the value of hb and hb monitoring_pm-es final w-notes

BUILDING STRONG® U.S. ARMY CORPS OF ENGINEERS | Jacksonville District

THE VALUE OF HARD BOTTOM AND HARD BOTTOM MONITORING DIPPING OUR TOES INTO THE NEARSHORE Eric Summa Chief, Environmental Branch Jacksonville District, USACE Patrice Morey Sr. Planner, Jacksonville District Dr. Clay McCoy Coastal Engineer, Jacksonville District

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Presentation Notes

Good morning everyone. I hope everyone enjoyed their evening. I remain thankful to the FSBPA for this forum, for convening this fine group of people. And this morning, provided you have had enough coffee to stomach it, I would like to speak to you about a component of the beach nourishment permitting process and invite your to have a hand in changing it. Before I get started, I need to acknowledge that many people contributed to this talk, but none more so than Patrice Morey, whose work many of you have seen hundreds of times here at the FSBPA. She has been behind the professional look of most every presentation here, and most every Corps of Engineers presentation in the past, but few know of her strong influence and she wouldn’t have it any other way. And finally, I want to give a nod to Dr. Clay McCoy who is relatively new the Community, but contributed significantly to this message and will no doubt be a strong player in FSBPA for years to come. So again, my message is centered around the process of permitting beach projects. The process is both time consuming and expensive, but very worth-while. For Florida is a unique place with unique resources. And Regulations are important in the protection of those resources. Protecting those resources is analogous to protecting our economy. But since we all, as proponents of beach projects or simply as taxpayers, have skin in the game, this talk is asking if we navigate this process in a more consistent and meaningful way. I plan on dissecting one component of the existing permitting program and asking that, if you agree with my rather rudimentary analysis, you help provide support for a change. I think the Department for one may be OK with a change so long as it incorporates sound practices, provides reasonable assurance and ensures environmental benefit. So let’s get started.


OVERVIEW Are hardbottom communities unique and

worthy of regulatory oversight?

If so, are the current regulatory mechanisms overseeing hardbottoms effective in assuring their continued existence and proliferation?

Are taxpayers and communities getting good value for their dollars spent?

Are there other methodologies which can both:

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assure the continued existence of hardbottom communities, and

ensure efficient use of beach renourishment dollars?


UNIQUE?

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Presentation Notes

CSA International 2009 “Hardbottom” is a truly unique community within coastal environs of the Southeastern US. It represents a diversity of compositions of substrate which Enable and Promote the recruitment and distribution of various invertebrate species throughout areas in SE and SW Florida. There are three main types of substrate: Coquina -limestone composed of broken shells, corals and other organic debris. It occurs primarily along the east coast, in marine areas in the vicinity of St. Johns and Flagler Counties. Limerock substrates - outcrops of sedimentary deposits consisting primarily of calcium carbonate. It is more widespread than coquina substrate and can be found in a patchy distribution from north Florida to the lower-most keys. Relic reefs - the skeletal remains of formerly living reefs - are more limited in distribution than limerock outcrops but more common than coquina substrate. Benefits of Hardbottom include forage for green sea turtles, substrate for macro algae, sponges, hard and soft corals, and numerous invertebrates, acts as shelter for prey species and provides a unique opportunity for recreationalists and researchers alike to observe a different component of nature. Unfortunately, few outside the community know this important biological resource…. In fact, my nine-year old loves it when I mention that I am doing a talk on the value of HB… Might show that we are missing our target audience!


HARDBOTTOMS…UNIQUE?

