SCOPTFoa-<» ^
George Henderson
FROM: Walter C. Jaap'
SUBJECT: CRUISE REPORT R/V Hernan §irtez, 28 September-2 October 1981
Scientific Party:
Walter Jaap ^
Jennifer Lowry
John Halas-FDNR Park Service
Richard Conant-USNPS
Richard Defenbaugh-BLM
Torn Burns-RSMAS-USNPS
Vessel departed Bayboro Harbor 1630 EOT, 28 September. Steamed to Florida '
Middle Ground (14131.16, 45741.12). On station at 0800, 29 September. En- .
tire Scientific Party dove on a large relief bank 78 ft (23 m) deep. A second
dive was made at 1305 on the same s.ite. At 1500 29 September, vessel moved
to another bank (14127.45,. 45734.01). Dive made to 90 ft(27.4 m).
Inclement weather precluded a fourth dive on the second Middle Ground bank.
On 30 September at 0900, vessel weighed anchor and steamed to a station of
Bayport (14312.40, 45149.41) arriving at 1745. A ledge community in ,2£ft :
(9rjrm) was sampled. . . • • • ' £*
10.7 - . ^
On i October we weighed anchor and steamed to the Blackthorn artificial reef
(14181.74, 44942.61). At 1545 we dove the site for 40 minutes. After com-
pleting this survey we steamed to a 60 ft(18.3 m) ledge (14168.63, 44798.00).
We dove this site for a short period for examination. Following this dive we
steamed to the "dump site" ledge off Tampa Bay (14164.05, 44754.00). On 2
October we made a sampling dive on the ledge. We returned to the dock at
2315, 2 October 1981. '
During the course of the cruise, six stations were sampled, 38 dives, or 23.1
hours of underwater observations were accomplished. A census of 56 one meter
square plots was taken; a total of 551 colonies, 15 species, and 14 genera
Were encountered.
Specific details of the sampling are included in accompanying tables.
cc: Captain Alan Nelson ' R. Conant
0. Lowry ft. T. Burns
• R. Defenb/ugh J. Hal as '
WCJ/wem
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TO: - GEORGE HENDERSON
THRU: WILLIAM LYONS
FROM: JENNIFER LOWR
DATE: 7 OCTOBER 1981 _
SUBJECT: Gulf of Mexico
REF: 15-2-4
Cruise 28 Sept - 2 Oct 1981
Six dives were made to record density and species composition data to supplement
Hourglass octocoral collections. Identification of vouchers of all specimens
are incomplete;- however most are accurate in situ identifications.
Site I, Florida Middle Ground, 2 dfves, 80-90 ft. Densities of MuriceaTlaxa
(the most abundant gorgonian) were up to 26 colonies/m . Usually no other
species were recorded within the^square meter. Other species collected include:
Eunicea knighti, Eum'cea calyculata, Plexaurella f us if era, Pseudoplexaura sp.,
Lophogorgia cardinal Is, Pseudopterogorgia fecerosa , and Pterogorgia guadTlupensis.
Site II. Florida Middle Ground, 1 dive 90 ft. Gorgonian species composition
the same as for site I; area dominated by Millepora. Drop off observed from about
85-125 ft. Proposed dive on drop off had to be aborted due to rough weather.
Site III. Off Bayport. 1 dive, about 60 ft. Low relief ledge. Average of
9.5 gorgonians/m recorded. Six species occurred in plot sampling; most to
least abundant were Plexaurella fusifera, Eunicea knighti, Pseudoplexaura ?porosa,
Pterogorgia quadalupensis, Eunicea calyculata, Leptogorgia virgulata. Lophogorgia
hebes and Huricea elongata were also collected from this site.
Site IV. Blackthorn wreck off Tampa Bay. 1 dive, 75 ft. No gorgonians were
observed colonizing the wreck structure. Surrounding bottom was hard but devoid
of gorgonians at first glance. Closer observations provided -five species:
Lophogorgia hebes, Leptogorgia virgulata, Eunicea calyculata,' PIexaurel 1 a sp.
an<^ Muricea elongata. With exception of the single whip noted, L^. virgulata, .
no colonies were taller,than 10 cm. Huricea was most abundant; however, no
colony taller than 7 cm was observed. Time limits disallowed collection of
specific density data. I can only surmise that debris (tire bundles) in the area
or the sinking of the Blackthorn itself perhaps scoured or otherwise damaged the
surrounding bottom; therefore resulting, incf\ly small gorgonians be'Img present.
Site V. Dump site for Tampa Bay dredge spoil off Tampa Bay. 1 dive, 55 ft.
Moderate relief ledge. Gorgonians were abundant up on the ledge proper and on
parts of the surrounding bottom. Densities of Muricea elongata v/ere up to 30
colonies/m , with addition of 1 or 2 other species occasionally. Other species
collected include: Eum'cea calyculata, Plexaurella fusifera, Lophogorgia hebes,
Leptogorgia virgulata, Pterogorgia guadalupensis. This area supports an incal-
culable monospecific population ofcphiuroid. Every attached benthic spbnge?and
•gorgonian supports numerous animals. One small (13 cm) Huricea was collected
with 11 animals mostly as~large as 1.3 cm disc diameter but some as small as
2 mm diameter. The same number were noted on a previous dive on thi's ledge last
June. They are probably Ophiothrix. I*collected these samples to send to Gordon
Kendler^at the Snrithsonian^who Maureen Downey recommendegl).
cc: Steidinger
. Lyons .
Jaap
Halas . . '
Conant and Burns
Archives
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Subject:
R/V Hernan Cortez Cruise. Dec. 1,-2, 1980; Reconnaissance of
•:.*;;
dredge spoil disposal area.
Dive I - Duration 17 minutes. Lat - 27°37.2'N, Loran C 14163.39; Long -. 82°59.9'W, "'
Loran C 44747.33; depth - 50-55 ft (15-17 m) ~
Bottom Character - rock overlaid with a (2-5 on) veneer of sediments.
Windrows of fossil gastropods noted on surface of sediment waves.
Organisms noted: Caulerpa sp., Siderastrea radians. Solenastrea hyades.
Phyllajiqia americana. Petrogorqia citrina. Lytechinu's variegatus. Echinaster
sp., Cassis sp.
i/'X fao 3-3
tlf Set »
Dive II - Duration 11 minutes. Lat - 27037.6'N, Loran C 14164.05; Long - 83°01.5'W, '
Loran C 44754.00; depth - 45 feet (14 m)
Bottom Character - a mosaic of rocky substrate with pockets of sediments
overlying the rock in some places. Octocorals visually dominant. A very
diverse benthic community, with corals, echinodenns, polychaetes, "mollusks,
and sponges. The height (1 ft) of some S_pjena_5trea hy.ade_s heads would imply
long term community stability. "
Organisms noted: Eunicea sp., Stephanocoenia michelinii, Siderastrea
radians. Millepora alcicorm's. Cladocora arbuscula. Solenastrea hyades.
Isophyllia sinuosa. Hanicina areolata. Scolymia lacera. Phyllangia americana.
> Ophiothrix suensoni. Echinaster sp., Diadema antillarum, sponges unidentified,
holothurians unidentified. V
Dive III - Duration 20 minutes. Lat - 27°37.6'N, Loran C 14164.05; Long - 83°01.5'W,
Loran C 44754.00; depth - 50 ft. (15 m)
Bottom "Character - ledge line with up to 1. m relief. Vertical, horizontal
interface with Millepora alcicornis colonies. Some slumping of overhanging
under cut ledges noted. While few large fish were observed, black grouper
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' -•' • VCStf —'"-VJT-/
I^partment of Natural Resources^SbBS^Interoftlce Memorandum
DATE:
TO:
FROM:
SUBJECT:
10 May 1982
Bill Lyons
<0#
Walt waap
George Henderson
Karen Steidinger
.
Observations from May 6 diNnng on dredge spoil disposal s1te0flf/^iA
Nine stations were sampled. Dr. Taylor took 4 benthic plug samples at each
station. Samples were sieved and preserved in rose bengal for later sorting
and identification. Each station took ca. 5 minutes of bottom time to sample,
hence my observations are not in great detail.. Stations were located ne*r the
corners, middle of the area, and one midway between each corner.
approximate N *-
8
The following summarizes observations by station. "~
1. 27°37'N, 82059.7'W, 38 ft.
Bottom strewn with large boulders and silt.
posal. No macro epibenthos seen.
Evidence of recent dis-
2. 27*37.3'N, 82°59.7'W, 44 ft.
Bottom uniformly covered with an ooze that had the consistency of
pudding. No macro epibenthos seen.
3. 27°37.4'N, 82°59.5'W, 45 ft.
Same as station 2. A few sand perch, Pi plectrum formosum were observed.
4. '27*37.3'N, 83°001W, 50 ft.. "
A small ledge with no more than^one to two feet of relief. A "live"
bottom community was seen. Algae included Halimeda and Udotea;
Sponges, stony corals: Cladocora arbuscula, Kanicina areolata; Solen-
astrgfl. hyades. Phyllangia americana, and Siderastrea radians; Octo-
corals with ophioroids in their branches.Black urchin Diadema aritil-.
Varum? or Arbacia punctulata? Red and black grouper and numerous
small tropical fishes were seen. Little or no sign of dredge impact.
5. 27°37'N, 83°00'W, 50 ft.
Hard packed sediment. Some piles of consolidated (clay like) dredge
- spoil. One small colony of £. arbuscula seen.
-recycled paper-
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•-» • Rocks and sand some si i ^./ mu.:. unuc>.^^'v. . ..»_ _>~..l .«, — _. - •' '
- '. .sediments. Sand perch observed.
*.''*«
; . 7. 27°36.75'N, 82°59.7'W, 55 ft.
Hard firm sand, no macro epibenthos seen. ...
8. 27*36.8 'N,- 8?059.5'W, 48 ft.
Hard sand. Piles of clay-like mud, very black in color. No macro
epibenthos.
9. 27C37.3'N, 82°59:5'W, 40 ft.
Large cable on bottom. Slimy ooze, no macro epibenthos observed.
Only station 4 seemed to have escaped impact. The remaining stations all had
received some impact, 1, 2, 3, and 9 appear to have received the greatest
insult. •*
WCJ/wm
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UKAl- i JK
-1 .. ,-a
Subject: 3fe^«rE±JCTrs» R/V Hernan Cortez Cruise. Dec. l/"2, 1980; Reconnaissance of
,7tr<«-» OC*"0-"\.
tit"' ~ ~—•—
dredge spoil disposal area.
.* . »-r
Dive I - Duration 17 minutes. Lat - 27°37.2'N, Loran C 14163.39; Long - 82°59.9'W,
Loran C 44747.33; depth - 50-55 ft (15-17 m)
Bottom Character - rock overlaid with a (2-5 cm) veneer of sediments.
Windrows of fossil gastropods noted on surface of sediment waves.
