APPENDIX G
 COMMENTS ON THE DRAFT  TAMPA HAY EIS
AND EPA's RESPONSES TO  THOSE COMMENTS
          SEPTEMBER,  1983

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             APPENDIX G
 COMMENTS ON THE DRAFT TAMPA BAY EIS
AND EPA's RESPONSES TO THOSE COMMENTS
          SEPTEMBER, 1983

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     The Draft EIS (DEIS) was released November, 1982.  This Appendix
includes copies of written comments received by EPA on the DEIS.  Responses
to comments were addressed in one of three ways:

     0    Acknowledgement of comments for those requiring no response.

     0    Correction or addition of information incorporated into text as
          noted.

     0    Specific comments not requiring text changes but requiring a
          response are numbered in the margins of letters with responses
          following.

     EPA appreciates the time and effort taken by those who offered their
comments on the DEIS.  Comments, criticisms, and additional information
offered were carefully considered in preparation of the Final EIS.
   81119833G

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                                               .^  r,::o S  1?32
                  FUOR1DA DEPARTMENTOFSTATE;!' |n~r—:    —-
                          George Firestone        '--* -'— —' '-
                            Secretary of State
                        DIVISION OF ARCHIVES,     .   	
                  HISTORY AND RECORDS MANAGEMENT
                   The Capitol. Tallahassee, Florida 32301
                           (904)488-1480
November 30, 1982                             In  Reply Refer To:

                                              Mr.  Frederick P. Gaske
                                              Historic Sites Specialist
                                              (904)487-2333
Mr. Walter O. Kolb
Division of State Planning
Department of Administration
Office of the Governor
The Capitol
Tallahassee, Florida  32301

Re:  Your Memorandum and Attachment of November  19,  1982
     Cultural Resource Assessment Request
    J3raft Environmental Impact Statement  for Tampa  Harbor
     Ocean Dredged Material Disposal Site  Designation, ^>
     Hillsborough County, Florida                 _____X^
    *•• i -
Dear Mr. Kolb:

     In accordance with the procedures contained  in  36 C.F.R.,
Part 800 ("Procedures for the Protection of  Historic and
Cultural Properties"), we have reviewed the  above referenced
project for possible impact to archaeological and historical
sites or properties listed, or eligible fcir  listing, in the
National Register of Historic Places.  The authorities for
these procedures are the National Historic Preservation Act
of 1966 (Public Law 89-665) as amended by  P.L. 91-243, P.L.
93-54,  P.L. 94-422, P.L. 94-458 and P.L. 96-515,  and Presiden-
tial Executive Order 11593 ("Protection and  Enhancement of the
Cultural Environment").

     A review of the Florida Master Site File indicates that
no inundated cultural resources are recorded within  Shallow-Water
Alternative Site 4.  Furthermore, use of the area for disposal of
ocean dredged material is deemed unlikely  to affect  any cultural
resources which may be present.  Therefore,  it is the opinion of
this office that the proposed project will have  no effect  on sites
listed,  or eligible for listing, in the National  Register  of Historic
Places,  or otherwise of national, state or local  significance.
                     FLDRIDA-State of the Arts

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Mr. Walter O. Kolb
November 30, 1982
Page Two
     If you have any questions concerning our comments, please do
not hesitate to contact us.

     Your interest and cooperation in helping to protect Florida's
archaeological and historical resources are appreciated.
                               Sine
                               George/v». Percy
                               Deputy State Historic
                               Preservation Officer
GWP:Geb
cc:   U. S. Environmental Protection
     Agency

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2-1

2-2
           DEPARTMENT OF HEALTH & HUMAN SERVICES
                                                                       Public Health Service
                                                                       Atlanta GA 3G333
                                                                        (404) 452-4095
                                                                        December  3,  1982
Criteria and Standards Division (WH-585)
Environmental Protection Agency
401 M Street, S.W.
Washington, D.C.  20460

Gentlemen:

We have reviewed the Draft Environmental Impact Statement  (EIS)  for Tampa
Harbor, Florida, Ocean Dredged Material Disposal Site Designation.  We  are
responding on behalf of the Public Health Service.

We have reviewed this document for possible health effects and  find that
the proposed alternatives have been adequately addressed.  We trust that
both the existing site and the proposed disposal site will be monitored for
dispersion of dumped materials and also for adverse impacts on  the local
fauna which could cause long-term food-chain effects.
       Thank you for the opportunity of reviewing this Draft EIS.
       a copy of the -final document when it becomes available.

                                           Sincerely yours,
                                                            Please  send us
                                           Frank S. Lisella, Ph.D.
                                           Chief, Environmental Affairs .Group
                                           Environmental Health Services Division
                                           Center for Environmental Health

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                                  TAMMPORT
                                  AUTHORITY
                               Serving America's Seventh Largest Port


                                    December 6,  1982
3-1
3-2
Mr. T. A. Wastler,  Chief
Marine Protection Branch (WH-585)
Environmental  Protection Agency
Washington, D.C.  20460

Reference:  40 CFR Part 228
            (OW-FRL 2234-8)
            Proposed Designation of  Ocean Disposal Site; Tampa Harbor

Dear Mr. Wastler:

I am writing in response to the public  notice which appeared in the
8 November 1982 Federal Register concerning proposed designation of a per-
manent disposal site for dredged material from  the Tampa Harbor Project.
I have reviewed the Draft Environmental  Impact  Statement issued by your
agency in regard to this proposed  action on 29  October  1982.  In addition,
I have reviewed all of the ancillary and background material regarding
this and other alternative.sites which  is referenced in that document.

In general, we support the proposed  designation proposed in the
8 November 1982 public notice.  We agree with the conclusion expressed in
the notice and the DEIS that current interim Disposal Sites A and B may
not be the best locations for the  disposal of dredged material due to the
presence of sensitive hard-bottom  communities to the west  and north of
these" areas.  Based on the limited information  presented in the DEIS and
supporting documents, we agree that  alternative Site 4  appears to be a
more acceptable site for the disposal of dredged material.

However, we are concerned that there has not been presented sufficient
evidence to confirm that all of alternative Site 4 is acceptable for
dredged material  disposal.  The television camera inspection presented by
EPA covers only a small portion of the  4 sq. mile-site. In addition, the
numerous sediment and biological samples collected during  the EPA survey
appear to have been conducted using  surface-deployed sampling devices.
The use of such devices does not afford information regarding the possible
presence of viable hard-bottom communities in those areas  sampled.

                                                               cont...
POST OFFICE BOX 2192  •
                      GEORGE B. HOWELL MARITIME CENTER

              811 WYNKOOP ROAD  •  TAMPA, FLORIDA 33601

                          AN EQUAL OPPORTUNITY EMPLOYER
813/248-1924
52441

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Mr. T. A. Wastler
December 6, 1982
Page 2


It would be our recommendation that,prior to final  designation and use of
this site,additional inspections of the area be conducted utilizing either
divers or the television camera to confirm the absence or limited presence
of hard-bottom communities and predominance of sandy substrates cited in
the DEIS for the entire area included in the proposed action.   We are con-
cerned that in the absence of such information this designation, and any
dredging contract conducted pursuant thereto, may be open to the same
challenge and delays which have been experienced in regard to  the use of
interim Sites A and B.  Delays which might result from such challenges
would have a severe economic impact on the Port of Tampa since the recently
proposed work in Section 38 of the Tampa Harbor Project is the last work
necessary for completion of the present phase of that project.

                                   Respectfully,
                                                          ****#
                                   William K. Fehring, Ph.D.   /
                                   Director of Environmental/ffairs

WKF:bw

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                                  TAMPA PORT
                                   'AUTHORITY
                                                        '^::i'.-=-.4A; —"••^^'^iii'ii"''1'  '"""••• ' '".'^----'iJj'-iiK^
                                Serving Amer/co's Seventh Largest Port

                                     December 6,  1982
         Criteria and  Standards  Division  (WH-585)
         401  M Street,  Southwest
         Environmental  Protection Agency
         Washington, D.C.   20460
         Reference:
         Gentlemen:
Draft Environmental  Impact Statement
Ocean Dredged Material  Disposal  Site Designation
Tampa Harbor, Florida
         I  have reviewed  the  Draft  Environmental  Impact Statement published by your
4-1      agency on  29  October 1982  in regard to the proposed permanent designation
         of a site  for the  disposal of dredged material from the Tampa Harbor Pro-
         ject.   In  addition,  I  have reviewed the  supporting documents, video tapes,
         studies, and  reports which have been presented by your agency to support
         this DEIS.

         In general, this Authority can support the proposed designation of Site 4
4_2      for dredged material  disposal as described in the DEIS.  We agree with the
         conclusion expressed in the DEIS that interim sites A and B which are cur-
         rently being  utilized  may not be the most appropriate sites for long-term
         disposal of dredged  material due to the  presence of sensitive hard-bottom
         communities near those areas.  Based on  the limited information contained
         in the DEIS and  associated documents, we agree that alternative Site 4
         appears to be more appropriate for use as a long-term dredged material dis-
         posal  site.

         However, we are  concerned that the DEIS  and the accompanying documentation
         do not contain sufficient evidence to confirm that all of alternative Site
         4  is appropriate for the proposed use.   We note that the video tape of
         Site 4 covers only a very small portion  of the 4 sq. mile-proposed site
         While  the  sediment and infaunal analyses described in the DEIS and attached
         documentation is certainly complete, the apparent use of surface-deployed
         sampling devices makes this data of little use in determining the presence
         or absence of sensitive hard-bottom communities within the proposed site.

                                                                         cont...
POST OFFICE BOX 2192  •
         GEORGE B. HOWEU MARITIME CENTER

 811 WYNKOOP ROAD  •  TAMPA, FLORIDA 33601

              AN EQUAL OPPORTUNITY EMPLOYER
813/248-1924
TELEX 52441

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Criteria and Standards Division
December 6, 1982
Page 2


We would strongly recommend that additional visual inspections of the pro-
posed disposal site be conducted utilizing either local divers or the
camera equipment utilized previously.  We believe that it may be important
to confirm the absence of hard-bottom communities and the predominance of
sandy substrates cited in the DEIS.  We are concerned that in the absence
of such additional observations, this designation may be subject to the
same challenges which have been experienced with regard to the use of
interim disposal Sites A and B.

Such challenges may result in delays to the final contract of the Tampa
Harbor Deepening Project and thus may have significant economic cost to
this Authority and to the Port of Tampa.

Should the decision be made to conduct the additional inspections by
divers which we have recommended, I would offer my personal assistance to
such efforts.

                                   Respectfully,
                                   William K. Fehring, Ph.D.
                                   Director of Environmental A/fairs
WKFrbw

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  State of Florida
  DEPARTMENT OF NATURAL RESOURCES
  DR. ELTON J. GISSENDANNER
       Executive Director
                3900 COMMONWEALTH BOULEVARD / TALLAHASSEE 32303
BOB GRAHAM
Governor
GEORGE FIRESTONE
Secretary of State
JIM SMITH
Attorney General
GERALD A. LEWIS
Comptroller
BILL GUNTER
Treasurer
DOYLE CONNER
Commissioner of Agriculture
RALPH D. TURLINGTON
Commissioner of Education
                                            December 8, 1982
5-1
5-2
United States Environmental Protection Agency
Criteria and Standards Division (WH-585)
401 M Street Southwest
Washington, D.C.  20460

Dear Sirs:

The Florida Department of Natural Resources thanks you  for  the
opportunity to comment on the Draft Environmental Impact  Statement
for Tampa Harbor, Florida Ocean Dredged Material Disposal Site
Designation.

Department testimony presented at the Army Corps of Engineers Public
Hearing June 30, 1982 called for the Immediate cessation  of dumping
at current Interim Site A.  The Department continues  to be  of that
opinion.   Further, the Department reiterates its concern regarding
any dredged material disposal offshore and its support  for  land-based
alternatives.

In regards to the current Draft Environmental Impact  Statement,  staff
review (attached) has shown it to be a fragmented, poorly developed
document which is both redundant and contradictory.   The  document is
inadequate for the purposes proposed as it does not explore all  alterna-
tives; it does not present a thorough environmental review;  and  it
proposes a new interim site (Site 4) without adequate survey or  investi-
gation of the site.
                     DIVISIONS /
                        ADMINISTRATION • LAW ENFORCEMENT • MARINE RESOURCES
                      RECREATION AND PARKS • RESOURCE MANAGEMENT • STATE LANDS

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         Environmental Protection Agency
         December  8,  1982
         Page  Two
         It  is  the Department's request  that  the  Environmental  Protection Agency
5-3      withdraw this  draft and schedule  full  public  hearings  to  receive necessary
         public and private input to  the document and  any  subsequent  designations.
                                          Sincerely,
                                          Elton  J. Gissendanner
         EJGrghh

         Attachment

         cc:   Governor  Bob  Graham
              Florida Legislative delegation
              Manatee County Commission
              Edwin  A.  Joyce,  Jr.
              Karen  A.  Steidinger
              George E.  Henderson
              Walter Jaap        " •

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                      : i~--. -.- T'e^artinent  of  Natural Resources
              '-.;:.     -r.er,:= co. Draft environmental Impact Statement
                 L.:.  -amps Harbor, Florida Ocean Dredged Material
                             Disposal Site Designation


     These  comments ar= referenced by page and  line for ease  in following  the
     critique.  Since  review  time  was short it  can be expected  that some
     additional comments could be made or  expanded  especially regarding physical
     oceanography and hydrology.

     Page x.  You have not included  certain existing diked  dredged disposal
C_A   islands  that could be used for the ongoing projects.  In  many cases  they
     are closer to the dredge projects than offshore disposal  sites.  In  fact,
     consideration is  only to offshore Gulf sites.

5_5   Page xii, line 4.  Should be 82°55'06"W  not 83e55'06"W.

     Page xiii, line 15.   Change hard bottom to  "live bottom."  Refer  to  CFR
     1978,  "Live bottom  areas  are  defined as those  areas  which  contain
     biological assemblages consisting of such  sessile invertebrates  as  sea
5.5   fans,  sea whips,  hydroids,  anemones, ascidians, sponges, bryozoans,  or
     corals living upon  and attached to naturally  occurring  hard or rocky
     formations with rough, broken,  or smooth topography or  whose lithotope
     favors the accumulation of turtles and fishes."

     Page xiii, lines  19-22.   The conclusion  that site 4 does not contain live
     bottom communities is not  based on adequate  field reconnaissance.   The
5-7  survey relied on  incomplete remote data  acquisition and box coring using  a
     symetrical station pattern.  Patchy distribution  of live  bottom requires
     intensive in situ observations to insure that  the total site of surrounding
     areas are sand or sedimentary facies.

     Page xv, item 9.   The benthic community is composed of  two  components.
     First, infaunal  communities  in  the sediments and secondly,  live bottom
5-8  communities superimposed on rock.   This  includes  sessile  attached algae,
     sponges, corals, bryopzoans,  tunicates  and mobile  invertebrates and
     demersal fish populations.   Both infaunal and  live bottom  communities  are
     composed of subtropical-tropical and  temperate species.

     Page xvi, lines  25-29.   Note that  the studies referred to  are  confined  to
  Q   "Sandy bottom habitats."   Here we  are dealing  with sandy  and  live bottom
     habitats.  Recolonization of a sedimentary habitat cannot  be extrapolated
     to  equate to recolonization of live bottom habitats that  occur  offshore of
     Tampa Bay.

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                                                                                          i
        United States  Environmental Protection Agency
        Page two
        7 December 1982


        Page xvii, line  4.  Your  statement of "will provide 4 nmi of  sand  bottom"
5-10    i-s made on the basis  of symetrical sampling stations, using  a  box core, and
        discarding any sample that contained <15 cm of  material.   This  is a poor
        technique for  reconnaissance of an  area suspected to contain  contagious
        distribution of  live  bottom.  The statement that  the alternative  site is
        "safe" is an unsubstantiated hypothesis at best.

        Page xvii, line  22.   "Most of the living corals are found shoreward of the
5-11    10 m isobath,  although  some exist  to  60 m."  Most reef  Scleractinian,
        Octocorallian, and Milleporarian corals are found  in 10 to  40 m, very few
        are found in depths <10 m.  Beyond 50 m, many ahermatypic corals are  found,
        see Cairns (1979).

        Page xviii, line  28.   The most common fish associated with the live bottom
5-12    habitat includes  red  grouper, white grunt, mangrove snapper,  trigger fish,
        and belted sand  fish.
                                                      >
        Page xix, line 4.  Hard bottom (live bottom) areas are inhabited by algae,
5-13    sponge,  corals, bryozoans,  tunicates,  and a diverse  motile  fauna  of
        crustaceans, polychaetes, molluscs, echinoderms, and fish.

        Page xix, line 8.  Recreational activities are  important to  the economy,
5-14    they generate  a  great  amount of money through attendant service  industries:
        dive shops, marinas,  ice,  fuel, bait, and boating accessories  all are
        significant.
                                                                       «
        Page xix, line 26-27.  Again, similar habitats are not being compared.  The
5-15    impact of dredge  spoil on a sedimentary habitat cannot be extrapolated to a
        live bottom community.

        Page xx, lines 18-22.  Sea turtles, especially loggerheads,  often remain on
 •'"     the same outcrop or live bottom  site.   Burial  of  the  site  may  be
        significant to individuals.   This  is  important  during breeding  periods
        since  turtles tend  to use  the same areas to mate  and  nest.   During
        internesting  intervals,  sea turtles  remain  in  the immediate nearshore
        vicinity. Degrading  the  offshore  environment may disrupt reproduction
        success.

 _ -7   Page xx,  lines  27 and 28.   Your  conclusion that  long  term  adverse
        biological effects will not occur from contaminants is not supported.

 _ ,Q   Page xxi, line 3-5.   Other resources lost due to disposal would include any
        live bottom habitat that dredge spoil was dumped on,  loss  of fish and other
        renewable resources from the site.

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       United 5;i.  ;. '     .-.^-id-.:si  Protection  Agency
       Page  three
       7  December
       Page xxi, lines 4 i.:d 5.  If you cite  the  benefits of  marine commerce you
       should also cite the negative aspects  of  these  activities.  For example the
       the accidents and loss of life (Blackthorn-Capricorn ,  S unmet Venture vs the
       Skyway Bridge), numerous other accidents;  two barges  hit the bridge in
       November, one  was  the dredge  contractors.   Commerce  also has other
5-19   undesirable attributes i.e.,  oil spills  and resultant  environmental
       degradation.

       Page xxi, line 22-26.  The  studies to date  are insufficient to  document
5-20   that there is less hard bottom (live bottom) in the site 4 area.

       Page 1-7, lines 11 and  12.   To date, EPA and  the Corps  studies  are not
5-21   adequate  to select or designate a most suitable site.

       Page 2-1.  You do not evaluate the existing  bulkhead spoil disposal islands
       in Tampa Bay.  Also, abandoned phosphate pits east of  Tampa are potential
«>~"   disposal  sites.  Only gulf  sites are considered.
                           t
       Page  2-2, line  4.   Mid-shelf  areas  are not  any more environmentally
•3~"   sensitive than areas near to shore.

       Page  2-3, line  11.   It would  be better to consistently  use  Lyons  and
•3~^*   Collard (1974) terminology- for benthic community distribution.  The Collard
       and D'Asaro (1973) interpretation is not as  accurate for offshore areas.

       Page 2-3, lines 12 and 13.   Chapter 3 of this draft indicates low  average
•3~"   winds  and seas  at  the  nearshore sites.  Lyons  and  Collard (1974)
       characterization referred to the area as the shallow shelf 10-30 m  (30-100
       ft).  Temperature and  substrate are the  physical-geological controls.
       Occasional severe  storms  place stress on this  area, but  it  is not  a
       consistent influence.  Freshwater runoff,  with  the exception of hurricane
       generated rains, has little  influence on bottom communities  13 to  17 nmi
       off the mouth of Tampa Bay.

c p/-   Page 2-5.  Land-based disposal.  .Why were  the  spoil islands  in Tampa Bay
       eliminated from consideration?

c 07   Page 2-6, line 22.  What are the technical  and  environmental reasons fot
       concluding that ocean disposal of sediments  is  the most practical  method of
       disposal?  Your site specific studies are  inadequate to show that  disposal
       is not harmful to the adjacent live bottom communities.
 5-28  ^a8e 2-11, lines 11  and 12.   Previous characterization on page xvi,  line  3
      states "(currents)  are generally  less than 1 kn."  Furthermore, the  cited
      reference (Holliday  1978)  is  not  relevant, there is nothing in this  report
      dealing with currents  off  Tampa Bay.

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        United Spates Envir :.-nr.sr.tal Protection Aj . •
        Page four
        7 December 1982


        Page 2-11.  In reference to animal species  found  in  . =e  region,  one should
        refer to the many Hourglass  monographs.  Jaap  (in  prep.)  identified 16
5-29    species of stony corals.  There is no attempt to  characterize dominant  live
        bottom flora or fauna in this EIS.

        Page 2-13, line 10-12.  Was there a rational reason why  the  May 1982 site
5-30    specific survey did not sample live bottom?   There  is  admission that live
        bottom does exist, but failure to sample or  study its  biota.


        Page 2-14, lines 5 and 6.  What evidence do  you cite  to  state that  "animals
        of a shallow-water area must be adapted to periodic burial—."?   You fail
5-31    to cite the range of what "shallow water" is; define  your  terms.   The area
        in 16-30 m depth is not  a  region of  high  energy.   Your contention that
        disposal at a mid—shelf site would have longer adverse effect on the  biota
        is" inadequately  supported.   The  community  type is  important  when
        considering sites.  There  is  more live bottom  in the  nearshore  10-30 m
        depths than in 70 m depth off Tampa Bay.

5-32    Page 2-15, line 1.  Long line fishing does occur  in this  area.

        Page 2-16, lines 22-24.  The, Hirsch et al. (1978) statement  is  irrelevant
5-33    to the area off Tampa Bay in depths of 16-30 m.  Live bottom communities
       . are not unstable and are not sedimentary.

        Page 2-17, lines 1-3.  The lack of addressing the effect  of  fine -silt-like
5-j4    sediment chronically deposited over a long period of  time on live bottom
        habitat is of more concern than mixing different  types of  sediments..

        Page 2-19, lines 9 and 10.   Interim  site A  had  a considerable  amount of
5-35    live bottom.

        Page 2-19, lines 20-24.  The video tape was only a  small portion of the
        entire site.  No side scan sonar or seismic  survey of the area  was  made.
        Symetrical sampling with box cores is inadequate  to discover  live bottom.

        Page 2-21.  Amenity Areas.   Egmont Key  and  Passage  Key,  at  the mouth of
 (. ,7    Tampa Bay, are National Wildlife Refuges with nesting  sites  for  endangered
        species  (Loggerhead turtle)  and species  protected by  statute (brown
        pelican).  Least terns, black skimmers and laughing gulls  also  nest on
        these islands.

 5 _„   Page 2-21, lines 18 and 19.  U.S.  Fish and Wildlife Service  1982 identifies
        reef (live bottom) areas in the area,  with red  grouper, cobia, grunts,  gag
        grouper, and sea bass.

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        United States  Environmental Protection Agency
        Page five
        7 December 1982


        Page 2—22, line 2.   The  survey was inadequate  to confirm  that major  live
5-39     bottom areas do not  occur within the site.

5-40     Page 2-24, paragraph 2.  What is the source for  this information?

        Page 2-24, paragraph 3.  Site A has received 4.4 million yd-', Site B
        received its volume  over 5 years and the total was 1,020,000 yd^.
5-41     There is no evidence to  insure that the mound at Site A won't remain.   Some
        of  the  material is  rock  1  ft  or more  in diameter.   It  will  take very
        dynamic seas to move it.

        Page 2-25, paragraph 2.  The dredge disposal  sites are in  40 ft depth  or
        greater.  This is not a  "high energy environment" with  the  exception  of  a
5-42     hurricane passing closeby.

        Page 2-25, paragraph 3.   It  is not  valid to  compare  eastern Gulf sites
        containing live bottom communities with a sedimentary site  off Galveston,
        Texas.   Furthermore, Taylor's (1982)  work was  largely  restricted  to
        soft-bottom infaunal recovery; he  did not  quantitatively look at  live
        bottom or hard bottom communities.  The nine—year temporal parameter is not
        a valid figure for the live bottom situation.   Experience  in coral reefs
        may be extrapolated  for  time-estimates.  Grigg and Maragos (1974) reported
        a time period  of 20  to 50 years for recovery following lava flows. Pearson
        (1981) reported in reference to reef recovery "The situation is not clear,
        following man-made disturbances, where the environment may  have  undergone
        permanent change."   Pearson reported that following natural disturbance,
        coral communities reguire several decades to recover. " ^

        Page 2-25, paragraph 4.  What research substantiates  the  claim that  "no
        major differences in finfish and shellfish species or  numbers  have  been
5 44    found between  stations within the affected site and control stations."?
        The 1979b cited report is  a  EIS for  port and  crude oil distribution  in
        Galveston, Texas.  It  is irrelevant to the Tampa Bay disposal sites.

        Page 2-27, last paragraph.  Many of the studies cited are not applicable,
        they are restricted  to Tampa Bay and not the nearshore Gulf (Saloman 1973);
        others are not  included in  the references  (Saloraan and  Saloman et  al.
5_45    1968).  The Smith et  al. (1975), Dawes and van  Breedveld (1969), through
      •  Huff and Cobb  (1979)  are not ecological studies  of the  area in  question.
        Smith et al.  (1975)  is a study of Florida Middle  Ground fish and Cairns
        (1977) is a taxonomic-systematic account of  Caryophyllid-Dendrophyllid
        Scleractinia from the Hourglass  Cruises.

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          United Scaces  Environmental Protection Age. :;
          Page six
         . 7 December 1982


         . Page 2-28, paragraph  2.   The area also contains  live  oottom  communities.
c_45      It is not a high  energy  environment.   The Holliday  1978 report  does not
          contain any data  about Tampa Bay nearshore environments.

          Page 2-29, conclusion 4.  The studies were insufficient to  insure that
5-47      major live bottom assemblages do not occur in  the Site  4  area.

          Page 2-32, line 14.   This  1980 survey must be a  typo; this  is  the  first
          mention of it, and  it is  not in the references.   Monitoring guidelines fail
          to address live bottom biota.  This is the most  sensitive community.   Both
5_48      Courtney et al. (1974) and Griffin (1974) have guidelines for monitoring
          and protecting reef type  habitats in and around  dredging operations that
          should be used here.

          Page 2-33, line 15.   The  statement "—(hard and  soft  corals)  are  expected
          to occur, only to  a  limited extent,  in the selected site; a  survey to
          assess these species  need not be made." is wrong.   First, on  the  basis  of
          your cursory field  study, you have no idea of coral  abundance within the
          area.  Secondly,   to  write them off  is  a poor  and  indefensible  option.
5-49      Florida statute (370.114) and proposed  federal  fishery management plan
          regulations (Gulf of  Mexico and South Atlantic Fishery  Management Councils)
          make  it  illegal  to  harvest;,  sell,  or  destroy  stony corals (orders
          Milleporina and Scleractinia) and  the sea fan Gorgonia.  It would seem
          rational  that  your  guidelines  reflect  Florida law  and  the Fishery
          Management Councils concern regarding the value  of coral  and its  intrinsic
          habitat value.

          Page 2-34, lines  16,  17.  Benthic sessile epifauna  is more sensitive than
5-50      the infauna.  Attached epifauna is unable to leave  the  area.

          Page  2-34,  lines 17, 18.   The  numerically  abundant organisms on  live
          bottoms can be observed  and censused in situ and monitored for  change  as
5-51      well as infaunal  populations.

          Page 2-35, paragraph  1.   It would appear  that  several  macroinvertebrates
          are found in the  area that could serve for trace  metal  accumulation study.
5-52      The arc Noetia ponderosa, starfish Astropectin,  and Echinaster, and several
          Holothurian species are  common and remove nutrients from  the  sediments  or
          s'ediment water interface.

          Page 3-8,  paragraph 4. .Sediments of Tampa Bay are  from previous  time,  the
 <- co      kay at present is not creating any appreciable sediments  (Brooks,  1973  and
 °'53      Doyle and Sparks  1980).

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        United States Environmental  Protection Agency
        Page seven
        7 December 1982


5_54    Page 3-30, third line from the bottom.  Sessile  epibenthic  organisms  are
        better indicators than infauna.

        Page 3-29 follows page 3-30.

5-55    Page 3-32.  Change Gymnodinium breve to Ptychodiscus  brevis,  see Steidinger
        (1979).

        Page 3-43, line 3.  The corals are colonial  and solitary.  These outcrops
5-56    also support a diverse assemblage of sponges, bryozoans,  tunicates, all of
        which are sessile and provide  habitat for many mobile organisms.

        Page 3-43, line 27.  The corals  Cladocora arbuscola and  Solenastreas hyades
5-57    are not Alcyonarians, they are Scleractinians.

        Page 3-47, paragraph 1.  You'should include  information  on  the  economics of
5-58    bait, gas, boats, supplies,  ice,  diving,  and other  service  industries that
        are fishing and boating related.

        Page 3-47, paragraph 2.  Spotted  sea  trout  is not a  fish found in  the
5-59    dredge spoil area.