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They are also Ephemeral

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Presentation Notes

They are found in Near shore and Off shore, but for this talk, I am focusing specifically on the near shore hardbottom. Those communities between 0 and 6Meters below the surface. These communities are also Ephemeral… Describing the communities as “ephemeral” is designed to inform you, as the audience that they are periodically exposed and buried. Mother nature, or “coastal dynamics”, in engineer speak, never meant for the HB communities to be static. They are to be as dynamic as their proximal beaches. Prior to man’s habitation of the coasts these beaches would have gone through periods of ebb and flow and the HB communities would experience similar periods of wax and wane. However, as the coastline has been “fixed” by man, coastal dynamics, (or mother nature) wishes to continue her habits to move the coastline. As a result, the HB’s are both exposed and covered by storms and sometimes by sand placed upon nourished beaches. So just how ephemeral are these areas… Well, the following slides are just to provide an example of how dynamic these areas can be. What follows is a group of slides surrounding one R-monument in Palm Beach County, between R-monuments 81 and 82 and between the years 2000 and 2011. These images were digitized from areal photography and serve to demonstrate that with or without nourishment. These communities change. This first slide is the area between R81 and 82 between 2000 and 2003



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The same area between 2003 and 2005.



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Between 2005 and 2007



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Betweeen 2007 and 2009



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And finally between 2009 and 2011.

BUILDING STRONG® U.S. ARMY CORPS OF ENGINEERS | Jacksonville District 9

CURRENT PRACTICES: A QUICK SYNOPSIS

APPLY FOR THE PERMIT: Current practices require a beach nourishment proponent to approach

the Regulatory Agencies with a plan to nourish.

Presenter

Presentation Notes

So we have established that HB are unique, That they are ephemeral communities worthy of protection and therefore: Regulation. What I’d like to do now is discuss how we are regulating these unique systems and hope to highlight a protection mechanism which I believe should be re-visited. This photo ought to be familiar to those of you who complete applications for beach nourishment projects here in Florida. It is where you begin. I am going to jump through the current practices and will highlight one component.



1) ASSESS THE IMPACT: Demonstrate through a functional assessment

the primary and secondary impacts

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Presentation Notes

So after you submit your permit application, one of the first responsibilities you have, Provided your project is in close proximity to HB communities, is to assess how that project will affect HB. Now there are well established process which enable you to do this. Specifically, FS requires you to convert the results of your engineering calculations to UMAM assessments UMAM stands for the UNIFORM MITIGATION ASSESSMENT METHOD 373.414(18), F. S. Your responsibility, specifically is to determine the primary and secondary impacts from your project.



2) ASSESS THE IMPACT:

The results of this analysis will provide a functional deficit (a loss of habitat function) from the proposed project

IMPORTANT: This primary and secondary analysis must be reviewed & approved by the Regulatory entity (they have the last word)

PRIMARY IMPACTS

SECONDARY IMPACTS

EQUILIBRIUM TOE OF FILL (ETOF)

OUTSIDE OF PROJECT INFLUENCE: NO IMPACTS

seaward limit of fill migration

DEP JURISDICTIONAL LINE FOR FILL

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Presentation Notes

In your analysis you determine the primary impacts, (those where your project is predicted to directly cover HB) and the secondary impacts, those areas will your predictions are that the project will not directly cover the bottom, but that the adjacent bottom will experience some degradation in function due to its proximity to the project. DEP and others believe these secondary impacts to be very hard to predict, but the assessment is required by statute and the Regulator has the last word in determining whether or not you reasonably assessed the impact. The ability to have the last word is an important aspect here, so please remember it as we move through this discussion.




Secondary Impact Analysis

SECONDARY IMPACTS

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Folks may question this issue of calculating secondary impacts, or whether they actually occur, but such impacts are calculated daily for all types of projects, even those in terrestrial environments. Take this example. Say you own property which contains a round cypress dome or prairie.





SECONDARY IMPACTS

INSERT YOUR FAVORITE BIG BOX STORE HERE

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And you are the proprietor of big box retail centers…





SECONDARY IMPACTS

PRIMARY IMPACT AREA

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Through working with the regulator, you are able to design a project which impacts just a portion of the pre-project wetland area. You have minimized the direct or primary impact to the wetland and still have a portion of the wetland remaining. Should you assume that the remaining wetland will exhibit no degradation in function?