Organisms noted: Caulerpa sp., Siderastrea radians, Solenastrea hyades,
Phyllafigia americana, Petrogorgia citrina, Lytechinus variegatus, Echinaster
sp. , Cassis sp.
t
Dive I! - Duration 11 minutes. Lat - 27°37.6'N, Loran C 14164.05; Long - 83°01.5'W, '
Loran C 44754.00; depth - 45 feet (14 m) •
Bottom Character - a mosaic of rocky substrate with pockets of sediments
overlying the rock in some places. Octocorals visually dominant. A very
diverse benthic community, with corals, echinoderms, polychaetes, mollusks,
and sponges. The height (1 ft) of some Scjen_a.s_trea hyade_s heads would imply
long term community stability. "*
Organisms noted: Eunicea sp. , Stephanocoenia michelinii , Siderastrea
radians, Millepora alcicorm's, Cladocora arbuscula, Solenastrea hyades,
Isophyllia sinuosa, Mam'cina areolata, Scolymja lacera. Phyllangia americana,
, Ophiothrix suensoni . Echinaster sp.» D i a dema a n t i 1 1 a rum . sponges unidentified,
holothurians unidentified. H-
27 r> ^" ^ ^°° ^
Dive III - Duration 20 minutes. Lat - 27°37.6'N, Loran C 14164.05; Long - 83°01.5'W,
Loran C 44754.00; depth - 50 ft. (15 m)
• Bottom "Character - ledge line with up to i m relief. Vertical, horizontal
interface with Mil 1 epora al cicornis colonie_s. Some slumping of overhanging
under cut ledges noted. While few large fish were observed, black grouper
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J'..
'J.tate of Florida
Department of Natural Resources
Interoffice Memorandum
DATE:
TO:
THRU:
FROM:
8 June 1981
George Henderson
Bill Lyons
Halt Jaap
Jenhi Lowry
SUBJECT: 4 June Cruise to Bayboro Harbor Dredge Spoil
Disposal Site
We met Scott Sobel and his cameraman, Lynn Rabren, at Captain
Warren Sturgess1 boat, the Proposition, on Madeira Beach. Using
R/V Hernan Cortez Loran coordinates from the December cruise,
three short dives were made.
Site 1, 14164.3-4, 44747.1, depth 45 ft, bottom: coarse
sediments with fossil freshwater mollusk (gastropod) shells.
No visual evidence of spoil disposal impact. This area is
estimated to be less than 1 km inshore of the second site, the
mid-disposal area which was visited in December.
Site 2 (mid-disposal area visited in December) 14163.8-7,
44748.2, depth 50 ft, bottom a hardpan veneered with a thin
layer of sediments. Bottom benthos included numerous octo-
corals, stony corals, anemones, sponges and numerous brittle
stars (possibly Ophiothrix sUensoni) entwined in the octocoral
branches. No visible evidence of impact was observed. Low
relief anemones and stony corals were not suffering from burial
and had not expelled zooxanthellae. Conditions appeared similar
to December observations.
Site 3 (ledge system just seaward of the northwest boundary of
the disposal site) 14164.5-6, 44754.4. Ledge outcrop, high di-
versity, hard substrate, benthic community with sponges, anemones,
octocorals, stony corals, molluscs, crustaceans and an abundant
ichthyofauna including triggerfish, grunts, jacks, grouper,
snapper, butterflies, and high hats. Again, there was no visible
evidence of dredge disposal. The stake established here in
December was found, hence we are certain of being on station.
-recycled paper-
-------
OHU rrencn angelfish were common. . . . . /.;
Organisms noted: Stephanocoenia micheli-nii. Siderastrea radians, Cladocora
arfauscula, Sblenastrea hyades, Phyllangia americana, Mi.TlepoT'a alcicorm's.
Condylactis gigantea, Rhodactis sanctihomae? , Panulirus argus, Ophiothrix
suensoni, Diadema an till arum.
s
Photographs were taken of representative community elements with a Nikonos .camera,
15 nni lens and flash. Film at RoMo for development. The ledge was marked with a
copper clad survey marker to establish reference.
cc: Gary Burns
Ken Haddad
Bill Lyons
Roy Williams
Terry Leary, GMFMC
Robin Lewis
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\
Page Two
Dumping impact was either very localized or tHe material dispersed
so fast that it did not have an effect on the three sites. It is
most probable that the impact was greater on the inshore side of
the disposal area. The contractor.probably made his dumps in this
area.
WCJ:dg
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January 5, 1983
campo bau
regional
planning
council
Mr. Jonathon Amson -' ~*'-e-'=><-•'•- ••-
jQil,£T'*i*i^i 7 ;j-n ,, -, ~ T '
U.S. Environmental Protection Agency ' ' """"
Criteria and Standards Division (WH-585)
401 M Street, S.W.
Washington, D.C. 20460
Dear Mr. Amson:
Subject: Tampa Bay Regional Planning Council A-9S Clearinghouse Review No.
218-82; Draft Environmental Impact Statement (DEIS) for Tampa
30-1 Harbor, Florida, Ocean Dredged Material Disposal Site
Designation, Hillsborough, Pinellas and Manatee Counties
Enclosed please find a copy of the Council's Clearinghouse Review report
for the above referenced project adopted by the Council's Clearinghouse
Review Committee on January 3, 1983.
Should additional clarification be needed, please feel free to contact me.
We appreciate the opportunity to review the proposal.
Sincerely,
Michael R. McKinJ
Director of Plapning
MRM/kh
Enclosure
Chairman Jan K Piatt
Commissioner. Hillsoofougn County
Vice-Chairman Geo'ge Mr.Gougn
Ma\'or. Cuv at Largo
Councilwotngn. Ofv of Braoennjn
Sradenton • Cieatwaier • Oade City • Duneaii • Guiioof. • Hiiisoorougn Coumv • largo • Manatee County • New Pon Ricurv « ui.jstn,r • ^I'-ow,
* Pasco Counsy • Pinellas County • Pinellas Pa'k « Safely Haroo' • Si Peie'SDurq * Si pi'OOr' Sor»'.g»
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Agenda Item #11A
A-9S #218*82; Draft Environmental Impact Statement (DEIS) for Tampa
Harbor, Florida, Ocean Dredged Material Disposal Site Designation,
Hillsborough, Pinellas and Manatee Counties
CIEARIfKiHOUJC R£VS£W
The U.S. Environmental Protection Agency (EPA) has requested review and
comment on the draft Environmental Impact Statement (EIS) for Tampa Harbor,
Florida which presents information necessary for the designation of a new
. Tampa Harbor Dredged Material Disposal Site. The purpose of the action is
to provide the most environmentally and economically acceptable ocean
location for the disposal of material dredged from the Tampa Bay area.
Based on recent surveys of four Shallow-Water Alternative Sites, EPA has
determined that Shallow-Water Alternative Site 4 is the alternative with
the fewest hard-bottom areas which may be affected by the disposal of
dredged material. It is the recommendation of the DEIS that Alternative
Site 4 be designated as the disposal site location for dredged material
from the Tampa Bay area. Agency - EPA; Location - Hillsborough, Pinellas
and Manatee Counties.
Local Comments Received From;
Hillsborough County Environmental Protection Commission: See attached
letter dated December 5, 1982.
Hillsborough County Department of Development Coordinations See attached
memorandum dated December 3, 1982.
Pinellas County Planning Department: No comment received as of December
30, 1982.
City of St. Petersburg Planning Department: See attached letter dated
December 16, 1982.
Manatee County Board of County Commissioners: See attached letter dated
December 13,1982
Mote Marine Laboratory: See attached letter dated December 9, 1982.
Gulf of Mexico Fishery Management Council: See attached letter dated
December 10, 1982.
Office of the Governor: See attached letter dated December 22, 1982.
Council Comments and Recommendations
This project has been reviewed for consistency with the Council's Areawide
Water Quality Management Plan and the Council's adopted growth policy, the
Future of the Region. The proposal has not been found to be consistent
with Council policy that a standard of water quality should be achieved
that allows for the protection and propagation of fish, shellfish, and
wildlife and provides for recreation in and on the waters in the region.
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tempo boy regional planning council
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A-95 #218-82; Draft Environmental Impact Statement (DEIS) for Tampa | 2.^-
Harbor, Florida, Ocean Dredged Material Disposal Site Designation,
Hillsborough, Pinellas and Manatee Counties
The U.S. Environmental Protection Agency (EPA) has requested review* and
comment on the draft Environmental Impact Statement (BIS) for Tampa Harbor,
Florida which presents information necessary for the designation of a new
Tampa Harbor Dredged Material Disposal Site. The purpose of the; action is
to provide the most environmentally and economically acceptable ocean
location for the disposal of material dredged from the Tampa; Bay area.
Based on recent surveys of four Shallow-water Alternative Sites, EPA has
determined that Shallow-Water Alternative Site 4 is the alternative ;with
the fewest hard-bottom areas which may be affected by the disposal of
dredged material. It is the recommendation of the DEIS that Alternative
Site 4 be designated as the disposal site location for dredged material
from the Tampa Bay area. Agency - EPA; Location - Hillsborough, Pinellas
and Manatee Counties. >-•• •--
" * * *
Local Comments Received From; '.A. ••*... i
Hillsborough County Environmental Protection Commission: See attached
letter dated December 5, 1982. _' •
Hillsborough County Department of Development Coordination: See attached
memorandum dated December 3, 1982.
Pinellas County Planning Department: No comment received as of December
30, 1982.
City of St. Petersburg Planning Department: See attached letter dated
December 16, 1982.
Manatee County Board of County Commissioners: See attached letter dated
December 13,1982
Mote Marine Laboratory: See attached letter dated December 9, 1982. :
Gulf of Mexico Fishery Management Council: See attached letter dated
December 10, 1982. ." :-
Office of the Governor: See attached letter dated December 22, ..1982. e
Council Comments and Recommendations
This project has been reviewed for consistency with the Council's Areawide
Water Quality Management Plan and the Council's adopted growth -policy;; the
Future of the Region. The proposal has not been found to be consistent
with Council policy that a standard of water quality should be achieved
that allows for the protection and propagation of fish, shellfish/ and
wildlife and provides for recreation in and on the waters in the-region.
: J.'. • si "1 '
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tampa boy regional planning council
•9-155 Koger Boulevard Si Peie'Sbyq, H 33702 (8i3)577-5i5i Tampa 224.9380
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This project is regionally significant and the following local and regional
concerns have been raised during the review:
• The staff of the Tampa Bay Regional Planning Council has reviewed the
Draft Environmental Impact Statement (DEIS) for Tampa*Harbor Ocean
Dredged Material Disposal Site Designation and offers the following
comments:
General Comments
1. The DEIS lacks sufficiently detailed evaluation and comparisons of
all possible alternatives including diked disposal islands and
upland disposal areas.
2. The designation of Alternative Site 4 for disposal of dredged
material from the Tampa Bay Area should be based on more detailed
studies of this area. The DEIS lacks site specific studies evaluat-
ing the impacts on marine environment and economy of the region.
The results of the studies done in other locations cannot serve as
the base for evaluating the impacts of the proposed dumping of
dredged material on the proposed site.
3. The environmental consequences of dumping dredged sediments on sand-
subs tate habitats also cannot be predicted based on the results of
the studies from other locations. The ecosystem of shallow-waters
in central-southwest Florida is different from the continental U.S.
waters.
4. Information pertaining to tidal currents is needed based on records
obtained from the tide guage station located in Egmont Key.
5. The monitoring program has not been specifically designed to deter-
mine whether disposal at the selected site significantly affects
areas outside the site and to detect long term effects occurring in
or around the site. It is stated in the DEIS that a monitoring
program may be established to supplement historical data. Details
on what the monitoring program will entail/must be included.
6. The recreational and commercial fishing values of the surrounding
area should be identified as well as the impacts of ocean disposal
on migratory fishing. »
7. It is stated that dispersion of disposal material outside the site
boundaries will be over time and in thin layers, and that such
dispersion is not expected to have unacceptable adverse environmen-
tal impacts. Specific studies need to be completed to determine
whether the thin layer of siltation adversely impacts the sur-
rounding hard bottoms (corals).
