April 4, 2014
Headquarters
U.S. Army Corps of Engineers
ATTN: CECW-P (IP)
7701 Telegraph Road
Alexandria, Va. 22315-3860
TO:
U.S. Army Corps of Engineers
FROM:
St. Johns Riverkeeper, Florida Wildlife Federation, North Florida Land Trust, Public
Trust Environmental Legal Institute of Florida, Inc., and Sierra Club Northeast Florida
Group
RE:
OPPOSITION TO THE JACKSONVILLE HARBOR CHANNEL DREDGING
St. Johns Riverkeeper has prepared these comments regarding the Jacksonville Harbor Channel
Deepening Study on behalf of the St. Johns River, our members, the Florida Wildlife Federation, North
Florida Land Trust, Public Trust Environmental Legal Institute of Florida, Inc. and Sierra Club Northeast
Florida Group.
St. Johns Riverkeeper along with our allies and team of experts have worked with the U.S. Army Corps
of Engineers (USACE) for more than two years on the proposal to deepen the St. Johns in an effort to
protect the river from unnecessary harm and to ensure the community has the necessary facts and
information to make a fully informed decision.
On March 7, 2014, the U.S. Army Corps of Engineers (USACE) posted the Final Environmental Impact
Statement (EIS) regarding the proposal to dredge the St. Johns River from 40 to 47 feet to
accommodate larger ships for the expansion of JAXPORT.
We cannot support the proposed plan to dredge the St. Johns River due to the following reasons:

The USACE analysis is flawed and incomplete, significantly underestimating the potential
threats to the health of the St. Johns River.
o Salinity will move farther upstream, adversely impacting hundreds of acres of wetlands
and submerged aquatic vegetation (SAVs) and further stressing numerous trees in
some sections of the river and its tributaries, such as Julington Creek and Ortega River.
o Critical habitat for fisheries and wildlife will be lost.
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o USACE used two different salinity models for the main stem and tributary analyses.
Use of different models for the salinity intrusion model makes evaluation unreliable
and calls into question the validity of one, if not both of the models.
o USACE’s river channel sedimentation model does not provide necessary information to
establish environmental effects for sedimentation.

The mitigation plan is woefully inadequate, failing to offset the damage that will be incurred
from dredging.
o Pre-project mitigation is limited with no net benefit to the river.
o Implementation of post-project mitigation is unlikely due to vague criteria, the lack of
specific thresholds and the absence of USACE commitment for needed corrective
action.

The federal and local economic interest has not been demonstrated and verified, as required
by Federal Law.
o A multi-port analysis assessing competition among regional ports has not been
conducted.
o Local job projections have not been independently peer-reviewed or verified.
o Economic methods and assumptions are not adequately documented.
For the above reasons, St. Johns Riverkeeper, Florida Wildlife Federation, North Florida Land Trust,
Public Trust Environmental Legal Institute of Florida, Inc. and Sierra Club Northeast Florida Group
oppose the proposed dredging and the continuation of this project as it currently stands. Further
review and a more comprehensive analysis are necessary to adequately determine the economic
viability of the proposed dredging and ensure the protection of the St. Johns River. Based on the
shortcomings of the studies that have been conducted to date and the unanswered questions that
remain, no decision should be made until the above issues and concerns are addressed and fully
resolved.
BACKGROUND
The purpose of the EIS is to “examine whether navigation improvements to the existing Federal
navigation project at Jacksonville, Harbor, Jacksonville, Florida are warranted and in the Federal
interest” (p. 1) and to address the potential environmental impacts of the deep dredge of the St.
Johns River from 40 to 47-feet, which is the Locally Preferred Plan (LPP).
Thirteen miles of the river would be deepened, from the mouth of the St. Johns River to just west of
the Dames Point Bridge near Blount Island, and two areas of the channel close to Chicopit Bay and Ft.
Caroline National Memorial would also be widened. This would result in the removal of 18 million
cubic yards of dredged material. In addition, up to 56 million cubic yards of dredge material would be
removed from annual maintenance dredging over the 50-year life of the project. The report estimates
the cost of the dredging project at $684.2 million, including only $2.9 million for mitigation of
anticipated environmental impacts.
Navigation channel dredging and urban development along the St. Johns River over the past 100+
years have resulted in a deeper and wider channel to downtown Jacksonville, a distance of more than
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20 miles upriver from the river mouth. The winding, relatively narrow and often changing natural
channel in the river has been replaced with a straighter, much wider and much deeper channel
varying in depth from around 34 to 60 feet.
The "cumulative impacts" of these changes have resulted in greatly increased tidal exchanges much
further upriver with substantial increases in the range and level of salinity in the lower St. Johns River
basin. These increased salinity levels have progressively increased stress on the natural ecosystems in
the river and on the natural and human environments that depend on them.
“I do not know how much more we can do and still expect to see fish, shrimp, manatees and dolphins
in the St. Johns River. And I hope we don’t have our grandchildren asking “Why did they do that?
Didn’t they know it was harmful to the river?”
- Dr. Quinton White, Florida Times-Union, 9/26/13
HISTORY OF STATED CONCERNS
Previously, as stated in a letter dated July 31, 2013, St. Johns Riverkeeper had the following concerns
that the proposed EIS:
 Underestimated the environmental impacts
 Overstated the economic impacts
 Proposed a mitigation plan that was woefully inadequate
 Denied the public of the opportunity to engage in meaningful public participation due to the
lack of detail, depth of analysis, and critical information and data that is missing from the EIS
 Had not completed numerous studies required for a thorough evaluation
Over the next three months, hundreds of pages of newly revised documents were released that did
not track or date modifications and revisions, making it extremely difficult for the public to identify
and follow changes during the evolution of the evaluation process. As a result, the unmarked version
of the EIS discouraged public review and minimized the opportunity for our community to have a
productive dialogue.
The bottom line is that:
 Changing the river depth by the proposed magnitude will have a negative impact on the St.
Johns River and its tributaries.
 Dredging will increase salinity in the St. Johns, damaging hundreds of acres of wetlands,
submerged aquatic vegetation and trees along the banks of our river and tributaries.
 Dredging will increase bank erosion, turbidity, sedimentation and the effects of nutrient
pollution, including the frequency and possible duration of toxic green algal outbreaks.
 Dredging will alter dissolved oxygen dynamics in the St. Johns and area waterways.
 Dredging will threaten endangered species and important fisheries that live in our river.
As of October 24, 2013, St. Johns Riverkeeper still had the following serious concerns that the USACE
EIS:
 Significantly underestimated the environmental impacts, even to a greater degree than in
previous drafts
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