2) ASSESS THE IMPACT: Secondary Impact Analysis

SECONDARY IMPACTS

SECONDARY IMPACT ZONE

PRIMARY IMPACT AREA

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No… With each big box establishment, you have lights, noise, run-off and other disturbances which will indirectly degrade the function of portions of the remaining wetland. This is a secondary impact.






PRIMARY IMPACTS

SECONDARY IMPACTS





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Well, the same thing happens with a beach project. You have your primary impact and then your secondary impact zone. You also have areas where your calculations tell you that based on an average set of conditions, will not be impacted by your project. You utilize functional assessment tools, (such as UMAM in the State of Florida) to assess the affect of the proposed project to each of the zones. The result of your assessment is a total functional loss score or index for the proposed project. NOTE: I use the term Equilibrium Toe of Fill in this presentation. It is a commonly used term in the current parlance of regulatory oversight and principally used to determine the seaward limit of beach fill migration. This term is highly controversial and often claimed to be "meaningless" by coastal engineers who believe the ETOF is not a predictable line in the highly dynamic waters of the mid-south Atlantic seaboard.



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ADJUST PROJECT TO AVOID AND MINIMIZE POTENTIAL IMPACTS

REGULATORY SEQUENCING:

AVOID

YES

NO MINIMIZE NO

COMPENSATE YES

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Presentation Notes

Once your functional analysis is complete, it is incumbent upon the project proponent to demonstrate Avoidance, Minimization, before they propose mitigation. May require a justification of overall volumes placed or a reduction in volume placement. This is the permit negotiation component of the process. However, as this talk is related to monitoring only, I will not focus much more here.


Mitigate for all unavoidable impacts

Monitor the mitigation


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Presenter

Presentation Notes

So you have submitted your application, performed your assessments, justified your project ti the regulatory and provided reasonable assurance of project performance. If approved, you receive a permit and, where necessary, build your mitigation to offset your impacts. In addition to building the mitigation you proposed in the permit, you must also MONITOR that mitigation area for successful achievement of the predicted functional gain…(basically until it becomes the habitat you predicted)…. If it doesn’t than you may have to modify the mitigation to assure you meet success.


NOW you must perform physical and biological monitoring

of the hardbottom area outside of the predicted impact area

CURRENT PRACTICES: A FINAL SUMMARY

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MONITOR FOR ACCURACY OF PREDICTED EQUILIBRIUM TOE OF FILL (ETOF)

Receive Authorization (permit) for volume &

placement

Acquire and Expend Funds

to build project as authorized

in permit

Build the Project & submit compliance

reports to regulatory entities

1 2 3 4 Propose a project.

Include solid calculations

(the “what & how”) to regulatory

entities

Presenter

Presentation Notes

So this is a final summary:






PRIMARY IMPACTS

SECONDARY IMPACTS





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Remember that’s these areas here: (point to secondary impact zone and area outside of project influence zone)


Few other resource protection program require you to:

WHERE THIS PROGRAM DIFFERS FROM OTHER RESOURCE PROTECTION PROGRAMS

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Continue to affirm your predictions (the predictions which were already affirmed

through the regulatory community)

In such a detailed manner (physical and biological monitoring protocols)

Within a known dynamic environment with several outside variables

For multiple years after the nourishment event

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Presentation Notes

So why is this a problem? For one…It’s different from the way other resource protection programs are run. Few other resource protection program require you to: Continue to affirm your predictions, (the predictions which were already affirmed from the regulatory community), In such a detailed manner, (with stringent physical and biological monitoring protocols) Within a known dynamic environment, with several outside variables, For multiple years after the nourishment event.


We are trying to assure that the projects work as intended via physical and biological monitoring.

But we can’t get there from here….