Specific Comments
1 . Statements that there are no hard-bottom habitats within or in
proximity to Site 4 are not well-documented. More extensive inspec-
tion of areas both within and around the site is necessary before it
can be known what types of organisms and communities will be
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adversely affected by dumping. In-depth surveys to determine the
nature and extent of live, hard-bottom habitats.in or near the site
should be further conducted.
2. It is stated in DEIS that results of dredged material disposal at
the Tampa Harbor alternative sites are anticipated to be similar to
the results of disposal operations at Calveston, Texas (page 2-28).
However, the West Florida Shelf cannot be compared with other areas
which have no hard-bottom communities. The conclusions that dispo-
sal will not result in any detectable changes in ecology of the area
are inappropriate.
3. An assessment of the siltation and turbidity caused by resuspension
of fine particles by waves, storms and tides has not been completed,
as well as the expected impacts of the siltation on live-bottom
habitats.
4. The long-term effects from the continual resuspension of spoil
material throughout the water column have not been adequately
studied nor documented. The amount and frequency of siltation, the
direction of sediment transport based on site-specific ocean current
information, and the environmental consequences of long-term tur-
bidity should be estimated before final recommendations are made.
5. It is stated in the DEIS that Site 4 is removed from areas of
recreational use, and has no known significant commercial fishery
use (page 2-27). This statement is not based on the detailed survey
of commercial and recreational fishing activities of this area.
Relevant studies should be completed based on public testimony
whether the proposed action affects the recreational activities of
the region and commercial fishing.
6. Cost-benefit analysis, taking into account the direct and indirect
economic benefits generated by the recreational use of this part of
the Gulf of Mexico have not been done at this time.
7. A public hearing should be scheduled to allow full and fair public
comment in the draft EIS and the overall suitability of dumping in
the Eastern Gulf of Mexico.
i
The Manatee County Board of County Commissioners has provided extensive
comments which already have been forwarded to EPA and are summarized
below (see attached letter dated December 13, 1982) regarding the Draft
EIS for a permanent ocean disposal site for Tampa Harbor:
1. The EPA survey upon which the EIS relies to recommend Site 4 for
permanent designation, used survey methodologies that are inadequate
for determining the nature and extent of live, hard-bottom habitats
in or near the site; yet, the entire EIS rests on the unproven
assumption that there are no hard-bottom habitats within or in
proximity to Site 4. This is critical because of the well-docu-
mented importance of live-bottom habitats to both commercial and
recreational fishery resources.
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2. Although the E1S notes that significant damage that can occur to *
hard-bottom habitats front siltation and turbidity, it completely
fails to describe or assess the siltation and turbidity that will be
caused by resuspension of fine particles by waves, storms, tides,
and combinations thereof, and it fails to quantify the resulting
siltation problem and its expected impacts to corals, sponges,
algaes, and the like.
3. The EIS recommendation of Site 4 is based on erroneous and under-
stated information concerning the use of the area in and around the
site, which is actually located in an area that is heavily used by
commercial and recreational fishermen, sport divers, and others.
4. The Site-Designation EIS presumes that ocean dumping is appropriate
in this part of the Gulf of Mexico, disregarding as a general matter
the high potential for damage from burial and siltation to the hard-
bottom habitats and organisms found scattered throughout this part
of the Gulf, and inadequately considering the possibility of using
uplands or diked disposal areas on a short-term basis pending
thorough investigation of the suitability of ocean dumping.
5. The EIS also relies on erroneous cost estimates for transporting the
dredged material to various alternative sites, and there is no
comparison of the environmental "pros and cons" of each alternative
site relative to the economic costs.
>
6. Finally, with respect to the EIS's cost analyses, the EIS fails to
take any account of the direct or indirect economic benefits gen-
erated by the recreational use of this part of the Gulf of Mexico,
thereby placing too-heavy emphasis on the immediate costs of spoil
transportation.
Therefore, in light of the many deficiencies of the Draft EIS, including
reliance on erroneous assumptions, inadequate surveys, and incorrect
infomation, the Board of County Commissioners of Manatee County requests
that a public hearing be scheduled to discuss the Draft EIS and proposed
site designation, or, in the alternative, that the Draft EIS be with-
drawn and subsequently resubmitted for public comment.
The staff of the Hillsborough County Environmental Protection Commission
has reviewed the Draft Environmental.Impact Statement (EIS) for Tampa
Harbor: Ocean Dredged Material Disposal Site Designation and submits
the following comments and recommendations:
It is recommended that all disposal at the Existing Site A be
stopped because it is too close to shore, too close to produc-
tive reef areas, and within easy reach of divers and small boat
users.
Site 4 is in 85 to 95 feet of water and is not as likely to be
used for recreational purposes such as diving and fishing. All
material should go to this site until some long range solution
is found.
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Site 4 has no hard-bottom outcrops and would therefore have the
least impact on fish and other types of life.
» The City of St. Petersburg Planning Department has reviewed the Draft
EIS for Tampa Harbor: Ocean Dredged Material Disposal Site Designa-
tion and recommends the following additions to the above referenced
EIS:
Incorporation of any appropriate review criteria
which may be forthcoming from the pending litiga-
tion related to offshore dumping initiated by
Manatee County;
Analysis of upland dumping sites;
Further analysis of Site 4. It appears that
Appendix C. (referenced on Page 2-13 of study) may
provide additional data to substantiate minimal
adverse environmental impacts.
• The Office of the Governor has submitted the following comments and
recommendations regarding the Draft EIS:
An interagency review of the statement has found
that the proposed action would smother the benthos
within the designated area and alter habitat within
the site. The document recognizes that these
adverse impacts at the site are unavoidable. Our
reviewing agencies report that the EIS statement is
inadequate and lacks the necessary information to
be of sufficient value as a decision-making docu-
ment (see attachments).
We have concerns with this designated site and
EPA's proposed rule for ocean dumping without a
Federal Coastal Zone Management Consistency Evalua-
tion. Recognizing our concerns, the impact of this
designation and its effect on the Tampa Harbor
project, we request that your agency participate in
an interagency meeting at your earliest convenience
to afford us the opportunity to discuss issues of
concern to the State of Florida. It is our desire
to use this initial meeting as a step toward re-
solving our concerns.
Based on the review of this document, it is-the opinion of the Tampa Bay
Regional Planning Council that no ocean dumping should be performed
until it is demonstrated that ocean dumping in this part of the Gulf of
Mexico is appropriate and that it is the most suitable method of dispo-
sal. That demonstration should include an actual determination of the
nature and extent of hard-bottom habitats and fishery resources in site
4 and in surrounding areas. This determination should be based on
further, site-specific surveys, including the direction, amount, fre-
quency, and distance of sediment transport and siltation, and a specific
quantification of the damage that will result therefrom. Also, a de-
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tailed, careful balancing of the economic versus environmental concerns
for each alternative method should be performed, including consideration
of the many commercial aspects of recreational fishing and diving and
development of a thorough monitoring program to assess the impacts of
any dumping on a long-term basis.
In conclusion, the final recommendation of the DEIS for Tampa. Harbor
which designates Shallow-water Alternative Site 4 as the Tampa Harbor
ocean dredged material disposal site is not consistent with the
Council's adopted policy to support the maintenance of Class III waters,
including bays, rivers, lakes, estuaries and open waters of the terri-
torial sea, at a quality sufficient to allow body-contact water sports
and propagation of fish and wildlife. (Future of_ the Region, 2.402)
It is recommended that Alternative Site 4 not be used as an interim
dumping site, and that all concerned parties meet to resolve identified
concerns.
It is therefore recommended that the above local and regional concerns and
recommendations be addressed in the final EIS for Tampa Harbor. Further,
it is recommended that any additional comments addressing local concern be
considered prior to issuance or approval of the final EIS.
Committee adopted January 3, 1983.
Mayor (Emerge McGough", Chai
Clearinghouse Review Committee
Please note: Unless otherwise notified, action by Clearinghouse Review
Committee is final. Append copy to application to indicate compliance with
clearinghouse requirements.: Comments constitute compliance with OMB Circu-
lar A-95 only.
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Responses to Comments
1-1 EPA appreciates the review and comments on the DEIS provided by
the Florida Department of State, Division of Archives, History and
Records Management, and acknowledges the response that the
proposed action is "...unlikely to affect any cultural
resources...."
2-1 EPA appreciates the review and comments on the DEIS provided by
the Public Health Service, Department of Health and Human.
Services, and acknowledges that possible health effects of the
proposed alternatives have been adequately addressed.
2-2 A monitoring program will be initiated for Shallow-Water
Alternative Site 4 to document any potential unacceptable adverse
environmental impacts caused by the disposal of dredged material.
Extensive baseline data and information has been collected in
preparation of this EIS (see DEIS, p. 2-31).
3-1 EPA thanks the Tampa Port Authority for their review and comments
and continued interest in the preparation of the FEIS.
3-2 Extensive video camera observation of the bottom characteristics
of Site 4 as well as other areas has been completed during EP^'s
February, March, and April 1983 extensive surveys. More than 80
miles and over 50 hours of video camera observation have been
recorded on videotape to document the physical characteristics of
the ocean floor and the presence of hard bottom and associated
flora and fauna.
4-1 EPA acknowledges that the Tampa Port Authority agrees that Site 4
may be a more acceptable long-term dredged material disposal
site than Site A.
4-2 Intensive surveys conducted during February, March, and April 1983
using an underwater video camera afforded extensive characteri-
zation of the ocean floor.
5-1 EPA acknowledges DER's concern regarding disposal of dredged
material offshore and its support for land-based alternatives.
5-2 The purpose of the document "...is to provide an environmentally
and economically acceptable ocean location for the disposal of
dredged material, which complies with the environmental impact
criteria of the Ocean Dumping Regulations {40 CFR 220-229)."
Preliminary survey work was followed-up by intensive surveys
during February, March, and April 1983. This work included
sediment cores, water quality samples, fathometer and side-scan
sonar tracings, fish tissue analysis and more than 50 hours of
video camera recordings of the bottom, in the area.
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5-3 Full public Involvement has been evident through the DEIS and site
designation process; 32 comments have been received in response to
the public notices of the availability of the two documents.
5-4 Non-ocean disposal of dredged material from the Tampa Bay Project
including upland and diked disposal areas has been considered.
According to the Corps of Engineers (letter from Harrison D. Ford,
to Joseph Freedman, EPA Attorney, July 14, 1983), upland disposal
areas which must be obtained by the local sponsor are not
available at a reasonable cost. Although disposal of dredged .
material on existing or proposed diked disposal islands was
considered a viable alternative, this alternative was later found
to be economically and environmentally unacceptable for disposal
of dredged material from the construction phase of the Tampa
Harbor Project. Existing diked disposal islands do not have
sufficient capacity to receive the construction phase dredged
material. In addition, the costs associated with diked disposal
islands are greater than originally thought because of the
presence of rocks in the material to be dredged. The dredged
material would be placed in a barge where the heavier rocks would
settle to the bottom. These rocks would be dropped to the bottom
in the area to be retrieved mechanically later and deposited on
the diked disposal island. After removal of the rocks, the finer
silt could then be pumped from the barge onto the diked disposal
area. This double handling of dredged material for diked disposal
alternative would result in increased costs. In addition, the use
of diked disposal islands could result in adverse environmental
effects including: increased turbidity during construction,
increased turbidity from post-construction erosion, changes in
circulation and flushing characteristics, reduction in aquatic
productivity, destruction of benthic organisms, and possible
increased levels of pollutants in the water column. In summary,
both upland disposal and diked disposal island alternatives have
been found to be economically and environmentally unacceptable,
because of increased costs and adverse environmental impacts.
5-5 Acknowledged; correction made in text.