Continued to overstate the economic benefits while failing to address the local cost/benefit
analysis
Slashed an already woefully insufficient mitigation plan from $80 million to $3 million
Denied the public of the opportunity to engage in meaningful public participation due to the
piecemeal release of critical and often inconsistent information without tracking and clearly
dating revisions or following conventional protocol
Failed to provide a thorough and complete analysis of the potential impacts or to sufficiently
answer and resolve outstanding questions and concerns voiced by stakeholders and other
state and federal agencies
As the rightful “owners” of the St. Johns River, the public expects a thorough and honest assessment
of the potential benefits, impacts, and costs of the proposed deepening of the Jacksonville Harbor
and a transparent and open decision-making process. We cannot afford to roll the dice with the
future health of our river or invest a billion dollars in a risky and highly speculative mega-project that
has not been fully vetted.
AS OF APRIL 4, 2014, THE MAJORITY OF THE PUBLIC’S CRITICAL CONCERNS REMAIN.
UNDERESTIMATES ENVIRONMENTAL IMPACTS
Saltwater Intrusion
Unfortunately, the proposed EIS continues to suggest that we repeat mistakes of our past.
On page 170 of the EIS, the USACE acknowledges the inevitable and unavoidable harm that will occur
to the St. Johns River as a result of the deep dredge:
“The deepened channel will allow a greater volume of seawater to penetrate up the St. Johns River.
This could result in:



Increased tidal amplitude within the river and adjacent marshes
.Increases in salinity within the estuary which could:
o Impact freshwater wetlands and submerged aquatic vegetation in areas of increased
salinity.
o Change community composition and diversity of plant and animal communities in
areas of increased salinities.
o Shift the location of optimal salinities for those species with salinity preferences.
Change water residence times, which in conjunction with salinity changes could:
o Alter plankton species composition and growth patterns.
o Alter dissolved oxygen dynamics in the river main channel” (p. 170)
Salinity will move farther upstream, adversely impacting hundreds of acres of wetlands and
submerged aquatic vegetation (SAVs) and further stressing numerous trees in some sections of the
river and its tributaries, such as Julington Creek and Ortega River.
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However, the USACE analysis is flawed and incomplete, significantly underestimating the potential
threats to the health of the St. Johns River.
The EIS fails to adequately account for the impact associated with salinity increases that will occur
upstream of the channel deepening. The EIS minimizes the ecological shift in species, populations
and communities that will occur. The EIS contains inconsistencies and questionable statements
regarding the potential impacts, calling into question the accuracy of the models used to make the
predictions.
The USACE-commissioned Independent Expert Peer Review (IEPR) underscores these concerns in
their July 2013 Report:


Use of different salinity models for the main stem versus the tributary evaluations makes
evaluating salinity effects very difficult.
The analysis and presentation of salinity results in the General Reevaluation Report II (GRR2)
provide an incomplete understanding of the impacts of channel enlargement.
USACE used two different salinity models for the main stem and tributary analyses. Use of different
models for the salinity intrusion model makes evaluation unreliable.
USACE used the numerical hydrodynamic model Environmental Fluid Dynamics Code (EFDC) to assess
the direct impacts of channel modifications to salinity and water circulation. While we have
additional concerns regarding the use of the EFDC model, we first want to highlight the IEPR concerns
regarding the use of different salinity models.
The IEPR explains “The General Reevaluation Report II (GRR2) states that the tributary and marsh
salinity effects modeling… is being conducted with a MIKE hydrodynamic model (pp. 180). (The MIKE
version is not specified, but is assumed to be either MIKE21 or MIKE3.) Replacing the original model,
Environmental Fluid Dynamics Code (EFDS), with a MIKE hydrodynamic model will cause confusion
and may reduce confidence in the results already produced as described below.”
“Changing to another model requires either that the new model be validated in the main stem of the
river (a task that is already complete for EFDC), or that the boundary conditions be matched at
awkward interior locations. Either choice adds time and cost to the study. It will also confuse salinity
intrusion issues and raise questions concerning how the EFDS and the new model results compare
and, if they are different, which results are correct. These and other questions will impede decisionmaking in mitigation studies and adaptive management. “(IEPR – pg. A-5)
We agree with the IEPR that “using a different model for the tributary salinity and marsh modeling is
ill-advised, “and “provides an incomplete understanding of the impacts of channel enlargements.”
Within the EIS, this point is also made on page 58 of Attachment M:
“The model underestimation of the salinity measurements at Station NSJ200015 is due to the low
salinity input provided by the USACE EFDC model at the mouth of the Ortega River. The model
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estimates well the very low salinity regime at the Ortega River Upstream Stations OR 434 and
20030349 but underestimates the episodic salinity spikes in the range of 4-6 ppt.”
“Notably, the absence of more frequent and detailed lateral inflow, water level, and salinity
measurements limits validation of the model to calibration and verification to observed salinity
range.”
The IEPR summarizes this concern: “Changing to any other model raises the a question, if EFDC was
the most appropriate choice for the St. Johns River circulation and salinity modeling, it is unclear why
it is not the most appropriate model choice for the extension of that study into the tributaries. In
essence, changing models reduces confidence in the earlier decision to us EFDC and, therefore,
reduces confidence in its results.”
In addition to the concern regarding inconsistent models, the EIS uses averages, subjective
assumptions and high-risk models to downplay the impact of the deep dredge.

“The evaluation of the project alternatives’ effects on natural communities as a result of the
movement of higher salinity water upstream in the LSJR and tributaries relies on the use of
hydrodynamic and ecological models. The hydrodynamic model reports (Taylor 2011, 2013b,
2013c) present error statistics for the EFDC and CE-QUAL-ICM models. Similar error statistics
cannot, however, be calculated for the ecological models. This represents an uncertain risk
associated with evaluation of the ecological model results.” (p. 256)

“Recorded conditions for streamflow, rainfall, land use, and other factors during a six-year
period (1996 – 2001) provide input data for the hydrodynamic models. Future condition
hydrodynamic model simulations further rely on assumptions about the rate of sea level rise,
quantity of water withdrawal from the middle St. Johns River, patterns of land use, and other
factors. Actual conditions will deviate from those used to drive the models. These deviations
introduce additional uncertainty in the models’ ability to predict future conditions and impacts.
“ (p. 256)

“The deepened channel will result in the movement of higher saline water farther upstream.
The magnitude of upstream movement increases with increase in project depth. The change
in salinity will shift the northern boundary of SAV upstream. Sections 7.3.7 -7.3.12 discuss the
magnitude of these effects for different project alternatives.”(p. 253)
The EIS dismisses project-related increases in salinity as being much smaller than those natural
variations in salinity that the river naturally experiences. While it is true that salinity levels naturally
change by drought, etc., these changes are acute and the river biota is adapted to them. The projectrelated increases are chronic; i.e., long-term. They shift the baseline condition to a higher-saline
regime such that acute, short-term natural changes in salinity have greater impact. In addition,
forested wetlands are impacted by very small changes in salinity and those impacts may take years to
see.
It is not scientifically acceptable or dutifully responsible to normalize the dredging’s long-term
predicted changes by natural short-term changes, particularly in regard to salinity and water levels.
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A uniform approach to calculate the risk of saltwater intrusion is necessary before a decision is made
to dredge the St. Johns River including:


Verification of model by calculating historic salinity changes due to previous dredging projects
in the St. Johns River.
Use consistent salinity models while addressing risks to the St. Johns and its tributaries.
Habitat Loss
Critical habitat for fisheries and wildlife will be lost.
Progressive increases in salinity in the river system over the past 100 years following past dredges of
the St. Johns have significantly stressed and altered the river ecosystem. Marine ecosystems have
been completely changed in some areas and stressed in many others, resulting in negative impacts to
the ecology of the river and commercial/recreational fishing.
The EIS states the following:

“Based on hydrodynamic modeling performed to evaluate salinity changes associated with
deepening the navigation channel, the recommended plan may cause average salinity levels in
that portion of the St. Johns River affected by the project to increase slightly, resulting in an
upriver shift of salinity breakpoints. The expected effect of such changes would be a shift in
wetland species composition and changes in distribution of wetland communities, although
uncertainty exists about the magnitude of both the effect of deepening on salinity and the
ecological response to changes in salinity. Such changes may also affect other ecological
resources, including fish and invertebrate species found in the river.” (p. vi)

“Salinity changes may modify the biological community, altering or eliminating vegetative
composition (i.e. SAV or wetlands) and thus altering or eliminating habitat for species using
those communities. Species composition may in general shift to more salinity tolerant species.
Species that depend on specific salinities in specific habitats may encounter inappropriate
salinities in otherwise acceptable habitat or if using salinity as a cue to seek specific habitats,
move away from appropriate habitat if salinity optimum for the species under consideration
occurs in less of the optimum habitat. Changes in the length of time water remains in the river
system may change phytoplankton dynamics and may slightly increase the potential for algal
bloom development.” (p. 188)

“Fishes and macroinvertebrates likewise will see an upstream shift towards higher salinity
levels in the area of effect. It is conceivable that there would be a reduction in habitat
utilization for freshwater fish and macroinvertebrates in the future with a near equal increase
in habitat utilization for those that are adapted to estuarine conditions. This change would
likely occur regardless of the proposed project, with SLR likely being the major contributor
towards the upstream shift to higher salinity levels. Cumulatively, however, there could be
some intensification caused as a result of the project. Assessment of potential salinity – fish
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population relationships, when completed (June-July 2013), may provide a more detailed
evaluation of potential long-term effects. “(p. 250)

“Potential fisheries impacts to freshwater species may occur due to salinity changes that
reduce freshwater and low salinity zones and increase higher salinity zones. Losses of SAV
from increased salinity would result in lower quality habitat for a wide variety of fish species.
Changes in circulation patterns may result in potential for phytoplankton blooms and
resultant declines in dissolved oxygen (SJRWMD Chapter 12).” (p. 218-219)