        Page 3-48.  Landing statistics for shrimp are misleading,  Tampa-St. Pete
        landings include harvest from  Tortugas,  Ft.  Meyers, Texas,  and  at one time
5-60    Mexico.  Vessels fish many areas  far from these ports.
                                                                         «
        Page 3-51, paragraph 3.  Egmont Key  and Passage Key  are U.S. Fish and
5-61    Wildlife Service Wildlife Refuges.

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                                                                                     \
Uniced 5:__.
Page eight
7 December  191',2
. r-j;-..7!>.nial Protection Agency
                               LITERATURE CITED
Brooks,  H.K.
  1973.   Geological  Oceanography  pp.  II, El to  IIE50, in^ A  summary of
         knowledge of the eastern Gulf  of Mexico.   Coordinated  by State
         University  System of Florida,  Institute  of Oceanography,  St .
         Petersburg,  FL.

Cairns,  S.
  197.9.   The  deep-water  Scleractinia  of  the Caribbean Sea and  adjacent
         waters.  Vitgaven Natuurwetenschappelijke  Studiekring voor
         Suriname en  de Nederlandse Antillen 96.   341 pp.

Courtenay,  W., D. Herrema, J. Thompson,  W. Azzinaro,  and  J. van  Monfrans.
  1974.   Ecological monitoring of beach erosion  control projects,  Broward
         County, Florida, and adjacent areas.  U.S. Army  Corps of Engineers
         Coastal Engineering Research Center,  Tech. Mem.  41, Ft.  Belvior,
         VA.  88 pp.
Doyle,  L.,  and T. Sparks.
  1980.  Sediments of Mississippi, Alabama,  and  Florida.
         50(3): 905-916.
                                        J.  Sed.  Petrol.'
Griffin,  G.
  1974.  Dredging in the Florida Keys.  A  case history of  a typical
         dredge-fill project in the northern Florida  Keys—effects on water
         quality,  sedimentation rates, and biota.  Harbor Branch  Foundation
         Publ. 33.  Ft. Pierce, FL.  67 pp.

Grigg,  R., and J.  Maragos.
  1974.   Recolonization of hennatypic  corals  on  submerged lava flows in
         Hawaii.   Ecology 55:  387-395.
Pearson,  R.G.
  1981.   Recovery and recolonization of coral  reefs.
         4:   105-122.
                                   Mar. Ecol.  Prog. Ser.
Steidinger,  K.A.
  1979.  Collection, enumeration, and identification, of  freeliving
         Dinoflagellates,  pp. 435-442  in  D. Taylor  and  H. Seliger  eds.
         Toxic dinoflagellate blooms.   ETFevier, North Holland, NY.

U.S.  Fish and Wildlife Service
  1982.   Gulf coast ecological inventory.   Biological  Services  Program
         FWS/OBS 82/55.  1 User guide,  22 maps.

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                                                                                    tempo bay
                                                                                       regional
          December  13,  1982
                                                                                        council
          Mr. Jonathan  Amson
          D. S. Environmental Protection Agency
          Criteria and  Standards Division  (WH-585)
          401 M Street,  S.W.                                                     9455 Koger Boulevard
          Washington, D. C.  20460                                               Si Petersburg.FL33702
                                                                            (813) 577-5151/Tampa 224-9380
          Dear Mr. Amson:

          Subject:   TBRPC A-95 Clearinghouse Review #218-82; Draft Environmental
                     Impact Statement (DEIS) for Tampa Harbor,  Florida,  Ocean Dredged
                     Material Disposal Site Designation, Hillsborough, Manatee and
                     Pinellas Counties

          Pursuant to OMB Circular A-95, the  Tampa Bay Regional Planning Council is
          conducting a  review of the above referenced DEIS  and,  based upon the
          December  13,  1982 required response date,  submits the  following preliminary
          comments  as  related to the document's specific  recommendations regarding
          the designation of Alternative Site 4:

          •  The DEIS lacks  sufficiently detailed evaluation and comparisons of all
g_j          possible  alternatives including  diked disposal islands  and upland dis-
             posal areas.

          •  The designation of Alternative Site 4 for disposal of dredged material
             from the  Tampa Bay Area should be  based on more detailed studies of  this
             area.   The DEIS lacks 'site specific studies evaluating  the impacts on
5_2          marine environment and economy of  the region.   The results  of  the
             studies done in other' locations cannot serve as  the base  for evaluating
             the impacts of the proposed dumping of  dredged material on the proposed
             site.

          •  The environmental consequences of dumping dredged sediments on sand-
             subs tate  habitats also cannot be predicted based  on the results of the
6-3          studies from other locations. The ecosystem of shallow-waters in cen-
             tral-southwest Florida  is  different from  the continental O. S. waters.

          •  Information pertaining  to  tidal currents is  needed based on records
6-4          obtained from  the  tide  guage  station located in  Egmont Key.

          •  The monitoring program has not been specifically designed to determine
              whether disposal at  the selected site significantly affects areas out-
              side the site  and  to detect long term  effects occurring in or around the
6-5           site.   It is stated in the DEIS  that  a monitoring program may be  estab-
              lished to  supplement historical data.   Details on what the monitoring
              program will entail must be  included.
           Chairman Jan K. Platt       Vice-Chairman George McGough       Secrelary/Treasurer Saundra Harm          w.A. Ockunzzi
       Commissioner. Hillsborough County        Mayor, City of Largo          Councilwoman. City ol Bradenton        Executive Director

        Sradenton « Clearwater « Dade City • Ounedin • Gulfport « Hillsborough County « Largo • Manatee County « New Port Richey • Oldsmar « Palmetto

          • Pasco County • Pinellas County • Pinellas Park • Safety Harbor • St. Petersburg • St. Petersburg Beach « Sarasota • Tampa • Tarpon Springs

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           Mr. Jonathan Amson               -2-               December 13,  1982
           •  The recreational and commercial fishing values of the surrounding area
              should be identified as well as the impacts of ocean disposal on migra--
°~°           tory fishing.   •

           •  It is stated that dispersion of disposal material outside the site
              boundaries will be over time and in thin layers,  and that such disper-
              sion is not expected to have unacceptable adverse environmental impacts.
... 7           Specific studies need to be completed  to  determine whether the thin
              layer of siltation adversely impacts the surrounding hard bottoms
              (corals).

           It is the opinion of the Council staff that the DEIS' is inadequate in
           detail on the above issues and should be  sufficiently documented prior to
           designating the most environmentally and economically acceptable location
           for disposal of large volumes of dredged  material.   The  amendments should
           include the feasibility of other possible alternatives,  including diked
c_o        disposal islands and upland disposal areas.   The Council staff does not
           support the identified ocean disposal areas located offshore due to the.
           potential destruction of wetlands.  If the revised studies of viable alter-
           natives prove that Alternative Site 4 is the most environmentally and
           economically acceptable location, both in the ocean and on land, then it is
           the opinion of the Council staff that a very stringent monitoring program
           should be established to trace the future changes caused by the disposal
           action.

           In conclusion, the final recommendation of the DEIS for Tampa Harbor which
           designates Shallow—Water Alternative Site 4 as the Tampa Harbor ocean
           dredged material disposal  site is not consistent with the Council's adopted
5_g        policy to support the maintenance of Class III Waters, including bays,
           rivers, lakes, estuaries and open waters of the territorial sea, at a
           quality sufficient to allow body-contact water sports and propagation of
           fish and wildlife.   (Future  of  the Region,  2.402)

           The above comments by the staff of the Tampa Bay Regional Planning Council
           are preliminary  and are  subject to approval by the  Council's Clearinghouse
           Review Committee and final approval  by the  Council's full policy board.
           Additional local and regional comments will be forthcoming upon the January
           3, 1982 meeting of the Council's Clearinghouse Review Committee.  As dis-
           cussed, the copy of the draft Clearinghouse report will be submitted to you
           prior to the meeting.  This format is necessary because, as noted in our
           November 19, 1982  letter to you, TBRPC was not included, as required by OMB
           Circular A-95, on  EPA's initial request for  comments, and therefore, did
           not obtain a copy  of the document until November 22,  1982.  Finally, any
           local comments received from interested parties in the Tampa Bay Region
           will be forwarded to EPA immediately upon our receipt.

           We appreciate  the opportunity to review this important DEIS and hope our
           comments  are helpful to you in preparing the  final  EIS for the Tampa Harbor

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Mr. Jonathan Amson              -3-               December 13,  1982
Disposal Site Designation.  Should additional clarification be necessary,
please contact Ms.  Margaret Guy of the Council's staff.

Sincerely,  /   f
    fil/  
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                                       UNITED STATES DEPARTMENT OF  COMMERCE
                                       National Oceanic and Atmospheric Administration
                                       Washington. D.C. 20230

                                       OFFICE OF THE AD'Viii\'iST = aTCS
                                       December 16,  1982
Environmental Protection Agency
Criteria and Standards Division  (WH-585)
401 M Street, SW, Room 2824
Washington, D.C.  20460

Dear Sir:

     This is in reference to your dratft environmental  impact statement
entitled "Tampa Harbor, Florida, Ocean Dredged  Material  Disposal  Site
Designation."  Enclosed are additional comments from the National  Oceanic
and Atmospheric Administration.

     Thank you for giving us an  opportunity  to  provide comments.

                                    Sincerely,
                                     Toyce M.  Wood
                                    'Chief
                                    Ecology and  Conservation Division
Enclosure

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                           V
                                              UNITED STATES DEPARTMENT OF COMMERCE
                                              National Oceanic and Atmospheric Administration
                                              OFFICE  OF MARINE  POLLUTION ASSESSMENT
                                              Rockville, Maryland  20852
       To:       PP/EC - Joyce Woo
7-1
From:     RD/MP - R.  Lawrence Swanson

Subject:  DEIS 8211.02 * Tampa BarBor, Flortda, Ocean Dredged Material Disposal
          Stte Destgnati'on

     This DEIS appears to be adequate to support the proposed ocean
disposal of dredged material.  The material  to be dredged is not severely
contaminated and should not cause any major  disruption  of the shelf
ecosystem beyond that due to turbidity and burial.  The monitoring
program outlined on pp 2-31 to 2-35 is a good one and should be continued
for a least several  years after disposal begins.   It should include con-
tinued sampling of the dredged material  itself to insure that there is
no major change in constituents.  On a more  general  level,, tnere should
be extensive coordination within and among the various  COE Districts to
insure intercomparibility of monitoring results.   The relative suitability
of the many present ocean disposal sites now being designated could then
be assessed, and the results used in the planning of future disposal
actions.

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                                        STATE OF FLORIDA
                  DEPARTMENT OF  ENVIRONMENTAL REGULATION
8-1
8-2
8-3
                                                                                BOB GRAHAM
                                                                                 GOVERNOR
                                                                         VICTORIA J. TSCHINKEL
                                                                                 SECRETARY
                                                                   DFC 17
TWIN TOWERS OFFICE BUILDING
2600 BLAIR STONE ROAD
TALLAHASSEE, FLORIDA 32301-8241
             December 17, 1982
            Mr. Walt Kolb
            Senior Governmental Analyst
            Office of Planning and Budgeting
            Office of the Governor
            415 Carlton Building
            Tallahassee, Florida   32301

            Dear Walt:
                Re:  Draft Environmental Impact Statement,
                     Tampa Harbor, Florida, Ocean Dredged
                     Material Disposal Site Designation

       We  have  reviewed the referenced document and offer the following comments.

       Essentially, the selection of a preferred alternative was based upon the
       tangible considerations of distance from shore (transport costs) and
       prevalence of hard bottoms.  Most of the potential ecological impacts,
       particularly long-term effects, are not weighed as strongly since they
       are less quantifiable and less studied.  Further, the conclusions presented
       in  the text are based upon information contained in appendices which
       were not included with the DEIS.

       The alternatives evaluations are understandably sensitive to the presence
       of  hard  bottoms, but this is not the only important component of live
       bottoms. Soft live bottoms are viable and vulnerable components of the
       ecosystem, too.  The characterizations on p. 2-19 do not discuss the
       biological characteristics of the Site 4 bottoms.  The only information
       given is geophysical, primarily noting fewer areas of hard bottom lithotype
       than alternative sites.

       While the DEIS asserts that recovery for soft bottoms is certain, many
       qualifications must modify these expectations.  This is a relatively
       unstudied topic with wide variability in results and predictions.  One
       of  the main factors repeatedly mentioned as a facilitator of recolonization
       by  non-opportunistic species is the similarity between the disposed
      "material and bottom sediments.  The dredged material proposed for disposal
       is  a finer material than the. recipient bottoms of Site 4.
                           AN EQUAL OPPORTUNITY / AFFIRMATIVE ACTION EMPLOYER

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            Mr. Walt Kolb
            Page Two
            December 17, 1932


            The distribution of  a discharge plume  at  sea  is unpredictable.   It  is
            not unrealistic to consider  the possibility of a  several mile  impact
            distance  (p. 2-26).   Entrainment  of pollutants is  even  less predictable.
            Some of these  pollutants will be  anthropogenic with  a greater  probability
            for persistence in the environment.  Dissolution may result in or contribute
8-4         to localized high nutrient concentrations, one of  the assumed  preconditions
            for red tide blooms  (p. 4-8) ..  Dissolved  contaminants may  also effect
            chronic, sublethal damages to biological  populations through interference
            with chemoreception.

           • The pile formed on the ocean floor may also spread and  slough  onto
            adjacent bottoms.  During the period that affected bottoms are devoid of
8-5         benthic organisms, their contributions to water quality, habitat and
            bottom stability are  lost.

            The combined results  of all  these potential effects  of  the proposed
            disposal will  operate on fishery  resources dependent upon  an intact
8-6         ecosystem.  Again, the full  extent of  these effects  cannot be  quantified
             (p. 4-22).

            It is a reflection of the complexity of the marine environment that many
            of the above impacts  are difficult to  assess  with  fixed numbers.  It is
            also a reflection of  the sensitivity of this  delicately balanced ecosystem
            that some degree of  all these impacts  can be  expected to result  from a
            perterbation such as  dredged material  disposal.  A difficulty  in quantifying
8-7         effects should encourage a cautious approach  to the  use of Gulf  coastal
            waters for  dumping grounds.  Also, this activity would  only be one  of
            many degrading influences operating on area environmental  quality.  It
            is myopic to continue to expect infinite  capacity  out of a finite waterbody.
            Dilution does  not solve environmental  contamination.

            Another long-term consequence of  the proposed dumping is the waste  of
            the material itself.   We continually lose upland  and nearshore sediments
            to erosion  to  the extent that we  should not discard  useable material.
            We recognize the magnitude and complexity of  dredged material  disposal,
8-8         but cheaper and quicker options are not always better economically  or
            environmentally.  Planning for port development,  expansion and maintenance
            should include consideration of appropriate,  conservative  disposal
            methodologies.  Upland disposal and recycling of previously used sites
            should be given the  highest  priority.

            On November 5, 1982,  we advised the EPA of the state's  concerns  for
            proceeding  with site  designation  and rule-making without benefit of the
8-9         federal consistency  review prescribed  by  the  Coastal Zone  Management
            Act.   (see  attached  correspondence.)   To  date, we  have  received  no  reply

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Mr. Walt Kolb
Page Three
December 17, 1982
or submission of consistency findings.  We reiterate our request for
attention to these federal requirements as soon as possible.

                                        Cordially,
                                        Lynn F.  Griffin
                                        Environmental Specialist
                                        Intergovernmental Programs
                                          Review Section
LFG/jb

cc:  Dave Worley
     Terry Cole
     Steve Fox
     Ann Berger-Blundon
     Elton Gissendanner

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November 5, 1982
Mr. T. A. Wastler, Chief
Marine Protection Branch (WH-585)
Environmental Protection Agency
Washington, D.C.   20460

Dear Mr. Wastler:

          Re:  Proposed Rule for Ocean Dumping, Gulf of Mexico

On review of the Federal Register (Vol. 47, No. 194), we note that the
EPA is proposing certain dredged material disposal site designations
pursuant to 40 CFR Part 228.  Specifically, the proposed rule would
extend the interim designation of Site A, which is currently being used
for the Corps of Engineers' Tampa Harbor Project, Section 2C materials.
Additionally, interim approval of a new site, Site 4, is proposed, which
would accommodate the remaining dredged materials from this project.  A
permanent ocean disposal site, not necessarily one of these, will be
designated through an Environmental Impact Statement review.

Adoption and implementation of the proposed rule enables an activity to
be conducted in an area in and surrounded by abundant marine resources
of significant importance to recreational and commercial enterprises in
Florida.  Under the federal Coastal Zone Management Act, federal activities
directly affecting the coastal zone of a state must be conducted in a
manner consistent to the maximum extent practicable with the approved
state coastal management program.  The EPA is required under 15 CFR
Section 930.33(c) to evaluate the full extent of these direct effects
and, subsequently, prepare a federal consistency determination for the
state's review and comment.

We, therefore, request that these findings be submitted to the Florida
Department of Environmental Regulation and/or the Governor's Office of
Planning and Budgeting, Natural Resources Policy Unit as soon as possible.
As appropriate, we expect the federal consistency review to precede

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Mr. T. A. Wastier
Page Two
November 5, 1982
final adoption of the proposed rule as specified in Section 930.34 of
the federal regulation.  We understand that ample tine is available
under the rulemaking and NEPA processes to accommodate this compliance
requirement.

                                        Sincerely,
                                        Terry Cole
                                        Assistant Secretary

TC/lgb
ccs  William Matuszeski
     Ann Berger-Blundon
     David Worley
     Elton Gissendanner
     Torn Herndon

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                                                                                tompa bay
                                                                                   regional
                                                                                   planning
                                                                                     council
                                                                       \ T ~^X   s	
    December  22,  1982
                                                                              9455 Koger Boulevard
                                                                             St Petersburg. FL 33702
                                                                        (8 1 3) 577-5 1 5 1 /Tampa 224-9380
    Mr . Jonathon Amson
    U.S. Environmental Protection Agency
    Criteria  and Standards  Division  (WH-585)
    401 M Street, S.W.
    Washington,  D.C.  20460

    Dear Mr.  Amson:

    Subject:   Tampa Bay  Regional Planning Council A-95  Clearinghouse  Review  No.
               218-82; Draft Environmental Impact Statement  (DEIS)  for Tampa
               Harbor,   Florida,  Ocean Dredged  Material  Disposal  Site
               Designation,  Hillsborough, Pinellas and Manatee Counties

    As referenced in my December 13,  1982 correspondence, enclosed  for your
    information is a copy of our draft  Clearinghouse  report  and recommendations
    concerning the  above referenced project.   The Tampa Bay Regional  Planning
    Council's  Clearinghouse Review Committee will consider  this  report  at its
    January  3, 1983 meeting.

    Should additional clarification  be necessary, please  contact me.

    Sincerely,
    Michael R.  McKinley
    Director  of Planning^/

    MRM/kh

    Enclosure
    Chairman Jan K. Plan        Vice-Chairman George McGough       Secretary/Treasurer Saundra Rahn          w.A. Ockunzzi
Commissioner, Hillsborough County        Mayor. City of Largo           Counci/woman. City of Braaenton         Executive Director

  Bradenton « Clearwater • Dade City • Dunedin « Gulfport • Hillsborough County • Largo • Manatee County » New Port Richey • Oldsmar • Palmetto

   • Pasco County « Pinellas County • Pinellas Park • Safety Harbor • St. Petersburg • St. Petersburg Beach « Sarasota • Tampa • Tarpor, Springs

-------
                                                                 Agenda  Item #11A
    A-95 #218-82; Draft Environmental Impact Statement (DEIS) for Tampa
    Harbor, Florida, Ocean  Dredged Material Disposal Site Designation,
    Hillsborough, Pinellas and Manatee-Counties - —  -•-
The U.S.  Environmental Protection Agency  (EPA) has requested review and
comment  on the draft Environmental Impact Statement (EIS) for Tampa Harbor,
Florida  which presents  information necessary for the designation  of a new
Tampa  Harbor Dredged Material Disposal Site.  The purpose of the  action is
to provide the  most environmentally and  economically  acceptable ocean
location for the disposal of material dredged from the Tampa  Bay area.
Based  on recent surveys of four Shallow-Water Alternative Sites,  EPA has
determined that Shallow-Water Alternative  Site 4 is the  alternative with
the fewest hard-bottom areas which may be affected by the  disposal of
dredged  material.  It is  the  recommendation of  the DEIS  that Alternative
Site 4 be designated as the disposal site location for dredged  material
from the Tampa  Bay  area.  Agency - EPA;  Location - Hillsborough,  Pinellas
and Manatee Counties.

                      Local Comments Received From;

Hillsborough County Environmental Protection Commission:  See  attached
  letter dated December 5,  1982.

Hillsborough  County  Department of Development Coordination:  See attached
  memorandum  dated December 3,  1982.

Pinellas County  Planning Department:  No comment received as  of  December
30, 1982.

City of  St.  Petersburg Planning Department:  See attached letter dated
  December 16,  1982.    -  .

Manatee County Board of County Commissioners:   See attached letter dated
  December 13,1982

Mote Marine Laboratory:   See attached letter dated December 9,  1982.

Gulf of Mexico Fishery Management Council:  See attached letter dated
  December 10, 1982.

Office  of the Governor:   See attached letter dated December 22, 1982,

                  Council  Comments and Recommendations

This project  has been reviewed for consistency with the Council's  Areawide
Water Quality Management Plan and the Council's adopted  growth policy,  the
Future of the Region.  The proposal has not been found  to be consistent
with Council policy that a standard of  water quality should  be achieved
that allows  for the protection  and propagation of fish,  shellfish, and
wildlife  and  provides for recreation in and on the waters  in the region.
                 tampa bau regional planning council
      9455 Koger Boulevard  St Petersburg, Ft 33702  (813) 577-5151-Tampa 224-9380

-------
       This project is regionally significant "and the following local and regional
       concerns have been raised during the review:

       •  The staff of the Tampa Bay Regional Planning Council has reviewed the
          Draft Environmental Impact Statement (DEIS) for Tampa Harbor Ocean
          Dredged  Material Disposal Site Designation and offers the following
          comments:

          General Comments

          1 .  The DEIS lacks sufficiently  detailed  evaluation and  comparisons of
9-1           all possible alternatives including diked disposal  islands and
              upland disposal areas.

          2.  The  designation of  Alternative Site 4 for disposal  of dredged
              material from the Tampa Bay Area should be based on more detailed
              studies of  this area.  The DEIS lacks  site specific studies evaluat-
              ing the impacts on marine environment and economy  of the region.
g_2           The results of the studies done  in other locations  cannot  serve as
              the base for evaluating the impacts of the proposed dumping of
              dredged material  on  the proposed site.

          3.  The environmental consequences  of dumping dredged sediments  on sand-
              subs tat e habitats  also  cannot  be predicted based on  the results of
              the studies from  other  locations.  The ecosystem of  shallow-waters
9-3           in central-southwest  Florida is  different from the continental U.S.
              waters.

          4.  Information pertaining to tidal currents  is  needed based on records
9-4           obtained from the tide guage  station located in Egmont Key.

          5.  The monitoring program  has not been specifically designed  to deter-
9-5  •         mine whether disposal at the selected site significantly affects
              areas outside the  site and to  detect long term effects  occurring in
              or around  the site.  It is  stated in the DEIS that a monitoring
              program may  be established  to supplement historical  data.  Details
              on what the monitoring program will entail must be included.

          6.  The recreational  and commercial  fishing values of  the surrounding
g_g           area should be identified as  well as the impacts of  ocean disposal
              on migratory fishing.

          7.  It is stated  that dispersion  of  disposal  material outside the site
o_7           boundaries will  be  over time and  in thin  layers,   and that  such
              dispersion  is not  expected to have  unacceptable adverse environmen-
              tal impacts.  Specific studies need  to be completed to determine
              whether the thin layer of siltation adversely impacts  the  sur-
              rounding hard bottoms (corals).

          Specific Comments

n_o       1.  Statements that  there are no hard-bottom  habitats within  or in
              proximity to Site 4 are  not well-documented.   More extensive inspec-
              tion of areas both within and around the site is necessary before it
              can be  known what types  of organisms  and communities will-be

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              adversely affected by dumping.  In-depth surveys to determine the
     .. .— -   nature and extent of live,  hard-bottom habitats  in or near the  site
              should be further  conducted.

          2.   It is stated in DEIS that  results of dredged material disposal at
              the Tampa Harbor alternative sites are anticipated to be  similar to
              the results  of disposal  operations  at Calveston,  Texas  (page 2-28).
              However,  the West  Florida Shelf cannot be compared with  other areas
              which have no hard-bottom  communities.   The conclusions  that dispo-
              sal will  not result in any  detectable  changes in ecology  of the  area
              are inappropriate.

          3.   An assessment of the siltation and  turbidity caused by resuspension
              of fine particles by waves,  storms and tides has not been completed,
q in      "as well  as  the  expected impacts of  the siltation on live-bottom
              habitats.

          4.   The long-term effects  from  the continual resuspension of spoil
              material  throughout the water  column  have  not been  adequately
              studied nor  documented.  The amount and frequency of siltation,  the
q .-          direction of sediment transport based  on site-specific ocean  current
              information,  and  the environmental  consequences of long-term  tur-
              bidity should be estimated before final recommendations are made.

          5.   It is  stated in the DEIS  that  Site 4  is  removed  from areas of
              recreational  use,  and  has  no  known significant commercial  fishery
              use (page 2-27).  This  statement  is  not based on the detailed survey
              of commercial and recreational fishing activities of  this area.
q .,,          Relevant studies  should be completed based on public  testimony
              whether the  proposed action affects the  recreational  activities of
              the region and commercial fishing.
9-13
          6.   Cost-benefit analysis,  taking into account the direct and indirect
              economic  benefits generated by the recreational use  of  this part of
              the Gulf of Mexico have not been done at this time.
          7.   A public  hearing  should be scheduled to allow  full and fair public
q ,.         'comment in the  draft  EIS and the overall suitability  of dumping in
              the  Eastern Gulf of Mexico.

       •  The  Manatee County  Board of County Commissioners has  provided extensive
          comments which already have been forwarded to EPA and are summarized
        •  below (see  attached letter dated  December 13,  1982) regarding the Draft
          EIS  for a permanent ocean  disposal site for Tampa Harbor:

          1.   The  EPA survey upon which the EIS relies  to recommend Site 4 for
              permanent designation, used survey methodologies that are inadequate
              for  determining the nature and extent of live,  hard-bottom habitats
              in or  near the site; yet, the  entire EIS  rests on  the unproven
Q . j.          assumption that  there  are no hard-bottom habitats  within  or in
              proximity to Site 4.  This is critical because of the well-docu-
              mented importance  of  live-bottom habitats to both commercial and
              recreational fishery resources.

-------
          2.-  Although  the  EIS  notes  that significant damage  that can occur to
              hard-bottom habitats from siltation and turbidity, it completely
              fails to describe  or assess the siltation and turbidity that  will be
QIC          caused by resuspension of fine particles by waves, storms, tides,
              and combinations  thereof, and it fails to quantify the resulting
              siltation problem and its expected impacts  to  corals,  sponges,
              algaes,  and the like.

          3.  The EIS recommendation of Site 4 is based on erroneous and under-
              stated information concerning the use of the  area  in and around the
9_17          site, which is actually located in an area that is heavily  used by
              commercial and recreational fishermen, sport divers,  and others.

          4.  The Site-Designation  EIS presumes  that  ocean dumping is appropriate
              in this part of the Gulf of Mexico, disregarding as a general matter
              the high potential for damage from burial and siltation to the  hard-
9-18          bottom habitats and organisms found  scattered  throughout this part
              of the Gulf,  and  inadequately considering, the  possibility o'f  using
              uplands  or diked  disposal areas on  a short-term basis  pending
              thorough investigation of  the suitability  of  ocean dumping.

          5.  The EIS also relies on erroneous  cost estimates for transporting the
              dredged  material  to various alternative sites,  and there is no
              comparison of the  environmental  "pros and cons" of each  alternative
9-19          site relative  to the  economic costs.

          6.  Finally,  with respect to the EIS's cost analyses,  the EIS fails to
              take any account of the direct or indirect economic benefits gen-
              erated by the recreational use of this part  of the Gulf of Mexico,
9-20          thereby placing too-heavy  emphasis on  the  immediate costs of spoil
              transportation.

          Therefore,  in light of  the many deficiencies of the Draft EIS, including
          reliance on erroneous  assumptions,  inadequate surveys, and incorrect
          infomation,  the Board of County Commissioners of Manatee County requests
9-21      that a public hearing be scheduled to discuss the Draft EIS and proposed
          site designation, or,  in the alternative,  that  the Draft EIS be with-
          drawn and subsequently  resubmitted for public comment.

       •  The staff of  the Hillaborough County Environmental Protection Commission
          has reviewed  the  Draft Environmental Impact Statement  (EIS)  for Tampa
          Harbor:  Ocean Dredged Material Disposal Site Designation and submits
          the following comments and recommendations:

             It is  recommended that all disposal at the Existing Site A be
             stopped  because it  is  too close to shore, too  close  to produc-
9-22         tive reef  areas, and within easy reach of divers  and small boat
             users.

             Site 4 is in 85 to 95 feet of water and is not as likely to be
             used for  recreational purposes  such as diving and fishing.  All
9-23         material  should go  to  this  site until  some long  range solution
             is  found.