THE CRUX OF THE ISSUE

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Presentation Notes

So we are trying to assure that the projects work as intended…And our methods for trying to affirm our earlier predictions are to employ extensive physical and biological monitoring. **Though we are trying to achieve regulatory success and provide confidence to the taxpayers that we are meeting the mandate of resource protection, these practices are costly and unfortunately will not meet success. The expense of performing the physical and biological monitoring protocol…knowing that the system will experience changes, (note my earlier slide where I stated-HB are ephemeral) is inefficient provides very limited value. Overall Ramifications of this Practice: -Compels the sponsor to PAY for monitoring which WILL document changes -These changed conditions will likely compel the DEP or Federal Regulatory Entity to request additional mitigation for changes they observe via the monitoring program. -This request for additional mitigation Progresses into protracted discussions –leading to professional disagreement- over known variability in the system not discussed or recognized in baseline conditions. Ultimately, some community may pay additional taxpayer dollars to mitigate for unanticipated impacts.


Reasons WHY Current Practices will NOT Work:

1. Lack of accounting for known variability in the monitoring plans*

*L.K.B. Jordan et al/Marine Pollution Bulletin 60 (2010) 261-271

THE VALUE OF HARDBOTTOM PHYSICAL & BIOLOGICAL REQUIREMENTS

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Presenter

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Why is the variability in the system not discussed or recognized in baseline conditions….? After all, we are monitoring. Variability in the system and its effects on the nearshore environment are extensively discussed in a number of papers… (L.K.B. Jordan et al/Marine Pollution Bulletin 60 (2010) 261-271 However, the physical and biological monitoring protocols do not account for, or appropriately recognize, this known variability. Additionally, the monitoring is not done with sufficient time to establish valid baseline information valuable to any construction/post-construction monitoring effort.


**Peterson, C.H., Bishop, M.J., 2005. Assessing the environmental impacts of beach nourishment. BioScience 55, 887–896

Reasons WHY Current Practices will NOT Work:

2. Lack of Sufficient Baseline**

THE VALUE OF HARDBOTTOM PHYSICAL & BIOLOGICAL REQUIREMENTS

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Presenter

Presentation Notes

This lack of sufficient baseline in monitoring programs, such as Florida’s, has been well-documented…Specifically by: Peterson, C.H., Bishop, M.J., 2005. Assessing the environmental impacts of beach nourishment. BioScience 55, 887–896. Its not all the State’s fault….They would love better baseline data. But they can’t require it UNTIL they issue you a permit.


Approximate costs and expenditures of physical and biological monitoring (active beach nourishment projects):

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COSTS OF HARDBOTTOM PHYSICAL & BIOLOGICAL REQUIREMENTS

PHYSICAL MONITORING

$125,000 to $300,000/year

MITIGATION CONSTRUCTION AND MONITORING

$675,000 to $1,000,000/acre

BIOLOGICAL MONITORING

$350,000 to $500,000/year

Presenter

Presentation Notes

So we have talked about: -How the existing monitoring protocols lack sufficient baseline and do not take into account known variables in the system. -How those deficiencies in the information could put the proponents of Beach projects at odds with the regulatory community ---And How, absent other monitoring data, that Regulatory Community may use these results to determine whether or not a project has impacted areas outside what was predicted pre-project. So there are deficiencies, but what are the costs? An admittedly cursory survey of project sponsors has led me to the numbers I am representing here. The bottom line here is that the costs of physical and biological monitoring may be commensurate with the costs associated with mitigation and moreover. When you build mitigation, you presumably create habitat in perpetuity but when you are monitoring to affirm your earlier predictions, you don’t create anything. Does monitoring represent the same value proposition that mitigation provides considering the comparable costs?


ALTERNATIVES TO THIS ADDITIONAL MONITORING

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Presenter

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As you can tell, I am firmly of the thought that the existing methods of post-project physical and biological monitoring are inefficient and ineffective. So what options do we have? I am a biologist. I love habitat, and think it’s the most important thing we have. I have also spent more than 24-years working in environmental and regulatory policies and believe it to impractical -or worse naïve- to believe that we will stop nourishing beaches for the benefit of nearshore hardbottom. So how about some alternatives?