“Expansion of habitats for estuarine and marine plant and animal species will occur at the
expense of salinity intolerant species.” (p. 252)
Risks and the necessary requirements for protecting critical habitat must be fully understood before a
decision is made to dredge the St. Johns River.
Sedimentation
USACE’s river channel sedimentation model does not provide necessary information to establish
environmental effects for sedimentation.
The proposed deepening – be it at 45-ft or 47-ft -- will clearly have a significant impact upon the
river’s hydraulic and sedimentation patterns which is not adequately discussed in the EIS. By
increasing the hydraulic efficiency of the channel in the center of the river, both the tidal and riverine
flow will become increasingly concentrated to the middle of the river, further changing the flow
patterns along the banks and side-channels. This effect is not adequately examined or described in
the EIS. The cell size of the numerical models is, as admitted in the EIS, too large to discern changes in
currents at specific locations. Also, the report principally considers changes in sedimentation and flow
that affect navigation – not the overall condition of the river, particularly the banks and streams.
The IEPR also warns of the shortcomings of the USACE Sedimentation Review.
“The adaptive hydraulics (ADH) sediment modeling results do not provide a reliable estimate of the
annual sedimentation rates necessary to establish environmental effects and sediment
management requirements.” Pg. A-7
The IEPR continues:
Standard sediment transport model validation consists of comparing deposition and erosion
rates and/or suspended solids concentration between model and prototype (field)
observations for a representative time period (Thomas and Chang, 2007; Ganju and
Schoellhamer, 2009). Invalidated sediment models are suitable only for sensitivity studies and
preliminary examinations.
Figure 27 (Appendix A, Attachment G) shows observed and modeled ending bed elevations,
but not starting bed elevations for either, so the observed sedimentation rate is indiscernible.
Therefore, the ADH model validation is limited to a comparison of final bed elevations (instead
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of deposition rates) for a single 3-month period that was not shown to be representative of
expected river conditions.
The model also used a single 3-month period to predict sedimentation rates for the existing
channel and the 46-foot channel. Because the period was not shown to be representative of
typical conditions and the model is not considered validated, the results are assumed to be
unreliable indicators of future conditions.
Given the above observations, the General Reevaluation Report II (GRR2) ADH model
predictions of sedimentation rates are considered insufficient for estimating dredging
requirements, benthic burial rates, or changes in suspended sediment concentrations in the
river. For these reasons, they cannot be used to identify or evaluate mitigation and adaptive
management measures.
A validated sedimentation model is needed before a decision is made to dredge the St. Johns River.
Rising Sea Levels
USACE implies in the EIS that sea level rise (SLR) is occurring more quickly than previously thought,
yet the USACE primarily evaluates the effects of the minimum value for SLR and never considers
either the Intermediate or the worst-case scenario. The EIS should be evaluating the worst case and
most likely scenarios, and yet the USACE instead focused on the most optimistic scenario that might
be expected. The EIS also uses outdated values for the Baseline, Intermediate, and High SLR
estimates, since the version of EC 1165-2-212 used in the EIS expired September 30, 2013. By using
these lower values instead of those in the updated version, the USACE further underestimates the
potential impacts from SLR in the EIS. This also further minimizes the overall projected impacts, since
the impacts from the dredging are expected to exacerbate and expedite the inevitable effects of SLR.
We maintain that the Corp of Engineers has not sufficiently considered sea level rise in the use of
their models. While the Corp did consider as to whether the project impacts sea level rise at the
Baseline, Intermediate, High and Extreme scenarios, sea level rise scenarios beyond the Intermediate
scenario (.39 feet) were not considered in any further environmental models. The cumulative impacts
of port expansion AND SEA LEVEL RISE in the High and Extreme scenarios were therefore not
considered in evaluating salinity, wake erosion, or any of the other hydrodynamic models.
Furthermore, the model used to predict the effects of sea level rise fails the “best available science”
test, as it is only an inundation model. As the wetland ecosystems expected to be impacted by sea
level rise are, by definition, inundated, the Corps’ Sea Level Rise model cannot predict changes to
those wetlands, and therefore has no capacity to predict the cumulative impacts of port expansion
and sea level rise on those ecosystems. SLAMM (Sea Level Affecting Marshes Model) is readily
available and utilized by a number of federal and state agencies and is actively promoted for use by
both the Fish and Wildlife Service and the National Oceanic and Atmospheric Association. Yet,
wetlands ecosystem modeling for sea level rise was not done. This is problematic as the composition
and make-up of the wetlands around the LSJR is radically different under the different sea level rise
scenarios. While it is easy to say, comparatively, that sea level rise will impact the LSJR more than the
port expansion, the Corp cannot say, with the work conceived thus far, that the wetland ecosystems
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in the study area will not be impacted by the port expansion under the different sea level rise
scenarios. The work has not been sufficiently completed. To summarize, the Corp cannot say to have
performed necessary due diligence by having modeled just the SLR scenario, because the changes to
the river ecosystem between the baseline and extreme scenarios are so large the river is