-------
          Site 4 has no hard-bottom outcrops and would therefore have the
9-24      least impact on fish and other  types of life.
                                        s
       • '  The City of St. Petersburg Planning Department has reviewed the Draft
          EIS for Tampa Harbor:   Ocean Dredged Material Disposal Site Designa-
          tion and recommends  the following additions to the above referenced
          EIS:

              Incorporation of any appropriate review criteria
              which may be  forthcoming  from the pending litiga-
              tion  related  to offshore  dumping initiated by
              Manatee County;

              Analysis of  upland dumping sites;

              Further  analysis  of  Site  4.    It  appears  that
              Appendix C.  (referenced on Page 2-13 of study) may
              provide additional data to substantiate minimal
              adverse environmental impacts.

       •  The Office of the Governor has  submitted the following comments  and
          recommendations regarding the Draft EIS:
                                                    f

              An interagency review  of  the statement has  found
              that the proposed action would smother the benthos
              within the designated area and alter habitat within
              the site.   The  document recognizes that  these
              adverse impacts  at the site are unavoidable.  Our
              reviewing agencies report that the EIS statement is
              inadequate and lacks the necessary information to
              be of sufficient value   as a decision-making  docu-
              ment (see  attachments).

              We have  concerns  with this designated site  and
              EPA's  proposed rule for ocean dumping without  a
              Federal Coastal Zone Management Consistency Evalua-
              tion.  Recognizing our concerns, the impact of this
              designation  and its effect on  the  Tampa Harbor
              project, we request that your agency participate in
              an interagency meeting at your earliest convenience
              to afford us  the  opportunity to discuss issues of
              concern to the State of Florida.  It is our desire
              to use this initial meeting as a step toward  re-
              solving  our  concerns.

      Based on the review of this document, it is the opinion of the Tampa Bay
      Regional Planning Council that no ocean  dumping should  be performed
      until it is demonstrated  that ocean  dumping in this part  of the Gulf of
      Mexico is appropriate and that it is  the most suitable  method of dispo-
      sal.  That demonstration  should include an actual determination of the
9-25  nature and extent of hard-bottom habitats  and  fishery resources in site
      4 and in  surrounding areas.   This  determination should be  based on
      further, site-specific surveys,  including  the direction,  amount,  fre-
      quency,  and distance of sediment transport and siltation, and a specific
      quantification of the damage that will result therefrom.  Also, a de--

-------
              tailed,  careful balancing of the economic versus environmental concerns
              for each alternative method should be performed,  including consideration
              of the  many  commercial aspects of  recreational fishing and diving and
              development of a  thorough monitoring  program  to assess  the impacts of
              any dumping on a long-term basis.

              In conclusion, the final recommendation of the DEIS for Tampa Harbor
              which designates Shallow-Hater Alternative Site 4  as  the Tampa Harbor
              ocean dredged  material  disposal  site is  not consistent  with the
              Council's adopted policy to support the maintenance  of Class III waters,
              including bays,  rivers,  lakes,  estuaries and open waters of the terri-
              torial sea,  at a quality sufficient to allow body-contact water sports
              and propagation of fish  and  wildlife.   (Future bf_ the Region,  2.402)

              It is recommended that Alternative Site 4 not be used as an interim
9-26          dumping  site,  and that all concerned parties meet to resolve identified
              concerns.

           It is therefore  recommended that the above local  and regional concerns and
           recommendations  be addressed in the final EIS for Tampa Harbor.   Further,
           it is recommended that any  additional comments addressing local concern be
           considered  prior  to issuance or approval of the final EIS.
           Committee adopted January 3, 1983
         /Mayor 
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                PEEPLES, EARL, REYNOLDS & BLANK
L. GRANT PEEPLES

WILLIAM L.EARL

ROBERT N. REYNOLDS. P.A.

ROBERT H. BLANK

PAUL H. AMUNDSEN

WILLIAM F. TARR

SANTIAGO G. LEON


MOORE & WILLIAMS, P.A.

 TALLAHASSEE, FLORIDA

    COUNSEL
                            PROFESSIONAL ASSOCIATION

                              ATTORNEYS AT LAW
December 14,  1982
ONE BISCAYNE TOWER, SUITE 3636

TWO SOUTH BISCATNE BOULEVARD

  MIAMI, FLORIDA 33131

     (3OS) 3S8-3OOO
                           3O6 EAST COLLEGE AVENUE
                             POST OFFICE BOX ns9

                         TALLAHASSEE, FLORIDA 333O3
                               (90.4) 222-2136


                                REPLY TO:
                                                          Miami
 Joseph  Freedman, Esquire
 Office  of  the General Counsel
 U.S.  Environmental Protection Agency
 Rm.  538, West Tower
 401  M.  Street, S.W.
 Washington,  D.C. 20460

      Re:  Comments on Draft EIS for Tampa  Harbor Site Designation

 Dear  Joe:

      This will confirm that you have agreed  to a one day extension
 within  which Manatee County can provide comments to EPA's Draft
 EIS  for a  permanent ocean dump site desigation outside Tampa
 Harbor, Florida.  Therefore, Manatee County will file the com-
 ments 'with EPA on December 14, 1982.   I have enclosed a copy of
 Manatee County's comments for your convenience.

      Thank  you very much for your cooperation.

                                 Yours very truly,

                                 PEEPLES, EARL, REYNOLDS & BLANK
                                 William F.  Tarr
                                 For the Firm
 WFT/yp
 cc: Mr.  T.  A.  Wastler

-------
L. GRANT PEEPUES

WILLIAM L.CARL

ROBERT N. REYNOLDS, P.A.
ROBERT H. BLANK

PAUL H. AMUNDSEN
WILLIAM F. TAHR

SANTIAGO G. LEON


MOORE S WILLIAMS, P.A.
 TALLAHASSEE, FLORIDA
    COUNSEL
PEEPLES, EARL, REYNOLDS &
            PROFESSIONAL ASSOCIATION
              ATTORNEYS AT LAW


             December 13, 1982
 ONE BISCAYNE TOWER, SUITE 3636

 TWO SOUTH BISCAYNE BOULEVARD

   MIAMI, FLORIDA 33131

     (3OS) 358-3OOO
   3O6 EAST COLLEGE AVENUE
    POST OFFICE BOX 1139

TALLAHASSEE, FLORIDA 323O2
        ) aza-aise
                                                           REPLY TO:
                                                          Miami
  Mr. T. A. Wastler
  Chief, Marine  Protection
    Branch  (WH-585)
  Environmental  Protection Agency
  401 M. Street  S.W.,  Room 2709
  Washington,  D.C.  20460

      Re:  Comments  on Draft EIS No. 820697, Tampa Harbor Ocean
           Dump  Site Designation; Request for Public Hearing  and
           for Withdrawal o& EIS.	

  Dear Mr. Wastler:

      This   letter   is   furnished   on   behalf  and  under  express
  authority of the Board  of County Commissioners of Manatee County,
  Florida,  to  provide  comments  to  the Environmental Protection
  Agency  (EPA) on  its Draft Site-Designation EIS  for  a permanent
  ocean  dump  site  outside  Tampa  Harbor.    This  letter  is  also
  provided  to request  a  public hearing  concerning  the  EIS and the
  site-designation  and,  because of  the many deficiencies  in the
  EIS,  to  suggest  that  it  be  withdrawn   and  resubmitted   after
  development  of  more  accurate  information.

      Because  of the County's  proximity to  the dump sites proposed
  in  the  EIS and   the  heavy  use of  the  Gulf  of  Mexico  by its
  citizens  and  tourists,  Manatee  County is  vitally  interested  in
  assuring  that  the most suitable ocean dump site  is selected  (if
  dumping  in  this  part  of  the Gulf  is, in  fact,  appropriate)  in
  order  to protect  commercial  and recreational activities  in the
  marine environment and  the public health,  safety, and welfare.

      In  pursuit of  those goals,  Manatee  County recently  filed  a
  lawsuit  against EPA  and the  Army  Corps of  Engineers,  which was
  joined  in  by the  cities of Anna Maria and  Holmes Beach, seeking
  to  enjoin  the  use of  the  existing Gulf  dump  site approximately
  thirteen  miles  offshore.    An  order  from  the   Court  in  this
  lawsuit, styled Manatee County et al.  v.  Gorsuch et al., Case No.

-------
         Mr. T. A. Wastler
         December 13, 1982
         Page -2-
         82-248-Civ-T-GC  (M.D. Fla.),  is expected  in  the  very  near  future.
         As a  result of that litigation,  a  great  deal of  information  has
         been  developed that  reveals  numerous deficiencies  in the  Draft
         EIS  and  militates  in  favor  of  withdrawing   it   for   further
         consideration.  As you know from  the  taking  of your deposition in
         June  of  1982, the  federal government at  all  times  had at  least
         four  attorneys working  on the  case, and the  same  four  people
         (including  Joseph  Freedman,  Esq., of EPA) were  actively  involved
         all the way through trial.  It is suggested  that you  consult with
         your  legal  counsel to  take advantage of their knowledge of  these
         matters.

             To  summarize  what  is   amply  demonstrated  by   the   below-
         enumerated  specific  comments, the  Draft  Site-Designation EIS  is
         either wrong or inadequate in at  least six general respects:

             (1) The EPA survey  upon which  the  EIS  relies  to recommend
         Site  4  for  permanent  designation, used survey methodologies that
         are  inadequate for  determining   the  nature  and  extent of  live,
         hard-bottom habitats  in or  near the  site;  yet,  the entire  EIS
         rests  on  the   unproven assumption that the4re  are no  hard-bottom
10-1      habitats  within  or  in  proximity  to Site  4.    This  is critical
         because of  the well-documented importance  of live-bottom habitats
         to both commercial and recreational fishery  resources.

             (2) Although  the  EIS  notes  that  significant damage that  can
         occur  to  hard-bottom habitats  from  siltation  and turbidity,   it
         completely  fails   to  describe   or  assess  the  siltation   and
         turbidity that will  be caused by resuspension of fine particles
         by waves,  storms,  tides,  and combinations thereof,  and it  fails
10-2      to  quantify  the  resulting  siltation problem  and  its expected
         impacts to corals, sponges, algaes, and the  like.

             (3) The EIS  recommendation  of  Site 4  is  based  on erroneous
         and understated information concerning the use of  the  area  in  and
         around  the  Site,  which  is actually  located in  an area  that  is
         heavily  used  by  commercial  and  recreational  fishermen,   sport
10-3      divers, and others.

             (4) The Site-Designation  EIS presumes  that  ocean dumping  is
         appropriate in this part of the Gulf of Mexico,  disregarding as a
         general matter the  high  potential for  damage   from  burial  and
         siltation   to  the   hard-bottom   habitats  and  organisms   found
         scattered  throughout this part  of  the  Gulf,  and   inadequately
         considering  the  possibility  of  using uplands or diked disposal
10-4      areas on a  short-term basis pending thorough investigation of  the
         suitability of ocean dumping.
                         PEEPXJES, EAIUL, RETTNTOUDS & BLAJOC
                                  PROFESSIONAL ASSOCIATION

                                    ATTORNEYS AT LAW

-------
     Mr.  T.  A.  Wastler
     December  13,  1982
     Page -3-
         (5)  The  EIS  also relies  on  erroneous  cost  estimates  for
     transporting  the  dredged  material to various  alternative sites,
 5   and there is no  comparison of the environmental  "pros  and cons"
     of each  alternative site  relative to  the economic costs.

         (6)  Finally,  with respect to  the  EIS's cost analyses, the EIS
     fails  to  take  any  account of  the direct  or  indirect economic
     benefits generated  by  the recreational  use  of this part  of the
     Gulf  of  Mexico,  thereby  placing  too-heavy  emphasis  on  the
 _g   immediate  costs of spoil  transportation.

         Therefore,  in  light  of  the  many deficiencies  of  the Draft
     EIS,  including  reliance  on  erroneous  assumptions,  inadequate
     surveys,  and   incorrect  information,   the   Board  of  County
     Commissioners of  Manatee  County requests that a public hearing be
     scheduled  to  discuss the  Draft EIS and proposed site designation,
     or, in  the  alternative,  that  the Draft  EIS  be  withdrawn  and
     subsequently  resubmitted  for  public comment.

         The  following comments are directed  toward specific portions
     of the EIS:

         COMMENT No. 1 — page x,  H 1;

             Non-ocean disposal methods were  considered  by
              the  U.S. Army Corps  of  Engineers  (C.E.,  1974)
              (while   evalutating   the   need   for   ocean
             disposal)  to be  less desirable  than  disposal
              in   the   ocean   because   of   the  quantity   of
             sediments to be  dredged, the  limited  receiving
             capacity of land disposal sites,  and  economic
             and  environmental concerns.


         That statement is erroneous.   In  fact,  the Corps  of  Engineers
     expressly   and    unequivocally  rejected  ocean  dumping   as   an
Q_7   alternative:

             6.05 Consideration  was  given  to disposal  in
             the  Gulf  of  Mexico.    This   would  entail
             covering 6.1 square miles of Gulf  bottom with
             an  average  of  ten  feet of   fill.   This plan
             produced the highest  costs of all alternatives
             considered.   (Final  EIS  at 142).

                  * * * *

             Gulf  disposal  was   ruled   out  because   of
             prohibitive costs.    (Final  EIS  at  page  v) .
                    PBEPXES, EAKL, REYWOUDS & BLANK
                             PROFESSIONAL ASSOCIATION

                               ATTORNEYS AT LAW

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        Mr.  T.  A.  Wastler
        December 13, 1982
        Page -4-
        The  statement  in  EPA's  Draft  EIS  implies  that  the Corps  of
        Engineers carefully examined several  types  of dumping but choose
        ocean dumping.  That clearly was not  the  case.   In addition, the
 IQ_Q    adequacy of the Corps's discussion of alternatives is now subject
        to challenge  in the above-described  lawsuit.   Further comment in
        this regard is provided below.

            COMMENT No. 2 — page 2-3,  fl 2;

                 However,  using Shallow-Water Alternative Sites
                 one  or  four  would  add  only  4-5  nmi  to  the
                 present  round-trip   distance   to   the  Outer
                 Existing  Site ....


            The round  trip  calculation has  apparently  been  cut  in  half
        through  a  clerical or typographical  error.    Testimony  by the
        Corps at trial  indicated  that  the additional distance  to Site 4
        (above and  beyond Site A) was  5.6  nmi one way,  so the round  trip
  lQ_g   distance would actually be approximately 11  nmi.

            COMMENT No. 3 — page 2-4,  11 2:

                      By taking no action, the  present  ODMDS's
                 would not  receive  permanent designation,  nor
                 would  an   alternate   ocean  disposal  site  be
                 permanently  designated.    Therefore,   the  CE
                 would  be   required   to:   (1)   justify   an
                 acceptable alternative disposal  method (e.g.,
                 land-based);      (2)      develop    information
                 sufficient to  select  an  acceptable  site  for
                 disposal  in the ocean; or  (3)  modify  or cancel
                 a  proposed  dredging   project  that  depends  on
                 disposal   in  the ocean  as  the  only  feasible
                 method for the  disposal of dredged  material.

            The next sentence  of the  Draft  EIS then  summarily states  that
        the  "No-Action  Alternative"   in   therefore   unacceptable.   No
        analysis of   the  reasoning  used  to discount   the   three  cited
        factors  is  provided,   and  this passage  suggests that  the  Corps
        should not  be burdened with environmental considerations.   Please
        explain  why   it  is unreasonable  for the Corps  to  "justify  an
10-10    acceptable  alternative disposal method (e.g.,  land-based)," which
        would  present less  environmental  damage  than that caused  to
        sensitive marine  habitats from  burial  and  siltation.   Equally
        important,  explain how it would  be unacceptable to  ask the Corps
        "to develop information sufficient to select  an acceptable site"


                       PEEPLES, EARL,  REYNOLDS &
                                 PROFESSIONAL ASSOCIATION
                                  ATTORNEYS AT LAW

-------
        Mr. T. A. Wastler
        December 13, 1982
        Page -5-
        for  ocean dumping.    Finally,  please  clarify  why  the  proposed
        dredging project  (apparently Section  3B) depends on  ocean dumping
        as  "the  only feasible method,"  when testimony  as  trial  clearly
        demonstrated that  the  diked disposal areas in upper Hillsborough
        Bay  are  closer  to Section 3B than  the  Gulf dump sites;  that  the
        use  of  the  diked  disposal  areas  would  not  have unacceptable
        adverse  impacts  to the environment, in stark contrast  to dumping
        in  the ocean;  that the diked disposal  areas have ample  capacity
        for  handling the  dumping  from Section 3B and other  projects;  and
        that the  cost of  disposing  materials at the diked disposal  areas
        would be approximately the same as  the costs of  ocean dumping.

            COMMENT No.  4 — pages 2-5 to 2-6;

             [See   Block-indented    quotation   of   Corps   of   Engineers
        concerning land-based disposal, dated 1974.]
            Reliance on  this  passage from  the  Corps of  Engineers'  Final
        EIS  for  the  Tampa Harbor Project  is  flawed for  several  reasons.
        First, the Corps quotation was dated  1974,  fully eight  years ago,
        and conditions may well have changed  drastically since  that  time.
        Please specifically reexamine  the  feasibility of upland  disposal
10-11    as   °f   today,   describe   potential  upland   sites  (and   other
        locations) in the  area, and explain why each is  less appropriate
        than ocean dumping.

            Second,  the  1974  decision regarding  land-based disposal  was
        based on  the dumping  of 72.8 million cubic yards of material  to
        be  dredged from  the Tampa Harbor Deepening Project.   Nothing  in
        EPA's  Draft  EIS suggests  that  like-quantities  are  proposed  for
        dumping in the near future, so that the feasibility  of  the use  of
        uplands,  diked disposal areas, etc.,  in the near  future should  be
        reconsidered.    Please describe  the  location  of  all  possible
        upland  disposal  areas and  assess  the  costs  and  enviromental
10-12    benefits  of  -transporting   dredged  materials   to  each  upland
        location versus ocean  sites  and  the diked disposal  areas.   Also,
        please discuss currently  proposed  dredging projects in the  Tampa
        area and  their  current,  projected  scheduling  so the actual  need
        for ocean dumping can be better determined  in the EIS.

            Finally,  as  noted  above, two  diked disposal  areas exist  in
        upper Hillsborough Bay that  are  stated  by the Corps of Engineers
        to contain 15 million cubic yards of capacity.   Although  they  are
        purportedly  slated  to  be  used  for  dumping   from maintenance
10-13    dredging over the next twenty-five  to fifty years, please  explain
        why  they  could  not  be  used  on  a  short-term   basis  as   an
        alternative  to ocean  dumping pending completion of  complete  and
        careful studies of  the feasibility and  suitability  of  particular
        ocean dump sites or other  methods of disposal.

                                , EARJL, REYNOLDS & BLANK
                                 PROFESSIONAL ASSOCIATION
                                  ATTORNEYS AT LAW

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        Mr. T. A. Wastler
        December 13, 1982
        Page -6-
            COMMENT No. 5 — page 2-8, 11 1;

                 It was determined during the initial screening
                 that  areas  immediately north  and  west of the
                 Existing  Sites   should   be  eliminated  from
                 consideration because of the presence of hard-
                 bottom    areas    and    artificial    reefs.

            That statement is  misleading  and inaccurate.   As a result of
        its September/October  1979 and January 1980  surveys, Interstate
        Electronics Corporation actually "strongly recommend[ed] that the
        Existing Sites not  be used  or  designated."    Nevertheless, the
        Corps  and  EPA  authorized  the dumping  of several  million  cubic
        yards  of  dredged  spoils  at  Site  A  in  spite  of  the  express
        recommendation  of  EPA's  contractor  to  the  contrary.    Please
10_14    furnish  the  documentation  showing that  IEC recommended  that the
        areas  north  and west  of  the  existing  sites,  as opposed  to the
        existing sites  themselves,  should  be eliminated.   Most important
        explain  why  the Corps and  EPA  used  Site  A in  spite  of  lEC's
        recommendation against it.

            COMMENT No. 6 — page 2-8, 11 2, 2nd circle;

                 At  this  point,  based on  evalutation  of  the
                 historical and survey data and information, it
                 was concluded that:

                      * * * *

                 Suggested   Shallow-Water   Site   2  and   the
                 Existing  Sites   are  the   most  economical;
                 however, Shallow-Water Alternative Sites 1 and
                 3 are probably more environmentally acceptable
                  locations  for   dredged   material  disposal.

            That  block-indented  material  is  similarly  erroneous  and
        demonstrates a  misunderstanding  of the  factual history  of EPA's
        own  site-designation  process.    The quoted  material refers  to
10_15    lEC's 1979/1980 survey, but  states  that conclusions were made at
        that  time   concerning  Alternative  Sites  1,   2,   and  3.    IEC,
        however, did not even survey Sites 1 through 3 at that time:  the
        first survey of those sites did not occur until  the Reconaissance
        Survey of October,  1981.

            COMMENT No. 7 — page 2-9, 11 3 (last line)  and 11 4;

                 Alternative  Site  3  appeared  to  be   sandy- ..
                 bottomed over its entire area.
                        PEEPI-ES, EARI,, REYNOLDS  & B:LANK
                                 PROFESSIONAL ASSOCIATION

                                   ATTORNEYS AT LAW

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        Mr. T. A. Wastler
        December 13, 1982
        Page -7-
                      Based  on  results  of  the  Reconaissance
                 Survey,  more  in-depth  surveys  were planned.

            Please   explain   the   difference  in   the   results  of   the
        Reconaissance  Survey  in October  of  1981  and the  EPA Survey of
        Site  4  in  May of 1982.  During  the Reconaissance Survey,  actual
        diver  observations  were  made,  which  is   (from   a   scientific
        standpoint)  the  most appropriate  way of  identifying  the  nature
        and extent of hard-bottom areas at  a particular site.   In the  May
        1982  survey  of Site  4,  however,  no diver observations were made;
        rather,  one  videotaped  transect and  two  otter  trawls  were  run
        across  the site,  along with  nine box  cores,  all  of  which  are
10-16    incapable  of accurately determining  whether or  not hard-bottom
        habitats exist in or  near  the  Site.  Since in-depth surveys were
        planned  to follow up the Reconaissance  Survey  of  1981,   please
        explain  why  an in-depth survey  is not now  planned  to follow up
        the preliminary survey that has been performed of Site  4.

             COMMENT No. 8— page 2-10, H  3;

                 Examination  of the  videotape  of  Alternative
                 Site  3  revealed  much more  hard-bottom  areas
                 than  was  revealed  by  the  results  of   the
                 Reconaissance Survey  of  October,  1981.   These
                 new   results  led  to   the  elimination   of        '
                 Alternative  Site   3   from  further  detailed
                 consideration'.

            Actually, the Reconaissance Survey report described Site 3 as
        being  mostly  sandy   bottomed  but  having  sparce  hard-bottom
        communities  appearing  at  five out  of ten  stations  at the site.
        That description of Site 3, based on diver observations, does  not
        appear to  differ  significantly from the  description now provided
       - as  a  result of  the  EPA's 1982  videotape.    Please  explain this
10-17    perceived  discrepancy  between  the  two surveys  and  the differing
        conclusions reached as a result of different methodologies.

            COMMENT No. 9 — page 2-12, H 2;

                 Disposal  of  large  quantities  of  additional
                 dredged  material may  result  in  an  adverse
                 impact  due  to burial  or  siltation  of  nearby
                 hard-bottoms and  artificial  reefs.   However,
                 these possibilites are dependent on the amount
                 of  material  and  on the  ultimate  direction of
                 mass  transport  of   dumped   material.     The
                 limited  knowledge  of  water  current phenomena
                        PEEPLES, EASL, REYNOLDS &
                                 PROFESSIONAL ASSOCIATION

                                   ATTORNEYS AT LAW

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        Mr. T. A. Wastler
        December 13, 1982
        Page -8-
                 in    this    region    suggest    that  ....

            This passage  highlights a  striking  omission  from the Draft
        EIS.   Although  the EIS expressly  recognizes the adverse  impacts
        from  burial  and,  importantly,  siltation,   it  stops  short  of
        quantifying  such   damage   because  of  a  lack  of   information
        concerning  water  currents.   This,  it  seems,   is  precisely  the
        purpose of an environmental  impact statement.  Since knowledge of
        water  current phenomena  is  "limited," and siltation is a widely
        recognized threat to hard-bottom habitats, please explain  why EPA
        has yet  to perform an ocean current  survey  to determine  current
        direction  and speed at Site  4  in order to accurately predict the
        amount of  siltation that  will  occur  and  the  distance  from  the
10-19    Site that  it  will cause problems.  Also,  please explain why  the
        Environmental  Protection  Agency  is   proposing  permanent ocean
        dumping  in  the  face of admitted environmental damage, especially
        when EPA has yet to assess the extent of that damage.

            COMMENT NO.  10 — pag 2-13, f 1;

                 A distance of several miles between a disposal
                 site  and  a   potentially   affected  area  will
                 provide for extensive  dilution  of a turbidity
                 plume  and dispersion  of  deposited  materials
                 transported   away   from   a   Site   by  water
                 currents.   Thus,  artificial  reefs  (5  nmi NE)
                 are less  likely  to  be  adversely affected, but
                 hard-bottom areas within one mile of the Outer
                 Existing   Site  may  be  adversely   affected.

            Please  provide site-specific  data  concerning  the  rates  of
        dilution of  the turbidity plume  and  the  distance  the deposited
        materials will be tranported from the site by water currents.   In
        addition, please specifically address  the  siltation that will be
        caused by  resuspension of  the  dredged  material  throughout  the
        water  column  by  subsequent  wave,  storm,   and  tidal   action.
        Finally,  once those amounts  of  turbidity and siltation have been
10-19    quantified, please  provide documented  information describing  the
        specific effects  of expected  siltation and  turbidity  on hard-
        bottom organisms  such  as corals,  sponges, and  algaes.   If such
        environmental damage to  these  important marine  habitats can  not
        be  quantified,  please  explain  EPA's  rationale  in  authorizing
        long-term dumping  in this  area  instead of  actively searching  for
        less-environmentally damaging methods of disposal.
                        PEEFLES, EARX, REYWOUOS & BLANK
                                 PROFESSIONAL ASSOCIATION

                                   ATTORNEYS AT LAW

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                                                                               Hi.
        Mr. T. A. Wastler
        December  13,  1982
        Page  -9-
            COMMENT No. 11 — page  2-13,  11  3;

                 No  dumping  has occurred  and no  environmental
                 studies have been  conducted  at  this  [Mid-Shelf
                 Alternative] site  ....

            If  no environmental studies have  been  performed regarding the
        Mid-Shelf Alternative  Site, please explain  how EPA  has  balanced
        the environmental  pros  and  cons of dumping at  that site  relative
        to  the  economic costs of transporting  the materials that  far  in
        the ocean.  In  addition, please explain  why the site proposed for
        the mid-shelf,  which runs  from 25 to 75  nmi offshore  (see  page
        x) , was selected  at the most  distant  portion of  the mid-shelf
10-20     (i.e.,  70  miles offshore),  as  opposed  to  the closer side  (e.g.,
        25  or  30 miles  offshore).   Obviously,  selection of a potential
        alternative mid-shelf  site  30 miles  offshore would  be much  less
        expensive  than one  70  miles  offshore.    Since no  environmental
        studies were  performed of  the seventy-mile  Mid-Shelf  site,  the
        selection of  that  particular  site for inclusion in  the EIS would
        seem  arbitrary  and  capricious  in  the  absence  of  a  specific
        rationale for such selection.

            COMMENT No. 12 — page  2-14,  H  1;

                 According  to  Oliver  et  al,   (1977)  shallow-
                 water, high-energy benthic communities  recover
                 more  quickly - from disturbances,  such  as  the
                 disposal of dredged material, than communities
                 in deeper water.

            This conclusion  from Oliver's  report  has  been taken  out  of
        context and  is quite misleading.   It is certainly not true  that
        Oliver  recommended  ocean   dumping  in hard-bottom  habitat  areas
        rather  than deep  water  areas.   Instead,  any  reliance on  Oliver's
        report  must be  restricted to discussion  of ocean dumping  on soft-
        bottom  organisms  that are  actually adaptable to periodic burial.
10-21    On  fc^e  otner  hand,  in comparing  the  adverse impacts from  burial
        and siltation  on shallow-water,  hard-bottom  organisms vis-a-vis
        the  relatively  sparce  populations  of  organisms   at  deep  water
        sites,  it  is clear  that Oliver's work  would not  apply.    Please
        discuss the  Oliver  report  in  more detail and carefully examine
        the applicability  of his findings to hard-bottom  areas  such  as
        those found off the  coast of Manatee  County.

            COMMENT No. 13 — page  2-14, 11  2;

                 It  is estimated  that the  increased  distance
                        PEEPI-ES, EARX, REYNOLDS &
                                 PROFESSIONAL ASSOCIATION

                                   ATTORNEYS AT LAW

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         Mr.  T.  A.  Wastler
         December 13,  1982
         Page -10-
                  would add approximately.$.15/ cubic yard/mi to
                  disposal  operations   (J.  Hendry/   personal
                  communication),   or  $102,600.00   per   hopper
                  vessel load.