5-6 Hard bottom is more appropriate terminology here, because fine or
coarse sand and shell hash also have a living biotic component.
The biological assemblages cited are associated with hard
substrate; therefore, it is more appropriate to differentiate
between "hard" substrate types and "soft" substrate types.
5-7 Intensive surveys conducted by EPA in February, March, and April
1983 in the area of Site 4 supported the conclusion that there is
little hard- bottom habitat in this area. Less than 17% of the
site was found to have hard-bottom, and less than 1% is densely
populated hard-bottom.
5-8 Acknowledged. Description of existing site has been expanded.
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5-9 Existing bottom at and in the vicinity of Site 4 is composed
primarily of fine and coarse sands, coarse sand and gravel, and
coarse sand and shell hash, as evidenced by recent February,
March, and April 1983 surveys. Since the area consists primarily
of these types of sand bottom, the Dredged Material Research
Project (DMRP) studies are applicable to the area of
consideration.
5-10 Recent February, March, and April 1983 surveys address this issue.
A large percentage (83%) of the area is "soft" bottom.
5-11 The coralline species noted in this area were seen in depths
between 35 and 90 feet of water during the February, March, and
April 1983 surveys.
5-12 The three fish species found most often during the February,
March, and April 1983 surveys in the study area were the Caesar
grunt, cusk eel, and sand perch.
5-13 The small, scattered patches of hard bottom consist of algae,
sponges, corals, bryozoans, tunicates, and a motile fauna of
crustaceans, polychaetes, molluscs, echinoderms and fish.
5-14 Little evidence of commercially or recreationally important uses
of the area of Site 4 was seen during EPA surveys. The Corps of
• Engineers conducted an aerial surveillance of Site 4 between
March 19 and June 5, 1983. During the twelve survey flights over
twelve weeks of observation, no commercial activity was observed
and no vessels were observed in the Site 4 area, with the
exception of one dive boat on June 1. No other source has
provided any reliable information concerning the commercial or
recreational uses of Site 4 or its vicinity.
5-15 Since a large percentage of Site 4 is sedimentary habitat
(approximately 83%), comparisons can be made to evaluate the
impact of dredged material on the site. (See also Comment 5-9).
5-16 No sea turtles were observed during any of the EPA or Corps
surveys. Turtles lay their eggs on beach areas; therefore, no
effect on turtle breeding success is anticipated by the disposal
of dredged material at Site 4 (see DEIS, p. xx, para. 3).
5-17 The conclusion is supported by analysis of liquid phase elutriate
samples discussed in DEIS page xx, paras. 2 and 4. In addition,
monitoring will be conducted at Site 4 to detect long-term effects
occurring at or near the site.
5-18 Adverse environmental effects of the action include "smothering of
the benthos within a designated site" which would include minimal
hard bottom and fish habitats.
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5-19 The hazards of marine commerce are far outweighed by the benefits
expected from the Tampa Harbor Project. Moreover, substantial
civil penalties may be assessed against those responsible for oil
spills or other accidents, which should encourage caution. Costs
incurred in clean-up may also be recovered by the Government.
5-20 Results from intensive surveys during February, March, and April
1983, indicate that Site 4 has less than 17% hard bottom and less
than 1% of the site is densely populated.
5-21 The intensive surveys discussed above and additional Corps work
are sufficient to select and designate an acceptable disposal
site.
5-22 Existing dredged material disposal islands were eliminated from
consideration for disposal because of the nature of the dredged
material. Rocks would necessitate double handling (see response
to Comment 5-4). Abandoned phosphate pits were considered and
found to have insufficient capacity (CE, 1976).
5-23 Dredged material disposal at a mid-Shelf site is considered to be
more likely to have long-term adverse effects on the benthos than
disposal at a shallow water site, because shallow water, high-
energy benthic communities recover more quickly from such adverse
impacts according to Oliver ££.£]_.» (1977).-
5-24 Col lard and D'Asaro's terminology is adequate for the discussion
of the alternative site under consideration.
5-25 The statement referred to is that the "Shallow-Shelf Alternative
Sites are in a high-energy environment influenced by wave action,
freshwater and storms." The magnitude or duration of that
influence is not discussed. The fact that there are low average
winds and seas at the nearshore sites has little bearing on the
influence of periods of high winds and seas on the Shallow-Shelf
marine environment.
5-26 The purpose of the EIS is to determine an acceptable disposal
site. The Corps of Engineers considered land-based alternatives
and found them economically and environmentally unacceptable (see
response to Comment 5-4).
5-27 See DEIS, p. 2-5, para. 2, continuing to p. 2-6.
5-28 Even if "currents are generally less than 1 Kn," this does not
preclude the effect of periodic strong currents. The cited
reference refers to the effect of strong currents on resuspension
of sediment, which is relevant to the study area.
5-29 Dominant live bottom flora and fauna are discussed in the DEIS
(see pp. 3-30 through 3-46, especially p. 3-43, para. 4).
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5-30 See..DEIS, Appendix C. See also February, March, and April 1983
surveys, Appendix F of the FEIS.
5-31 a. Benthic communities in shallower waters are adapted to periodic
stresses and therefore likely to recover more rapidly from burial
than a community in a deeper, more stable, low energy environment
(Oliver et al., 1977).
""""" s,
b. Shallow-waters are defined as depths less than 30m, and located
within 25nmi of shore; mid-Shelf waters are defined as depths from
30 to 200m, from 25 to 75nmi offshore; deepwater Slope waters are
defined as depths greater than 200m, approximately 105nmi offshore
(DEIS, p. x).
c. Areas in depths of 16-30m are considered areas of higher energy,
. because wind-driven currents affect bottom characteristics and
maintain a dynamic environment.
d. Because the mid-Shelf site is an area of lower energy, the dredged
material could be expected to remain in place for a longer period
of time, and therefore, would have a longer adverse effect on
benthos.
e. Both shallow water (depths less than 30m), and mid-Shelf (30 to
200m), have characteristic benthic communities, either of which
will be impacted by dredged material disposal.
5-32 This is discussed in DEIS, p. 3-50 Marine Recreation (see also
response to Comment 5-14).
5-33 Hard bottom communities are not termed unstable or sedimentary;
rather, the statement describes the bottom and sediment
characteristics of a shifting, dynamic environment, to which
nearshore biota have adapted.
5-34 These are two different issues. The deposition of dredged
material over time will preclude complete recolonization of the
site. Only on cessation of disposal at the site would complete
recolonization occur, and this would depend on the mix of disposed
and in situ sediments in the area.
5-35 There were indications (hard bottom remnants on the fringes of
Site A) that there may have been hard bottom areas located within
Site A.
5-36 Extensive video camera work, side-scan sonar, and supporting
physical, chemical, and biological sampling was conducted during
EPA's February, March, and April 1983 surveys.
5-37 Disposal of dredged material at Site 4, 18 nmi seaward of these
amenity areas, will not impact any of these species, because of
the distance involved.
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5-38 Hard bottom habitat within the area studied are not true coral
reefs; however, grunts are often found in hard bottom areas.
5-39 The February, March, and April 1983 EPA surveys provided extensive
data to adequately characterize the bottom habitat in the vicinity
of Site 4. Less than 17% of the site is hard bottom, and less
than 1% is densely populated.
5-40 Techni caljteport: Rice, Patton, and Mahadevan, 1981, p. 18; see
Appendi x r of DEIS.
5-41 The mounds at disposal sites will disperse at a rate based on the
volume and composition of the disposed material. Larger rocks
will remain longer than the finer sands and silts; however, they
make up only a small percentage of the composition of the disposal
material. The rocks remaining will also provide hard substrate to
encourage recolonization of the site. Further, there is no
evidence of any mound remaining at Site B, despite the deposition
of over 1 million yds3 at that site.
5-42 Storm- and wind-generated currents do contribute to the high
energy environment in these depths, and thereby resuspend and
disperse sediments at depths of 40 feet (Ichiye et aU, 1973).
5-43 - It is more appropriate to compare sandy bottom recovery to the
current and proposed sites, because the high ratio of sandy bottom
to hard bottom habitat. Comparison with recovery from lava flows
has no validity to a dredged material disposal site.
5-44 Construction and maintenance of a multipurpose, deepwater port
requires dredging with subsequent disposal of dredged material;
this is the environmental impact being evaluated, and therefore,
should have bearing on the Tampa Bay disposal sites.
5-45 References cited refer to the "region containing the alternative
sites", and are not presented as site-specific water quality
studies.
5-46 See lines 4-8 of the cited paragraph. The Hoi1iday report
discusses the general processes affecting the fate of dredged
material; such processes apply in the Tampa Bay area.
5-47 - Video camera transects in the Site 4 area during the February,
March, and April 1983 surveys revealed that less than 17% is hard
bottom and less than 1% is densely populated.
5-48 Monitoring guidelines to be established by EPA will address
effects of disposal on hard bottom biota. Both Courtney et
(1974) and Griffin (1974) guidelines will be considered.
further guidelines, see pp. 2-31 through 2-35 of the DEIS.
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5-49 - The February, March, and April 1983 EPA Surveys address these
Issues. The disposal of dredged material is not expected to
destroy stony corals or sea fans within the area of Florida's
jurisdiction, and is expected to have a minimal impact on hard
bottom communities in general.
5-50 The predominant substrate in the area is sand, occasionally
intermixed with shell hash; this substrate has a benthic infaunal
component. With the sporadic occurrence of sessile benthic
epifauna, the infauna remain the better organisms to monitor
changes at the site.
5-51 Although organisms on hard bottom can be observed in situ and
monitored for change, only a relatively small area could be
covered practically by use of this method.
5-52 Although these species are not reported to be common to the
proposed site, they will be considered if the study of trace
metals is included in the monitoring plan. Indications from EPA
analyses are that trace metal levels in the vicinity of Site 4 are
extremely low.
5-53 The creation of sediment is not being discussed here, but rather,
the redistribution of existing sediments by tidal currents.
5-54 Sessile epibenthic organisms may be better indicators in some
areas. However, because of the sparse and sporadic occurrence of
epibenthic organisms in and near the Site 4, the more uniformly
distributed infaunal organisms are a better choice of indicator
organisms.
5-55 The change has been effected.
5-56 Corals are predominantly colonial and solitary within the study
area (see DEIS, p. 3-43, para. 4).
5-57 The change has been effected.
5-58 Information on the economics of fishing and boating are included
in the DEISi p. 3-50, Marine Recreation (see also response to
Comment 5-14).
5-59 The spotted sea trout is reported to occur in association with
rock outcrops and artificial reefs located offshore and
approximately 3 nmi. north of Sites A and B.
5-60 Paragraph 2, line 3, has been changed to read as follows: "Pink
and rock shrimp comprised 97% of the total shellfish tonnage
(2,066 tons) and represented 96% of the commercial value. Some of
the landings at the Tampa-St. Petersburg area were reported taken
from waters outside the immediate area" (letter from Florida
Department of Natural Resources to EPA, December 10, 1982).
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-8-
5-61 The change has been effected.
6-1 Non-ocean alternatives were considered by the U.S. Army Corps of
Engineers (CE, 1976). However, non-ocean alternatives were found
to be economically and environmentally unacceptable (see response
to Comment 5-4). The EPA is responsible for evaluating
alternative ocean disposal sites based on the five general and
eleven specific criteria of 40 CFR 228.5 and 228.6 (see DEIS, pp.
2-5 and 2-6).
6-2 Data from intensive site specific surveys conducted by EPA during
February, March, and April 1983, provide a basis for evaluating
the impacts of the proposed dredged material site designation.
6-3 The comparison of similar environments allows a degree of
predictive judgment for evaluating potential impacts on sandy-
substrate habitats off the coast of Florida.
