November 12, 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:
The Surfrider Foundation Miami Chapter would like to provide additional comments
based upon information received by reaching out to coral scientists and researchers
throughout the globe. This information continues to support 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). Please consider the following prior to your finalization of the EA as the
USACE is may not be accurately characterizing what it expects to see growing on the reef balls:
Types of marine life we could expect to naturally reside in a reefball reef here
1) A thriving coral community will not grow naturally on the reefballs in a modest period
of time (less than 15 years) without transplanting coral clippings from other locations.
This would require additional experts, permitting, money, and time to get the outcome
that is suggested by the USACE.
2) The current environment of our marine area will likely provide mainly algae, stinging
nettles and fire coral to grow naturally on the reef balls. All are unintended and unwanted
residents of a tourist attraction.
3) Reefball artificial reefs deployed throughout the globe have mixed results. It seems in
low wave energy environments that can work well. However in locations where there is
at least occasional periods of higher energy wave action, like South Florida, the breaking
waves over the reefballs act to scour out sand behind the line of reefballs and create a
trench behind this line. Also, accumulating sand as designed for this project will steal
sand from somewhere, and from someone else’s beachfront property.
Additional Resources
We would also suggest that the following literature is reviewed and incorporated prior to
decisionmaking:
Draft EA - Submerged Artificial Reef Training Structure – Miami-Dade County, Florida
November 1, 2010
Page 2 of 2
Walker, B.K., Henderson, B., Spieler, R.E., 2002. Fish assemblages
associated with
artificial reefs of concrete aggregates or quarry stone
offshore Miami Beach, Florida,
USA. Aquat Living Resour 15, 95-105.
Brian K. Walker, Ph.D.
Research Scientist
National Coral Reef Institute
Nova
Southeastern University
Oceanographic Center
8000 N Ocean Drive
Dania Beach,
FL 33004
954-262-3675
Based upon the above additional information, 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 System
Miami-Dade Commissioners.