             The quoted cost  figure  is erroneous.   Testimony  at  trial by
        Mr.  Hendry  and others revealed  a lower  cost figure, which,  by
        Court   Order  and  agreement  of  the  parties,   is  to  be  kept
        confidential.   Nevertheless,  because the  Draft EIS relies on the
        higher, incorrect  cost  estimate,  all  of  its cost  estimates are
10-22    exaggerated.  If the real cost figures  are  not used in the Draft
        EIS,   it  should   be  made  clear  that  all cost  figures  are
        hypothetical and used merely for comparison.

             In addition,  the MPRSA regulations  require  a quantitative
        analysis  of the percentage  of a resource  lost, reduction in user
        days of  recreational areas,  dollars  lost  in commercial fishery
        profits,  and  the  profitability  of other  commercial enterprises.
        See  33 C.F.R.  § 227.19.   Because Site 4  is in  an area of high
        commercial  and  recreational activity,  any  consideration  of the
        economic  disadvantages of using the Mid-Shelf Site in comparison
        with  Site  4   must  include  balancing  a   consideration  of  the
        environmental   and  commercial  advantages  of using  the Mid-Shelf
10-23    Site vis-a-vis Site  4.   This  is  especially  so  in light  of the
        inappropriatness of relying on the Oliver  study  to determine the
        environmental   consequences  of  dumping  in mid-shelf  areas  as
        opposed to hard-bottom habitat areas.   Please provide a  detailed
        assessment comparing  the  economic  costs of going  to the Mid-Shelf
        Site with  the  commercial   and  environmental advantages  of  not
        going  to the heavily used Site  4  area.  Also, describe  how that
        assessment would change  if  a Mid-Shelf  Site closer to shore  (say,
        30  to  35 miles  offshore)   were chosen instead  of one  70 miles
        offshore.

             Lastly,  it must  be  noted  that ocean dump sites much farther
        out  than  that  proposed  for the Mid-Shelf Alternative Site have
        been established  for  receipt of  disposal materials.  For  example,
        on  NOAA Chart  No.  13003, a dump  site  used for  the  disposal  of
        industrial  wastes  has been designated  approximately 125  miles
        from nearest  landfall,  with center coordinates  at approximately
10-24    72°  15' w and  38°  45' N>  There are  also  two dump sites  about 40
        and  50  miles   offshore  of  Cape  May,  New  Jersey,  respectively.
        Please  explain why it is  economically feasible to use a dump site
        125  miles off  the coast  of New York but it is infeasible  to use a
        dump site 30 to 75 miles  off the coast  of  Florida.
                        PEEPLES, EARL, REYNOLDS &
                                  PROFESSIONAL ASSOCIATION
                                   ATTORNEYS AT LAW

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       Mr. T. A. Wastler
       December 13, 1982
       Page -11-
           COMMENT No. 14 — page 2-16, 11  2t

                     Although  the  Deep Water Alternative  Site
                supports  a  lower density  of organisms,  these
                organisms would  be more  sensitive to  adverse
                effects from disposal.

           Please  identify  the  study  that  specifically quantifies  the
       adverse  effects  from  both  burial  and siltation to  hard-bottom
       organisms  such  as  corals,  algaes,  and sponges.   If there  is  no
       such  study  that  specifically describes  the nature and extent  of
       damage  to  hard-bottom  organisms  from  particular  amounts  and
       frequencies of burial  and siltation,  explain  how you arrived  at
       the conclusion that  deep  water  organisms would  be more sensitive
       to dumping  than  shallow-water organisms,  especially in light  of
10-25   the fact that EPA  conducted no  environmental studies of the deep
       water  site  and  ostensibly does not know  what  organisms exist  as
       the site.

           Additionally,  please  consider  the  comments  and  questions
       posed  regarding  the  Mid-Shelf Site  and  explain  in each instance
       how your  response  would  differ with  respect   to the Deep  Water
10-26   site.

           COMMENT No. 15 — page 2-16, fl  2;

                According to  Slobodkin and  Saunders   (1969) a
                perturbation   (such   as   dredged    material
                disposal)  which  would  have  a small effect  on
                groups of organisms  in stressful  environments
                (e.g.,  a  shallow-water  environment)   "may  be
                catastrophic   when   applied"  to   groups   of
                organisms in  relatively  constant  environment,
                e.g.,     a     deep     water     environment.

           First,  please  clarify the meaning of the term "small  effect"
       in relation to the impacts to hard-bottom organisms  in and around
       a dump site, from burial and siltation caused by  dumping.   if EPA
10-27   cannot quantify the  effects  to  hard-bottom habitats  from  burial,
       siltation,  resuspension,  etc.,  how can comparisons  such   as  that
       in the above passage be made?

           Second, once again, the findings  of  the  report relied  on  in
       the EIS have been taken out of context. (See discussion of Oliver
       above.)   Please  explain,  with  specific  textual references, how
10-28   the Slobodkin and  Saunders  report  can be meaningfully applied  to
       the long-term  dumping  of massive  quantities   of dredged  spoils

                       PEEP:LES, EARJL, Rims & BLANK
                                 PROFESSIONAL ASSOCIATION
                                  ATTORNEYS AT LAW

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        Mr.  T. A. Wastler
        December 13, 1982
        Page -12-
        (and the associated sediment transport and siltation) at an ocean
        dump site in or near productive hard-bottom areas.

            COMMENT No. 16 — page 2-16, 11 3;

                      Shallow-water,   high-energy   communities
                 recover more  quickly  from  disturbances, such
                 as  the  disposal  of   dredged  material,  than
                 communities  in  deep  water  (Oliver  et  al.
                 1977).

            The  passage is extremely  misleading  and  totally disregards
        the recovery  potential for  hard-bottom  habitats  and organisms.
        Although a soft-bottom community may recolonize a site soon after
        dumping, hard-bottom  communities will be  killed  by  dumping  and
        will not be  capable of recolonizing the dump  site until all  the
        dumped spoils have  been transported  away  from the site leaving a
        hard  substrate.     Even   after  a  hard   substrate  reappears,
        scientific literature  clearly  demonstrates that  the hard-bottom
10-29    communities  themselves will   not  recover  to their  pre-dumping
        state   for  25  to  50  years.    In  light  of  these  facts,  please
        explain your conclusion that the communities discussed in the  EIS
        will  "recover   more   quickly"  than  deep   water  communities.
        Further, please compare  the  amount of  environmental damage  at
        shallow-water  versus  deep-wateriTtes  (i.e.,  will  as  much  be
        damaged by dumping in deep water?).


            COMMENT No. 17 — page 2-17, 11 1;

                 Thus, dredged material sediments  are likely to
                 differ   from   Deep   Water   Disposal   Site
                 sediments, and  this   difference  increases the
                 adverse  effects   of   disposal  on  deep  water
                 benthos.

            The quoted  material,  along with other  portions of  the EIS,
        erroneously implies that  the dredged spoils  being dumped outside
        Tampa  Harbor are in fact similar to the sediments found naturally
        in and  around Site 4.  The evidence at trial,  including  I.E.G.
        findings and  expert  testimony, showed that natural  silt in  this
10--30    area off Tampa-Bay ranges  from 1%  to possibly  10%.-  However,  the
        evidence  also  showed  that  materials that  have  actually  been
        dumped from  Tampa  Harbor   to date  have averaged  almost  60%  silt
        and have sometimes  contained  as much as  100% silt.   Thus,  these
        two sets of sediments cannot be considered similar.   In  light  of
        such differences, please explain whether  the  "increase[d] adverse
                        PEE PUSS, EAKL, REYNOLDS & BLANK
                                  PROFESSIONAL ASSOCIATION

                                   ATTORNEYS AT LAW

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        Mr. T. A. Wastler
        December 13, 1982
        Page -13-
        effects  of disposal  on  deep  water  benthos"  would  likewise  be
        applicable to dumping at Site 4.

            COMMENT No. 18 -- page 2-17, 1( 2;

            [Paragraph regarding  the  additional costs  of  transporting  to
        the Deep Water Site.]

            With regard  to the Deep Water Site,  please address the  same
        considerations noted  in  Comment No.  13, above,  concerning  the
10-31    mid-shelf alternative site.

            COMMENT No. 19 -- page 2-19, 11 4;

                      Shallow-Water  Alternative   Site  4  has
                 never been used  for  dredged material  disposal
                 and  is  devoid of major  typographic  features.
                 A  videotape  taken  of  this area  revealed  no
                 rock  or   hard-bottom   outcroppings   and  low
                 vertical   relief.      A  recent   EPA  survey
                 determined  that  the  site  is  predominately
                 characterized  by the  presence  of  fine  sands
                 and  coarse silts  and  plains  of  shell  hash.

            This entire passage highlights the unfounded assumptions  that
        run throughout the Draft EIS,  i.e.,  that Site 4  and surrounding
        areas  contain no  hard-bottom  habitats  and  are  unimportant  to
        commercial  and  recreational  activities.    As   is  clear   from
        discussion  with  several  scientists, however,  the methodologies
        used in  the EPA  survey of Site  4  in May  of 1982  were completely
        inadequate for identifying  the nature  and  extent  of hard-bottom
        habitats both within and  without the Site.   The survey consisted
10-32    solely of  one videotape  run  across  part or  possibly all  of  the
        site,  two  otter  trawls that  did not run across  the  whole site,
        and nine box  cores.   No diver observations were made.   Based  on
        that survey,  it  cannot  be  known  what  exists  in  the unseen  and
        unstudies 95% or  more of the Site.  Equally important, EPA cannot
        possibly know what  exists anywhere outside  the boundaries of  the
        site because  those areas were  not studied  (except for  the  four
        small  box  core  locations).   Thus, the survey of   Site  4  can  be
        considered preliminary  at best, and  a  more  extensive inspection
        of areas both within and  without the Site is necessary before  it
        can be known  what  types of organisms and  communities in the  area
        will be  adversely  affected by  dumping.   Actually,  observation  by
        divers and fisherman with many,  many years  of experience in  this
        part of  the  Gulf  demonstrates  that  Site 4  itself contains  hard
        bottoms   and   possibly   ledges   (and   EPA   found  live-bottom
                                 , EARJL, REYNOIOJS &
                                  PROFESSIONAL ASSOCIATION

                                   ATTORNEYS AT LAW

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        Mr. T. A. Wastler
        December 13,  1982
        Page -14-
        communities  at the Site); and  that  the areas surrounding Site  4
        contain   hard-bottom   habitats,  ledges,  wrecked  vessels,   and
        valuable  shrimping and fishing  grounds.

            EPA's   unfounded   assumption   is   rendered   all   the  more
        questionable  by the high  likelihood of encountering hard-bottom
        habitats  in this general area of the Gulf of Mexico.  Sites  1,  2,
        and 3  all were found  to contain productive hard-bottom habitats,
10-33    an<^ I«E.C. recommended against  using or designating Sites  A  and  B
        in 1980 because of the existence of  such hard-bottom areas.  This
        highlights the need for  further study  of Site 4 before it can  be
        reasonably recommended as  a permanent Site for ocean dumping.

            COMMENT No. 20 — page 2-21, Hi;

                       Use  of  Shallow-Water  Alternative  Site 4
                  is  not anticipated  to affect any biologically
                  unique habitats  or  interfere  with spawning or
                  migration  activities.   The  site  was selected
                  on  the  basis  of its  remoteness  from  known
                  hard-bottoms.   A recent EPA survey determined
                  that  this site apparently contains fewer  hard-
                  bottom  areas  than  any of  the  other shallow-
                  water alternative sites.

            The   reliability-   of   those   conclusions   is   extremely
        questionable because they  are based  solely on the  preliminary EPA
        survey  of May  1982.    (Refer  to preceding  comment.)   Actually,
        local  divers  and  fishermen have stated unequivocally that Site  4
        is not remote  from known hard bottoms  and  have countless  Loran
        numbers demonstrating  the presence  of  hard  bottoms,  ledges, and
10-34    tne like.  Additionally,  Site  4 is  in an area  that  is  heavily
        relied on for  shrimping,  recreational fishing, by charter boats,
        party  boats, and individuals, and scuba divers.

            In light  of the above, it  would appear  Site 4 does not meet
        the second of  the eleven factors found  in EPA's Criteria.  Please
        reevaluate Site 4  for  the suitability  of its use  "in relation  to
        breeding, spawning" grounds under 40 C.F.R.  § 228.6(a)(2).

            COMMENT No. 21 -- page 2-21, fl 4;

                  Recreational  fishing  and  diving  may   occur
                  anywhere  in  the  near  shore waters.   However,
                  most  of  these  activities  are limited to  high-
                  relief  hard-bottom  areas,  artificial  reefs,
                  and  sunken vessels, all of which are removed
                         PEEPLES, EARL, REYNOLDS & BLANK
                                  PROFESSIONAL ASSOCIATION

                                   ATTORNEYS AT LAW

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        Mr. T. A. Wastler
        December 13, 1982
        Page -15-
                 from the site.   Some scuba diving and fishing
                 activities  may  occur  in   the  site  vicinty,
                 although  these activities  are probably less
                 frequent in similar  use in the vicinty of the
                 existing sites.

            With  the  exception  of  the  first  sentence  and  part  of the
        third, the above passages are mistaken and misleading.  As stated
        above, Site 4  is  located in an  area of  the  Gulf that is heavily
        used  for  shrimping,  recreational fishing,  and  scuba  diving, and
        the Site  is  not  far  removed from  hard-bottom  areas, artificial
        reefs, and sunken vessels;  in fact, the "gunsmoke"  is a 65 foot
        vessel approximately one mile to the north of Site 4 that is very
10-35    important to fishing and diving  interests.   Further, scuba diving
        and fishing activities  are  actually more  frequent  around Site 4
        than  around   the  existing   sites,  because  the  dumping  at the
        existing  sites  has  ruined  those areas  by burial  and recurrent
        siltation.

            Therefore, Site  4  fails to  meet the requirements concerning
        its location relative to beaches and other  amenity areas under 40
        C.F.R. § 228.6(a)  (3) .

            COMMENT No. 22 — pages 2-23 to 2-24;

                 [Dispersal, horizontal  transport,  and vertical
                 mixing characteristics  of  the  area including
                 prevailing current  direction  and  velocity,  if
                 any.]

            This entire discussion  in the Draft EIS  is too speculative.
        Testimony of two experts at trial demonstrated that the direction
        and   ultimate  distance  of   sediment   transport  could  not  be
        predicted accurately without a site-specific ocean current study,
        and that  combinations  of tides, wave  action,  storms, and bottom
        currents create variable current directions and  velocities.  No
10-36    investigation  of  the  currents  at   Site  4  has  been  performed.
        Therefore,  please  explain  how  the  Site-Designation  EIS  has
        satisfied the requirements of  40 C.F.R.  §  228.6 (a)(6) concerning
        movement of the dredged spoils.

            COMMENT No. 23 — page 2-25, 11 3;

                 Although dredged material disposal causes some
                 localized  decreases   in   the  abundance   of
                 benthic  fauna, fairly  rapid  recollinization
                 has been observed at  similarly  affected areas
                        PEEPUES, EABJL, REYNOLDS &
                                  PROFESSIONAL ASSOCIATION

                                   ATTORNEYS AT LAW

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        Mr. T. A. Wastler
        December 13, 1982
        Page -16-
                 within  three  months  after  disposal operations
                 ceased.    At  the   Galveston,   Texas  ODMDS,
                 organisms  which  colonized  the  affected areas
                 were  members  of the  surrounding  unaffected
                 areas and  no  nuisance  species were recruited.

            The implication that  the  Galveston dump site is analogous to
        the sites off Tampa Harbor is erroneous because it disregards the
        numerous hard-bottom  areas found off  the coast of  Florida that
,0 37    are not  found off  the coast  of Texas.   Thus,  recolonization of
        soft  bottom organisms  at Texas  would  be  quite  different from
        recolonization by corals, sponges, and algae.

            COMMENT No.  24 — page 2-26, 11 1;

                 [Unacceptable  adverse  effects  could  result
                 within  several miles of  the  disposal site due
                 to deposition of suspended  particulate matter
                 and   dispersion  of   accumulated   sediments
                 following disposal operations.

            The  passage  is  undeniably  true,  but  the  EIS  consistently
        fails  to  adequately address  resuspension of  particulate matter
        and to  quantify both  the  amount  and  frequency  of re-suspension
        and the impacts  to  hard-bottom  habitats  and organisms.  Because,
        as was demonstrated at trial, hydrodynamic  energies in this part
        of  the  Gulf  of  Mexico are  sufficient to  continually resuspend
,Q 38    fine materials,  siltation and turbidity are problems that must be
        described  before a  permanent  dump  site  should  be  designated.
        Please quantify  these  impacts with specific reference to Site 4,
        and include ocean current data relied on in such quantifications.
        In the absence of such information,  the requirements of 40 C.F.R.
        § 228.6(a)(7) cannot be considered to have been fulfilled.

            COMMENT No.  25 — page 2-27, fl 3;

                 This    site   is   removed    from   areas   of
                 recreational use, and has no known significant
                 commercial fishery use.

            As  stated   above   in  several  comments,   that  conclusion
        concerning Site  4 is plainly incorrect.  Site 4 is located within
10-39    an area tnat is  heavily used for both commercial and recreational
        use,  including  sport  fishing,  shrimping, party  and  charter boat
        fishing, and  scuba  diving.  Therefore,  Site 4 also fails to meet
        the requirements of 40 C.F.R.  §  228.6 (a)(8).
                        PEEPLES, EARL, REYNOLDS & BLANK
                                  PROFESSIONAL ASSOCIATION

                                   ATTORNEYS AT LAW

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       Hz. T. A. Wastler
       December 13, 1982
       Page -17-
           COMMENT No.  26 — page  2-28  fl  3;

            [Reference dumping operations  in  other  regions].

           Because   the   numerous   hard-bottom    habitats    scattered
       throughout  this  part of  the Gulf  of Mexico  make this a  unique
       area,  reliance upon  studies of dumping operations  near  Texas  and
       other  dissimiliar  areas  is inadequate.   Adequate  site-specific
10-40   studies of  Site  4  and of the effects of burial and siltation on
       hard-bottom  habitats  is  necessary before  ocean  dumping off  the
       coast  of Manatee County can be reasonably authorized.

           COMMENT No. — page 2-29, conclusion no.  1;

                A limestone shelf  is believed  to occur 0.5 nmi
                northwest  of  the  outer  existing  site,  and
                small outcrops  are suspected  to  occur within
                the  site.     An  artificial  reef   has   been
                constructed within 3 NMI  of  the inner existing
                site.

           The quoted passage,  which is  relied on to recommend the  use
       of  Site  4,  fails  to  note  the existence of numerous  hard-bottom
       areas  and  ledges  in  proximity  to  Site 4  and the  wreck  of  the
       "Gunsmoke" one mile  to  the north of  the site.  The existence of
10-41   these  would militate  against  the  use of  Site 4 for  permanent
       ocean  dumping.

           COMMENT No. 28 — page  2-29, conclusion no. 4;

                These   surveys   indicated  that  disposal  of
                dredged  material  at  alternate  Site  4   would
                affect the fewest  hard  bottoms since  this area
                is sandy bottomed.

           For the  reasons  indicated  in comments above,  the  preliminary
       nature  of  the  EPA survey  of Site  4  in  May of   1982  makes  it
       unreasonably  speculative  to  presume  that  there  are  no   hard-
10-42   bottoms, ledges, or other important habitat areas within or near
       Site 4.

           COMMENT No. 29 -- page  2-30, 11  2;

                All  dredged  material  scheduled  for disposal
                must    comply    with    the    Ocean   Dumping
                Regulations'      elutriate,     bioassay,     and
                bioaccumulation  test  procedures.   Disposal of
                        PEEPUBS, EABX, REYNOLDS  &
                                 PROFESSIONAL ASSOCIATION

                                   ATTORNEYS AT LAW

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       Mr.  T.  A.  Wastler
       December  13,  1982
       Page -18-
                 this material  should  not  cause  unacceptable
                 and  adverse effects  outside  the  designated
                 dump site nor should this material cause long-
                 term  adverse/chronic   effects   at   a   site.

            The  first sentence  of that  paragraph  fails  to  mention  that
        bioassay  tests are regularly performed on worms,  clams, and fish,
10-43    rather  than on corals,  sponges,  and algaes.   Please explain how
        elutriate,   bioassay,  and   bioaccumulation   testing  accurately
        predicts  the  impact  of  burial and siltation  on  such hard-bottom
        organisms.

            In  addition,  the second  sentence  of the  passage  disregards
        the  impact to hard-bottom organisms  from siltation and continual
        resuspension of the  dredged  spoils  throughout the  water  column.
        Because  this resuspension will occur on  a  continual basis for as
10-44    long as  the dump  site is  being used  (permanently),  these  impacts
        will be long-term and, as  stated  in  the EIS,  adverse.

            COMMENT No.  30 — page 2-33,  fl 3;

                 However,  in  the  event that the  selected  site
                 is  determined  to   have  hard-bottom  outcrops
                 within   0.5   nmi,  pollution-sensitive  species
                 outside    the   site   should   be   surveyed.

            That  passage  emphasizes  the importance  of  identifying  the
        nature  and  extent of hard-bottom outcrops  both  in  and near  the
        dump site,  which  was  not  adequately accomplished by the EPA  1982
        survey.    The sentence  preceding the  quoted  passage  once  again
        erroneously presumes that hard and soft  corals do  not  occur  near
10-45    the  site.  In light of the admitted  importance of  monitoring for
        pollution-sensitive  species  within one-half  mile  of  the  site,
        please explain why it is  unnecessary  to conduct an  examination of
        Site 4 that  better identifies hard and  soft  corals in and  near
        the  site.                                           ^

            COMMENT No.  31 — pages  3-47  to  3-48;

            [Re:  Recreational and  commercial  fisheries]

            As stated above in numerous other  comments the  EIS's  findings
        regarding commercial and  recreational  fishing  in  the area  of  Site
        4  are inaccurate.   In light  of the EIS's  reliance on a  study  that
10-46    is  nearly   20 years  old   (see  Figure  3(18)),  this  error  is
        understandable.    The  drafters  of  the  EIS   should discuss  the
        current,   actual   use  of  the  area  around  Site   4  with  local
                        PEEBLES, EARJL, REYTTOUDS &
                                 PROFESSIONAL ASSOCIATION

                                   ATTORNEYS AT LAW

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       Mr.  T.  A.  Wastler
       December  13,  1982
       Page -19-
        governmental   agencies   and  interested  persons.     After  such
        discussions  and resort  to more recent  studies,  please report the
        findings  and  reevaluate  the  EIS's  conclusions.

           COMMENT No.  32  — page  4-4  1  4;

            [Re:  characteristics  of  dumping  after  release into the water]

           The  EIS  has  failed  to mention  the fourth  characteristic  of
        post-release  dumping,  i.e.,  the resuspension of find  particle  by
        wave  action,  tides, storms, and ocean  currents.   Please describe
   _     these  characteristics  with  specific reference  to  data  collected
        from  Site 4  and identify  the potential  impacts  to  hard-bottom
        habitats  and  organisms in and  near Site 4.

           COMMENT No.  33  — page  4-8  11  1;

            [Discusses  the  short-term turbidity  effects  on  coral-type
        organisms.]

           Although  the  severe  adverse impacts from short-term turbidity
        are described,  the  EIS makes no attempt to  quantify the long-term
        effects   from   the  continual  resuspension   of  the   material
        throughout  the  water  column.   Please quantify  the  amount  and
        frequency of  siltation,  the  direction  of sediment transport based
        on site-specific  ocean current  information,  and  the environmental
        consequences  of  long-term turbidity.

           COMMENT NO.  34  — page 4-19 11  4;

                 Short-term avoidance of locally high  turbidity
                 may  be  the  only  significant environmental
                 effect on  fisheries.

           The  paragraph is erroneous.   Testimony  by  a  scientist  with
        the *• National Marine Fisheries Service clearly  demonstrated  that
        high  turbidity will cause  significant  adverse  impacts  to  live,
        hard-bottom  habitats and resulting  adverse  impacts  to  fishery
1Q  .g    resources.  Please  explain the  discrepancy  between the statements
        in the EIS and  those of  the NMFS  scientist  regarding  the adverse
        impacts  on  fisheries  due to  turbidity and  siltation,  especially
        in light of   the  unquestionable relationship between  hard-bottom
        habitats  and  fishery resources.

            COMMENT No.  35 — page  4-21,  H  4;

            [Reference   to   lack  of   recreational  fishing   and  diving
        activities at Site  4, and to nature  of  the  bottom.]
                        PEEFLES, EARJL, RETTFTOUDS &
                                 PROFESSIONAL ASSOCIATION

                                   ATTORNEYS AT LAW

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        Mr. T. A. Wastler
        December 13, 1982
        Page -20-
            The paragraph  is  incorrect  for  the  reasons  stated  several
        times previously.

        COMMENT No. 36 — pages 4-21 to 4-22;

            [Discussion regarding effects on economics.]

            This entire  section  fails  to take account  of  the commercial
        aspects of recreational  fishing,  which  are clearly recognized
        under the  MPRSA  regulations.   See  40 C.F.R. §  227.19.   In fact,
        the EIS  notes that  the  "full extent  to  which  fisheries  may be
10-50    affected,   including damage  to  spawning grounds  or  juvenile fish,
        is  unknown."     In  light   of  the   admitted  lack  of  knowledge
        concerning  impacts  to fisheries  in the  area,   the  necessity of
        further  study   is   obvious.     Please   explain  the  rationale
        underlying EPA's recommendation of  designating an ocean dump site
        on  a  permanent  basis in   the  absence of  knowledge  concerning
        impacts to fisheries.

            COMMENT No. 37 — page 4-22,  fl  3:

                 Disposal of dredged material  will  result  in a
                 turbid plume  that  will  reduce water  cleary at
                 the  site.   Because all  sites are  located at
                 least 9 nmi offshore adverse impacts on visual
                 aesthetics  from shore  will  be  non-existent.

            The quotes  passage  ignores  two  important  factors:   (1)  it
        unreasonably  ignores  the effects of turbidity  on  sport  diving,
        the enjoyment  of which is substantially dependent upon visibility
10_5i    and aesthetics.  r(2)  It  fails  to take account  of   the  fact  that
        there will  be continual  resuspension of  the materials as  tides,
        storms, etc.,  act on the  dredged  spoils.

            The above  comments make it pellucidly  clear that  the  Draft
        Site-Designation  EIS  is   critically  flawed.     It  should  be
        withdrawn   and  substantially revised for  further public comment.
        Because of  the  extreme significance of  the marine  habitats  and
10-52    fishery resources  in  this  part of the  Gulf  of  Mexico to  the
        people  of  Manatee  County   and  the  general   area,  EPA  should
        schedule a  public  hearing  to allow  full  and fair  public  comment
        on the revised EIS and the  overall  suitability  of  dumping  in the
        eastern Gulf of Mexico.

            In  addition,  the  Environmental  Protection  Agency must  not
10-53    allow further ocean  dumping and  the concommitant  damages  to the
        environment and natural resources unitl it has been affirmatively
                        PEEPLES, EARL, REYNOLDS & BLANK
                                 PROFESSIONAL. ASSOCIATION

                                   ATTORNEYS AT LAW

-------
Mr. T. A. Wastler
December 13, 1982
Page -21-
demonstrated  that  ocean  dumping  in  this  part of  the  Gulf of
Mexico is appropriate and that  it  is  the most suitable method of
disposal.     That   demonstration   should   include   an   actual
determination of  the nature  and extent  of  hard-bottom habitats
and fishery  resources  in  Site 4 and  in  surrounding areas, which
must be  based on  further,  site-specific surveys; a determination
of  the  direction, amount,  frequency,  and  distance  of sediment
transport  and  siltation  and  a specific  quantification  of  the
damage that  will result therefrom;  a  detailed, careful balancing
of  the economic  versus  environmental concerns  involved in using
each  alternative  method  and  location   for  dumping,  including
consideration of   the  many  commercial  aspects of  recreational
fishing  and  diving;  and  development of  a  thorough  monitoring
program  to   assess  the  impacts  of any dumping  on  a long-term
basis.

    Pending  completion  of  necessary  studies,  no  ocean  dumping
should be allowed  — especially  on  another  "interim"  basis.   Any
consequential  delays  in   important  dredging  projects  can  be
avoided by using the massive diked  disposal areas in Hillsborough
Bay in the meantime.