6-4 See DEIS, p. 3-4, para. 4, "Currents". Information is based on
appropriate tide gauge stations in the region.
6-5 A detailed monitoring program will be established at Site 4 by EPA
with input from members of State and local technical and
^ scientific staffs.
6-6 No significant impacts on migratory fish are expected, since fish
are mobile and will avoid areas of temporary turbidity (see DEIS,
pp. 3-47 through 3-50).
6-7 Sufficient baseline information is available to evaluate the
potential impacts-"of the long-term dispersion of disposed
material, outside the site boundaries. Designation of the release
zone can minimize the dispersion of dredged material outside the
boundaries of the site.
6-8 The area in the vicinity of Site 4 is not a wetland, but open sea.
A comprehensive monitoring program will be initiated following the
site designation.
6-9 Designation, of Site 4 as a dredged material disposal site will not
preclude maintenance of Class III Waters to allow body-contact
water sports and propagation of fish and wildlife. In any event,
Site 4 is not within the territorial sea.
7-1 Acknowledged. We thank the U.S. Department of Commerce, National
Oceanic and Atmospheric Administration' for their comments.
Suggestions are well-taken, and are incorporated in the Final
EIS. •
8-1 No significant ecological impacts including long-term effects are
expected, because of the characteristics of the dredged material
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-9-
and the lack of densely populated hard bottom within Site 4 (less
than 1%). The appendices were distributed with the DEIS.
8-2 Many organisms adapted to soft bottoms are capable of recovering
from burial following disposal operations, and are capable of
recolonization of the site. Biological components of the Site 4
bottom habitat are discussed in the DEIS, pp. 3-37 through 3-46.
8-3 The time required for recolonization of a dredged material site
following the termination of dredging operations depends in part
on the similarity in composition of the original site sediment
with that of the dredged material. Existing bottom sediments at
Site 4 contain some of the geological components common to the
dredged material, which makes recovery of Site 4 more probable
within a reasonable period of time.
8-4 Although distribution of an ocean discharge at sea cannot be
specified with 100% accuracy, a reasonable prediction based on
prevailing currents can provide a sound basis for evaluating
potential impacts. Continued site-specific studies will allow
more accurate distribution predictions. In most cases, dredged
material planned for disposal at sea must pass the Ocean Dumping
Regulations' elutriate, bioassay, and bioaccumulation test
procedures, found at 40 CFR Section 227. Anthropogenic
contaminants in harmful levels are not anticipated; however,
monitoring of the dredged material and the dredged material site
will be conducted. Disposal operations are not expected to
promote red tide blooms, or to cause damage to biological
populations outside the site through chemorecept'ion interferences,
because of the character of the dredged material and dilution
factors.
8-5 . No unacceptable adverse environmental long-term effects are
expected inside or outside the designated site. Short-term
impacts to non-motile benthic organisms may occur from smothering
and burial within the site.
8-6 The combined results of all the potential effects of the proposed
disposal are not expected to have any significant effect on the
ecosystem or on fishery resources. Estuarine spawning and nursery
areas, none of which are at Site 4, are more susceptible to
damage. Adults can avoid areas of high turbidity, whereas eggs
and fry often may not survive.
8-7 In satisfying the five general and eleven specific criteria for
selecting sites for disposal of dredged material found at 40 CFR
'Sections 228.5 and 228.6, all of the factors discussed must be
taken into account and carefully evaluated. That was done in this
case.
8-8 The Corps considered in detail the use of upland disposal and
diked disposal areas (CE, 1976) but later found these alternatives
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-10-
to be economically and environmentally unacceptable for disposal
of dredged material from the construction phase of the Tampa
Harbor Project (see response to Comment 5-4).
8-9 EPA has determined that the site designation will have no
appreciable direct effect on the coastal zone. Nevertheless, a
consistency determination has been completed and submitted to the
State of Florida. In addition, under 40 CFR 222.3, State agencies
responsible for the Coastal Zone Management Act are to receive
notice of applications for ocean dumping permits.
9-1 through 9-7 Identical to Comments 6-1 through 6-7.
9-8 Intensive surveys conducted during February, March, and April 1983
were specifically designed to determine the nature and extent of
bottom habitats within and near the site. The paucity of hard
bottoms at the site was confirmed, with less than 17% hard bottom
and less than 1% densely populated hard bottom found at Site 4.
9-9 The low incidence of hard bottom in the Site 4 area (estimated at
less than 17% of the bottom) makes comparisons allowable with
other, essentially soft bottom habitats.
9-10 Dr. Henry Bokuniewicz of the State University of New York Marine
Sciences Research Center discussed siltation and turbidity caused
by resuspension of fine particles by waves, storms and tides
(Bokuniewicz, 1982) as it pertains to the Tampa Bay area. He
concluded that between 3 and 10$ of the material would be
dispersed from a site, depending on long-term erosion of sediment.
Material leaving the site will most likely be widely dispersed and
diluted. In addition, the Corps of Engineers Waterways Experiment
Station is conducting a site-specific study of Site 4 to determine
the probable fate of dredged material disposed of at Site 4 and
the distribution of resuspended sediments. It is expected to be
completed in November 1983. This baseline data will provide
information for the direction of the monitoring program.
9-11 Resuspension of disposal material will cause temporary, localized
turbidity in the immediate area of disposal until the material is
dispersed. The EPA Ocean Dumping Regulations and Criteria do not
require quantification of the amount and frequency of siltation,
or the direction of sediment transport based on site-specific
ocean information; however, a study being conducted by the Corps
of Engineers will address many-of these concerns (see response to
Comment 9-10 above).
9-12 The proposed action is not expected to cause unacceptable adverse
effects on fisheries of the region. Based on the paucity of hard
bottom habitat within the Site 4 area (estimated at less than 17%
of the area, with less than 1% densely populated), the commercial
and recreational value of Site 4 is negligible. DEIS, p. 3-47:
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-11-
"Fisheries (Recreational and Commercial)". See also response to
Comment 5-14.
9-13 EPA has no evidence indicating that Site 4.is a significant marine
recreational area. See also response to Comment 5-14.
9-14 EPA believes that the public has had adequate opportunity to
comment on the proposed site designation.
9-15 through 9-24 We have responded specifically to the Manatee County and
Hillsborough County Environmental Protection Commission comments
(see response to Comments 10, 13, 14, and 15.
10-1 The February, March, and April 1983, intensive EPA surveys address
this issue comprehensively. Over 50 hours of video camera
observation were conducted on Site 4. While no area will be
completely devoid of life or even hard bottom habitat. Site 4 has
less hard bottom habitat than any other site studied in this area.
The hard bottom in this area is characterized by low relief flora
and fauna. The widely scattered hard bottom habitats within Site
4 may support some corals, sponges and algae; however, few
colonies attain heights over six inches. The characteristic biota
in this area does not indicate a highly productive ecosystem. It
is estimated that the widely scattered hard-bottom habitat
represents less than 17% of the bottom area on Site 4 and less
than 1% is densely populated.
10-2 See response to Comment 9-10. See also DEIS, pp. 2-24, 4-7, and
4-17 for descriptions and assessment of siltation and turbidity.
Precise quantification of the siltation is not feasible and is not
necessary for the designation of a dump site.
10-3 Available information does not indicate that the Site 4 area is
heavily used by commercial or recreational fishermen, or sport
divers. An aerial survey by the Corps of Engineers indicates that
use of the area is minimal (see response to Comment 5-14).
10-4 Burial and smothering of benthic populations by dredged material
disposal were considered carefully (see DEIS, pp. 4-17 through
4-19).
10-5 The Corps developed an estimate of 15
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-12-
10-7 The Corps of Engineers did not "expressly and unequivocally"
reject ocean dumping as an alternative. They stated that "This
plan [ocean disposal] produced the highest costs of all
alternatives considered." Lack of sufficient suitable land for
disposal and the unsuitability of the dredged material for diked
disposal areas lead to the ocean disposal alternative {see
recponse to Comment 5-4). In any event, the availability of
land-based alternatives must be considered by the Corps in each
authorization for disposal.
10-8 The Corps of Engineers considered several types of dumping in
detail, including in-Bay disposal, upland disposal, and dredged
material island disposal (CE, 1976). See also response to Comment
5-4.
10-9 Acknowledged; the EIS has been corrected. The actual distance is
approximately 18nmi.
10-10 The primary reason that the "No-Action Alternative" is
unacceptable is the adverse economic impacts to the area. The
Port of Tampa is one of the leading ports in the United States,
ranking seventh in total tonnage and third in export tonnage. The
Tampa Port Authority has estimated that about 36,000 persons were
directly or indirectly employed in port industries through the
Tampa Bay region (DEIS, p. 1-5). The Corps is required to
consider both economic and environmentally feasible alternatives
of accomplishing the proposed objective. The Corps has found
non-ocean disposal alternatives not to be economically or
environmentally feasible (see response to Comment 5-4).
Therefore, EPA, in cooperation with the Corps, initiated the
necessary studies.-required by 40 CFR 228.4(e) to select, evaluate,
and designate (if feasible) acceptable site(s) for the ocean
disposal of dredged material.
10-11 It is EPA's responsibility to designate an environmentally
acceptable ocean dredged material disposal site. The Corps of
Engineers examined upland disposal in detail (CE, 1976). This
alternative proved to be economically unacceptable'(see response
to Comment 5-4). Presumably, land is even less available and more
expensive today than in 1977, making upland disposal even less
feasible economically. However, the Corps must consider non-ocean
disposal alternatives before authorizing ocean disposal at Site
*•
10-12 The site designated is for disposal of dredged material from the
Tampa Harbor Project, which is described in detail in the Corps of
Engineers Final EIS (CE, 1976).
10-13 Rocks in the dredged material cause unexpected problems making
this alternative economically and environmentally unacceptable
(see response to Comment 5-4). The recent February, March, and
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-13-
April 1983, intensive EPA surveys address the feasibility and
suitability of the designated site.
10-14 The fact that an EPA contractor recommended a course of action
does not mean the Agency is bound to follow that course. In fact,
the contractor's recommendation was based on limited data, which
EPA later supplemented by re-investigating the existing and
alternative disposal sites, and found that Site 3 was
environmentally unacceptable for dredged material disposal.
10-15 Note the final conclusion: "Further studies should be conducted
to validate the preliminary findings." Note also that the wording
of the statement in question states that "...Sites 1 and 3 are
probably more environmentally acceptable..."
10-16 Diver observations can be an effective site-specific method to
characterize small localized areas; however, they are a very
ineffective tool for characterizing large areas, such as Site 4.
In fact, the divers found little evidence of hard bottom habitat
at Site 3; however, EPA's May 1982 survey found considerable
evidence of hard bottom. Thus, videotape transects are capable of
more accurately determining the presence of hard bottom habitats.
An in-depth videocamera survey of Site 4 has been completed,
recording approximately 80nm of bottom during the February, March,
and April 1983 EPA surveys.
10-17 Divers observations are limited to a small localized area at each
station. Videocamera transects cover a much larger area in a
continuous line, thereby giving far more conclusive evidence as to
the extent of hard-bottom communities. In fact, EPA's initial
reconaissance survey of Site 3 (where divers were used
extensively) first indicated a potentially suitable disposal site;
this was later proved to be an invalid assumption, based upon
extensive videocamera observation and sample collection.
10-18 The assessment of impact does not require a quantification of all •
factors. EPA must make a determination on site designation based
on reasonably available information. Further, the natural marine
environment is dynamic; currents are not static either in
direction or speed. A site-specific study, expected to be
completed by November 1983, is being conducted by the Corps to
assess currents and sediment transport to provide additional
baseline data. The site designation will be for 3 years. See
also response to Comment 9-10.
