September 7, 2010
Terri Jordan-Sellers
Planning Division
USACE Jacksonville
701 San Marco Blvd
Jacksonville, FL 32207
Re: Draft Environmental Assessment
Section 227/2038 National Shoreline Erosion Control Development Program
Submerged Artificial Reef Training Structure – Miami-Dade County, Florida
Dear Ms. Jordan-Sellers:
We are writing, as representatives of the Surfrider Foundation Miami Chapter, to convey
our opposition to the proposed Submerged Artificial Reef Training Structure (Structure)
cited in the referenced Draft Environmental Assessment (Draft EA) developed by the
U.S. Army Corps of Engineers (USACE). We herein present our specific comments
relative to significant impacts associated with the proposed Structure, and the alternatives
evaluated in the Draft EA. Please consider the following:
Significant Impacts: Significant adverse impacts to the environment are expected due to
the Structure creating the following:

Cultural impacts: As the Structure is intended to reduce wave energy in its lee,
the Structure would alter the esthetic character of the beach including
diminishment or elimination of the viability of recreational beach uses associated
with the natural breaking of waves along a sandy beach - such as surfing, other
wave riding activities, and the associated esthetics of waves. The potential future
applications of a comparable Structure would lead to significant cumulative
adverse impacts in other locations. The Draft EA should recognize these cultural
impacts.

Attractive Hazard: Miami Beach is a significant national destination for
recreational beach use. The Structure is proposed close to shore - in close
proximity to existing buoys that demark the customary limits of beach swimming.
Due to a paucity of attractive snorkeling venues in the Miami Beach area, the
proposed structure will attract swimmers and snorkelers to enter the waters
around the Structure to view the sessile organisms and fish expected to colonize
the Structure. Due the shallow depth of the top of the Structure (-1.5’ MLLW),
swimmers and snorkelers will be subject to the effects of waves and currents that
may wash swimmers/snorkelers onto the Structure where they can become
battered or trapped - causing injury or death. This impact does not appear to be
addressed in the Draft EA.
Draft EA - Submerged Artificial Reef Training Structure – Miami-Dade County, Florida
September 7, 2010
Page 2 of 5

Downdrift Beach Erosion: Section 1.3 of the Draft EA (“PROJECT NEED OR
OPPORTUNITY”) cites that: “The proposed SMART structure is designed to
help dissipate wave energy in order to stabilize the identified ‘Hotspot erosion
area’ and help prevent storm damage.” However, in theory, along sandy beaches,
long-term erosion, such as at the reported “hot spot”, is primarily caused by an
increase in littoral drift along the shoreline, where less sand enters the “hot spot”
beach segment than the amount of sand that leaves the beach segment – per the
fundamental principle of the Conservation of Mass. Based on this principle, in
theory, breakwaters:
o are intended to reduce littoral drift to trap or prevent erosion of a volume of
sand causing accretion or reduced erosion along the updrift shoreline
and/or in the lee of each breakwater, and
o increase erosion of the downdrift beach by preventing an equivalent
volume of sand from moving into the downdrift beach.
This expectation of downdrift erosion is reflected in the report titled “Letter
Report: GENESIS Modeling Study of Reefball Breakwater, Miami Florida 227
Project” – obtained from the website of the Florida Department of Environmental
Protection (FDEP) per the FDEP permit application filed by the USACE. This
report predicts updrift accretion and downdrift erosion as reflected in the figure
(from the report) below for various potential wave transmission coefficients.
Also note that:
o The report employs the USACE model GENESIS, for which the predicted
shoreline response (per the figure above) is predominantly of a lesser
magnitude than the accuracy of the model as reflected in the “calibration”
and “verification” cited in the report.
o The report states “…the shoreline is predicted to be in approximately the
same position with the beach fill and the breakwater as it would be
Draft EA - Submerged Artificial Reef Training Structure – Miami-Dade County, Florida
September 7, 2010
Page 3 of 5
without the fill and the breakwater.” This statement appears to reflect
minimal expectations of the proposed Structure and the potential for a
similar outcome for the “No-Action” alternative.
The expected downdrift beach erosion would adversely affect human environment
and sea turtle nesting habitat; these impacts should be reflected in the EA.

Economic Impacts: The Structure is proposed as an Experimental Project, but
there appears to be no reasonable expectation of benefits from the project as
indicated above. As a result, it is expected the Structure would result in the
useless expenditure of federal funds that could more appropriately be used to
benefit the U.S. economy and environment. The economic impact of a likely
failed Structure – including the cost of construction and removal - should be
included in the EA.

Cumulative Impacts: Section 4.22 of the Draft EA cites: “If the proposed action
performs as modeled and expected, further use of these features could be
appropriate for Miami-Dade County and other similar coastal areas.” As indicated
above, the expectations cited in the EA are inconsistent with the expectations
cited in the GENESIS model Letter Report. The intended determination of the
Structure performance appears to be identified in the document titled “Test Plan
Section 227 National Shoreline Erosion Control Development and Demonstration
Program 63RD Street ‘Hotspot’ Miami Beach, Dade County, Florida” – obtained
from the FDEP website. This Test Plan does not appear to reflect assessment of
updrift and downdrift beaches, but appears to provide a basis for a determination
of Structure “success” leading to the potential for proliferation of similar
structures (per Section 4.22 of the Draft EA) with corresponding cumulative
significant adverse impacts as cited above. These potential cumulative effects
should be included in the EA.
Alternatives: In general, the draft EA does not adequately address the proposed
Structure or other alternatives as described below:

Structure: Section 1.4.1 of the Draft EA cites: “Objectives of the 63rd Street
Hotspot Miami Beach, Florida, and Section 227 / 2038 project are to retain sand
without causing impacts to adjacent shorelines, to maintain and preserve
environmental habitat, and protect the shoreline when exposed to the combination
of storm surge and design wave events with a 10-year return interval.” However,
(a) the GENESIS model Letter Report appears to indicate the Structure will cause
adverse impacts to adjacent shorelines” – as described above, and (b) the EA
appears to present no assessment of the structure effects during a 10-year storm
event when storm surge is expected to result in elevated water or free board
“freeboard” above the Structure.
Draft EA - Submerged Artificial Reef Training Structure – Miami-Dade County, Florida
September 7, 2010
Page 4 of 5
In addition, during storm events, the proposed breakwaters have the potential to
increase erosion in the lee of the breakwaters per prior studies as identified in
studies by Ranasinghe et al, which indicate reefs or submerged breakwaters
placed too close to shore can cause erosion [Ref: Ranasinghe, R., I. Turner and G.
Symonds 2006. “Shoreline response to multi-functional artificial surfing reefs: A
numerical and physical modeling study.” Coastal Engineering, 53: 589-611]. The
figure below presents results of numerical and physical modeling tests conducted
by Ranasinghe et al - “proposed as a preliminary engineering tool to evaluate the
potential shoreline response to submerged structures”, where:
Sa = Distance offshore to Apex of Structure
SZW = Natural Surf Zone Width
B = Alongshore Structure Width
Y = Magnitude of Shoreline Response
As cited in the Ranasinghe et al study and as reflected in the figure below:
“Shoreline accretion (i.e. salient growth) can be expected when Sa/SZW>1.5,
regardless of wave incidence direction. However, the width of the salient will be
smaller under oblique wave incidence. Conversely, if the structure is very close to
the shoreline (Sa/SZW<1), the shoreline will erode regardless of the direction of
wave incidence.” Both (a) the effectiveness of the proposed structure during a 10year storm event and (b) the potential to induce erosion in its lee – should be
addressed in the EA.

Other Alternatives: Section 2.1.2 of the Draft EA cites: “The no-action alternative
does not provide the benefits needed to protect the coast from the effects of
erosion and storm damage over the long-term, nor the means for sustainable use
of available sand sources. The no-action alternative may result in more frequent
renourishment events within the footprint of the proposed SMART structure”.
These statements appear unfounded as the Draft EA does not appear to provide
any quantitative assessment of these benefits with or without the Structure. Based
upon the expected effects from the GENESIS model results – as identified above,
it appears that “No Action” may be a viable alternative. The EA does not appear
to reasonably consider other alternatives to avoid or minimize the significant
adverse impacts associated with the proposed Structure. Further evaluation of the
“No Action” alternative and other alternatives appears warranted.
Draft EA - Submerged Artificial Reef Training Structure – Miami-Dade County, Florida
September 7, 2010
Page 5 of 5
In summary, we contend that the proposed Structure does not comply with the provisions
of the National Environmental Policy Act (NEPA) in that the Structure:
(1) does not provide for provide for preservation of the “environment for succeeding
generations” – in that the Structure is expected to unnecessarily produce adverse
impacts without any apparent net benefit;
(2) does not “assure for all Americans safe, healthful, productive, and esthetically and
culturally pleasing surroundings” – in that the Structure is expected to be diminish
the cultural esthetics of the beach and be an Attractive Hazard;
(3) does not “attain the widest range of beneficial uses of the environment without
degradation, risk to health or safety, or other undesirable and unintended
consequences” – in that the Structure is expected to cause erosion and
“degradation” of the downdrift beaches, and the Draft EA does not reasonably
address other alternatives, which appear to have less impacts and reasonably
meet the overall objectives;
(4) does not “preserve important historic, cultural, and natural aspects of our national
heritage, and maintain, wherever possible, an environment which supports
diversity and variety of individual choice” – in that the Structure would alter the
esthetic character of the beach and adversely impact cultural uses such as surfing,
and potential future applications of a comparable Structure would lead to
significant cumulative adverse cultural impacts;
(5) does not “achieve a balance between population and resource use which will
permit high standards of living and a wide sharing of life’s amenities” - in that the
Draft EA does not adequately assess alternatives nor reasonably characterize any
“balance between population and resource use”, and
(6) does not “enhance the quality of renewable resources and approach the maximum
attainable recycling of depletable resources” – in that the Structure does not
appear to provide for any reduction in the need for beach nourishment but simply
rearranges the area where future nourishment will be needed.
Based upon the above, we respectfully request that the (USACE) abandon the proposed
Structure, or, if not abandoned, elevate the proposed Structure to the appropriate review
of an Environmental Impact Statement. Thank you for considering the public interests
represented by the Surfrider Foundation.
Sincerely,
Surfrider Foundation
Mike Gibaldi
Miami Chapter, Chairman
cc:
Ericka Davanzo – Surfrider Foundation
Brian Flynn – Miami-Dade DERM
Steven MacLeod – FDEP Bureau of Beaches and Coastal Systems
Michael Walther – Coastal Tech