                               Yours faithfully,
                               William F. Tarr
                               On behalf and under
                               authority of the Board of
                               County Commissioners of
                               Manatee County, Florida

WFT/yp
cc: Honorable Charlotte Long, Holmes Beach, Fla.
    Honorable Ernest Cagnina, Anna Maria, Fla.
    Gulf of Mexico Fishery Management Council
    Dr. Elton Gissendanner , Florida DNR
    National Marine Fisheries Service, Reg'l Dir.
    U.S. Fish and Wildlife Service, Reg'l Dir.
    Col. Alfred Devereaux, District Engineer
    Florida DER
    Tampa Bay Regional Planning Council
    Joseph' Freedman, Esquire
                PEEPLES, EARL, REYNOLDS & BLANK
                         PROFESSIONAL ASSOCIATION

                           ATTORNEYS AT LAW

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11-1
 11-2
                                                 GULF OF MEXICO FISHERY MANAGEMENT COUNCIL
                                                	Lincoln Center. Suite 881  • 5401 W. Kennedy Blvd.
                                                     Tampa, Florida 33609 • Phone: 813/228-2815
             December 10,  1982
                                                         03.DEC.32*G02229
Environmental Protection Agency
Criteria and Standards  Division  (VVH-585)
401 M Street, S.W.
Washington,  D.C.  20460

Dear Si r:

The Gulf Council has reviewed  the DEIS  for Tampa Harbor Ocean Dredged
Material Disposal  Site  Designation.   I  would  like to take this oppor-
tunity to express  the Council's  position with the following comments
and recommendations:

GENERAL COMMENTS

The Council  is a federally  funded entity charged with insuring that
the United States  obtains the  best  possible use of fishery resources
in the Fishery Conservation Zone (FCZ), out to the 200 miles offshore.
Fishery management  plans developed  by  the Council for shrimp, reef
fish,  and coral reef resources place  great  importance on habitat pro-
tection.  Spoil disposal in or near productive hard-bottom habitat is
a  significant threat to fisheries dependent on these habitats.  This
threat is not adequately analyzed  in  the DEIS nor are alternative
disposal sites adequately explored.  We find  the DEIS to have serious
deficiencies in content and scope.  Our comments of June 4, 1982 (copy
attached), have not been addressed.   The survey of offshore sites and
disposal impacts is totally inadequate.  The DEIS does not seriously
address disposal alternatives  other than the Gulf, nor does it con-
sider the economic  and  social  cost  to  recreational and commercial
fishermen dependent on  fishery populations  in and near the dump sites.
We are particularly concerned  that  offshore disposal of maintenance
material on a continuing basis (1.1 million cubic yards per year, DEIS
page 1-6) will permanently  destroy  or  degrade hard-bottom communities
and associated fishery  values  for several miles surrounding the site.

SPECIFIC COMMENTS

1.  The site survey on  which designation of disposal site 4 is based
    is inadequate.   Although the site  survey  is not clearly described
    in the DEIS, our staff  has obtained additional documents which
    detail the survey.   It  consisted  of one transect with an under-
    water camera approximately one-half way across site 4, two otter
    trawl samples  of unknown duration  in or near the site and an
    unspecified, but apparently  small  number  of box cores and sediment
    samples.  This  is not an adequate  base  on which to conclude that a
          A council authorized by the Magnuson Fishery Conservation & Management Act

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             Environmental  Protection Agency
             December  10,  1982
             Page  Two
                 site  of  approximately 3,000 acres contains no hard-bottom  com-
                 munities or that the thousands of acres immediately  surrounding
                 the  site are equally barren.  According to published information
                 there are two artificial  reefs nearby,  one less than one mile
                 north of site 4 (loran coordinates 14138.5,  44789.6  and 14143.6,
                 44762.4).  Personal  communications from divers and fishermen  that
                 use  these areas indicate  that there are several areas of hard-
                 bottom habitat within site 4, including at least one ledge.   In
                 addition, hard-bottom areas with ledges have been found on the
                 northwest,  northeast, and southeast corners  of the site.   There  is
                 a large  concentration of  hard bottom within  1.5 miles of the
                 southern boundary of the  site, a large  concentration of  ledges
                 approximately one mile east of the site,  a ledge one-half  mile
                 south of the site,  and another area with several ledges  less  than
                 one mile north of the site.

                 The DEIS states that site 4 is removed  from  areas of recreational
                 and  commercial use (page  2-27).   This is in  error.   The artificial
                 reefs and hard-bottom areas surrounding the  site are well  known
   „             and  very popular with divers and recreational fishermen and are  a
                 major fishing ground for  the charter and head boat fleet operating
                 out  of Manatee County.

                 The  EPA field survey conducted to look  for alternative disposal
                 sites consisted of two camera transects,  one from site 2 approxi-
                 mately six miles to  the southwest and another west from site A
                 through  site 3, approximately ten miles.   It isdifficult  for us
   .              to understand how this could be considered an adequate search or
                 survey.

             2)   DEIS  does not consider the  long-term, essentially permanent effect
                 of siltation resulting from disposal of maintenance  material.  The
                 DEIS  indicates that  a total maintenance budget of 1.0 million
                 cubic yards per year.  An earlier document indicated 0.5 million
                 cubic yards per year would be disposed  of off-shore.  This
                 material will be primarily soft, silty  sediments, highly suscep-
                 tible to movement by current and wave action.  It is anticipated
                 that  this material will spread out in a thin layer for many miles
   ,.              surrounding the site, as  indicated in the DEIS, pages XV11  and
                 2-11.  This recurring, essentially permanent siltation can be
                 expected to severely stress hard-bottom communities, decrease the
                 habitat's ability to support valuable fish stocks and their
                 aesthetic value for  scuba divers.

                 The  DEIS suggests on page 2-28 that disposal will not result  in
                 any  detectable changes in ecology of the area.  However, the
....  f.       '      studies used  to back up this conclusion were all from areas which
                 have  no hard-bottom communities.  The animal and plant communities

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         Environmental Protection Agency
         December 10, 1982
         Page Three
             in those areas are already adapted to soft sediments,  high silta-
             tion and turbidity.  Those studies are totally inappropriate to
             use in making conclusions about the west Florida shelf.   This area
             is characterized by  low freshwater inflow, clear water,  high light
             levels, and  low  levels of silt and turbidity.  Personal  reports
             from divers  indicate substantial changes in hard-bottom habitat
             since offshore disposal began.  Many species, including basket
             sponges and  spiny oysters, have disappeared from ledges in and
             around the present disposal site.  The Council regards the per-
             manent stress resulting from ma intenance disposal siltation to be
             a very serious threat  to the offshore habitat and human activities
             dependent on  i t.

         3.  The DEIS does not make any attempt to analyze the effect which the
             proposed disposal will have on fisheries and the economic damage
             which will result in the Florida economy.  Recreational  and com-
             mercial fishing  is a multibillion dollar business in Florida.  A
             large fraction of this value is derived from the west  Florida
11-7         shelf and will be directly affected by degradation of  the habitat
             on which these fishery resources are dependent.   The values given
             in the DEIS  are  very much out of date and grossly underestimate
             the actual value of  this activity.

         4.  The DEIS does not seriously consider alternatives to open Gulf
             disposal.  Upland disposal is mentioned but rejected because con-
             demn at ionproceedings  by the sponsor will be necessary.   However,
             it is the legal  responsibility of the sponsor to find  environmen-
             tally acceptable sites.  Condemnation is a viable alternative and
             is not a particularly  lengthy process.  As an example, the Alabama
11-8         State Docks  recently used condemnation to acquire an industrial
             site for port expansion.

             An environmentally acceptable alternative exists which has not
             been addressed.  Two diked enclosures exist today in upper
             Hillsborough  Bay which have tremendous capacity.  These sites are
             not mentioned in the DEIS.  Although no official estimates were
             available to  our staff, the diagrams in the 1977 Supplemental EIS
             for the Tampa Harbor Project indicate a capacity of roughly 39
11-9         million cubic yards, assuming a six* foot elevation.  If existing
             dewatering technology  was used and the dikes increased in height,
             the capacity  could be  increased many fold.  This appears to us to
             be sufficient to hold  all material scheduled for offshore disposal
             for many years to come.

         5.  The DEIS considers the possible adverse affects of heavy metals
             and other toxic  substances which may be contained in dredged
             spoil.  It cites bioassay testing by Jones, Edmonds and
             Associates,  to support a conclusion that no human health hazards
11-10        are indicated.  We have examined sworn affidavits by two former

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         Environmental Protection Agency
         December 10, 1982
         Page Four
             employees of that firm which allege that some sediment samples
             failed bioassay tests.  However, only favorable results were
             reported.  This casts serious doubt on the reliability of any
             conclusions based on  the Jones, Edmonds and Associates report.
             Another study by Mote Marine Laboratory found extremely high
             levels of heavy metals at the existing disposal site.   This infor-
             mation indicates to us that dangerously contaminated sediments
             were dumped offshore  and may be dumped again as a result of main-
             tenance dredging activity.

         6.  The DEIS ignores the  fact that  spoil is being dumped outside the
             site.  Several individuals have observed dumping outside the site.
             A large pile of spoil material was found by a member of our staff
             one mile outside the  site.  Dr. Blake Edwards of the University of
11-11        South Florida observed five disposal trips.  In two of the five
             trips, disposal occurred outside the site.  This dumping greatly
             increases the area affected and the potential damage to U.S.
             f i sher i es.

         The Council would like to make the  following requests and recommen-
         dat i ons :

         1)  Immediately cease all.offshore  disposal until the following is
             compIe ted -

             a.   Adequate studies  are made of the offshore environment.  This
                  should include a  well planned series of transects with an
                  underwater camera or high resolution fathometer.  Transects
 H_12            should be run from near shore to beyond 100-foot depths.
                 Transects should  be spaced  no more than one-half mile apart.
                 The area of coverage should extend from at least 15 miles
                  south of the harbor entrance to ten miles north of it.

             b.   A careful study  is made of  the present disposal site and
                  surrounding area  to determine how far the-materia I already
                  dumped has spread and what  effect siltation is having on hard-
 11-13            bottom communities.  Observations from local divers indicate
                  that siltation from the present disposal site has spread at
                  least seven to eight miles  beyond the site.  This should be
                  confirmed and its effect determined.

 H-14       c.   A good economic analysis of potential damage to fisheries is
                  produc ed.

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      Environmental Protection Agency
      December  10, 1982
      Page Five
         d.  A detailed analysis  is made  on how  the capacity of the
             existing diked disposal areas could be increased.  We suspect
I*  ,r        that  a carefully planned program of de-watering,  increasing
             dike  height, and reusing spoil material could extend the life
             of  existing site far  into  the future, perhaps permanently.

     2)  Until the above are accomplished, the existing diked  disposal
         areas should be used for  disposal of material proposed to be
         dumped  in the GuIf.

     3)  We  request that a public  hearing be held to allow full and complete public
         comment.  As indicated above,  our preliminary review  of this project indica-
11  i/-    tes that  it  is a serious  threat  to fishery resources  for which the Council
         is  responsible.  It may  also represent  a serious health hazard to the human
         population in the area.

     Sincere ly,

             +*   H
      J ohn M. Gr een
      Ch a i rma n

      JMGrJCD:Iod

      At tachment s

      cc:  Gulf  CounciI
          Director, Florida DNR
          Secretary,  Florida DER
          District Engineer, Jacksonville COE
          Regional Director, National Marine Fisheries Service
          Regional Administrator, Fish & Wildlife Service
          Staff

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                              1600  CITY  ISLAND  PARK
                              SARASOTA.   FLORIDA   33577

                                    PHONE:  (813)  388-4441

                                WILLIAM R. MOTE           WILLIAM H. TAFT. Ph.D.
                              CHAIRMAN OF THE BOARD              PRESIDENT
December 9, 1982
Mr. Michael R. McKinley
Director of Planning
Tampa Bay Regional Planning Council
9455 Roger Boulevard
St. Petersburg, FL  33702

Dear Mr. McKinley:

Enclosed please find a copy of  the Mote Marine  Laboratory's
comments on the Draft EIS for Tampa Harbor,  Florida  Ocean Dredged
Material Disposal Site Designation, dated November 1982.   These
same comments have been sent:to the EPA Criteria  and Standards
Division.

I hope that these comments are  of use  to you in evaluating the
offshore dumping issue as it relates to the  plans and goals of
your organization.

Sincerely,
Stanley A. Rice, Ph.D.
Staff Scientist

SAR:lef
Enclosure

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                                           1600  CITY  ISLAND   PARK
                                           SARASOTA.   r L O  R  I 0 A  33577

                                                 PHONE:  (813)   383-4441

                                             WILLIAM R. MOTE           WILLIAM H. TAFT. Ph D.
                                           CHAIRMAN OF THE BOARD              PRESIDENT
                     Comments on the Draft Environmental  Impact Statement
                                 For Tampa harbor,  Florida
                      Ocean Dredged Material Disposal  Site Designation.
                                    Dated November, 1982


                    I have thoroughly  reviewed  the  above  draft EIS and the associated
             appendices and would like  to register  the following comments.

                    The proposal to designate Site  4 (located 18 n mi southwest of
             the nouth of Tampa Bayl as a permanent disposal site for dredged material
             is unjustified for two major reasons.   First, insufficient information is
             available concerning the  physical  and  biological characteristics of Site 4
             and the Surrounding area  to predict  the impact of ocean disposal of dredged
             material.  Second, site specific ronitoring  studies of post-disposal impacts
             have been incomplete and  insufficient  to  evaluate the impact of ongoing dis-
             posal operations on the nearshore  Gulf of Mexico environment.  Attempts are
l'~l         made in the EIS to draw conclusions  about potential impacts at Site 4 based
             upon studies conducted in  other parts  of  the U.S. and under very different
             environmental conditions.  The Gulf  of Mexico off Tampa Bay constitutes a
             unique ecological system  containing  hard-bottom as well as soft-bottom
             habitats, tropical and subtropical species,  and productive commercial and
             recreational resources.   For these reasons,  site specific studies are
             essential to any evaluation or prediction of disposal impacts within this
             area.

                    A review of environmental studies  conducted in the Gulf of Mexico
             near Tampa Bay as part of  the EIS  process reveals that Site 4 has only
             recen-ly been considered  and that  little  more is known about Site 4 than
             was known about Site A when it was first  designated as an interim disposal
             site.  Of the eight major  site-specific environmental studies that have been
             conducted since 1979 (Taylor, 1979;  IZC,  1979; IEC, 1980; MML, 1981; EPA,
             1981; CCI, 1982; Taylor,  1982; EPA,  1982), only the last study considered
12-2         Site 4.  The latest EPA survey (Appendix  C of EIS)  collected certain physi-
             cal, chemical and biological information  from Sites A, B, 3 and 4.   In this
             study, the sediment grain  size analyses,  sediment chemical analyses and
             water column chemistry would appear  to be sufficient to characterize the
             existing and proposed sites; however,  the biological sampling, habitat
             descriptions and tissue chemical analyses fall far short of being adequate.

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                                             -2-


                  Biological  sampling  during the EPA,  1982  survey was  carried our
           with a box core ar.d  an  otter  trawl.   As  stated on page A-4  of  EIS
           Appendix C, with reference  to box core samples,  "All  sar.ples obtained
           with less than 15  cm penetration  depth were rejecter5.."  This type of
           sampling methodology would  automatically exclude any  samples collected
           from hard-bottom habitats since a box core .would not  penetrate 15 cm. into
12-2       hard substratum.   Since no  hard-bottom habitat samples were retained or
           analyzed and since no record  is given on the number of times that box
           core samples were  rejected, absolutely no conclusions can be drawn from
           these benthic samples with  regard to presence or absence of hard-bottom
           habitats and organisms.

                  The only other data  from the  Site 4  study that might be used to
           estimate bottom habitat coverage  are the video tape records mentioned
           on page 2-10 of the  EIS.  These videotapes, however,  represent only
12-3       one partial transect of the site  and do  not cover enough terrain to
           justify conclusions  about the entire site or surrounding area.

                  Local fishermen  and  divers frequent  the area within  and around
           Site 4 and hard-bottom  habitats are  known to exist within the  site.  Unless
           more detailed habitat studies are completed at Site 4, the  ETA will be
           running the risk of  repeating the same mistake it made with regard to
12-4       Site A, that is, designating  an environmentally unacceptable site for
           dredged material disposal because Df inadequate site-specific  studies.

                  Since insufficient data presently exists with  regard re benthic
           habitats within and  around  Site 4, several  conclusions in the  EIS cannot
           be substantiated since  they are based upon  the assumption that hari-bctton
           habitats are rare or non-existent at Site 4.  These conclusions ir.clu.ie:
12-5       EIS page 2-21, first paragraph; page 4-13,  second paragraph; page 4-19,
           third paragraph; page 4-21, fourth paragraph.

                  Table S-l on  pages xiv-xv  of  the  EIS lists eleven sp-jcific cri-
           teria to be considered  in selection  of an offshore disposal site and
           ccnpares the existing sites with  Site 4.  Ir. light of the arc-ve -iscussion
12-6       criteria =1, 3, 8, and  9 cannot be adequately evaluated with respect to
           Site 4 due to insufficient environmental characterization cf that site.

                  The prediction of environmental Impacts due to dredged  material
           disposal and the success of environmental monitoring programs  rests
           heavily upon having   a  thorough knowledge of the composition of poten-
           tially affected habitats.  The Gulf  of Mexico off Tacpa Bay is unique  in
12-7       that it contains highly  productive  and  diverse hard-iottom habitats inter-
           spersed among sandy  substrata.  With the exception of studies by Jaap  (1981),
           Mote Marine Laboratory  (1981)  and  scattered observations by Taylor (1982),
           no studies have considered the impact of dredged material disposal upon
           hard-bottom attached organisms.   The importance of the.se hard-bottom
           habitats and their associated  flora  and  faur.a has beer, adequately stressed
           in the literature  (see  EIS for OCS Sale  365, 1978;  ar.c Fed.  Regist.  Vol.
           45, No. 194, pg. 55946)  and even  the present EIS states on t-age 2-25,

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                                              -3-


             "To further minimize adverse Impacts, disruption jof hard-bottom
             communities should be avoided to the greatest extent possible."  Hard-
             bottom communities have been identified within all of the existing and
             shallow water alternative sites yet no studies have been undertaken
             to determine the sensitivity of these organisms to disposal operations.
             The effects of disposal operations upon soft-bottom communities are not
             transferable to hard-bottoms.

                    In order to predict potential short-term impacts upon hard-
             bottom communities, it will be necessary to determine:   (1) the species
             composition of site-specific hard-bottom habitats; (2) the sensitivity
             of .selected representative hard-bottom organisms to siltation and burial;
       v.     and (3) the potential for bioaccumulation or biomagnification of toxic
             chemicals in hard-bottom organisms and food webs.  In addition, long-term
             monitoring programs should include studies on colonization, growth, and
12-8         reproduction of attached hard-bottom organisms in the vicinity of any
             active dump site.  At the present time, none of Che above information is
             available for the existing or alternative sites and thus no predictions
             can be substantiated with regard to acute nor chronic impacts upon hard-
             bottom habitats.

                    In addition to the above comments, the Draft EIS is incomplete
             with respect to the following points:

                    1)   Bacteriological studies reported in EIS Appendix C considered
             only total and fecal coliform with no tests made for vibrio-type bacteria
12-9         that have been identified in Tampa Bay sediments ar.d pose a human health
             threat.

                    2)   Data contained within the EIS and Appendices indicate that
             Tampa Bay sediments are not compatible or comparable to dump site sedi-
             ments.  For example: Table 3-5 on page 3-30 and Table 4-2 on page 4-5
             report very low background values for heavy metals like cadmium, lead,
             and mercury, yet Tampa Bay sediments contain significantly higher concen-
             trations of these metals.  How can these sediments be assumed to have no
12-10        significant impact?  Sediment grain size analyses reported for Site A
             and vicinity prior to disposal operations (Appendix A, page A-14)  indi-
             cated a silt/clay fraction of less than 2%,  whereas post disposal-samples
             reported silt/clay fractions as high as 11-42% at the same site (Appendix
             C, page A-33).   These are obviously not similar sediments and would
             definitely be expected to cause a significant impact  upon endemic organisms.

                    3)   The EIS sections concerning endangered species (pages 3-46
             and 4-19)  fail to consider any of the invertebrate species that are
             listed as threatened or endangered by the State of Florida Game and
 12-11        Freshwater Fish Commission and that have been reported in the vicinity
             of the dump sites.

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                    4)  Site-specific  studies are lacking which address the poten-
             tial for toxic chemical release from dumped sediments  in spite of the
12-12        fact that potentially  toxic  concentrations of heavy tnetals have been
             found in Site A post-disposal  sediments  (EIS Appendix  C, page A-54;
             Appendix E, page  17) and  tissue samples  (Appendix C, page A-68) .

                    5)  Bioassay  studies  conducted by Jones, Edmunds and Associates,
             Inc. (1979)  (EIS  page  2-25)  on pre-disposal sediments  did not employ
12-13        endemic species and  are further invalidated by pre-exposure of test
             organisms to significantly high concentrations of toxic chemicals in
             control water.  Thus,  these  studies have no predictive value.

                    6)  The possibility and economic feasibility of other than ocean
             disposal has not  been  adequately treated in the EIS.   Serious consi-
             deration should be given  to  using diked disposal areas within Hillsborough
             Bay, at least until  a  suitable permanent disposal area can be found.
io_l4        Further studies,  as  listed above, are needed before the impact of ocean
             disposal in the Gulf of Mexico can be predicted or evaluated.  These
             studies oust be designed, executed and reviewed by competent scientists
             to ensure that reliable information is obtained and that the results
             address the appropriate concerns.  Additional studies  should be undertaken
             immediately at Site  4  (as suggested in EIS Appendix C, page A-1S3) to
             ensure that another  inappropriate disposal site is not authorized pre-
             maturely.
             Stanley A. Rice, Ph.D.
             Staff Scientist

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-   HIU.SBOROUGH COUNTY
 ENVIRONMENTAL PROTECTION
       COMMISSION
      FRED A. ANDERSON
      JERRY M. BOWMER
        FRAN OAVIN
        JOE KOTVAS
      JAN KAMINIS PLATT
  ROGER P. STEWART
    DIRECTOR

   1900 - «tn AVE.
 TAMPA. FLORIDA 3360$

TELEPHONE (813) 272-5860
          December 5, 1982
          Ms.  Margaret Guy
          A-95 Coordinator
          Tampa Bay Regional Planning Council
          9455 Roger Boulevard
          St.  Petersburg,  FL   33702

          Dear Ms. Guy:

          The  staff of the Environmental Protection Commission has reviewed the
          Environmental  Impact Statement for Tampa Harbor,  Florida:  Ocean
          Dredged Material Disposal Site Designation.  The  attached memo defines
          our  concerns and recommendations of the project.

          If you have any  questions concerning our comments,  please contact me.

          Sincerely,
          Michael Heerschap
          Environmental Specialist
          Hillsborough County Environmental
              Protection  Commission
          MH/rr
          w/Attachment
                                      An AffirmatKra Action - Equal Oflponundy Employer

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OUNTY
To.
                                     OF HILLSBOROOG^
                                 MEMORANDUM
                                                           Dote  November  18. 1982
        Mike Heerschap, Assessment
Sub ecr
        Tom Cardinale, Laboratory
                                  •£•
           " Ocean  Dredged Disposal  Site
14_2
14_2
        I would recommend that al 1 disposal at  the Existing Site A be stopped because
        it  is too close to shore, too close to  productive reef -areas, and within
        easy reach of divers and small  boat users.

        Site k is in 85 to 95 feet of water and is not as likely to be used for
        recreational purposes such as diving and  fishing.  All material  should go  to this
        site until some long range solution is  found.

        Site k has no hard-bottom outcrops and  would therefore have the least impact
        on  fish and other types of life.

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                                                                      (.1
COUNTY
                                                                               G

                          OF  HILLSBOROUGH
   To.
                                 MEMORANDUM
Margaret F. Guv. A-95 Coordinator.  TBRPC
                                                               December 3. 1982
   From	


   Subject:
Christy SuppVsem'or Planner, Department of-Development Coordination
TBRPC A-95 Clearinghouse Review No. 218-82; Draft Environmental Impact Statement
for Tampa Harbor, Florida, Ocean Dredged Material Disposal Site Designation,
Hi 11sborough, Manatee and Pinellas Counties	
 15-1
We have no comment on the above-stated project proposal.  Offshore impacts
related to water quality are within  the jurisdiction of the Environmental
Protection Commission.  It is understood that you have already sent, under
separate cover, a copy of the Draft  to the Environmental Protection Commission
and the Planning Commission for review and comment as appropriate.

Thank you for informing us of the project.
            CSrpkh

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                                 STATE OF FLORIDA
                                 of %
                                   THE CAPITOL
                                 TALLAHASSEE 323O1
    BOB GRAHAM
     GOVERNOR                            December  22,  1982
        Mr. Chris Schilling
        U.S. Environmental Protection Agency
        Criteria and Standards Division  (WH-585)
        401 North Street, Southwest
        Washington, D.C. 20460

        Dear Mr. Schilling:

             This Office reviewed and coordinated  a  state agency
        review of your Draft Environmental Impact  Statement for Tampa
        Harbor Florida, Ocean Dredged Material Disposal  Site
        Designation for Hillsborough, Manatee and  Pinellas Counties.

             The document describes a proposed action  designating a
        dredge material disposal site for Tampa Harbor.   The site will
        be managed by the U.S. Environmental Protection  Agency, Region
        IV.  The proposed recommended site is approximately 18 miles
        southwest of the mouth of Tampa Bay and covers a four-mile
        area.  It is intended that the site be permanently designated
        for the disposal of dredge material resulting  from the dredging
        of the Tampa Harbor area.

             An interagency review of the statement  has  found that
        the proposed action would smother. the benthos  within the
        designated area and alter habitat within the site.  The document
        recognizes that these adverse impacts at the site are unavoid-
16-1     able.  Our reviewing agencies report that  the  EIS statement is
        inadequate and lacks the necessary information to be of sufficient
        value as a decision-making document  (see attachments) .

             ,We have concerns with this designated site  and EPA's
        proposed rule for ocean dumping without a  Federal Coastal Zone
        Management Consistency Evaluation.  Recognizing  our concerns.
        the impact of this designation and its effort-  on
        Harbor project, we request that your agency participate in an
        interagency meeting at your earliest convenience  to afford us
        .the opportunity to discuss issues of concern  to  the State of
        Florida. m It is our desire to use this  initial meeting as a
        step toward resolving our concerns .
                        An Affirmative Action/Equal Opportunity Employer

-------
Mr. Chris Schilling
December 22, 1982
Page 2


     Please contact Walt Kolb of my office at (904) 488-5551
concerning arrangements for this meeting.  Thank you for your
cooperation.
                               Sincerely,
JTH/mkq

cc:  Ms. Victoria Tschinkel
     Dr. Elton Gissendanner
     Mr. L. Ross Morrell
     Mr. William A. Ockunzzie
                                           .   	
                                 hn T. Herndon, Director
                                'ffice of Planning and Budgeting

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   A very H. Gould
9907 Spoonbill Road East
    Flamingo Cay
  Bradenton, FL 33529
              &e^ 4f £U*&la&> £^*^w  t^t^ty&rfa*^
              frfite^  ^farum %6tL^a^_

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                                         Avery H. Gould
                                     9907 Spoonbill Road East
                                         Flamingo Cay
                                       Bradenton, FL 33529
7-5
7-6
                                                                    *^
 &tL&+J <£2_t &d&. l<&*££. ^L fo/uArf $> &U, 7&&i*A; &~*
^ /---/-               '             V                /,n^_,

                                                 AzW^
                                                 . .   « / *-£ f
7-7
7-8

-------
                                 Avery H. Gould
                             9907 Spoonbill Road East
                                  Flamingo Cay
                               Bradenton,  FL 33529
Q.  £&&si«~&.  T&~
Ms&^ *6"G?&/r


-------
                      NATIONAL SCIENCE FOUNDATION
                      •:..,-'
                            WASHINGTON.  D.C.  2O55O

                                 October 28, 1982
  OFFICE OF THE
ASSISTANT DIRECTOR
FOR ASTRONOMICAL.
ATMOSPHERIC. EARTH.
AND  OCEAN SCIENCES
 Environmental  Protection Agency
 Criteria and Standards Division (WH-585)
 401  M Street,  SW
 Washington,  DC 20460

 Dear Sir:

 The  National Science Foundation has_no comment on the DEIS  for

 Tampa Harbor,  Florida Ocean Dredged Material Disposal Site

 Designation.
                                 Sincerely yours,
                                 Barbara E. Onestak
                                 Acting Chairman
                                 Committee on Environmental
                                   Matters

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                (la it» attempt to stop au ocean uumping, the I
              county has tried to show in the trial that no
              matter wtare you damp the material, it. will
              move and destroy hard bottoms, ft hopes the
              judge will make the feds damp the material at
              OTJgip  ^ikorf spoil 'glando  .   -'
                    ^^.^U  '
                            ^9£o


                                                                         __  t      .        .y -- v
                                                                       s£t-i<^     -   -  ~

18-1

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                         FLORIDA  COOPERATIVE EXTENSION SERVICE
                         UNIVERSITY OF" FLORIDA
                         FOR SEA GRANT PROGRAM of STATE UNIVERSITY SYSTE.VI OF" FLORIDA
                                         MARirsiE ADVISORY PROGRAM
                                         REPUV TO  1303 17th St. W.
                                                 Palmetto, Fl. 33561 299!
                                                 (813) 722-4524
       November 29, 1982
       Criteria and Standards Division
       401 M Sheet SW
       Environmental Protection Agency
       Washington, B.C.  20460

            I have reviewed the draft Environmental Impact Statement
       for Tampa Harbor,  Florida Ocean Dredged Material Disposal Site
       Selection, and have some questions and comments.

            1. In the report it is clearly and repeatedly stated that
       existing dump sites are located near areas of hard bottom and
       charter boat operations. Also, that since this area is a "high
       energy" environment there is the possibilty that dredge material
       could drift back  into the Tampa Bay channel entrance (approx.
20-1    1.25 nm south of  the existing sites).  To me this suggests that
       the orginal site  selection was conducted in a hasty and arbitary
       matter.