10-19 Detailed quantification of the rates of dilution of the turbidity .
plume and the distance the deposited materials will be transported
are not required for site designation. Examination of available
facts and information using best professional judgment is
sufficient to determine whether a site is suitable for designation
as an ocean disposal site. Site 4 is 4nmi square, and no movement
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-14-
of sediment is expected from the site that will cause significant
adverse environmental harm. See also response to Comment 9-10.
10-20 There are two reasons the Mid-Shelf was not considered feasible:
1) the Corps indicated that sites located in excess of 18nmi were
not economically feasible; and 2} a Mid-Shelf site, considered a
low energy environment, is likely to sustain more severe
environmental impacts of longer duration from dredged material
disposal than alternative higher energy sites. The most distant
portion of the Mid-Shelf (i.e., 70 miles offshore) was selected as
the alternative Mid-Shelf sf t e, because this was the area
recommended by the State of Florida.
10-21 The sentence clearly does not state or imply that Oliver et al.,
(1977), recommended ocean dumping in hard bottom areas ratfier than
deep waters. The statement was that "...shallow-water, high
energy benthic communities recover more quickly from disturbances,
such as the disposal of dredged material, than communities in
deeper water." Since about 83% of Site 4 is soft bottom, the
basic concept of recovery that Oliver et _al_., (1977), described
applies in this case.
10-22 According to the Corps (letter from J. Wall to 0. Amson,
August 19, 1983) the average cost to transport dredged material is
15f/cu. yd. The basic premise here is still logically true; it
will cost considerably more to transport dredged material 70nmi
than to transport it 18nmi.
10-23 The Agency is unaware of any evidence of that demonstrates that
Site 4 is an area of high commercial and recreational activity
(see response to Comment 5-14).
10-24 The economic feasibility of a dump site is determined on the basis
of project costs. According to the Corps of Engineers, sites in
excess of 18nmi from Egmont Key are not economically feasible,
based on project costs for the Tampa Bay Harbor Deepening Project.
The sites described by the commenter were used for disposal of
sewage sludge and industrial waste, not dredged material.
10-25 It is well known that the primary productivity of deep waters is
less than that of shallower waters. This is due, in part, to the
decreased influx of nutrients and decreased light penetration.
Productivity decreases with increasing distance from land, and
with, increasing depth. Benthic organisms adapted to the
relatively constant environment in deeper water are less adaptable
to change. Those benthic organisms adapted to the more dynamic
inshore waters tend to be more adaptable to environmental changes,
either as individuals or as a species (Oliver et £]_., 1977).
Although EPA has not conducted studies in the area of the
Mid-Shelf or Deep Water Sites, the Florida Department of Natural
Resources did study a site approximately 15nmi to the northwest of
these sites during the Hourglass Cruise studies in 1969.
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10-26 The Mid-Shelf site is a more dynamic environment than the Deep
Water site, and therefore, more resilient to impact from dredged
material disposal (see also response to Comment 9-10).
10-27 Precise quantification is not necessary to make a comparison. In
addition, the term "small effect" in this context did not refer
specifically to hard-bottom organisms.
10-28 The basic point here is that deeper water organisms are less
adaptable to perturbations such as dredged material disposal than
shallow water, inshore organisms. Therefore, recovery from
dredged material disposal would generally be more rapid at a
shallow water site than at a deep water site. Immediate impacts
would be more severe at the deeper water sites, and recolonization
would be slower.
10-29 During the recent February,-March, and April 1983 intensive EPA
surveys, there was already some evidence of recolonization noted
at Sites A and B. We are unaware of "scientific literature" which
clearly demonstrates that hard-bottom communities will not recover
to their pre-dumping state for 25 to 50 years, even after hard
substrate is available. The increased entrainment of water during
the descent phase of disposal operations at deep water sites will
increase both the amount and duration of turbidity, as well as the
distance from the discharge point the material is transported,
thus potentially increasing the extent of environmental damage.
10-30 The increased percentage of silt in the dredged material compared
to the disposal site sediments can be expected to change the
characteristics of the infauna accordingly. The composition of
the biota would be expected to shift to those organisms more
adapted to these sediments. As these finer sediments disperse,
leaving coarser material, the composition of the biota will
gradually shift back towards biota that are adapted to the
original substrate.
10-31 The same considerations apply to the Deep Water Site as to the
Mid-Shelf Site (see response to Comment 10-22). Increased
distance increases the costs of transportation.
10-32 Intensive surveys by EPA during February, March, and April 1983
were conducted throughout the area with extremely detailed
examination of Site 4. More than 50 hours of underwater video
camera work was obtained, to extensively study the character and
extent of various bottom types, both inside and outside of Site 4.
The video camera technique was found to be-an excellent tool for
this type of data collection effort, and covered far more area
more rapidly with a greater degree of veracity than could be
accomplished by divers in the same amount of time.
10-33 See response to Comment 10-32, above.
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-16-
10-34 See response to Comment 10-32, above for discussion of February,
March, and April 1983 EPA surveys. Site 4 is not devoid of
hard-bottom habitat; however, less than 17% of the site is
estimated to have this type of habitat. This is far less than any
other site studied in this area, and therefore less productive.
We have no information that Site 4 is an area heavily used for
shrimping, recreational fishing, or scuba diving (see response to
Conment 5-14).
10-35 Disposal of dredged material at Site 4 is not expected to have
unacceptable adverse environmental impacts to beaches, hard bottom
areas, artificial reefs, sunken vessels, shrimping, commercial or
recreational fishing, or other amenity areas of the region because
of the distances from the proposed disposal site. There has been
no evidence presented to EPA that Site 4 is an important fishing
or diving site (see response to Comment 5-14).
10-36 See DEIS, pp. 3-4 to 3-11 for consideration of storms and
currents. A site-specific current and sediment transport study is
being conducted by the Corps of Engineers to augment available
information, and is- scheduled to be completed in November 1983
(see also response to Comment 5-14).
10-37 Since approximately 83% of the bottom at Site 4 is "soft bottom",
comparison with other soft bottom areas such as the Galveston dump
site is appropriate.
10-38 Quantification of the amount and frequency of resuspension of
sediment and impacts to hard bottom habitats and organisms is not
specifically required by 40 CFR 228.6(a}(7). However,
resuspension of sediment is discussed in response to Comment 9-10
(see DEIS, p. 2-11, para. 3 for discussion of Sites A and B, and
pp. 3-4 to 3-11 for discussion of currents).
10-39 Dredged material disposal at Site 4 is not expected to interfere
with shipping, fishing, recreation, mineral extraction,
desalination, fish and shellfish culture, areas of special
scientific importance or other legitimate uses of the ocean.
Site 4 may be located in a general area used for sport fishing,
shrimping, party and charter boat fishing, and scuba diving;
however. Site 4 and its immediate vicinity have not been
identified with these uses (see also response to Comment 5-14).
10-40 An intensive site-specific study of Site 4 was conducted by EPA in
February, March, and April 1983. A monitoring program will be
designed to detect unacceptable adverse environmental effects. If
it appears that those effects are or will become unacceptable, EPA
will take appropriate steps to limit or halt dumping operations.
10-41 The intensive EPA survey of Site 4 in February, March, and April
1983 revealed a minimum of hard-bottom areas within and
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-17-
surrounding Site 4, and no ledges in or near the site. No
unacceptable adverse environmental effects from disposal
operations are anticipated outside the immediate vicinity of the
designated disposal site.
10-42 During EPA surveys in February, March, and April 1983, less than
17% of Site 4 was found to contain hard bottom, and less than 1%
of the site was found to be densely populated hard bottom.
10-43 Bioassays of dredged material are designed to insure that the
- material will not cause unreasonable acute or chronic toxicity, or
other sublethal adverse effects, or cause accumulation of toxic
materials in the human food chain (see 40 CFR §227.27(b)). These
tests are not designed to predict direct impacts from burial or
si 1 tation on hard-bottom organisms.
10-44 Less than 17% of the site is hard bottom and less than 1% is
densely populated, so the impact of dredged material disposal on
hard-bottom organisms would be minimal. The site will be
designated for a three-year period, and if monitoring detects
unacceptable adverse environmental impacts, the Agency will move
to halt disposal operations.
10-45 During EPA surveys in February, March, and April 1983, detailed
examination of the area of Site 4 was conducted to identify areas
of hard-bottom normally associated with this type habitat.
10-46 No evidence has been provided to EPA or the Corps to indicate that
Site 4 is a heavily used commercial or recreational fishing site
(see response to Comment 5-14).
10-47 Impacts within and immediately surrounding Site 4 from
resuspension of fine particles will be negligible (see DEIS, p..
3-2, para. 6, and p. 3-8, para. 3). See also response to Comment
9-10.
10-48 Resuspension of dredged material will cause temporary localized
turbidity in the immediate vicinity of the disposal area until the
material is dispersed and diluted (see response to Comment 9-10).
10-49 Much of the commercial fishery in the area is dependent on pelagic
species, which are not generally associated with or dependent on
hard-bottom areas. These species tend to be highly mobile, and
avoid areas of high local turbidity. Dumping of dredged material
at Site 4 is not expected to significantly affect hard bottoms in
any case.
10-50 See response to Comments 5-14 and 10-39.
10-51 See DEIS, pp. 3-47 through 3-51. No spawning or nursery grounds
are known to occur in the immediate vicinity of Site 4, and since
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-18-
there is minimal hard-bottom habitat within Site 4 (estimated at
less than 17%), it is unlikely that fish dependent on hard-bottom
habitat for spawning and/or nursery areas would be severely
impacted by dredged material disposal at this site.
10-52 Sport diving at Site 4 is an unlikely site for sport diving, since
there are a minimum of hard-bottom areas at the site, with a
concomitant reduction in abundance and diversity of marine
species. Resuspension of dredged material during severe storms is
unlikely to significantly impact sport diving in the area, since
it is too hazardous to attempt diving during such events.
Turbidity following storms would be temporary and localized within
the immediate vicinity of Site 4.
10-53 EPA believes that the public has had adequate opportunity to
comment on the proposed site designation.
10-54 Intensive site-specific surveys conducted during February, March
and April 1983 by EPA address many of these concerns, including
the extent and nature of hard-bottom habitat in the Site 4 area.
Additional site-specific current and sediment transport studies,
expected to be completed in November 1983, are currently being
conducted by the Corps of Engineers to provide baseline data. A
monitoring program will be formulated to assess the impacts of
dredged material disposal during the three-year designation.
10-55 After careful evaluation of all factors including intensive
site-specific surveys, quantification of the extent of hard-bottom
habitats, and consultation on the subject of sediment dispersal
during and after disposal operations with experts in the field, we
feel that Site 4 is an environmentally acceptable ocean dredged
material disposal site and will not result in unacceptable adverse
environmental effects (see response to Comment 9-10). Use of
diked disposal areas is not preferable, for reasons discussed
earlier (see response to Comment 5-4).
11-1 Surveys conducted during February, March, and April 1983, which
included approximately 80 hours of video camera observation of the
bottom throughout the area, boxcore samples, trawls, side-scan
sonar and fathometer tracings, and water samples have provided
sufficient data for a site designation. The Corps evaluated
upland and other alternatives to ocean disposal (CE, 1976). These
alternatives were found to be economically and environmentally
unacceptable (see response to Comment 5-4). The economic and
recreational resources of the area are discussed in the DEIS, pp.