fundamentally different in each scenario.
The unintended consequences and cumulative impacts of more than 100 years of dredging the St.
Johns River have not been adequately considered in the current or past environmental studies. A
deeper channel will make Jacksonville and the lower St. Johns much more vulnerable to the impacts
of ongoing sea level rise.
A more precise sea level rise model, such as SLAMM (Sea Level Affecting Marshes Model), must be
utilized before a decision is made to dredge the St. Johns River.
Offshore Dredged Material Disposal
The proposed offshore disposal area is not clearly defined in the EIS. The present offshore disposal
area has less than 4 million cubic yards of capacity, yet the project requires disposal of about 18
million cubic yards. A proposed expansion of the offshore disposal area has not yet been approved,
and its draft design is sited very close to the existing offshore sand borrow area for the Duval County
federal shore protection project.
”The use of another, new ODMDS in the Atlantic Ocean off the Jacksonville coast will also result in
potential impacts as the site is used repeatedly to dispose of dredged material from maintenance
operations. These impacts can be avoided and minimized by using best management practices
defined by the federal agencies responsible for these resources, including seasonal avoidance of site
use and ship operation to avoid impacts with threatened and endangered species.” (p. 252)
EPA made multiple comments in their July 2013 letter regarding ODMDS Impacts including:
“EPA recommends the final SEIS address the Marine Protection, Research and Sanctuaries Act
Requirements. All dredged material from this project must be evaluated and determined to be
suitable for ocean disposal if it is to be disposed at the new Jacksonville ODMDS, and EPA must
concur with the USACE’s compliance determinations. EPA also recommends the SEIS discuss what
testing is likely to be performed and when. Additionally for material not meeting the ocean disposal
criteria, EPA recommends the final SEIS discuss where it will be disposed, including whether the
project will maintain its feasibility if a portion of the material fails to meet the ocean disposal
criteria… In the area of the proposed action, there have been incidences of dredged material failing to
meet the ocean dumping criteria....Consequently, EPA notes a potential for adverse effects on aquatic
environments of dredged material does exist."
We remain concerned about the lack of sufficient information regarding the disposal methods,
locations, and testing of the dredge material.
The plan for disposal and testing of the dredge material is needed before a decision is made to
dredge the St. Johns River.
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NATIONAL ENVIRONMENTAL POLICY ACT (NEPA) CONCERNS
NEPA requires federal agencies to thoroughly and objectively investigate, evaluate, and disclose
environmental consequences associated with any major federal action to foster informed decisionmaking. NEPA also requires the environmental impact statement to serve as an “environmental full
disclosure law so that the public can weigh a project’s benefits against its environmental costs.” Nat’l
Audubon Society v. Hoffman, 132 F. 3d 7, 12(2d Cir. 1997)
If the EIS does not fully consider all reasonably foreseeable, significant, and adverse impacts of the
proposed deep dredge, the USACE is shortchanging this community and the St. Johns River and is in
violation of NEPA and its regulatory obligations.
Lack of Review of Cumulative Impacts
Previous dredging and navigational changes to the St. Johns River have progressively increased the
salinity levels, degraded water quality and accelerated shoreline erosion. These unintended, longterm "cumulative impacts" have not been adequately considered in past studies. The USACE EIS must
address cumulative impacts on the river system and potential mitigation options, not just the
incremental difference between the existing channel and the proposed deeper channel.
The USACE has worked to identify and correct the unintended consequences that South Florida flood
drainage canals and related land development efforts have had on the Florida Everglades ecosystem.
A comparable effort is needed to help maintain important tidal and freshwater ecosystem functions
in North Florida and the St. Johns River.
Under NEPA, USACE is required to thoroughly assess the cumulative effects of the proposed deep
dredge. NEPA’s implementing regulations define cumulative effects as “impacts on the environment
which result from the incremental impact of the action when added to other past, present, and
reasonably foreseeable future actions regardless of what agency (federal or non-federal) or person
undertakes such other actions.” 40 C.F.R. §1508.7
A full review of cumulative impacts must be conducted before a decision is made to dredge the St.
Johns River.
Fails to Consider Alternatives
The EIS is fundamentally deficient in consideration of other engineering alternatives for project
design. It is acknowledged that the overall length of the considered deepening project was initially
decreased from about 20 miles to 13 miles at the outset of the evaluation. However, there is no
discussion of other possible, shorter project lengths that may further reduce environmental impacts
and costs while achieving optimum benefits. There is no discussion of alternative construction
methods that may mitigate long-term environmental impacts. Overall, the engineering analysis was
limited to a narrow range of alternatives: i.e., deepening to various depths along a fixed channel and
quasi-fixed methods of dredge disposal.
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MITIGATION PLAN WOEFULLY INADEQUATE
The mitigation plan is woefully inadequate, failing to offset the damage that will be incurred from
the dredging.
The EIS estimates that nearly 395 acres of wetlands and 180 acres of submerged aquatic vegetation
(SAVs) are expected to be impacted from changes in salinity, but, as stated above, the extent of the
damage may be much worse.
Much uncertainty exists as stated in the EIS Executive Summary:

“Based on hydrodynamic modeling performed to evaluate salinity changes associated with
deepening the navigation channel, the recommended plan may cause average salinity levels in
that portion of the St. Johns River affected by the project to increase slightly, resulting in an
up-river shift of salinity break-points. The expected effect of such changes would be a shift in
wetland species composition and changes in distribution of wetland communities, although
uncertainty exists about the magnitude of both the effect of deepening on salinity and the
ecological response to changes in salinity. Such changes may also affect other ecological
resources, including fish and invertebrate species found in the river.” (p. vi)
The May 2013 mitigation plan to offset the anticipated damage to the river was woefully inadequate.
The previously proposed mitigation plan would simply not have reversed the harm that will result
from the dredging nor provide a net benefit or improvement to the St. Johns River.
Unfortunately, the USACE has slashed the mitigation budget from $80 million to $2.9 million.
The EIS does propose monitoring for “model verification.” The stated intent of USACE is to verify
their model AFTER THE HARM IS DONE TO THE ST. JOHNS with no guarantee of any mitigation. This is
simply unacceptable to use the St. Johns as a guinea pig without guarantee of corrective action. The
corrections will only be CONSIDERED if it is proven that damage results from the dredging project,
and not sea level rise or other influencing factors, which USACE admits would be extremely difficult
to discern.
The IEPR also identifies the weaknesses of the limited mitigation plan:
“The Mitigation and Adaptive Management Plans generally lack specific success criteria,
thresholds, standards, and procedures that reinforce the commitment to mitigating for
environmental impacts.”
“The Adaptive Management Plan does not include key elements such as trigger thresholds
and specific actions to correct deficiencies.”
“The Adaptive Management Plan and the Monitoring Plan will govern how the project sponsor
satisfies relevant permit conditions for the life of the project so the information should be
clearly identified, comprehensible, and easily found.”
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A much more proactive and comprehensive mitigation plan that includes fully developed
commitments, criteria, and threshold triggers must be developed before a decision to dredge the St.
Johns is made.
Corrective Action Falls on Local Entities
In Appendix D, Page V of the Environmental Impact Statement it states that “Annual variability and
long-term increases in salinity due to sea level rise and water withdrawal will have greater effects on
the LSJR ecological communities than the proposed deepening project. The effects from the long-term
salinity changes occurring independent of the proposed project may obscure smaller, project-related
effects.” We do not deny that sea level rise, surface water withdrawals and other human impacts will
further aggravate the impacts of port expansion or that the Corps is limited to the “best available
science” due to the fast-tracking. However, this statement still belies the underlying issue that
there’s no guarantee the Corp will be able to assess their own impacts given the magnitude of the
other potential outside impacts to the river. Yet, those impacts may still happen, detected or not. In
those tributary systems most likely to be impacted, such as Black and Julington Creek, responsibility
for the health of the wetlands falls on the state, counties, and even private landowners. Costs of
management and restoration will therefore fall on local entities, and in the case of Clay, St. Johns
County and private landowners, to non-direct beneficiaries of the port expansion. Even if the Corp is
able to assess for port impacts, because funds are not currently allocated for those impacts, the cost
will still likely fall on local entities, as invasive species are likely to colonize stressed habitats faster
than Congress approves budgets. In other words, all the risk and potential costs of environmental
damage resulting from the port expansion could fall to local entities with no guarantee of federal
support.
FLAWED AND INSUFFICIENT ECONOMIC ANALYSIS
The federal and local economic interest has not been demonstrated and verified, as required by
Federal Law.
“The idea that the Panama Canal will instantly bring more business to the Eastern Seaboard is an
‘urban myth.’ Whatever business the Atlantic ports could easily take from Los Angeles and other
Pacific cities has already moved east.” (John Martin, JAXPORT’s Consultant - The Dallas Morning
News, Feb, 2012).
Even though the economic component of this project is not SJRK’s primary focus, the potential
economic benefits that could be reasonably expected must be accurately assessed, if we, the
community, are to adequately assess the pros and cons and make an informed decision.
The deepening of navigation channels does not increase world trade. To propose an over-abundance
of deeper navigation channels along the U. S. East Coast, given the substantial costs and
environmental impacts associated with dredging, is not a well-developed strategic position. The
USACE planning process includes no consideration of broad regional economic or environmental
issues. It seeks to evaluate deepening at every port on an individual basis in the absence of any
regional or national strategy. This will lead to aggressive competition that could potentially drive
down port fees to the point where it is not feasible to achieve an acceptable return on investment.
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The USACE responded to this previously stated concern by saying that “reduced port fees due to
competition have no bearing on the economic analysis.”
However, the Independent Expert Peer Review expresses grave concern over the lack of a multi-port
analysis as a “showstopper” issue.
The IEPR listed the lack of a multi-port analysis of “high” significance. Criteria for “High Significance”
are defined as follows:
Describes a fundamental problem with the project that could affect the recommendation,
success, or justification of the project. Comments rated as high indicate that the Panel
analyzed or assessed the methods, models, and/or analyses and determined that there is a
“showstopper” issue.
The IEPR lists the lack of a multiport analysis as a concern of high significance.
Federal interest has not been demonstrated in the General Reevaluation Report II (GRR2)
because a multi-port analysis assessing competition among regional ports is not provided.
A system-based (multi-port) approach to navigation economic analysis that demonstrates how
national resources are efficiently allocated to navigation projects is not included in the
documents provided for review. This type of analysis would assess and prioritize national
needs of port development and expansion. It would take into account geographic, intermodal,
and cost issues to determine which U.S. east coast ports require deepening in order to
accommodate the anticipated increase in deeper-draft vessel traffic associated with the
expansion of the Panama Canal.
During the scoping process, a commenter asked whether there would be an analysis showing
the hierarchy of ports (GRR2, p. 302, fourth bullet). In response to that comment, USACE
indicated that a multi-port analysis would be conducted.
Although USACE committed to the multi-port analysis, it has not been conducted, and therefore,
USACE has not proven that the deep dredge of the St. Johns is in the federal interest as required by
Federal Law.
In addition, economic methods and assumptions are not adequately documented.
The IEPR identified the following shortcomings:
Accurate and documented commodity and fleet forecasts and total voyage costs are essential
for calculating transportation cost savings and benefit-to-cost ratios and for selecting a
recommended plan. The documents provided for review do not describe: (1) the methods and
assumptions used to develop the commodity and fleet forecasts; (2) the methods and
assumptions used to calculate total voyage costs by trade route; and (3) the variables and
assumptions incorporated into the HarborSym model simulations. The Panel is thus unable to
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determine whether the commodity and fleet forecasts and the total voyage costs accurately
reflect future conditions in the study area. These calculations could significantly impact the
findings and understanding of the economic analysis.
According to Appendix B, Section 3.3, the commodity and fleet forecasts are based on Global
Insight (GI) and Maritime Strategies International (MSI) forecasts, respectively. Descriptions of
methods and assumptions used to develop these forecasts are not provided, and the GI and
MSI reports are not cited in the references.
Commodity and Fleet Forecasts. The Panel finds a discrepancy between stated commodity
growth rates and projected increases in commodity movements. For instance, in Table 22 of
the General Reevaluation Report II (GRR2), growth rates for the FE-ECUS-PAN trade route are
stated as 10.27% for 2010-2020 and 3.67% for 2020-2060 (the table does not indicate
whether growth rates are annual or for the total period). However, in Tables 19 and 23 of the
GRR2, the number of 20-foot equivalent units (TEUs) projected to move through the port on
that route increase by 184% from 2010-2020, 79% from 2020-2030, 30% from 2030-2040, and
31% from 2040-2050.
Assumptions associated with the transition of the Jacksonville with-project fleet to postPanamax vessels (Appendix B, Table 3-8) over the period of analysis are not provided.
Total Voyage Costs. The methods and assumptions used to develop total voyage costs for
each trade route/vessel class (i.e., vessel time at sea, idle and productive port times, with- and
without-project cargo handling, transfer, and in-port charges, Panama versus Suez canal toll
costs, etc.) are not provided.
Total transportation costs (mean, standard deviation, median, min, max, etc.) are only
presented in aggregate, by alternative channel depths. Details used to develop the total costs,
such as total transportation costs by trade routes, are not provided.
Cost savings attributable to the individual components of the project (i.e., channel deepening,
channel widening, turning basins, and reduced congestion) are not provided.
A lack of understanding of the methods and assumptions used to calculate the National
Economic Development (NED) benefits affects the calculation of the benefit-to-cost ratio
and the selection of the recommended plan.
The federal and local economic interest must be demonstrated and verified, as required by Federal
Law.