            I applaud the efforts to find a more suitable disposal site
       but question whether damage has already occoured. It will soon
20-2    be  six years since the initial dump site selection. To me the
       information presented would argue against permitting any additional
       dumping I.e. 1.7  million cubic yards at the present dump location.

            2. On page 4-7 the report states:  "Dilution and dispersion
       will reduce suspended particulate levels relatively quickly".
20-3    What does "relatively quickly" mean, (hours, days, weeks,?).

            3. On page 4-19 the report states:  "Short-term avoidence of
       locally high turbidity may be the only significant environmental
       effects on fisheries".  If this short term avoidence were to occur
       concurrently with  the short-term seasonal migrations of mackerel
20-4    and mullet, the effect would be greatly increased. Therefore it
       would seem to be  advisable to consider seasonal restrictions on
       dumping activity.

            4.  On page 4-22  the report indicates that since the sites are
20-5    a least 9 nmi from shore,  a turbid  plume would have non-existent
       adverse impacts on visual  aesthetics from shore.  What about for
       sport  diving?
                            EQUAL. OPPORTUNITY EMPLOYER


      COOPERATIVE EXTENSION WORK IN AGRICULTURE. HOME ECONOMICS ANO MARINE SCIENCES. STATE OF FLORIDA.
  U. S. DEPARTMENT OF AGRICULTURE. U. S. DEPARTMENT OF COMMERCE. AND BOARDS OF COUNTY COMMISSIONERS. COOPERATING

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         UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                      WASHINGTON, D.C. 20460
                           3KC. 1982
                                                          OFFICE OF
                                                           WATER
Mr.  Richard E. Pease, President
Florida Skin Divers Association
3901 Lynwood Avenue
Tampa, Florida  33611

Dear Mr. Pease:

       Thank you for your letter of November 1, 1982, containing
comments on the Draft Environmental Impact Statement (DEIS) for
the Tampa Harbor Ocean Dredged Material Disposal Site Designa-
tion.  Comments on this DEIS should be addressed to Mr. W. C.
Shilling, Criteria and Standards Division (WH-585), EPA, Washington,
DC,  20460.  I have taken the liberty of forwarding your comments to
Mr.  Shilling.

       The notice of availability of this DEIS was published in the
Federal Register on Friday, October 29;  the comment period does
n ot  close until December 13.

                               Sincerely yours,
                               T. A. Wastler,  Chief
                               Marine Protection Branch (WH-585)

-------
                                 orida Skin
                                         *•;>_} /"' ."j  • .

                                          November  1,  1982
          Mr. T. A. Wastler
          Chief, Marine Protection Branch
          
-------
          been greatly reduced,  reducing penetration of  light  and
          productivity o-f the bottom community.  As a side  effect,  it has
          become impossible  to dive in much of this area, and  greatly
          reduced the receational  value o-f the rest.  In  our  experiance,
          turbidity and siltation  -from dumping continue  to  disrupt  the
          system for months  or years,  not days.

          The DEIS Does not  differeniate between the likely environmental
          e-f-fects of spoil from harbor deepening versus  maintenance.  In
          our opinion, the difference will be radical.   Large  grain
          matarial, rock, sand,etc from channel deepening will  probably
          stay within the site.  Longterm adverse impacts  outside the site
21-3       may not be too serious.   Maintenance dreding will produce
          primarily silt and other fine grain material.   This  material
          will inevitably be distributed for miles surrounding the  site.
          If  the effects of  the material are evident for  months or  years,
          and maintenance dreding  is conducted annually  or  bi-annual 1y, we
          have a permanent problem.   longterm chronic damage  to thousands
          of  acres of. coral  habitat is likely.  The DEIS gives no
          suggestion that this problem might exist.

          The DEIS ignores the effect on the human environment.   TWere'has
          already been and will  continue to be a sustantial loss of
          esthetic value to  divers.   This will inevitably translate into
          economic loss for  diving related businesses.   The same is  true
21-4       for recreational and charter fishing.  The values for
          recreational fishing given in the document are ridiculously
          understated and 8  years  out of date.  Economic  value of diving
          is  not even mentioned.   Recreational fishing and  diving is a
          multi-bi11ion dollar industry in Florida.


          The DEIS ignores the effect of illegal dumping  outside the site.
          As  you are aware,  from previous correspondence with  us, dumping
          is  now occuring outside  the site.  A spoil pile can  be found at
          loran coordinates  14168.2, 44327.5.  This is about  one mile east
2i_5       of  the present site.  When found, it was obviously  fresh, with
          little growth on the rocks.   Some of our members  have reported
          other instances where hopper dredges appeared  to  be  dumping
          outside the site.   This  may be a common occurance.   If so,  it's
          environmental effects should be considered.

          FSDA is strongly opposed to offshore disposal  of  spoil,
          particularly maintenance material.  We reccommend that dumping
2l_5       cease, at least until the following is completed:
             1.  The DEIS should be modified to fully examine  all disposal
          alternatives, including  upland disposal.  Economic  values for
          fishery and recreational losses should be included.

          Proper management  of existing disposal sites could  solve  most or
21-7       all a* DLir problems and  eliminate the need for  offshore
          disposal. Most material  from channel deepening is good quality

-------
       •fill,  for which there is a  ready  market in this area.  Presently
       available techiques for de-watering and compacting soft  material
       could  greatly expand the capacity of  existing sites  in upper
       Hillsborough Bay.

            2.  If offshore disposal  is  inevitable, a serious study of
22-8    ^ne °ff5haris area should be completed.   Work to date has been
       piece  meal and totally inadequate.  A  complete mapping study of
       the entire area is needed along  with  current and wave energy
       studies to determine exactly where spoil material will end up.

       Thank  you for this opportunity to comment.
       Si ncerel y
       Richard E. Pease, President
       Florida Skin Divers Association

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          Captain  L.  F.  Borden
          5301 35th Avenue  West
          Bradenton,  Florida  33529
          December 8, 1982
          Criteria  and Standards  Division  (WH-585)
          401 H Street, S.W.
          Environmental Protection  Agency
          Washington,  D.  C.  20460
          RE:   Draft Environmental  Impact  Statement  11/82

          Dear Sirs:

          Page 10 of the  summary.   The  Corps  stated  that non-ocean  disposal  methods were
          considered in  1974.   We  see nothing in  the 1982  draft that compares the cost
          benefit ratio  of  offshore dumping with  any other alternatives such as upland
          disposal  of dredged  material.  The  Federal  Register 40CFR, Subpart C227.15,
          Paragraph C states that  in the factors  considered,  the need for dumping will  be
          determined by  evaluating  the  relative environmental  risk  impact and cost for
 22-1      ocean dumping  as  opposed  to other feasible alternatives:  including, but not
          limited to, landfill,  well injection, consideration of spreading the material
          over open ground, recycling material, storage, etc.   Again, the Corps has not
          dealt with the  cost-ratio benefits  between ocean dumping  and upland containment
          as  they must according to "EPA1s  Federal  Register.

          Page 13,  paragraph 4.  States "the  shallow water Alternative Site  4 will  provide
          a  sandy bottom  environment that  is  further removed  from the hard bottom areas
          and  of sufficient size to permit the disposal of dredge material  without unaccept-
 22-L      able adverse affects."  There is quite  a lot of  sand in Site 4.  However, this
          site also contains many  highly productive,  low relif, hard bottom areas.   There-
          fore Site 4 is  not an  entirely sand bottom as so specified.

          Page 16,  first  paragraph.  States "the  tropical  storms and hurricanes produce
          strong bottom  currents of 3 to 4 knots  which can profoundly affect dumped material.
          This is true,  however, every  northwestern  blow that commonly occurs with the
22-3      winter fronts  causes considerabledrifting  of the dumped material.   These prevail-
          ing  winds will  disperse  the material towards the southeast, a very sensitive area
          located off Sarasota.

          Page 16,  paragraph 2.  EPA states "dispersal of  dumped sediments,  particularly
          the  large volume  projects from the  Tampa Bay Harbor Deepening Project may
          adversely affect  hard  bottom  outcrops near the existing site".   Again they are
22-4      stating that migitation  of the silt is  probable.  "Relocation of the disposal
          site to an area containing fewer or no  hard bottom  outcrops  will  present less
          conflict  with  the environmental  characteristics  of  the area and the commercial
          fishing,  diving and  recreational use of the area."   One mile north of Alternative
          Site 4 lies one of the best dove areas  in  the West  Coast  of Florida; the wreck

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        Criteria and Standards Division
        December 8, 1982
        Page 2
        of the Gunsmoke in 80 feet of water.  The Gunsmoke is a 65-70 foot fishing
        vessel sunk some 6-7 years ago.  Without a doubt the siltation will affect that
        dive site.  The Draft goes on to say "in addition continued use of existing
        sites or use of Alternative Site 2 may result in repositioning of dump sediments
        into the entrance of the channel".  Again they are stating that migration is
        probable.  The last portion of that paragraph states that shallow water Alternative
        Site 4 will provide a large sandy bottom area for disposal of dredged material.
        Again, they stated that is is all sandy bottom.  It is not.

        Page 17, paragraph 2.  States "dispersal of material outside the site boundaries
        will be over time and in thin layers.  Such dispersion is not expected to have
        unacceptable adverse environmental affects."  It is my belief that a thin layer
        over a period of time is what is doing the damage to the limestone ledge forma-
22-5    tions, particularly the low relief hard bottom outcrops in the Gulf of Mexico.
        This thin layer that the draft is discussing unnaturally resuspends and smothers
        every little section of outcropping in the area, destroying the chain of life.

        Page 19, summary Environmental Consequences.  EPA states "previous disposal of
        dredged materials at existing sites has not been monitored to determine specific
        environmental effects".  It goes on to say that "studies of dredged material
        disposal in other operations conducted in other areas of the continental waters
        had determined no significant long term adverse affects resulted in the dumping
        of dredged material on sandy bottoms".  The West Coast of Florida is not tfke
        other locations throughout the continental U.S.A.  The flushing patterns are
22-6    completely different than the East Coast of Florida or the northeast coast of
        the continent.  Flushing patterns and dispersal patterns cannot be compared to
        other areas of the United States.  Again, they have stated in the summary that
        dispersal is evident.  The problem is that it does not collect on the sandy
        areas, it collects in the limestone pockets, the habitat for the fish.

        Page 20.  States "that mounds of dredged material may persist several months.
        The physical characteristics of the dredged sediment may be dissimilar to the
        existing sediments resulting in changes to the bathynic biological characteris-
2<-~'    tics of the affected site."  The Draft summary states "the marine organisms are
        not adapatable for burial or the high level of silt, therefore the dredged
        material and disposal at the existing site may result in a more significant
        environmental consequence than at an alternative site, such as Site 4."  The
        problem with this statement is that the quality of the water is much better
        at Site 4 in 80 feet of water.  The corals are in better shape, the spiny oysters
        are surviving and the general quality of the water is much better and much
        clearer.  Therefore there would be more environmental consequences due to the
        siltation at Site 4.

        Page 20, paragraph 2.  States that "based on analysis of the samples, certain
        trace elements would be released in the water during disposal.  Some of these
        materials contain heavy metals, organic compounds, nitrogen compounds, and
        phosphorous compounds.  It states however the estimated volume release and
22-8    calculated dilution of this mater indicated that there would be reduced back-
        ground levels after the permitted 4 hour period of initial dilution.  The problem
        seems to be that the samples and the 4 hour periods of initial dilution are not
        actual paramenters, but in fact samples. -Samples of silt removed from the actual
        dump site.

  o_     Page 20, paragraph 3.  States "the proposed action is expected to have minimal

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          Criteria and  Standards  Division
          December 8,  1982
          Page 3
22-10
22-11
impact on threatened and endangered species occuring in the region." Turtles
inhabiting the area are predominantly loggerhead.  The last portion of that
paragraph states "that the general area of the site under consideration, Site 4,
do not contain unique feeding or breeding grounds for any specie of turtle and
the site used is not anticipated to affect their survival."  Perhaps the bottom
within Site 4 is not unique in that it does not have the high relief that the
loggerheads seem to stay around and feed, however the scope of the siltation
will affect the loggerhead feeding.  Silt migration is evident to other areas
that the loggerhead will be feeding and living.  There are loggerheads in the
area of Site 4.  I feel that siltation will definitely affect the feeding
pattern and perhaps the breeding pattern as well.

Page 21. paragraph 1.  States that "disposal operations on Alternative Site 4
would not interfere with long term use of the resource".  I disagree with that.
It goes on to say that, adverse environmental effects of the proposed action
include smothering of the bottom within the designated site to possible habitat
alteration of the site and states adverse impacts within the site are unavoid-
able, but the disposal operations will be regulated to prevent unacceptable and
environmental degration outside the boundaries".  Regulation seems to be the key
would here.  The EPA has proven to the residents of Manatee County that it does
not intend to abide by it's own regulations set up in the Federal Register.

Page 21. paragraph' 2.  States "the CE District Engineer or EPA may_ establish a
monitoring program to supplement historical data.  The primary purpose of the
monitoring program is to determine whether disposal at the selected site signifi-
cantly affects areas outside the site, and to detect long-term effects occurring
in or around the site."   This monitoring plan will no doubt be as incomplete as
Mr. Amson's site survey of Site 4.  Retrospective monitoring serves no purpose
after the damage is done and the habitat is destroyed.  As in the case of Site A.
Bataymetric studies must be conducted before the ocean disposal if adverse im-
pacts are expected.
                         orden
          cc:   Alfred  B.  Devereaux,  Jr.
               Charles Hunsicker
               Bob Reynolds.

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                                  DEPARTMENT OF THE ARMY
                        WATER RESOURCES SUPPORT CENTER, CORPS OF ENGINEERS
                                       KINGMAN BUILDING
                                  FORT BEUVOIR, VIRGINIA 22060
                 REPLY TO
                 ATTENTION OF:
         WRSC-D                                                        9   DEC 1982
        Mr. Jonathan Amson
        Criteria and Standards Division
        0. S. Environmental Protection Agency
        401 M Street, S. W.
        Washington, D. C.  20460
        Dear Mr. Amson:

        The Draft Environmental Impact Statement for  the Tampa Harbor,  Florida,  Ocean
        Dredged Material Disposal Site Designation, dated November,  1982,  has  been
        reviewed by the U. S. Army Corps of Engineers.  The Corps' general and specific
        comments are inclosed, Incl  1.

        The Corps concurs with EPA'a recommendation that the ocean site at center
        coordinates 27° 31' 27"N, 83° 04' 54"W, is environmentally acceptable  for the
23-1    ocean disposal of dredged material and should receive permanent designation for
        the disposal of dredged materials from the Tampa Bay area that  are in
        compliance with the criteria and requirements of EPA and Corps  regulations.

                                               Sincerely,
         1 Incl
         As stated                              Chief, Dredging Division

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                                                               1 December 1982
                     SAD Comments on EPA DEIS  (November  1982)
            for Tampa Ocean  Dredged Material Disposal  Site  Designation
1.   General.

    a.   While the EIS recommends  the  designation  of a  new ocean  disposal  site,
it does not clearly show the  trade-offs  involved  in changing sites.   That is,
the additional economic costs of utilizing  Site  4  are not  weighed^against  the
environmental damages to the  existing site and  adjacent areas.   Furthermore,
the significance of the hard  bottom areas  in  Site A to the hard  bottom in the
geographic region is not discussed or demonstrated.

    b.   The EIS should clarify the concept that previous  studies "showed  no
significant environmental degradation outside Site A,  and, in EPA's  best
professional  judgment, the balance of the  dredged material from  Section 2C
(portion) will remain within  the  site without causing unacceptable adverse impact
beyond the site boundary."  (Federal  Register,  October 6, 1982).  The EIS does  not
appear to be totally consistent with  the concept as indicated by paragraph 1,
page 2-26 and paragraph 1, page 4-2.

    c.  Recovery of Site A after  completion of disposal should be disc-.-sed.

2.  Page VI, first sentence,  item (2).  "possible" should be deleted.

3.  Pages X, 10th line and 2-4. 11th  line,  "justify an acceptable"... suggest
replace "justify" with "develop," and method needs to be  pluralized.
    Pag
    r~of
e 1-6.  The second paragraph needs  to be revised to reflect the compie-
4.
tion of recent maintenance dredging of St.  Petersburg Harbor and Port Tampa
Channel.  St. Petersburg Harbor dredging was  completed on May 1981; 362,652
cubic years of dredged material was taken from St.  Petersburg Harbor and
deposited in the Gulf d/a (Site A).  Dredging at Port Tampa Channel (Cut G)
was completed on March 1982; 662,897 cubic  yards of dredged material from
the Port Tampa Channel was deposited at the Gulf d/a (Site A).

5.  Page 2-3, first full paragraph.  Freshwater runoff from upland is not
considered a significant influence at the subject disposal areas.  It is   -
recommended that "freshwater runoff" should be deleted.
6.  Page 2-3,
than existing
miles).
       last paragraph.  Site 4 is 5.6 statute miles farther hauling distance
       site.  A round trip would therefore be 11.2 statute miles (9.7 nautical
 7.   Page  2-5.  A  total  land-based operation is not expressed on this page.  The
 alternative  should  be  identified as a land and water-based disposal area.  In
 addition,  the  mention  of dike locations is confusing.  During successive
 dredging  operations, dredged material will be placed landward of temporary dike
 structures located  above the waterline.  This will confine unconsolidated material
 and  control  the  runoff from the disposal area.
                                                                 Incl.  1

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                                                     UNITED STATES DEPARTMENT OF COMMERCE
                                                     National Oceanic and Atmospheric Administration
                                                     Washington. D.C. 20235
                                                     OFFICE OF THE ADMINISTRATOR

                                                     December  13,  1982
24-1
Environmental Protection Agency
Criteria and Standards Division  (WH-585)
401 M Street, SW, Room 2824
Washington, D.C.  20460

Dear Sir:

     This is in reference  to your draft environmental impact  statement
entitled "Tampa Harbor, Florida,  Ocean Dredged Material Disposal  Site
Designation."  The enclosed comments from the National Oceanic  and  Atmospheric
Administration are forwarded for  your consideration.

     Thank you. for giving  us an opportunity to provide comments.  We would
appreciate receiving four  copies  of the final environmental impact  statement.

                                     Sincerely,
                                                     \. Wood
                                              Chief
                                              Ecology and  Conservation Division
          Enclosure
                                                     10TH ANNIVERSARY 1970-1SSO

                                                     National Oceanic and Atmospheric Administration
                                                     A young agency with a historic
                                                     tradition of service to the Nation

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                                                                                > -f
                                    UNITED STATES DEPARTMENT OF COMMERCE
                                    National Oceanic and Atmospheric Administration
                                    NATIONAL MARINE FISHERIES SERVICE       -JJ>   U //
                                   Southeast Region
                                   9450 Roger Boulevard
                                   St. Petersburg,  FL 33702

                                   November 4, 1982

TO:        PP/EC - Dave Cgttingham
                      f^£ {*—//(*/<<
FROM:      F/SER64 - Andreas Mager,"
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     Blue Whale (Balaenoptera musculus) - Blue whales are known
from the Gulf of Mexico based only on two strandings.  The
identification of one of these strandings may be suspect.  No other
data is available for this species in the Gulf of Mexico, but blue
whales seem to prefer cold water and avoid warm waters.

     Humpback Whale (Megaptera novaeangliae) - This species is known
from the Gulf of Mexico based mainly on three sightings, one of these
was off the mouth of Tampa Bay within 40 miles of the coast.  Captures
are also reported from the Gulf of Mexico.  Humpback whales are a
coastal species and are likely to be found inshore.  Breeding and
calving are known to occur in Caribbean waters from January to March,
but no life history data is available for the species in the Gulf of
Mexico.

     Right Whale (Eubalaena glacialis) - One sighting and one stranding
of this species are reported from the Gulf of Mexico.  The sighting
occurred off New Pass, Manatee County, Florida.  These whales are
primarily coastal, occurring very close to shore.  Therefore, they
are threatened by pollution, habitat destruction, and ship traffic,
especially since they are near extinction.  No life history data is
available for the right whale in the Gulf of Mexico.

     Sperm Whale (Physeter catodon) - A number of captures, strandings,
and sightings have been reported for this species in the Gulf of Mexico.
Sperm whales occur primarily in deep water off the continental shelf.
The sperm whale was once numerous in the Gulf, but is now considered
to be uncommon.  No life history data is available in the Gulf of Mexico.

     The information in the DEIS on sea turtles is also not accurate.
Specifically, we disagree that the five endangered turtles migrate from
the Caribbean to nest along the Gulf coast of Florida and that the
turtles range from Cedar Keys south to the Dry Tortugas.  Moreover,
the loggerhead sea turtle is listed as threatened, not endangered.

     The five species of sea turtles mentioned are distributed through-
out the Gulf of Mexico and not only from the Cedar Keys to the Dry Tortugas,
Also, the reference used to document that sea turtles migrate from the
Caribbean to the Gulf of Mexico should be provided.  The loggerhead is
the only sea turtle that nests with any frequency along the Gulf coast
of Florida.  Nesting here by other sea turtles would be very rare to
non-existent.

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      In view of the above, the information in the DEIS on sea turtles
and marine mammals should be upgraded.   Also,  the discussion of project
impacts on endangered and threatened species (page 4-40) should
be re-examined in the light of new information obtained.

      The DEIS would also be more complete if  it contained the results
of the Section 7 Consultation required  by the  Endangered Species Act.
This could perhaps be included in Chapter 5 -  Coordination.

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                                                                                                92,
         December 17, 1982
                                                                                    tempo boy
                                                                                       regional
                                                                                       planning
                                                                                         council
                                                                                  9455 Koger Boulevard
                           .                                                      SI Petersburg. FL 33702
         Mr. T. A. Was tier                                                   (813)577-S15l/Tampa 224-9380
         Chief, Marine Protection Branch  (WH-585)
         Environmental Protection Agency
         402 M Street S.W.,
         Washington, D.C. 20460

         Dear Mr. Wastier:

         Subject:  Capacity of an Ocean Disposal Site to Contain Dredged Material
                   with Special Reference to Outer Site A, Tampa, Florida


         The staff of the Tampa Bay Regional Planning Council has reviewed the
         above referenced report prepared to support the  extended area of  Site A
         for the disposal of dredged material from the Army Corps of Engineers
         Tampa Harbor Deepening Project.  Based on the  limited information  in the
         report and minimal review time frame, a determination cannot be made
         until detailed evaluation of the proposed action on the  human health,
         welfare,  amenities,  marine environment,  ecological system, and economic
         potentialities are completed  and public hearing  is held.

         The report contains some  valuable scientific  information  assessing the
         impact  of disposing dredged  material on sites  located  on the Atlantic
         Continental  Shelf.   However;  as  it is stated  in this report, the  number
         of  conducted  studies  is  relatively small  and there  is  not  yet a
         generalized  model that is widely accepted and available to describe all
         the relevant processes.

         Further disposal of  dredged material at Site A may result  in  more  signi-
         ficant environmental consequences than at other locations.   Since  May
25-1     1981,  about 4.68  million cubic yards  of dredged  sediment have  been
         discharged  at Site A;  about  59 percent of this material was mud,  39
         percent was sand,  and 2 percent was rock. The additional dumping may
         cause irreversible negative impacts on the marine environment.

         Therefore,  the Council staff  recommends  that  a public hearing be held to
         evaluate  the impact of the continued disposal of dredged material  of the
25-2     designated site.   The public  hearing should be held in order to receive
         this public testimony on  the  following issues:
             Chairman Jan K. Ptalt       Vice-Chairman George McGough      Secretary/Treasurer Saundra Rahn         W.A. Ockunzzi
         Commissioner. Hillstxirough County       Mayor. City of Largo           Councilwoman, City ol Bradenton        Executive Director

           Bradenton • Clearwater « Dade City • Dunedm • Gullport • Hillsborough County « Largo • Manatee County « New Port Richey • Oldsmar • Palmetto

            • Pasco County « Pinellas County « Pinellas Park • Safety Harbor « St. Petersburg « St. Petersburg Beach « Sarasota « Tampa « Tarpon Springs

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    /,-...
        Mr. T. A. Wastler                -2-                   December  17, 1982
25-3    o    Evaluate other alternatives than ocean  disposal  like diked disposal
             islands and upland disposal areas.

25-4    o    Evaluate the impacts of the proposed action  on  marine environment
             and economy of the region.

25-5    o    To further review the EPA proposal for extension  of Site A for the
             disposal.

25-6    o    Determine whether  the proposed action  affects  the recreational
             activities of the region and commercial fishing.

 25-7    o    The possible impact on migratory fishing,  should  be identified.

 25-8   o    Contribute to the knowledge of  the  environmental features of this
             area based on the previous activities in/around the site.

 25-9   o   Determine what studies' and monitoring should be done in  this area in
            order to detect long term adverse impacts.

        We appreciate the opportunity to review this important project and hope
        the above comments are helpful  to you in reaching a decision on a public
        hearing.  Should additional  clarification be  necessary/  please contact
        me or  Mr. Michael  McKinley of  the Council's staff.
        Sincerely,
        William
        Executive Director

        WAO/rbm

        cc:  Jan Platt
             Westwood Fletcher
             Jesse Carr

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                                Florida  Skin Divers Association, Inc.
                                                    December  9,1982
          Environmental  Protection Agency
          Criteria and  Standards Division 
-------
         types of disposal alternatives.

         A practical, environmentally sa-fe alternative  to  offshore
         disposal does exist.  Two diked disposal areas are  available in
         upper Hillsborough Bay. These areas cover  several square miles
         and  have tremendous capacity.  That capacity could  be
2fi_4      sustantially increased by increasing dike  heights and
         de-watering the spoil material.  There is  no need for any
         offshore disposal for many years to come,  probably  never.
         Failure to consider this alternative is a  serious legal
         deficiency in the DEIS.

         We request that a public hearing be held in the Tampa Bay area
         to allow full and complete public comment  on this issue.

         Please be aware that we are considering legal  action  against the
26^-5      EPA  and Corps of Engineers if offshore disposal continues.

         Thank you for this opportunity to comment.
         Sincerely
         Richard E.  Pease, President
         Florida Skin Divers Association

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January 14, 1983
       3
Mr. Jonathon Amson
U.S.  Environmental Protection Agency
Criteria and Standards  Division  (WH-585)
401 M Street, S.W.
Washington, D.C.  20460
                                                                                       tampa bay
                                                                                          regional
                                                                                         Plonnln9
                                                                                           council
                                                                               <8'3) 577-515 i.'
         Dear Mr.  Amson:

         Subject:   Tampa Bay  Regional Planning Council A-95 Clearinghouse  Review No.
                    218-82;  Draft Environmental Impact Statement (DEIS)  for Tampa
                    Harbor,   Florida,  Ocean Dredged  Material  Disposal  Site
                    Designation,  Hillsbor ough ,  Pinellas  and Manatee Counties

27-j.     Enclosed please find a copy of the Council's Clearinghouse Review report
         for the above referenced  project  adopted by the  full Council on January 14,
         1983.
         Should  additional  clarification be needed,  please feel  free to contact me.
         We appreciate the  opportunity to  review the proposal.

         Sincerely,
                 Platt
         Chairman - TBKPC
         Hillsborough County  Commissioner

         MRM/kh

         Enclosure

         cc:  Walt O. Kolb, Governor's Office
              Westwood Fletcher,  TBRPC
              Jesse Carr, TBRPC
    Chairman Jan K Plat!
Commissioner. Hillsborough County
Vice-Chairman George McGough
  Vice-Mayor. City of Largo
                                                Secretary/Treasurer Saunara Rann
                                                Councilwoman. City of Bradenton
                                                                                      w A OcKur,zz>
                                                                                     Execuir;e D/recro--
         8'acenton • Oearwater « DaOe City • Dunedm » Gulfoort • Hillsoorough County « Largo • Manatee County • New Port Richey • Oldsmar • Palmetto

          • Pasco County « Pinellas County • Pinellas Park • Safety Haroor • St. Pete'SDurg • St. PetersDurg Beach • Sarasota • Tamoa « Taroon Sonngs

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                                                                Agenda Item
                                                                1/14/83
    A-95 #218-82; Draft Environmental Impact Statement (DEIS) for Tampa
    Harbor, Florida, Ocean Dredged Material Disposal Site Designation,
    Hillsborough, Pinellas and Manatee Counties
The O.S. Environmental Protection Agency (EPA) has requested review and
comment on the draft Environmental Impact Statement (EIS) for Tampa Harbor,
Florida which presents information necessary  for the  designation of a new
Tampa Harbor Dredged Material Disposal Site.   The purpose of the action  is
to provide the most environmentally and economically acceptable ocean
location  for the disposal of material dredged from the Tampa Bay area.
Based on recent surveys  of four  Shallow-Water  Alternative Sites,  EPA has
determined that Shallow-Water Alternative  Site 4 is the alternative with
the fewest hard-bottom areas which may be  affected by the disposal  of
dredged material.   It is  the recommendation of the DEIS that Alternative
Site 4 be designated as the disposal site  location for dredged material
from the  Tampa Bay area.  Agency - EPA;  Location  - Hillsborough,  Pinellas
and Manatee Counties.

                      Local Comments Received From;

Hillsborough County Environmental Protection Commission:  See attached
  letter dated December 5,  1982.

Hillsborough  County Department of Development Coordination:   See attached
  memorandum  dated December 3, 1982.