3-47 through 3-52 (see also response to Comment 5-14). Disposal
of maintenance dredged material is not expected to permanently
destroy or degrade hard-bottom communities or associated fishery
values.
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•11-2 The additional Intensive surveys conducted with the video camera
during February, March, and April 1983, confirm that there are few
hard-bottom areas within the site, and those observed are sparse
and of low relief. Less than 17% of Site 4 is estimated to
contain hard- bottom communities and less than 1% is densely
populated.
11-3 According to available information (Moe, 1963, see Figure 3-18,
DEIS, p. 3-48) and EPA 1983 survey results (see response to
Comment 3-2), there are no artificial reefs or concentrations of
hard-bottom areas which would attract large numbers of divers or
recreational and commercial fisherman to the immediate vicinity of
Site 4.
11-4 Intensive surveys utilizing a towed video camera during February,
March, and April 1983, provided considerable information for
evaluation of potential dredged disposal sites to augment the
earlier survey.
11-5 The movement of sediments is not expected to cause long-term
unacceptable environmental impacts (see response to Comment 9-10).
The planned monitoring program will be designed to detect any
unacceptable adverse environmental impacts.
11-6 The majority of Site 4 consists primarily of flat sandy bottoms,
. and therefore is similar to the referenced study areas. No
permanent environmental impacts are expected from disposal at Site
4. There is no evidence that the previously designated disposal
site has contributed to "the disappearance" of basket sponges or
spiny lobsters from ledges near the site. A number of factors may
have contributed to a decrease in lobsters, including overfishing
by divers, seasonal changes, and large amounts of natural
siltation, as observed in the February, March, and April 1983 EPA
surveys. Permanent stress to offshore habitats from maintenance
dredged material disposal is not expected to occur.
11-7 According to the Florida Department of Natural Resources (see
response to Comment 5-61), the fishery resources indicated in the
DEIS may actually be overestimated, as the landings in the Tampa-
St, Petersburg area are not all taken from the local coastal area,
and therefore the fishery resources may be less than indicated in
the DEIS. Only limited, short-term disruption of recreational or
commercial fishing is expected to occur, if any, during actual
dumping operations (see also response to Comment 5-14).
11-8 The Corps of Engineers examined the upland disposal of dredged
material (CE, 1976), and were unable to locate sufficient suitable
upland disposal areas (see response to Comment 5-4).
11-9 The Corps considered the diked dredged material disposal island
alternative in detail (CE, 1976). However, with further study,
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-20-
this alternative was found to be economically unacceptable for the
disposal of dredged material from the construction phase of the
Tampa Harbor Project (see response to Comment 5-4). In addition,
diked disposal islands may have unacceptable environmental impacts
by reducing circulation in the Bay and increasing turbidity during
dredging operations and subsequent erosion of the islands after
construction reducing productivity.
11-10 There are many reasons why a sediment sample may "fail" a
bioassay. Some of these reasons include high mortality in the
control organisms or changes in required test conditions, such as,
level of dissolved oxygen. Tests that are invalidated for these
reasons are not normally reported. An invalid bioassay does not
indicate "failure" of a sediment sample to pass a bioassay for
toxicity. Moreover, these allegations concerning the field and
•laboratory procedures were refuted in court proceedings. The
court deferred to Dr. Engler of the Corps, who testified that
field surveys were conducted using proper scientific procedures
and that bioassays were conducted in strict accordance with EPA
and Corps guidelines (Manatee County v. Gorsuch, No. 82-248-CIV-T-
GC (M.D. Fla., December 22, 1982) (slip op. at 14 note 12).
11-11 Disposal of dredged material outside any designated site is
occasionally a problem. However, the U.S. Coast Guard is charged
with monitoring dumping activities, and dumping outside of a
designated area is illegal. Further, Site 4 is almost six times
larger in area than the previously designated disposal site (Site
A), so incidents of dumping outside the site should be
substantially reduced.
11-12 Disposal has been- halted at Site A. Additional extensive studies
- have been conducted during February, March, and April 1983.
Transects were conducted at 1/4 mile intervals using the video
camera. In addition, fathometer and side-scan sonar tracings were
taken.
11-13 Evidence collected during the February, March, and April 1983 EPA
surveys indicate that siltation occurring in the area may be
largely of natural origin because of the uniformity of sediment
found throughout the area. Further, a monitoring program will be
designed to detect any unacceptable adverse environmental impacts
caused by the potential spread of the dredged material.
11-14 No significant impact is expected to fisheries because of the
relative small size of the site, and avoidance of the area by fish
during disposal operations.
11-15 Diked disposal areas proved to be economically and environmentally
unacceptable for the disposal of dredged material from the
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11-16
12-1
12-2
12-3
12-4
12-5
12-6
12-7
12-8
con struct ion phase of the Tampa Harbor Project (see response to
Comment 5-4).
Opportunity for full and complete public comment has been afforded
through the DEIS and the site designation proposal. Designation
of Site 4 is not expected to seriously affect fisheries resources
in any way, or cause a serious public health hazard.
The February, March, and April 1983 EPA surveys provided extensive
information to evaluate the site-specific impacts of dredged
material disposal (see response to Comment 3-2).
Recent intensive surveys address most of deficiencies in the
biological sampling. The box core is designed to sample infauna
on and in the bottom and to provide information on the abundance
and diversity of organisms. Video camera observations are a more
effective tool for judging the relative abundance of hard-bottom
communities.
Recent intensive surveys in February, March, and April 1983 by EPA
employed extensive use of the video camera on site. Preliminary
examination of video tape recordings indicate that less than 17%
of Site 4 bottom could be classified at hard-bottom, and less than
was densely populated.
The February, March, and April 1983 EPA surveys provided adequate
evaluation of the extent of hard-bottom habitats in the area of
Site 4.
The recent 1983 EPA surveys discussed above confirm that hard-
bottom habitat is.- a minor component within the Site 4 area. Less
than 17% is hard-bottom, and less than 1% is densely populated.
Sufficient information is now available from the February, March,
and April 1983 EPA surveys to evaluate Site 4 under the five
general and eleven specific criteria of the Ocean Dumping Act (40
CFR 220-229).
Sufficient information from EPA's February, March, and April 1983
surveys (see response to Comment) and information from Bokuniewicz
(see response to Comment 9-10) is available to make a predictive
evaluation of the impact of dredged material disposal on hard-
bottom areas. The monitoring program will be designed to detect
unacceptable adverse environmental impacts in which case, EPA will
move to halt disposal operations at the site.
Much of this information is available and is either discussed in
the DEIS, or in Appendices C and F. Further, the monitoring
program to be established may well include the studies on
hard-bottom organisms that are suggested.
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12-9 Analyses for vibrio-type bacteria would not provide an indication
of a human health threat. Only Vibrio parahaemolyticus has been
implicated as a public health hazard, rarely as an opportunistic
pathogen infecting wounds, more commonly as a food poisoning
organism when allowed to grow uninhibited in contaminated seafood
products. Culture and identification of Vibrio parahaemolyticus
using an array of biochemical tests still does not positively
identify the causative form of Vibrio in cases of acute
gastroenteritis, making this test of questionable value.
12-10 See DEIS, p. 4-19, para. 1. "Recolonization of dredged material
disposal sites depends [in part] on the disparity between site and
dredged sediments...." As the silt/clay ratio returns to pre-
dumping conditions, recolonization is expected to accelerate.
12-11 None of the invertebrate species listed by the Florida Game and
Freshwater Fish Commission as threatened or endangered, have been
identified at Site 4.
12-12 The monitoring program will provide continuous site-specific data
on the disposed dredged material to insure the quality does not
change. Tissue samples, water column samples and sediment samples
may be part of this program. Toxic metal concentrations were not
found in Site A post-disposal sediments.
>
12-13 Use of a non-endemic species in bioassays is a scientifically
valid procedure. In fact, it is often more valid to use test
organisms of known uniform age and condition then to use endemic
species which are often difficult to obtain and often not uniform
in age or condition. Test organisms were not pre-exposed to
"significantly high concentrations" of toxic chemicals in. control
water. Moreover,.-these allegations concerning the field and
laboratory data procedures were refuted in court proceedings. The
court deferred to Dr. Engler of the Corps, who testified that
field surveys were conducted using proper scientific procedures
and that bioassays were conducted in strict accordance with EPA
and Corps guidelines (Manatee County v.Gorsuch, No. 68-248-CIV-T-
GC (M.D. Fla., December 22, 1982) (slip op. at 14 note 12).
12-14 Evaluation of utilization of diked disposal areas has been
discussed in detail by the Corps of Engineers (CE, 1976), but were
found to be economically and environmentally unacceptable (see
response to Comment 5-4). Additional studies were undertaken in
May 1982, and in February, March, and April 1983, to ensure that
an environmentally appropriate disposal site is designated.
13-1 Acknowledged.
14-1 All disposal of dredged material at Site A was discontinued on
December 24, 1982.
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14-2 Acknowledged.
14-3 Site 4 has fewer hard-bottom outcrops than any other site
examined in the Tampa Bay area, and therefore would have less
impact on fish and other organisms. Less than 17% of Site 4 is
hard-bottom and less than 1% is densely populated.
15-1 Acknowledged.
16-1 The requested meeting was held in Jacksonville, Florida, on
January 26, 1983; representatives from all affected Federal,
State, and local agencies were present at that meeting.
17-1 The reduced visibility reported is highly unlikely to have been
caused by disposal operations at Site A. It is more probable that
the apparent reduction in visibility is caused by activities
occurring within the Bay. This could include nonpoint sources
such as runoff from construction sites, or agricultural
activities; it could also include point sources such as discharges
from sewage treatment plants, or industrial wastewater treatment
discharges.
17-2 The order of presentation of material in the DEIS does not
necessarily reflect the order of the impact assessment. The
summary and conclusion, while placed before the actual evaluation,
were written after evaluation of all considered alternatives.
Site 4 was selected only after careful study .showing that the site
has few hard bottom areas.
17-3 Additional survey work was conducted in the area with
approximately 50 hours of video recordings taken of the bottom.
Site 4 was surveyed in 22 runs that were 1/4 nautical mile apart
in both NW and SE and SW to NE directions. Analysis of this data
reveals that the majority of the site is soft bottom, with
scattered, sparse patches of hard bottom.
17-4 The Corps of Engineers (CE, 1976) considered upland disposal sites
and found that insufficient suitable land was available for
disposal of the dredged material, even on McDill Air Force Base
(see response to Comment 5-4). This alternative must be
reconsidered by the Corps before individual ocean dumping projects
are approved.
17-5 The dredged material islands would be less environmentally
acceptable, because of the resultant reduced circulation in the
Bay, and increased turbidity caused by disposal operations.
17-6 No impacts are expected on Anna Maria Island or Long Boat Key
beaches from disposal of dredged material at Site 4, because of
the distance of the site from the shore.
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17-7 The DEIS has been reviewed by the National Oceanic and Atmospheric
Administration, and the Department of Health and Human Services;
both agencies agree that no unacceptable long-term environmental
effects or adverse health effects are expected to occur from
disposal of dredged material at Site 4.
17-8 No significant adverse environmental effects are expected either
on recreational use of the area outside the site, or to the
commercial fishing of the area (see also response to Comment
5-14).
17-9 Disposal of dredged material at Site 4 is not expected to cause
any proliferation of the "red tide" organism. Further, the
primary phosphorus sources in the Tampa Bay area are probably
attributable to phosphate industries along the Alafia River (CE,
1976).
18-1 Diked disposal areas were considered in detail by the Corps of
Engineers (CE, 1976), however, this alternative was later found to
be economically and environmentally unacceptable for the disposal
of dredged material from the construction phase of the Tampa
Harbor Project (see response to Comment 5-4).
