An update on the Lido Beach Renourishment project
By Catherine Luckner
On Sept. 4, nearly six months since the Permit application notice, the Army Corps of Engineers (ACOE) responded to questions (RAI) from the Florida Department of Environmental Protection (FDEP). Questions from FDEP were extensive regarding the project with multiple areas of focus including project design, wildlife species protection, the requested volume of sand to be dredged, the choice of sand borrow sites and down drift consequences of the groin structure and placement. The FDEP sent their RAI on April 15, 2015 which coincided with the public presentation by the ACOE.
The FDEP is reviewing the ACOE response and will determine if it satisfies the RAI or raises additional questions. FDEP Project Manager Chiu Cheng provided guidance on the process. “We will try our best to take any external comments into consideration. As far as the review process for the response to RAI #1, the response was received on September 4, 2015. With the allotted 30 days to take action on this information, the Department will have to either 1) complete the application, 2) issue a partial response letter (if not all questions were answered in this response) or 3) issue an RAI #2 if some questions were inadequately answered and/or new questions directly develop from any of the responses. The date to undertake any of these actions will be Friday October 2, 2015.”
The anticipated third party review by Atkins North America Coastal Engineering has been provided in ‘draft’ format to County Staff. A ‘draft’ is provided in advance of a Final Report to ensure all contracted scope of work was completed. Once reviewed by County Staff, a Final report and Executive summary is issued. Primary areas of study contract include the following: “physical effects of the proposed shore protection project with focus on: a) The shoreline of Ted Sperling Park b) Siesta and Lido Key Beaches,
- c) Navigation in Big Sarasota Pass, d) the north shoreline of Siesta Key adjacent to the Pass, e) the no-action alternative”. County Staff have up to ten days for review and Atkins seven days to submit the Final Report. According to County Coastal Resource Manager, Laird Wreford, the study will be presented in final form to the Board of County Commissioners (BCC) who may then direct communication to FDEP.
While this publication and SKA is awaiting the final report to make further comments regarding the study, the draft appears to suggest, at minimum, a second RAI for the ACOE project.
Several comments stand out and we provide them ’rough draft’ by Atkins: re Ted Sperling Lido Park, “any beaches present on the downdrift side would suffer concomitant sand losses. The construction of groins would have to be supplemented with nourishment so that adjacent beaches would not be starved of sand.” This statement indicates that Ted Sperling Park would likely become sand-starved without regular nourishment.”
Re Siesta Key beaches: “ …Corps work proposed is especially important to Siesta Key since it involves back-passing at an inlet ebb shoal rather than bypassing of sand to the downdrift side of the inlet. Most inlet ebb shoal mining projects are those in which material dredged from the ebb shoal is placed on downdrift shorelines helping restore the flow of sand in the direction of natural net transport. As the present situation is one of back-passing material to an updrift shoreline, more risk exists due to interference with the natural net directional movement of sediment. In the present case, approximately 1.3 million cubic yards (MCY) of sand is being considered for placement on updrift beaches which is over 10 times the estimated net annual, southward transport of sediment.”
For the FDEP, it’s likely the ACOE response, comments from public and from the Atkins report may result in several rounds of RAI from the FDEP.
Comments contained in a letter response to the FDEP re the ACOE application were submitted by Catherine and Bob Luckner, and on behalf of The Siesta Key Association are as follows:
“Comments by CB& I (Coastal Engineering, Boca Raton) on behalf of the ACOE focused primarily on inconsistencies within the original design and provided “draft” details of possible monitoring plans for sea grass, water quality, dredged sand quality and potential artifacts in the dredged area during and after the construction. The ACOE also stated that US Fish and Wildlife Service and National Marine Fisheries Service have not yet completed their Biological Opinion and consultation letters and their Incidental Take Authorization for protected species such as sea turtles and migratory and beach nesting birds. Historically this is a complex set of documents that require significant additional protections to be included in the ACOE plan. It has also historically been on the critical path for permitting.
Within the ACOE response, an area of concern relates to questions raised regarding an alternative groin field and groin design. They state no consideration of this alternative technology was given in 1999 when the initial Federal approval was provided as it was not yet ‘proven’ technology. It was also arbitrarily not considered when the current design was optimized in 2002 and 2004 and also not considered in the Value Engineering Report of 2013. The pier-type Permeable Adjustable Groin (PAG) was approved by FDEP in February of 2009 for Longboat Key. The original application for PAG groins was in 2007. The first PAG was installed in 2010 and most recent in March of 2015. This provides” real time” outcomes and modeling data of sand accretion monitoring data by a Coastal Engineer. The PAG demonstrate beach protection both upstream and downstream, are attractive and considered an amenity versus the six foot high wall of “boulders” which will (according to the ACOE report ) be exposed on the beach likely within a year after placement. “
Our conclusion without the consideration of an alternative design: if such alternative would remedy concerns for erosion along the Ted Sperling Lido County Park, eliminate issues of sufficient sand volume for stabilization and accretion, reduce the initial volume of sand necessary, and increase intervals between renourishment, many environmental concerns could be eliminated. The need for dredging such a quantity of sand from Big Pass and the ebb shoal could be eliminated. “
For now, it appears unlikely a Permit for Dredging will be FDEP approved soon. If the application continues to generate valid questions, the ACOE will have opportunity to respond and hopefully, provide a ‘best practices’ and “do no harm” project.