Pinellas County Planning Department:  No comment received as  of  December
30, 1982.

City of St. Petersburg Planning Department:  See attached letter dated
  December 16, 1982.       '  "

Manatee County Board of County  Commissioners:   See attached letter  dated
  December 13,1982

Mote Marine Laboratory:  See attached letter dated December 9, '1982.

Gulf of Mexico Fishery Management Council:   See attached letter dated
  December 10,  1982.

Office of the Governor:  See attached letter dated December 22, 1982,

                  Council  Comments and Recommendations

This project  has been  reviewed for consistency  with the Council's  Areawide
Water Quality Management Plan and the Council's adopted growth policy, the
Future of the Region.  The proposal has not been found to be consistent
with Council policy that  a standard of water quality  should be achieved
that allows  for the protection and propagation  of fish, shellfish, and
wildlife and  provides for recreation in and on the waters in  the region.
                  tcimpo bay regional planning council
       9455 Koger Boulevard Si Petersburg, FL 33702  (813) 577-5151-Tampa 224-9380

       *'*^<^

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                                                                             •It
This project is  regionally significant and  the following local and  regional
concerns have been raised during the  review:

•  The staff of the Tampa Bay Regional Planning Council has reviewed the
   Draft Environmental Impact Statement (DEIS) for Tampa Harbor Ocean
   Dredged  Material Disposal Site Designation and offers the following
   comments:

   General Comments

   1 .  The DEIS lacks sufficiently detailed  evaluation and  comparisons of
       all possible  alternatives including diked disposal  islands and
       upland disposal areas.

   2.  The  designation of  Alternative Site 4 for disposal of  dredged
       material from the Tampa Bay Area should be based on more detailed
       studies of  this area.  The DEIS lacks  site specific studies  evaluat-
       ing the impacts on marine environment and economy  of  the region.
       The results of the studies  done in  other locations  cannot  serve as
       the base for  evaluating the  impacts of the proposed dumping of
       dredged material  on the  proposed site.

   3.  The environmental consequences of dumping dredged sediments  on  sand-
       subs tate habitats  also  cannot  be predicted based on  the  results of
       the studies  from  other  locations.   The ecosystem of  shallow-waters
       in central-southwest Florida  is different from  the  continental U.S.
       waters.

   .4.  Information pertaining  to tidal  currents  is needed based on records
       obtained from the tide guage station located  in Egmont Key.

   5.  The monitoring program  has not been specifically designed to deter-
       mine whether disposal at the  selected site  significantly affects
       areas outside the  site  and to  detect  long term effects occurring in
       or around the site.   It is stated in the DEIS that a monitoring
       program  may be established to  supplement historical data.   Details
       on what the  monitoring program will  entail must be included.

   6.  The  recreational and commercial  fishing values of the surrounding
       area should be identified as well as  the  impacts  of  ocean  disposal
       on migratory fishing.

   7.  It  is  stated  that dispersion  of disposal material outside  the site
       boundaries  will be over time and  in thin  layers,  and that such
       dispersion is not expected to  have  unacceptable  adverse environmen-
       tal  impacts.  Specific studies need to  be completed to determine
       whether the  thin  layer of siltation adversely  impacts the sur-
       rounding hard bottoms (corals).

   Specific Comments

    1.  Statements that there  are no hard-bottom  habitats within  or' in
       proximity to Site 4 are not well-documented.  More extensive inspec-
       tion of areas both  within and around the  site is necessary before it
       can  be known what types of  organisms and communities  will be

-------
    adversely affected  by dumping.  In-depth surveys to determine  the
    nature and extent of  live,  hard-bottom  habitats  in  or  near  the site
    should be  further conducted.

2.  It is stated in DEIS that  results of dredged material disposal at
    the Tampa  Harbor alternative sites are  anticipated  to  be similar to
    the results  of  disposal  operations at  Galveston, Texas (page 2-28).
    However, the West Florida Shelf cannot  be compared  with other areas
    which have no hard-bottom  communities.   The conclusions  that dispo-
    sal will not result in any  detectable changes in ecology of  the area
    are inappropriate.

3.  An assessment of the siltation and turbidity caused by resuspension
    of fine particles by  waves,  storms and  tides has not been completed,
    as well as  the expected impacts of the siltation on live-bottom
    habitats.

4.  The long-term  effects  from  the continual resuspension of spoil
    material  throughout the  water column  have  not  been  adequately
    studied nor  documented.  The amount and  frequency of siltation,  the
    direction of sediment transport  based on  site-specific ocean current
    information, and  the environmental consequences of long-term tur-
    bidity should be estimated  before  final recommendations are  made.

5.  It is stated in the  DEIS that Site  4  is  removed from  areas of
    recreational use, and has  no known significant commercial  fishery
    use (page  2-27).  This statement is not based on the detailed survey
    of commercial  and recreational fishing activities  of this area.
    Relevant  studies  should be  completed based on public  testimony
    whether  the proposed action affects  the  recreational  activities of
    the region and commercial  fishing.

6.  Cost-benefit analysis,  taking into account the  direct and  indirect
    economic benefits generated by the recreational use of this part of
    the Gulf of  Mexico have not been done at  this time.

7.  A public  hearing should be scheduled to  allow  full and  fair public
    comment in  the  draft EIS and  the overall suitability  of dumping in
    the Eastern  Gulf of  Mexico.

The Manatee County  Board of  County Commissioners has provided extensive
comments which already have been forwarded .to EPA and are summarized
below  (see  attached letter dated  December  13, T982) regarding the Draft
EIS for a permanent ocean disposal site for Tampa Harbor:

1 .  The EPA survey upon which the  EIS relies to recommend Site 4  for
    permanent  designation, used survey methodologies that are inadequate
    for determining the  nature  and extent of live,  hard-bottom  habitats
    in or near  the site; yet, the  entire EIS rests  on  the  unproven
    assumption  that there  are no hard-bottom habitats  within or in
    proximity to Site 4.  This is critical  because of the well-docu-
    mented importance of live-bottom habitats to both commercial  and
    recreational fishery resources.

-------
2.  Although the EIS  notes  that significant damage that can occur to
    hard-bottom habitats from siltation and turbidity, it completely
    fails to describe  or assess the siltation and turbidity  that will be
    caused by resuspension of fine particles by waves, storms, tides,
    and combinations thereof, and it fails to quantify the  resulting
    siltation problem and its  expected  impacts to corals,  sponges,
    algaes,  and  the like.

3.  The EIS recommendation of Site 4 is based on erroneous and under-
    stated information concerning the use  of the area in and around the
    site, which is actually located in an area that is heavily used by
    commercial and recreational fishermen, sport divers,  and others.

4o  The Site-Designation  EIS presumes that  ocean dumping is appropriate
    in this part of the Gulf of Mexico, disregarding as  a general  matter
    the high potential for damage from burial and siltation to the hard-
    bottom habitats and organisms found scattered throughout  this part
    of the Gulf, and  inadequately considering the possibility of  using
    uplands  or  diked  disposal areas on  a short-term basis pending
    thorough investigation of  the suitability of ocean  dumping.

5.  The EIS also relies on erroneous cost  estimates for transporting the
    dredged  material  to  various alternative  sites,  and there is no
    comparison of the environmental "pros and cons" of  each alternative
    site relative  to the  economic costs.

6.  Finally, with respect to  the EIS's cost analyses,  the  EIS fails to
    take any account  of the direct or indirect economic benefits gen-
    erated by the recreational use of this part of the Gulf of Mexico,
    thereby placing too-heavy  emphasis on the immediate costs of  spoil
    transportation.

Therefore,  in light of the many  deficiencies of  the Draft EIS,  including
reliance on erroneous assumptions, inadequate surveys, and incorrect
infomation, the Board of County Commissioners  of Manatee County requests
that a public hearing  be scheduled to discuss  the Draft EIS  and proposed
site designation,  or, in the  alternative,  that the Draft  EIS be with-
drawn and subsequently resubmitted for public  comment.

The staff of the Hillsborough County Environmental Protection Commission
has reviewed the Draft Environmental  Impact  Statement (EIS)  for Tampa
Harbor:   Ocean Dredged Material Disposal Site Designation and submits
the following comments and recommendations:

   It is recommended that all disposal at the Existing Site A be
   stopped because  it is  too close  to shore, too close  to produc-
   tive reef areas,  and within easy reach of divers and small  boat
   users.

   Site 4 is in 85 to 95  feet  of water and is not as likely to be
   used for recreational purposes such as  diving and fishing.   All
   material should go to this  site  until  some long range solution
   is found.

-------
   Site 4 has no hard-bottom outcrops  and would therefore have  the
   least impact on fish and other types  of  life.

•  The City  of  St. Petersburg Planning Department has reviewed  the Draft
   EIS for Tampa Harbor:  Ocean Dredged  Material Disposal  Site Designa-
   tion and  recommends the following additions  to the  above referenced
   EIS:

        Incorporation of any appropriate review  criteria
        which  may be forthcoming from the  pending litiga-
        tion related  to offshore  dumping  initiated  by
        Manatee County;

        Analysis of upland dumping sites;

        Further analysis of  Site 4.   It  appears that
        Appendix C.  (referenced on Page  2-13 of study)  may
        provide additional data to substantiate minimal
        adverse environmental impacts.

•  The Office  of  the Governor has submitted the following comments and
   recommendations regarding the Draft EIS:

        An interagency review of the statement has found
        that the proposed action would smother the benthos
        within the designated area and alter habitat within
        the  site.   The document recognizes  that  these
        adverse impacts at the site are unavoidable.  Our
        reviewing agencies report that the EIS statement is
        inadequate and  lacks  the necessary  information  to
        be of  sufficient value as a decision-making docu-
        ment (see attachments).

        We have concerns with  this  designated  site  and
        EPA's proposed rule for ocean  dumping without a
        Federal Coastal Zone Management  Consistency Evalua-
        tion.  Recognizing our  concerns,  the impact of this
        designation and its effect  on the Tampa  Harbor
        project, we request that your  agency participate in
        an interagency meeting at your earliest convenience
        to afford us the opportunity  to discuss issues of
        concern to the State of Florida.  It is  our desire
        to use  this  initial meeting as a step toward  re-
        solving our  concerns.

Based on the review  of this document,  it is  the opinion of the Tampa Bay
Regional Planning Council that no ocean dumping should  be performed
until it is  demonstrated that  ocean dumping in this part of the Gulf of
Mexico is appropriate and that it is the most suitable method of dispo-
sal.   That demonstration should  include an actual determination of the
nature and extent of hard-bottom habitats and fishery resources in site
4 and  in  surrounding areas.  This determination  should be  based on
further,  site-specific surveys, including  the direction,  amount,  fre-
quency, and  distance of sediment transport and siltation, and a specific
quantification of the damage  that will result therefrom. Also, a de-

-------
     tailed,  careftil balancing of the economic versus environmental concerns
     for each alternative  method should be performed, including consideration
     of the  many  commercial  aspects of  recreational  fishing  and  diving  and
     development of a  thorough monitoring  program to assess the  impacts  of
     any dumping on a long-term basis.

     In conclusion,  the final recommendation of the DEIS for Tampa Harbor
     which designates Shallow-Water  Alternative  Site  4  as the Tampa  Harbor
     ocean  dredged  material disposal  site  is not consistent with  the
     Council's adopted policy  to support the maintenance  of Class  III waters,
     including bays,  rivers,  lakes,  estuaries  and open  waters  of  the  terri-
     torial sea,  at a quality sufficient to allow body-contact water  sports
     and propagation of fish and wildlife.   (Future  of the Region,  2.402)

     It is recommended that  Alternative Site 4  not be used  as  an interim
     dumping site, and  that all concerned parties meet to resolve identified
     concerns.

  It is therefore recommended that the above local and regional concerns  and
  recommendations be addressed in the final EIS  for Tampa Harbor.  Further,
  it is recommended that  any  additional comments addressing local concern be
  considered prior to issuance or approval of the  final  EIS.
  Committee adopted January 3,  1983.        Council adopted January  14,  1983.
/Mayor (Se'orge McGough^  Chai^aan           Jan K^Platt,  Chairman
  Clearinghouse Review Committee           Tampa Bay Regional Planning  Council

  Please note:  Unless otherwise notified, action by Clearinghouse Review
  Committee is final.  Append copy to application to indicate  compliance with
  clearinghouse requirements. Comments constitute compliance with OMB Circu-
  lar A-9 5 only.

-------
                       United States Department of the Interior

                                     OFFICE OF THE SECRETARY
                                      WASHINGTON, B.C.  20240
          ER-82/1689
                                                               'JAH
                                                                      5 '.923
          Mr. T. A. Wastler, Chief
          Marine Protection Branch (WH-585)
          Environmental Protection Agency
          Washington, D.C.  20460

          Dear Mr. Wastler:

          We have reviewed the draft environmental statement for Tampa Harbor, Florida, Ocean
          Dredge Material Disposal Site Designation, and have the following general and specific
          comments.

          General Comment

          It is  our understanding that present  and alternate Tampa Bay disposal sites have been
          selected without the benefit  of intensive and thorough underwater surveys.   A fairly
          comprehensive analysis of impacts at Site A disclosed that severe environmental damage
28-1      was occurring.  However, the same degree of analysis was  not devoted to any  of  the
          alternate spoil sites suggested.  The preferred alternative (Site 4) may not have highly
          productive  or  unique bottom  communities,  but  this  document  does not provide  the
          information to make that choice.

          Specific Comments

          Page 2-2, 203:  The so-called  "11 criteria analysis" has been restricted just to the two
          existing spoil disposal sites and Site 4.  It would seem appropriate to consider the same
28-2      factors for Site 3, the mid-shelf site, and any other alternative which is not infeasible.

          Page 2-4;  In considering the no action alternative, it is stated that the Corps would be
          required to:  1) justify an acceptable alternative disposal method; 2) develop information
          sufficient to select an  acceptable  site for ocean  disposal;  or 3) modify or cancel a
          proposed  dredging project that depends on disposal in the ocean.  Apparently each of
28-3      these is considered an unacceptable alternative to the proposed action.  The EIS fails to
          explain how Alternative 2 (developing information sufficient  to select an acceptable site
          for disposal in the ocean)  is unacceptable. In fact, this is the major problem with  the
          spoil  disposal sites which have  been proposed  to date and with the  draft EIS itself. It is
          apparent that no source has developed sufficient information for selecting an acceptable
          site for ocean disposal.  Even  proposed Site 4 is supported  only  with minimal data: a
          single photographic transect did not disclose large quantities of productive hard bottom.
          It is  fully  possible  that Site  4 may indeed be  an ideal spoil disposal  site,  but  this
          environmental  impact  statement  does  not  offer  sufficient evidence for a  rational
          selection.

-------
           Mr. T. A. Wastler, Chief
           Page 2-5;  A  Corps of Engineers 1974  document is used to explain the review of land-
           based spoil disposal alternatives. The EIS does not describe how the construction of spoil
           retention berms  in shallow  waters of Tampa Bay and backfilling of wetlands can be
28-4       considered a "land-based" scheme.  If this "CE proposal" is to be described in the final
           document, it should simply be considered another form of open water disposal.

           Page 2-19; It  appears that the  entire justification for selection of site 4 is stated in two
           sentences:  1) "A  video tape  taken of this area  revealed  no rock or  hard bottom
           outcroppings and low vertical relief." and 2) "A  recent EPA survey determined that the
           site is predominately characterized by the presence of fine sands  and coarse silts and
           plains  of shell hash."   Considering the number of  alternative sites that  have  been
           proposed by various parties, and their later rejection upon the finding that they contained
28-5       environmentally  sensitive  areas,  the reader surely must  question whether those  two
           statements are sufficient to justify the permanent designation of four square miles of
           shallow ocean bottom  to receive millions of cubic yards of silt and other materials both
           during this project and annually for maintenance dredging.

           Page 3-21; The analysis of Site 4 is further detailed on  this page.  A camera was towed
           across part  of the spoil site and noted "flat, featureless sandy  bottom".   A "few" soft
           coral  communities were noted  during  the video  tape  transect, but no hard corals.
           Presuming that this transect consisted of a single 2.8 mile line, and the width of bottom
28-6       scanned was about 50 feet, then this analysis was based upon examining about one-half of
           one percent of the area proposed for spoiL  The document should state whether this is
           statistically valid or significant.

           Page 3-29;  The EIS provides few bits of data which are directly comparable between the
           existing and proposed spoil site.  However, here  it is stated that dissolved oxygen levels
           in the area currently receiving spoil are lower than dissolved oxygen levels over proposed
23-7       spoil Site 4. In fact, dissolved oxygen levels actually dip below minimum State standards
           in area currently receiving spoil.  The EIS should explain the significance of these data, if
           any.

           Page 4-13;  The EIS states "a stress reaction or death may have greater environmental
           consequences  to  the surrounding benthic community than to the organism in question."
           The average reviewer  may find it difficult  to conceive of circumstances in which  death
23-8       would  not be  considered a  primary or major consequence to an organism.  Additional
           information should be provided.

-------
Mr. T. A. Wastler, Chief
Concluding Comment

It is our opinion that the draft environmental statement contains insufficient information
and impact analyses to  support a decision to designate the  proposed ocean  dredge
material disposal sites.

                                         Sincerely,
                                              Blanchard, Director
                                         Environmental Project Review

-------
                                                   "  .  '                        . i *J
               of  Natural  Resources^jes^Interofilce Mcmor'anuuf*
 DATED:    6 October  1981
 TO:       Bill Lyons.  <£»r™s COPY FOR <^
           George Henderson

 FROM:     Walter C. Jaap'

 SUBJECT:   CRUISE REPORT R/V Hernan (Jirtez, 28 September-2 October 1981

 Scientific Party:

      Walter Jaap                 ••*
      Jennifer Lowry              "*
      John  Halas-FDNR Park Service
      Richard Conant-USNPS
      Richard Defenbaugh-BLM
      Tom Burns-RSMAS-USNPS

 Vessel departed Bayboro Harbor 1630 EOT, 28 September.   Steamed to Florida '
 Middle Ground (14131.16, 45741.12).   On station at 0800, 29 September.   En-  .
 tire  Scientific Party  dove on  a large relief bank 78 ft(23 m) deep.   A  second
 dive  was made at 1305  on the same site.  At 1500 29 September, vessel moved
 to  another bank (14127.45, 45734.01).  Dive made to 90  ft(27.4 m).

 Inclement weather precluded a  fourth  dive on the second Middle Ground bank.
 On  30 September at 0900,  vessel  weighed anchor and steamed to a station  of
 Bayport (14312.40,  45149.41) arriving at 1745.   A ledge community In^ffft :
 (•9-ri~m) was sampled.    .   . •  . •                          .   •       £f
  jo.7            .                       ^
 On  \  October we weighed anchor and steamed to  the Blackthorn  artificial  reef
 (14181.74,  44942.61).   At  1545 we dove the site  for 40  minutes.   After com-
 pleting this survey we  steamed to a 60 ft(18.3 m)  ledge (14168.63, 44798.00).
 We  dove this site for a short  period  for examination.   Following  this dive we
 steamed to  the  "dump site"  ledge off  Tampa  Bay  (14164.05,  44754.00).  On 2
 October we  made a sampling  dive on the ledge.  We  returned to  the dock at
 1315, 2 October 1981. '

 During the  course of the cruise, six  stations were  sampled, 38 dives, or 23.1
 hours of underwater observations were accomplished.  A  census of  56 one meter
 square plots was taken; a total of 551  colonies, 15  species, and  14 genera
 were encountered.

 Specific details of the sampling are  included in accompanying tables.

 cc:   Captain Alan Nelson   -   R. Conant
     J. Lowry O,              T. Burns
    • R. Defenb/ugh            J. Hal as

WCJ/wem
                                —recycled paper-

-------
^ ( STATION DATA R/V HERMAN CORTEZ CRUISE 28 SE.PT-2 OCT 1981

LORAC . LAT.
e. 14131.16 28*34. 5'N
45741.12

:. 14127.45 28*35'N
45734.01
t. 14312.40
45149.41 28*30'N
14181.74
44942.61 27*53'N •

:. 14168.63 27*39'N
44798.00
u
:. 14164.05 27*37. S'Ntt
44754.00

1
LONG. DEPTH (m) EJ no. TEMP. SURFACE CO . REMARKS
84*/l6.5'W 23.7 (78 ft) 81-84 28* Florida 2 dives 9:18, 13:05
/ Middle
«• ' Ground
84*16'W 27.4 (90 ft) 81-85 28* 1 dive 17:15

, '.
83'02'W 10.7 (35 ft) 81-86 28* Bayport 1 dive 18:00

83*11 'W 10.7-22.9 (35-75 ft) 81-87 ' 28* Blackthorn' 1 dive 15:45
wreck
83* 2'W ' 18.3 (60 ft) ' 81-88 28* Tampa Bay 1 dive 18:10

i
83*01 'W .16.8 (55 ft) 81-89 28* Tampa Bay 1 dive 09:00
dump site
ledge
Diving:  38 dives, 23.1 hours of divers time underwater.
   W. Jaap   DNRMRL
   J. Lowry  DNRMRL
   T. Burnu  RSMAS-USNPS
R. Conant      USNPS
R. Defenbaugh  BLM
J. Halaa       DNRPS

-------
BAYPORT DENSITY SAMPLING 28*30'N  83'02'W, 10,7 ra

:ies 1
:rea radians 9
: a areolaca
ra arbuscula
a robusCa
strea hyadea
ngia Americana

Genera 1
Species 1
Colonies 9





2
8
1
5
1



4
4
15





3 4 5
5 1 4

4.2 2

1


223
223
9-3 7
U
T
•


6
4

2
1



3
3
7





789
322
1
3

1 ' \


41 2
4 1 2
825
Density (m?)
Genera
Species
Colonies
Plot number
10 .11 12 .13 14
4 578 2
1
3 12 44
1
1
1

342 2 2
3 4. 2.2 2
8 19 • 8 12 $
x s
2.33 - 0.87
2.33 0.87
9.21 4.38

15 16 17 18 19
6 11 9 5 12

2 4.4 3 3

1 1
i
\
22332
223-32
8 15 14 9-15
range
1-4
1-4
2-19
.
20 21 22 • 23 24 Total
427 1 121
•' 3 ,
5 5 4 13 87 . .
3
1 6
1

22212 6
22212 6
5 7 12 4 14 221
'

• ,
•

-------
                         FLORIDA MIDDLE GROUND  DENSITY  SAMPLING  27*37.5'N   83*01'N,  16.8 ra
                                      Sice  I
                           28'34.5'N,  84*16.5'N,  23.7  m
28
Plot number   1
           Sice II
  28*35'N,  84*16'W,  27.4 ra

10   11   12   13   14   15   16
•>ora alcicornis
:ia decaccis
1 3
3 2
ja poritea divaricata
la diffusa
:oenia stellaria
nnocoenia michel
:oenia atokesii
nia lacera
;strea radians

umber Genera
Species
Colonies




1
1 3
inn




4,3V 3 1
3 1\\ 1
• 5 72
Density (m2) "x
Genera 1.75
Specieo 1.75
Colonies 3.75
2 7

1
.






2 1
2 1
3 7
8
0.89
0.89
2.31



•
3 1
1




1 2
1 2
3 2
range
1-3
1-3
1-7
* ,
13
5
1
1
. 8 ' ;
1
1 . ' 1


• . . •
tot
1 ' 6
1 . . 7
1 . 30
*



1
1
1
1
3




•
5
5
7




4 2
3
1
2
5 3
',




34
3 4
12 8
x"
2.75
2.75
9.75
32
2
2

4 2 i


3


2311
2311
6 7 1 32
a range
1.39 1-5
1.39 1-5
9.50 1-32
1 40
2 8
4
3
18
•

3
2 2
•
3 7 .
3 -7
5 ?8





-------
TAMPA BAY DENSITY SAMPLING 27*37.5'N  83*01'N, 16.8 m


1

' ocoenia michelinii
trea radians 4
a areolata 3
ra arbuscula . 8
:trea hyades
a lacera
lia sinuosa
: ra alcicornis
gia amaricana

Total Genera . 3
Species 3
Colonies ]O






2

1
5
8
1






4
4
15
SH





3


1
5
9
1
1




5
5
17






4 5

2
2 3
3 3
2 5

.1
2

,

3 6
3 6
7 16
Density (m^)
Genera
Species
Colonies

Plot r
6


4
5
7

.1
1
•

'
5
5
18
X
3.81
3.81
.13.88
•
lumber .
7 8

1
2 • • ,. 9
5
3 3

2
. ' 1
•

. ,
2 ' .' 6
2 6
5 . 21
8
. 1,47
1 1.4
4.66


9 10 11



3
4 7 12



2 1


2 3 1
2 ' 3 1
6 11 12
range
1-6
1-6
5-21


12

1
2
3
4

3




5
5
13






13

•
1
6
8
1
.


i

5
5
17

•




14

2 .
4
2
8






4
4
16






15

•
3
6
9

1



.
4
4
19




I

16 .Total j
*
7 :
1 41
1 53
12 102
2 .
9 -.
4
3
1

3 9 ,
3 9 ;
14 222 ':



1

-------
  TO: •  GEORGE  HENDERSON   'i '
  THRU:   WILLIAM LYONS
  FROM:   JENNIFER LO
  DATE:   7 OCTOBER 198l(J
  SUBJECT:  Gulf of Mexico Cruise 28 Sept - 2 Oct  1981
  REF:   15-2-4

  Six dives were made to record density and species  composition  data  to supplement
  Hourglass octocoral collections.  Identification of vouchers of all  specimens
  are incomplete; however most are accurate in situ  identifications.

  Site  I,  Florida Middle Ground, 2 dfves, 80-90 ft.   Densities of Muricea 71 axa
  (the most abundant gorgonian) were up to 26 colonies/m  .   Usually no other
  species  were recorded within  the^square meter.  Other species  collected  include:
  Eunicea  knighti,  Eunicea calyculata, Plexaurella fusifera, Pseudoplexaura sp.,
  Lophogorgia  cardinal is, Pseudopterogorgia %cerosa  , and Pterogorgia  guadTlupensis.

  Site II.   Florida  Middle Ground, 1 dive 90 ft.  Gorgonian  species composition
  the same  as  for site  I; area  dominated by Millepora.  Drop off observed  from about
  85-125 ft.  Proposed  dive on  drop off had to be aborted due to  rough  weather.

  Site III.  Off Bayport.  1  dive, about 60 ft.   Low relief ledge.  Average of
  9.5 gorgonians/m   recorded.   Six species occurred in plot sampling;   most to
  least abundant were Plexaurella  fusifera,  Eunicea knighti, Pseudoplexaura ?porosa,
  Pterogorgia guadalupensis,  Eunicea calyculata,  Leptogorgia^ virgulata.  Lophogorgia
  hebes and Muricea  elongata were  also collected from this site.

  Site IV.  Blackthorn wreck off Tampa Bay.   1 dive,  75 ft.   No gorgonians were
  observed colonizing the wreck structure.   Surrounding bottom was hard but devoid
•  of gorgonians at first  glance.   Closer observations provided -five species:
  Lophogorgia hebes,  Leptogorgia virgulata,  Eunicea calyculata,'  PIexaurella sp.
  and Muricea elongata.   With exception of the single whip noted, U  virgulata,
  no colonies were taller.than  10  cm.   Muricea was  most abundant; however,  no
 colony taller than 7 cm was observed.   Time limits  disallowed collection  of
 specific density data.  I can only surmise that debris (tire bundles) in  the area
 or the sinking of the Blackthorn itself  perhaps scoured  or otherwise damaged the
 surrounding bottom; therefore resulting  in chly small  gorgonians be'Jng present.