19-1 Acknowledged. >
20-1 Hard bottom areas in this region occur only in scattered patchy
distributions. As a result, it is difficult, if not impossible,
to avoid all hard bottom areas. Those outcroppings with
substantial relief offer a more diverse and productive habitat to
benthic organisms. It is highly unlikely that dredged material
will drift back into the Tampa Bay channel entrance in any
si-gnificant amount.
20-2 Disposal operations at Site A have been terminated.
20-3 Depending on the composition of the dredged material as well as
physical oceanographic conditions, suspended particulate levels
could be expected to decline rapidly within hours, with the
turbidity levels returning to ambient concentrations within 24-36
hours.
20-4 The short-term avoidance referred to is over a matter of hours,
or, at most days, thus it would not affect the seasonal migrations
of the cited teleosts.
20-5 The turbidity plume would have temporary, localized adverse
effects on any sport diving in the immediate area of disposal.
20-6 Commercial finfishing for pelagic species exists seaward of Sites
A and B and the Shallow-Water Alternative Sites.
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_25-
20-7 There are no confirmed reports that Site 4 is a good shrimping
area, nor do any EPA or Corps survey results indicate that this is
the case (see response to Comment 5-14).
20-8 A monitoring program will be instituted at the completion of the
o site designation process and prior to initiation of disposal
activities. If serious adverse environmental effects are
discovered, the Agency may terminate or limit the use of the
ci. site.
21-1 The Corps considered other alternatives to ocean disposal
including upland and within Bay disposal (CE, 1976). However,
these alternatives were found to be economically and
environmentally unacceptable {see response to Comment 5-4). The
Environmental Protection Agency is responsible for designation of
ocean disposal sites under the five general and eleven specific
criteria of the Ocean Dumping Regulations (40 CFR §220-229).
21-2 Dredged material disposal has been discontinued at Site A.
Disposal at Site 4 is not expected to cause unacceptable adverse
environmental effects, although temporary impacts will occur
during disposal operations.
21-3 Impacts from disposal of maintenance dredged material are not
expected to cause unacceptable adverse environmental effects. The
volume of maintenance operations is less than the initial
construction operations. Most impacts are expected to be of short
duration, and to not extend beyond the site boundaries.
21-4 The value of the site area to the diving industry is judged to be
minimal (see response to Comment 5-14).
21-5 The U.S. Coast Guard monitors disposal activities to prevent this
illegal form of dumping which may result in a fine to the parties
involved. Persons with knowledge of short-dumping incidents
should report such events to their local Coast Guard District.
21-6 Upland disposal alternatives were considered in detail by the
Corps of Engineers (CE, 1976), but were found to be economically
unacceptable (see response to Comment 5-4). Significant economic
losses in fisheries or in recreational uses are not expected to
9 occur (see response to Comment 5-14). Diked disposal areas were
considered in detail by the Corps of Engineers (CE, 1976), but
were later found to be economically and environmentally
unacceptable for disposal of dredged material from the
» construction phase of the Tampa Harbor Project (see response to
Comment 5-4).
21-7 The February, March, and April 1983 intensive surveys by EPA
provide adequate baseline data to evaluate projected impacts of
dredged material disposal. The Corps of Engineers is currently
conducting an on-site current measurement study, expected to be
completed by November 1983, to provide additional baseline data.
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22-1 The DEIS follows the five general and eleven specific criteria
found at 40 CFR §228.5 and §228.6 for management of ocean disposal
sites. 40 CFR §227.15 applies to permit applications for ocean
dumping, which must be reviewed by the Corps of Engineers in
approving disposal projects. Section 227.15 does not require a
cost-benefit ratio study.
22-2 Additional surveys conducted during February, March, and April
1983 establish that hard bottom accounts for less than 17% of the
site and less than 1% is densely populated. The DEIS does not
state that Site 4 is covered entirely by a sandy bottom.
22-3 Drift of dredged material is not expected to extend beyond the
boundaries of the site {see response to Comment 9-10).
22-4 Dispersal of dumped sediments is not expected to cause
unacceptable adverse environmental impacts to nearby artificial
reefs or wrecks because of their distance from the proposed site.
It is incorrect to conclude from the statement that "Site 4 will
provide a large sandy bottom area" that'Site 4 is entirely covered
with sandy bottom. Less than 17% of the site is hard bottom;
thus, approximately 83% is soft bottom.
22-5 The thin layer of sediment is expected to disperse vrtth time,
causing no unacceptable long-term adverse environmental effects.
Further, evidence collected during the February, March, and April
1983 EPA surveys indicates that siltation noted in the offshore
areas may be largely of natural origin, because of the uniformity
of sediment distribution throughout the study area.
22-6 Flushing patterns-'and predominant bottom characteristics off the
west coast of Florida are similar to cited areas where studies
have been conducted; thus, it is acceptable to compare this area
with these areas.
22-7 Less than 17% of the bottom on Site 4 is estimated to have hard-
bottom habitat, and less than 1% is densely populated; the site
has less hard bottom habitat than any other area surveyed in the
Tampa Bay area (see response to Comment 3-2).
22-8 The parameters established for elutriate testing to determine the
amount of trace contaminants released by the dredged material
disposal are found at 40 CFR 227.13 and 227.27.
22-9 Turbidity resulting from disposal operations is expected to be of
short duration, and not long enough to cause unacceptable adverse
environmental effects to the loggerhead turtle's feeding or
breeding habits.
22-10 Permit conditions can be stipulated to prevent unacceptable
adverse environmental effects. These conditions include, but are
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not limited to, designation of the disposal site, limitations on
time and rate of disposal, disposal site monitoring, designation
of release zones, limited site designation, or termination of
designation.
22-11 Complete bathymetric studies were done in the February, March, and
April 1983 EPA surveys. The monitoring program will be
sufficiently detailed to determine if unacceptable adverse
environmental effects are being caused by dredged material
disposal.
23-1 EPA thanks the Corps of Engineers for its concurrence with the
recommendation of an ocean dredged material disposal site at
center coordinates 27° 31' 27"N, 83° 04' 54"W (Site 4).
24-1 EPA thanks the National Oceanic and Atmospheric Administration for
their comments and helpful information. The information in the
DEIS on whales and turtles has been revised, based on NOAA's
suggestions. Consultation with NOAA, pursuant to Section 7 of the
Endangered Species Act has been accomplished.
25-1 Dredged material disposal at Site A was discontinued December 24,
1982.
25-2 EPA believes that sufficient opportunity has been provided for
public response to the site designation.
25-3 The Corps of Engineers considered in detail non-ocean dredged
material disposal {CE, 1976), but later found these alternatives
to be economically and environmentally unacceptable for disposal
of dredged materi.al from the construction phase of the Tampa
Harbor Project (see response to Comment 5-4).
25-4 The proposed action is not expected to have unacceptable adverse
environmental impacts to the marine environment. The proposed
action will have a beneficial effect on the economy of the region
(FEIS, 1983).
25-5 Dredged material disposal at Site A was discontinued on
December 24, 1982.
25-6 According to information available, the proposed action will have
no significant effect on recreational activities of the region nor
commercial fishing (see response to Comment 5-14).
25-7 Impacts on migratory fish are expected to be minimal, because fish
will avoid temporary turbidity caused by disposal operations.
25-8 The many studies conducted in the Site 4 vicinity, and in
particular, the February, March, and April 1983 EPA surveys, have
provided considerable information on the environmental features of
this area.
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25-9 A monitoring program will be established for Site 4 to detect
significant adverse environmental impacts. Should unacceptable
adverse environmental effects be noted, EPA will move to halt
disposal operations.
26-1 Intensive surveys were conducted by EPA during February, March,
and April 1983 to augment the preliminary surveys.
26-2 Designation of a release point within the site may be specified in
the site designation. Consequently, the Gunsmoke wreck may be one
to two miles from actual dumping operations, and as much as three
miles. No unacceptable adverse environmental effects are expected
at these distances.
26-3 Non-ocean disposal was considered in detail by the Corps of
Engineers, but were found to be economically and environmentally
unacceptable for disposal of dredged material from the
construction phase of the Tampa Harbor Project (see response to
Comment 5-4). The potential impacts of ocean disposal, are
presented in the DEIS, Chapter 4, "Environmental Consequences."
(See also response to Comment 9-10.)
26-4 The use of diked disposal areas were considered in detail by the
Corps of Engineers (CE, 1976), but was later found to be
economically and environmentally unacceptable for disposal of
dredged material from the construction phase of the Tampa Harbor
Project (see response to Comment 5-4).
26-5 EPA believes that sufficient opportunity has been provided for
public comment on the site designation.
27-1 Transmittal of Clearinghouse Review. Identical to responses to
Comments 9-1 through 10-55, above.
28-1 Intensive surveys conducted by EPA during February, March, and
April 1983 included water column sampling, sediment samples (for
infauna, grain size analysis, and trace metals), trawls (for fish
tissue analyses), extensive video camera observations of the
bottom, and side-scan sonar tracings. These surveys provide
adequate baseline data for evaluation of environmental impacts.
28-2 According to the Corps of Engineers, mid-Shelf and deepwater sites
would not be economically feasible, due to increased
transportation costs. Site 3 has been judged environmentally
unacceptable for dredged material disposal, due to the presence of
hard-bottom areas.
28-3 Intensive surveys conducted during February, March, and April 1983
provides sufficient evidence for designation of Site 4. Less than
17% is hard-bottom, and less than 1% is densely populated.
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28-4 Construction of diked dredged material disposal islands could
better be described as "a non-ocean alternative" (see response to
Comment 5-4).
28-5 The additional studies conducted at Site 4 and vicinity by EPA
during February, March, and April 1983, provides data needed for
designation of Site 4.
28-6 The video camera observations conducted in February, March, and
April 1983 by EPA were transects 1/4 mile apart in both northwest
to southeast and southwest to northeast directions. The method
enabled detection of any significant areas of hard bottom
communities. It was found that less than 17% of Site 4 was hard
bottom, with less than 1% densely populated.
28-7 The dissolved oxygen data for the previously designated site and
the proposed site are not directly comparable. The percent
saturation of dissolved oxygen depends on the ambient temperature.
Therefore, the time of year and depth a sample is taken are.
important factors in evaluating dissolved oxygen data. The data
presented, however, does provide baseline data on the Tampa Bay
area.
28-8 A stress reaction or death may have a greater environmental
consequence to the surrounding benthic community than the loss of
the organism in question. Loss of individual organisms is often
naturally high, but stresses or deaths which exceed the natural
fecundity of a species may lead to a decline in the population.
In the complex interrelationship of marine organisms, .decline in
one species may lead to a decline or an increase in a competing
species. This relationship can be partly seen in the simplified
food web with potential adverse impact from dredged material
disposal, presented in Figure 4-1 of the DEIS, p. 4-15.
28-9 The surveys conducted during February, March, and April 1983, have
provided sufficient information to recommend the designation of
Site 4 as an ocean dredged material disposal site (see response to
Comment 9-10).
29-1 EPA thanks the State of Florida Department of Natural Resources
for the site-specific dive reports provided. The June 4, 1981,
dive survey by Japp and Lowery supports the conclusion that
impacts from disposal operations will cause negligible adverse
effects outside "the actual site. No visible evidence of impact
was observed beyond 1 km inshore of a disposal site.
30-1 Transmittal of Clearinghouse Review. See response to Comment
10-26, above.
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U S. Environmental Protection
Library. Room 2404 PM-211-A
401 S Street, S.W.
Washington, DC 20460
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