A multi-port analysis must be completed and verified before a decision is made to dredge the
St. Johns.

Verification of the methods, assumptions and critical parameters used to calculate the
National Economic Development (NED) and the benefit-to-cost ratio must be conducted
before a decision is made to dredge the St. Johns River.
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WE ARE OPPOSED TO THE DEEP DREDGE OF THE ST. JOHNS RIVER
For the above reasons, St. Johns Riverkeeper, Florida Wildlife Federation, North Florida Land Trust,
Public Trust Environmental Legal Institute of Florida, Inc. and Sierra Club Northeast Florida Group
oppose the proposed deep dredge and the continuation of this project as it currently stands. Further
review and a more comprehensive analysis are necessary to adequately determine the economic
viability of the proposed dredging and ensure the protection of the St. Johns River.
Based on the shortcomings of the studies that have been conducted to date and the unanswered
questions that remain, no decision should be made until these issues and concerns are addressed and
fully resolved.
1. A uniform approach to calculate the risk of saltwater intrusion is necessary before a decision is
made to dredge the St. Johns River including:
a. Verification of model by calculating historic salinity changes due to previous dredging
projects in the St. Johns River.
b. Use consistent salinity models while addressing risks to the St. Johns and its
tributaries.
2. Risks and the necessary requirements for protecting critical habitat must be fully understood before a
decision is made to dredge the St. Johns River.
3. A validated sedimentation model is needed before a decision is made to dredge the St. Johns
River.
4. The use of a more precise sea level rise model, such as SLAMM (Sea Level Affecting Marshes
Model) must be used.
5. The plan for disposal and testing of the dredge material is needed before a decision is made to
dredge the St. Johns River.
6. A full review of cumulative impacts must be conducted before a decision is made to dredge
the St. Johns River.
7. A much more proactive and comprehensive mitigation plan that includes fully developed
commitments, criteria, and threshold triggers must be developed before a decision to dredge
the St. Johns is made.
8. A multi-port analysis must be completed and verified before a decision is made to dredge the St.
Johns.
9. Verification of the methods, assumptions and critical parameters used to calculate the
National Economic Development (NED) and the benefit-to-cost ratio must be conducted
before a decision is made to dredge the St. Johns River.
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It is the responsibility of USACE to provide the public a thorough and honest assessment of the
potential benefits, impacts, and costs of the proposed deepening of the Jacksonville Harbor and a
transparent and open decision-making process. Anything less, fails to meet the minimum thresholds
set by Federal Law.
USACE fails to adequately assess the environmental impacts, fails to provide a beneficial mitigation
plan to offset harm to the St. Johns and its tributaries, and fails to articulate the need for this project.
We cannot afford to roll the dice with the future health of our river or invest a billion dollars in a risky
and highly speculative mega-project that has not been fully vetted.
St. Johns Riverkeeper, Florida Wildlife Federation, North Florida Land Trust, Public Trust
Environmental Legal Institute of Florida, Inc. and Sierra Club Northeast Florida Group strongly urge
USACE to abandon this expensive, unsustainable, unnecessary and environmentally destructive
project.
For the River,
Lisa Rinaman
St. Johns Riverkeeper
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St. Johns Riverkeeper, Inc. • 2800 University Boulevard N. • Jacksonville, FL 32211 • 904.256.7591