Idea 1: Re-examine Risk Enhance Mitigation


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Presenter

Presentation Notes

Those that work with me know that I am NOT a fan of bringing up issues without also bringing potential solutions to the table. So, since I have the podium, I want to take the opportunity to share 4 separate ideas with you which might address the deficiencies in the existing monitoring program. Idea 1: Toss the detailed physical and biological monitoring program, incorporate risk of variability into the secondary impact assessment –to account for the variability in the system- and provide additional mitigation for projects rather than spending $$ to affirm your engineering calculations and predictions. This is a known practice to regulators who commonly assess risk. But they do it on the mitigation end only. Regulators will assign a risk factor that the mitigation you propose will not be successful, but they employ no similar risk assessment that variability in the project area may upend your engineering calculations. So what are the Benefits of this proposal: No painful costs of monitoring which will show changes, (because of the influence of variables). Money will be spent on habitat creation and assuring the habitat creation is successful. Mitigation to habitat Creation may be awash….or could be cheaper to build the habitat



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Idea 2: Adopt Remote Sensing surveys - long spans, each year, during spring and fall. Combine with known meteorological data to determine coastal

movements on scales better suited to beach management.

LIDAR

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Presentation Notes

Idea 2: Toss the current detailed physical and biological monitoring program, adopt Remote Sensing surveys (Lidar or Side Scan), over long coastal spans, each year, during spring and fall. Combine those surveys with known meteorological data to determine coastal movements on scales better suited to beach management. Benefits: Cheaper method, larger scale with greater frequency will better identify the short and long-term effects of beach nourishment programs. The scale is important here also. These beach projects are of a large scale, in a dynamic environment. Shouldn’t the monitoring be of a similar scale? Is the establishment of transects every 150M and using tools such as rulers to measure sediment depth in millimeters or centimeters appropriate when we are placing volumes on the beach which we measure in the hundreds, thousands or hundreds of thousands of cubic meters?



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Idea 3: Use the FSBPA as a platform to develop a Task Force to examine the current monitoring program

& develop alternative solutions

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Presentation Notes

Idea 3: Toss the current detailed physical and biological monitoring program, utilize the FSBPA as a platform for a task force designed to examine the current monitoring program and to develop methodologies again, over broad scales, to develop a better picture of the effects of nourishment and help improve project life and reduce environmental impact... In Dr. Edwards talk, she will bring up the development of a HB protocol standard. Perhaps now is the time for this larger community of engineers and scientists to participate with the FDEP to develop a monitoring program which serves to answer the question the agencies are seeking to answer. Benefits: An approach led by a broad body of practitioners will assure clarity in goals and objectives, advancing knowledge of environmental impacts and focusing mitigative efforts.



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Idea 4: A combination of all of the prior three ideas

Presenter

Presentation Notes

Finally, Idea 4: A combination of all the prior three: 1. Until the adoption of a more reasonable method to account for known variability in the system, adopt “Risk” as a factor to generate additional mitigation and reduce monitoring. 2. Supplement monitoring with Remote Sensing and; 3. Enable the this Community of Practice to develop effective monitoring methodologies. Either way: Revisit the current detailed physical and biological monitoring program.


SUMMARY

Goals for Projects: A long design life

With great profiles just as readily used by nesting turtles

& piping plovers as by tourists & recreationalists

Equally effective at protecting the coastal community as it is at ensuring the existing & continued proliferation of nearshore HB communities

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Presenter

Presentation Notes

I appreciate your time this morning and hope that I did not come across as too strong with the Department or NOAA. It’s the Process we’d like to modify, not the Providers of the Process. At the end of the day, we all share the same goals: We would all like a project with a long life, and a great profile just as readily used by nesting turtles and piping plovers as it is tourists and recreationalists, Just as effective at protecting the coastal community as it is ensuring the existing and continued proliferation of nearshore HB communities. We can have both. So join me and the Jacksonville District in offering assistance to the FDEP, NOAA and others to examine the current practice and implement some meaningful change. I think they’d be open to it. If we work With them, together. Thank you.


THANK YOU!

#bethechange@fsbpa

[email protected]

mailto:[email protected]

the value of hb and hb monitoring_pm-es final w-notes

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