 Site V.   Dump site for Tampa Bay dredge spoil off Tampa  Bay.  1 dive, 55  ft.
 Moderate relief ledge.  Gorgonians were abundant  up on the ledge proper and  on
 parts  of the  surrounding bottom.   Densities of Muricea elongata^ v/ere up to 30
 colonies/m',  with addition of 1 or 2 other species  occasionally. Other species
 collected include:   Eunicea calyculata, Plexaurella  fusifera, Lophogorgia hebes,
 Leptogorgia virgulata, Pterogorgia guadalupensis.   This  area supports an  incal-
 culable  monospecific population of ophiuroid.  Every attached benthic spongerand
•gorgonian supports  numerous animals.  One small (13  cm)  Muricea was  collected
 with 11  animals mostly as large as 1.3 cm disc diameter  but some as  small as
 2 mm diameter.  The same number were noted on a previous dive on this  ledge last
 June.  They are probably_0phiothrix.  I'collected these  samples  to send to Gordon
 Hendler^at the Smithsonian^who Maureen Downey recommended}.

 cc:  Steidinger
     Lyons               .
     Jaap
     Halas      .                                                  '
     Conapt and Burns
     Archives

-------
   Subject:  -Si^e«=a±iD7^>  R/V Hernan  Cortez Cruise.  Dec.  1,-2,  1980;  Reconnaissance of
;; ,««T« «••'•«»      OC*«-»^                   •                               _                  '
'   dredoe  spoil disposal  area.
 A             '      .        •               .or                         .      „"?-
   Dive I  -  Duration 17 minutes.  Lat -  27°37.2'N,  Loran  C  14163.39;  Long  - 82°59.9'W,
             Loran C 44747.33;  depth  -  50-55  ft  (15-17 m)
             Bottom Character  -  rock  overlaid with  a  (2-5 cm)  veneer  of sediments.
             Windrows of fossil  gastropods  noted on surface of sediment waves.
             Organisms noted:   Caulerpa  sp.,  Siderastrea  radians. Solenastrea hyades,
             Phylla^gia americana, Petrogorgia citrina, Lytechinus variegatus, Echinaster
             sp., Cassis sp.
                                              trf"                         *•><*>  ^
   Dive II - Duration 11 minutes. Lat - 27°37.6'N, Loran C 14164.05; Long  - 83°01.5'W,  '
             Loran C 44754.00;  depth -  45  feet (14 m)
             Bottom Character - a mosaic of  rocky  substrate with pockets of sediments
             overlying the rock in some places.  Octocorals visually dominant.   A very
             diverse benthic community, with corals,  echinoderms, polychaetes,  mollusks^
             and sponges.  The height (1 ft) of some  SpJ_ena.s_trea hy.ade_s heads would imply
             long term community stability.                            "*
             Organisms noted:  Eunicea sp., Stephanocoenia michelim'i, Siderastrea
             radians,  Millepora alcicornis, Cladocora arbuscula, Solenastrea hyades,
             Isophyl1ia sinuosa, Manicina areolata. Scolymia lacera. Phyllangia americana.
           , Ophiothrix suensoni, Echinaster sp., Diadema antillarum, sponges unidentified,
             holothurians unidentified.                                 \-
                                         2-7 r^ «•/"      "*"              y^ P° "'^
   Dive III - Duration  20 minutes. Lat - 27°37.6'N, Loran C 14164.05; Long - 83°01.5'W.
              Loran  C  44754.00; depth - 50 ft. (15 m)
              Bottom'Character - ledge line with up to J. m relief.   Vertical, horizontal
                                   "i
              interface with Millepora  alcicornis colonies.   Some slumping of overhanging
              under  cut ledges noted.  While few large fish were observed, black grouper

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Department  of  Natural Resources^Sbss^'lntefoffice Memorandum
                                                                                 !! S;

  DATE:     10 May 1982                                       i
                      u#c                   x-v*   '•.:.;    '
  •0:       Bill  Lyons	      George  Henderson -"* A     Karen Steidinger

  FROM:     Walt  Oaap
 SUBJECT:  Observations from May 6 dicing on dredge  spoil  disposal  sitefl^f ^••


 Nine stations were sampled.  Dr. Taylor took 4  benthic plug samples at each
 station.  Samples were sieved and preserved in  rose bengal for later sorting
 and identification.  Each station took ca.  5 minutes of bottom time to sample,
 hence my observations are not in great detail.   Stations were located ne*r the
 corners, middle of the area, and one midway between each corner.
                                  approximate N
      893

 The following summarizes observations by station.  ~~

      1.  27°37'N, 82°59.7'W, 38 ft.
         Bottom strewn with large  boulders and silt.  Evidence of recent dis-
         posal.  No macro epibenthos seen.

      2.  27°37.3'N, 82°59.7'W,  44  ft.
         Bottom uniformly covered  with an ooze that had the consistency  of
         pudding.  No  macro epibenthos seen.

      3.  27°37.4'N, 82°59.5'W,  45  ft.
         Same as station 2.   A  few sand perch, Diplectrum formosum were  observed.

      4. '27°37.3'N, 83°00'W,  50 ft..  '
         A small ledge with no  more than^ne to two feet of relief.   A "live"
         bottom community was seen.  Algae included Halimeda and  Udotea;
         Sponges, stony corals:  Cladocora a'rbuscula, Manicina areolata'. Solen-
         astrea hyades.  Phyllanqia americana, and Siderastrea radians; Octo-
         corals with ophioroids  in their branches.Black urchin  Diadema aritil-.
         Varum? or Arbacia punctulata?  Red and black grouper and numerous
         small  tropical  fishes were seen.   Little or  no sign of dredge impact.

     5.  27°37'N,  83°00'W, 50 ft.
         Hard packed sediment.   Some  piles of consolidated (clay  like) dredge
      -  spoil.   One small colony of  £.  arbuscula seen.


                                -recycled paper-

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   •-» •     Rocks and sand  some si i -..,-' mu.;.   mud^'-.. >._ __^_  _«,— _.     .  •  .•
 -  .'. •    .sediments.   Sand  perch  observed.
*    •  »
     7.   27°36.75'N,  82°59.7'W,  55 ft.
          Hard firm sand, no macro epibenthos seen.

     8.   27°36.8'N, 82°59.5'W, 48 ft.      '
          Hard sand.   Piles  of clay-like  mud, very black in color.  No macro
          epibenthos.

     9.   27°37.3'N, 82°59;5'W, 40 ft.
          Large cable  on  bottom.   Slimy ooze, no macro epibenthos  observed.

 Only station 4 seemed to have escaped impact.   The remaining stations all  had
 received  some impact, 1, 2,  3, and 9 appear to have received the  greatest
 insult.                            •*


 WCJ/wm

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          I  JK litUKut i
     Subject:  -£i*?w=rs±rD7r&> R/V Hernan Cortez Cruise. Dec. l,-2,  1980; Reconnaissance of
-. ;: ,„.<,. .~
L '   dredge spoil disposal area.
   A             f-                      '          "                                  . ••
                 •              •                .el                                  -;i
     Dive  I - Duration 17 minutes. Lat - 27°37.2'N, Loran C 14163.39; Long - 82°59.9'W,
              Loran C 44747.33; depth - 50-55 ft (15-17 m)
              Bottom Character - rock overlaid with a (2-5 cm) veneer of sediments.
              Windrows of fossil gastropods noted on surface of sediment waves.
              Organisms noted:  Caulerpa sp., Siderastrea radians, Solenastrea hyades,
              Phyllafigia americana, Petrogorgia citrina, Lytechinus variegatus, Echinaster
              sp. , Cassis sp.
                                                ^"                           3^oo  33
     Dive  II - Duration 11 minutes. Lat - 27°37.6'N, Loran C 14164.05; Long - 83°01.5'W, '
               Loran C 44754.00; depth - 45 feet (14 m)
               Bottom Character - a mosaic of rocky substrate with pockets of sediments
               overlying the rock in some places.   Octocorals visually dominant.  A very
               diverse benthic community, with corals, echinoderms, polychaetes, mollusksf
               and sponges.   The height (1  ft) of some SoienaijTea hyade_s heads would imply
               long term community stability.                             "
               Organisms noted:  Eunicea sp. ,  Stephanocoem'a michelinii, Siderastrea
               radians.  Millepora alcicorm's,  Cladocora arbuscula, Solenastrea hyades,
               Isophyllia sinuosa,  Manicina areolata ,  Scolymia lacera, Phyllangia americana,
             ;  Ophiothrix suensoni, Echinaster sp., Diadema antillarum, sponges unidentified,
               holothurians  unidentified.                                  v
     Dive III - Duration  20  minutes.  Lat - 27°37.6'N, Loran C 14164.05; Long - 83°01.5'W,
                Loran  C 44754.00;  depth - 50 ft.  (15 m)
                Bottom "Character - ledge line with up to T. m relief.  Vertical, horizontal
                interface with  Millepora alcicornis coloniejs.   Some slumping of overhanging
                under  cut ledges noted.  While few large fish were observed, black grouper

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'J.tate of  Florida

Department of  Natural Resources
                                 Interoffice Memorandum
     DATE:

     TO:

     THRU :

     FROM:


     SUBJECT:
8 June 1981

George Henderson
              x
Bill Lyons
Walt Jaap
Jenni Lowry

4 June Cruise to Bayboro Harbor Dredge Spoil
Disposal Site
    We met Scott Sobel and his cameraman, Lynn Rabren, at Captain
    Warren Sturgess1 boat, the Proposition, on Madeira Beach.  Using
    R/V Hernan Cortez Loran coordinates from the December cruise,
    three short dives were made.

    Site 1, 14164.3-4, 44747.1, depth 45 ft, bottom:  coarse
    sediments with fossil freshwater mollusk (gastropod) shells.
    No visual evidence of spoil disposal impact.  This area is
    estimated to be less than 1 km inshore of the second site, the
    mid-disposal area which was visited in December.

    Site 2 (mid-disposal area visited in December)  14163.8-7,
    44748.2, depth 50 ft, bottom a hardpan veneered with a thin
    layer of sediments.  Bottom benthos included numerous octo-
    corals, stony corals, anemones, sponges and numerous brittle
    stars  (possibly Ophiothrix sUensoni) entwined in the octocoral
    branches.  No visible evidence of impact was observed.  Low
    relief anemones and stony cprals were not suffering from burial
    and had not expelled zooxanthellae.  Conditions appeared similar
    to December observations.

    Site 3 (ledge system just seaward of the northwest boundary of
    the disposal site) 14164.5-6, 44754.4.  Ledge outcrop, high di-
    versity, hard substrate, benthic community with sponges, anemones,
    octocorals, stony corals, molluscs, crustaceans and an abundant
    ichthyofauna including triggerfish, grunts, jacks, grouper,
    snapper, butterflies, and high hats.  Again, there was no visible
    evidence of dredge disposal.  The stake established here in
    December was found, hence we are certain of being on station.
                             -recycled paper-

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                rrencn  angel fish  were  common.                                     •/ :
                                                 '   .                             i'"
            Organisms noted:   Stephanocoenia micheli-nii,  Siderastrea  radians, CladocorST

            arbuscula,  Sblenastrea  hyades,  Phynangia  americana,  Mi'.VIepora aTclcorm's,

            Condylactis glgantea, Rhodactis sanctihomae?,  Panulirus arqus. Ophiothrix

            suensoni, Diadema  anti'llarum.
                                                           s
Photographs were taken of  representative community  elements with a Nikonos.camera,

15 mm lens and  flash.  Film at RoMo for development.  The  ledge  was marked with a

copper clad survey marker  to  establish reference.

                         #
cc:  Gary Burns

     Ken Haddad

     Bill Lyons

     Roy Williams                              ^

     Terry Leary, GMFMC         .    .
                                    \
     Robin Lewis

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                                                                   ,   \

Page Two
*

Dumping impact was either very localized or the material dispersed
so fast that it did not have an effect on the three sites.  It is
most probable that the impact was greater on the inshore side of
the disposal area.  The contractor probably made his dumps in this
area.
WCJ.-dg

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       January  5,  1983
                                                                                   tempo bay
                                                                                      regional
                                                                                     planning
                                                                                       council
30-1
Mr. Jonathan Amson                                                      -:--
U.S. Environmental Protection Agency                              >8'J
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                                                             Agenda Item  #11A
    A-95 #218-82; Draft Environmental Impact Statement (DEIS) for Tampa
    Harbor,  Florida, Ocean Dredged Material Disposal Site Designation,
    Hillsborough, Pinellas and Manatee Counties
     €lEfiRIfKiHOU*£  li£VB£UJ
The U.S. Environmental Protection Agency (EPA) has requested review and
comment on the draft Environmental Impact Statement (EIS) for Tampa Harbor,
Florida which presents information necessary for the designation  of a new
Tampa Harbor Dredged Material Disposal Site.  The purpose of the  action  is
to provide the  most environmentally and economically acceptable ocean
location for the  disposal of material dredged from the Tampa Bay area.
Based on recent surveys of four Shallow-Water Alternative Sites,  EPA has
determined that Shallow-Water Alternative Site 4 is the alternative with
the fewest hard-bottom areas which may be affected by the disposal  of
dredged material.   It  is  the  recommendation of  the DEIS that Alternative
Site 4 be designated as the disposal site location for dredged  material
from the Tampa  Bay area.  Agency - EPA; Location - Hillsborough,  Pinellas
and Manatee Counties.

                     Local Comments Received From;

Hillsborough County Environmental Protection Commission:  See  attached
  letter dated December 5, 1982.

Hillsborough County Department of Development Coordination:   See attached
  memorandum dated December 3,  1982.

Pinellas County  Planning Department:  No comment received as of  December
30, 1982.

City of St. Pet'ersburg Planning Department:  See attached letter dated
  December 16,  1982.

Manatee County Board of County Commissioners:   See attached  letter dated
  December 13,1982

Mote Marine Laboratory:  See attached letter dated December 9,  1982.

Gulf of Mexico Fishery Management Council:   See attached  letter dated
  December 10, 1982.

Office of the Governor:  See attached letter dated December 22,  1982,

                 Council Comments and Recommendations

This project has been reviewed for consistency  with the Council's  Areawide
Water Quality Management Plan and the Council's adopted  growth policy,  the
Future of  the Region.   The proposal has not been found to be consistent
with Council policy that a standard of  water quality should be achieved
that allows for the protection and propagation of fish,  shellfish,  and
wildlife and provides for recreation in and on the waters in the region.
               tempo boy regional planning council
      OMCC. l/~.~-~. D~. .,~...,.,i c. 0~.~~.t->...,, Cl T-T-.O  , C77 C, 1 c. 1 T ~

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    A-95 #218-82; Draft Environmental Impact Statement (DEIS) for Tampa   | 2X-"
    Harbor, Florida, Ocean  Dredged Material Disposal Site Designation,
    Hillsborough, Pinellas and Manatee Counties
The U.S. Environmental Protection Agency (EPA) has requested review and
comment on the draft Environmental Impact Statement (EIS) for Tampa Harbor,
Florida which presents  information necessary for the designation of a new
Tampa  Harbor Dredged Material Disposal Site.  The purpose of the; action is
to provide the  most environmentally and economically  acceptable ocean
location for the disposal of material dredged from the Tampa; Bay  area.
Based  on  recent' surveys of four Shallow-Water Alternative Sites, EPA has
determined that Shallow-Water  Alternative Site 4 is the  alternative ;with
the fewest hard-bottom areas  which may be affected  by the disposal of
dredged material.  It is  the  recommendation  of  the  DEIS that Alternative
Site 4 be designated as the disposal site location  for  dredged material
from the  Tampa  Bay  area.  Agency - EPA;  Location - Hillsborough,  Pinellas
and Manatee Counties.                                    •      -.. •-•-
                                                                "  ^ * '
                      Local Comments  Received From;           '±<. •-. •. '   i

Hillsborough County Environmental Protection Commission:  See attached
  letter dated December 5, 1982.                               _'     :

Hillsborough  County  Department  of Development Coordination:   See  attached
  memorandum  dated December 3, 1982.

Pinellas County  Planning  Department:   No  comment received as of December
30, 1982.

City of St.  Petersburg Planning Department:  See attached letter-' dated
  December 16,  1982.

Manatee County Board of County Commissioners:  See  attached  letter dated
  December 13,1982

Mote Marine Laboratory:   See attached  letter dated December 9,  1982.   :

Gulf of Mexico  Fishery Management Council:   See attached  letter dated
  December 10, 1982.                                             .''   '•

Office  of  the Governor:   See attached  letter dated December 22, ..1982, '.

                  Council Comments and Recommendations

This  project  has been reviewed for consistency with the Council's Areawide
Water Quality Management Plan and the Council's adopted growth .rpolicy/ the
Future of the Region.  The proposal  has  not  been found to be consistent
with Council policy that a standard of water quality  should be achieved
that allows  for the protection and propagation of  fish,  shellfish/ and
wildlife and  provides for recreation in and on the waters in the -region.
                                                             -. on t '.
                 tompo boy regional planning council
          KogerBouievarcJ St Pete'Sburq, H 33702  (813) 577-5151 Tampa 22-1-9380

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This project is  regionally significant and the following local and regional
concerns have been raised during the  review:
                                                     •
•  The staff of the Tampa Bay Regional Planning Council has reviewed the
   Draft Environmental Impact  Statement (DEIS) for Tampa*Harbor Ocean
   Dredged  Material Disposal Site Designation and offers  the following
   comments;

   General Comments

   1 .  The  DEIS  lacks sufficiently detailed evaluation and comparisons of
       all  possible  alternatives including diked disposal  islands  and
       upland disposal areas.

   2.  The   designation of Alternative Site 4  for  disposal of dredged
       material from the Tampa Bay Area should be based on  more detailed
       studies of this area.  The DEIS lacks site specific studies evaluat-
       ing the impacts on marine environment and economy of the region.
       The  results  of the studies done in other  locations cannot serve as
       the  base for  evaluating the  impacts of  the  proposed dumping of
       dredged material  on  the proposed site.

   3.  The environmental consequences  of dumping dredged  sediments on sand-
       substate  habitats  also  cannot  be predicted based on the results of
       the studies from  other  locations.  The  ecosystem of shallow-waters
       in central-southwest Florida is  different from the continental  U.S.
       waters.

   4.  Information pertaining to tidal currents  is  needed  based on records
       obtained  from  the tide guage station located in Egmont Key.

   5.  The monitoring program  has not  been specifically  designed to deter-
       mine whether disposal at the selected site significantly affects
       areas outside  the  site and to detect  long term  effects  occurring in
       or around the site.  It  is stated in the DEIS that a monitoring
       program  may  be established  to supplement historical  data.   Details
       on what the monitoring program will entail must be included.

   6.  The  recreational  and  commercial fishing values of the surrounding
       area  should be identified as  well as  the impacts of ocean  disposal
       on migratory fishing. t

   7.  It is stated  that dispersion  of disposal  material  outside  the site
       boundaries will  be  over time  and in thin layers, and that such
       dispersion is  not  expected to have unacceptable adverse environmen-
       tal impacts.  Specific studies need to be completed to determine
       whether  the  thin layer of siltation adversely impacts the sur-
       rounding  hard  bottoms  (corals).

   Specific  Comments

   1.  Statements  that there are no hard-bottom habitats within or in
       proximity to Site 4 are  not well-documented.  More  extensive inspec-
       tion  of areas  both within and  around the site is necessary before it
       can  be known what  types of  organisms  and communities  will  be

-------
    adversely affected by dumping.   In-depth surveys to determine the
    nature and extent of live, hard-bottom habitats.in or near the site
    should be further conducted.

2.  It is stated in DEIS that results of dredged material disposal at
    the Tampa Harbor alternative sites are anticipated to be similar to
    the results of disposal operations at Calveston,  Texas  (page  2-28).
    However,  the West Florida Shelf cannot be compared with other areas
    which have no hard-bottom communities.   The conclusions that dispo-
    sal will not result in any detectable changes in ecology of the area
    are inappropriate.

3.  An assessment of the siltation and turbidity caused by resuspension
    of fine particles by waves, storms and tides has not been completed,
    as well  as  the  expected impacts  of  the siltation on live-bottom
    habitats.

4.  The long-term effects  from the continual resuspension of  spoil
    material throughout the  water  column  have not  been adequately
    studied  nor documented.   The amount  and frequency of siltation,  the
    direction of sediment transport based on site-specific ocean current
    information,  and the environmental consequences of long-term tur-
    bidity should be estimated before  final recommendations are made.

5.  It is stated in the DEIS that Site 4  is removed  from areas  of
    recreational  use,  and  has no known  significant commercial  fishery
    use (page 2-27).   This statement  is not based on the detailed survey
    of commercial and recreational fishing activities of  this area.
    Relevant studies should  be completed based  on  public testimony
    whether the proposed action affects  the  recreational  activities  of
    the region and commercial fishing.

6.  Cost-benefit  analysis,  taking  into account  the direct  and  indirect
    economic benefits  generated by the recreational use of this part of
    the Gulf  of  Mexico have not been  done at  this time.

7.  A public hearing should be scheduled to  allow  full and fair public
    comment in the draft EIS and the  overall  suitability of  dumping  in
    the Eastern  Gulf of Mexico.

The Manatee County Board  of County Commissioners has provided extensive
comments which already have been forwarded to EPA and are summarized
below (see attached  letter  dated December 13, 1982) regarding the Draft
EIS for a  permanent ocean disposal  site for Tampa Harbor:

1.  The EPA survey upon which the EIS relies to recommend Site 4  for
    permanent designation,  used survey  methodologies that are inadequate
    for determining  the nature and extent of  live,  hard-bottom  habitats
    in or near  the  site;  yet, the entire EIS rests  on  the unproven
    assumption  that there are no hard-bottom habitats within  or  in
    proximity to Site 4.  This is critical because of the well-docu-
    mented importance of  live-bottom habitats to both  commercial  and
    recreational  fishery resources.

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   2.  Although the EIS notes  that  significant damage that can occur to
       hard-bottom habitats from siltation and turbidity,  it completely
       fails  to describe or assess the  siltation and turbidity that will be
       caused by resuspension of fine particles by waves, storms, tides,
       and combinations  thereof, and it fails to quantify the  resulting
       siltation problem and its expected  impacts to corals,  sponges,
       algaes,  and  the like.

   3.  The EIS recommendation of Site 4 is based on erroneous and under-
       stated information  concerning  the use  of the  area in  and around the
       site,  which is actually located in an area that is heavily used by
       commercial and recreational fishermen, sport divers, and others.

   4.  This Site-Designation  EIS presumes that ocean dumping is appropriate
       in this part of the Gulf  of Mexico, disregarding as  a  general matter
       the high potential  for damage  from burial and siltation to the hard-
       bottom habitats and organisms found  scattered  throughout  this part
       of the Gulf,  and inadequately considering  the  possibility of using
       uplands or  diked disposal areas on  a  short-term  basis pending
       thorough  investigation of  the  suitability of  ocean dumping.

   5.  The EIS also relies on erroneous  cost estimates for transporting the
       dredged material to various alternative sites,  and  there is no
       comparison of  the  environmental  "pros and cons"  of  each alternative
       site relative  to the  economic costs.
   >
   6.  Finally, with respect to the  EIS's cost analyses, the EIS fails to
       take any account of the direct or indirect economic benefits gen-
       erated by the  recreational use of this part  of the Gulf of Mexico,
       thereby placing too-heavy  emphasis on  the  immediate  costs of spoil
       transportation.

   Therefore,  in  light of the many deficiencies  of the Draft EIS,  including
   reliance on erroneous assumptions, inadequate surveys, and  incorrect
   infomation, the Board of County Commissioners of Manatee County requests
   that a public hearing be scheduled to discuss the Draft EIS and proposed
   site designation,  or,  in the alternative,  that  the Draft EIS be with-
   drawn and  subsequently resubmitted for public comment.

•  The staff  of the Hillsborough County Environmental Protection Commission
   has reviewed the Draft Environmental.Impact Statement (EIS)  for Tampa
   Harbor:  Ocean Dredged Material Disposal Site Designation and submits
   the following comments and recommendations:

      It is recommended that all disposal at the Existing Site  A be
      stopped because  it is  too close to shore, too close  to produc-
      tive reef areas, and within easy reach  of divers and  small  boat
      users.

      Site 4  is  in 85  to 95 feet of water and is not as  likely to be
      used for recreational purposes  such as diving and fishing.   All
      material should  go  to  this  site until some long  range  solution
      is found.

-------
    Site 4 has no hard-bottom  outcrops and would therefore have the
    least impact on fish and other types of life.

 •   The City of St. Petersburg Planning Department has reviewed the Draft
    EIS for Tampa Harbor:   Ocean  Dredged Material Disposal Site Designa-
    tion and recommends  the following additions to the above referenced
    EIS:

        Incorporation of any appropriate review criteria
        which may be  forthcoming from the pending litiga-
        tion  related  to offshore  dumping initiated by
        Manatee County;

        Analysis of  upland dumping sites;

        Further  analysis  of Site  4.    It  appears  that
        Appendix C.  (referenced  on Page 2-13 of study) may
        provide additional data to  substantiate minimal
        adverse environmental impacts.

 •   The Office of the Governor has submitted the following comments  and
    recommendations regarding the Draft EIS:

        An interagency review of the statement has found
        that the proposed action would smother  the benthos
        within the designated area and alter habitat within
        the site.   The  document recognizes  that  these
        adverse impacts  at the site are unavoidable.  Our
        reviewing agencies report that the EIS statement is
        inadequate and lacks  the necessary information to
        be of sufficient value   as a decision-making docu-
        ment (see attachments).

        We have  concerns  with  this designated site and
        EPA's  proposed rule  for ocean  dumping without a
        Federal  Coastal Zone Management Consistency Evalua-
        tion.  Recognizing our concerns, the impact of this
        designation  and its effect on  the Tampa  Harbor
        project, we request that your agency participate in
        an interagency meeting at your earliest convenience
        to afford us  the  opportunity to discuss issues of
        concern to the State  of  Florida.  It is our desire
        to use this  initial meeting as a step  toward re-
        solving  our  concerns.

Based on the review of  this document, it is' the  opinion of the Tampa  Bay
Regional Planning Council that no  ocean dumping should  be performed
until it is demonstrated that ocean  dumping in this part of  the  Gulf of
Mexico is appropriate and that it is  the most  suitable  method of  dispo-
sal.  That demonstration  should  include an actual determination  of  the
nature and extent of hard-bottom habitats  and  fishery resources  in site
4 and in  surrounding areas.  This  determination should be based on
further, site-specific surveys, including the direction,  amount, fre-
quency,  and distance of sediment transport and siltation,  and a specific
quantification of the damage that will result therefrom.   Also, a de-

-------
     tailed, careful balancing of the economic versus environmental concerns
     for each alternative method  should be performed, including consideration
     of  the many commercial  aspects  of  recreational  fishing  and  diving  and
     development  of  a  thorough  monitoring program to assess the  impacts  of
     any dumping  on a long-term basis.

     In conclusion,  the final recommendation of the DEIS for Tampa.Harbor
     which  designates Shallow-Water  Alternative  Site  4  as the Tampa  Harbor
     ocean  dredged  material disposal  site  is not consistent  with  the
     Council's  adopted policy  to support the maintenance  of Class  III  waters,
     including bays,  rivers,  lakes,  estuaries  and open  waters  of  the  terri-
     torial sea,  at a quality sufficient to allow body-contact water  sports
     and propagation of fish and wildlife.  (Future  of_ the Region, 2.402)

     It is recommended that  Alternative Site 4  not be used  as  an interim
     dumping site, and that all concerned parties meet to resolve  identified
     concerns.

  It is therefore recommended that the above local and regional concerns  and
  recommendations be addressed in the final EIS  for Tampa Harbor.   Further,
  it is recommended that any additional comments addressing local  concern be
  considered prior to issuance or approval of the  final EIS.
  Committee adopted January 3,  1983.
/Mayor 
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                           Responses to Comments
1-1       EPA appreciates the review and comments on the DEIS provided by
          the Florida Department of State, Division of Archives, History and
          Records Management, and acknowledges the response that the
          proposed action is "...unlikely to affect any cultural
          resources...."

2-1       EPA appreciates the review and comments on the DEIS provided by
          the Public Health Service, Department of Health and Human
          Services, and acknowledges that possible health effects of the
          proposed alternatives have been adequately addressed.

2-2       A monitoring  program will be initiated for Shallow-Water
          Alternative Site 4 to document any potential unacceptable adverse
          environmental impacts caused by the disposal of dredged material.
          Extensive baseline data and information has been collected in
          preparation of this EIS (see DEIS, p. 2-31).

3-1       EPA thanks the Tampa Port Authority for their review and comments
          and continued interest in the preparation of the FEIS.

3-2       Extensive video camera observation of the bottom characteristics
          of Site 4 as  well as other areas has been completed during EP^&'s
          February, March, and April 1983 extensive surveys.  More than 80
          miles and over 50 hours of video camera observation have been
          recorded on videotape to document the physical characteristics of
          the ocean floor and the presence of hard bottom and associated
          flora and fauna.

4-1       EPA acknowledges that the Tampa Port Authority agrees that Site 4
          may be a more acceptable long-term dredged material disposal
          site than Site A.

4-2       Intensive surveys conducted during February, March, and April 1983
          using an underwater video camera afforded extensive characteri-
          zation of the ocean floor.

5-1       EPA acknowledges DER's concern regarding disposal of dredged
          material offshore and its support for land-based alternatives.

5-2       The purpose of the document "...is to provide an environmentally
          and economically acceptable ocean location for the disposal of
          dredged material, which complies with the environmental impact
          criteria of the Ocean Dumping Regulations (40 CFR 220-229)."
          Preliminary survey work was followed-up by intensive surveys
          during February, March, and April 1983.  This work included
          sediment cores, water quality samples, fathometer and side-scan
          sonar tracings, fish tissue analysis and more than 50 hours of
          video camera  recordings of the bottom in the area.

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                                    -2-

5-3       Full public involvement has been evident through the DEIS and site
          designation process; 32 comments have been received in response to
          the public notices of the availability of the two documents.

5-4       Non-ocean disposal of dredged material from the Tampa Bay Project
          including upland and diked disposal areas has been considered.
          According to the Corps of Engineers (letter from Harrison D. Ford,
          to Joseph Freedman, EPA Attorney, July 14, 1983), upland disposal
          areas which must be obtained by the local sponsor are not
          available at a reasonable cost.  Although disposal of dredged
          material on existing or proposed diked disposal islands was
          considered a viable alternative, this alternative was later found
          to be economically and environmentally unacceptable for disposal
          of dredged material from the construction phase of the Tampa
          Harbor Project.  Existing diked disposal islands do not have
          sufficient capacity to receive the construction phase dredged
          material.  In addition, the costs associated with diked disposal
          islands are greater than originally thought because of the
          presence of rocks  in the material to be dredged.  The dredged
          material would be  placed in a barge where the heavier rocks would
          settle to the bottom.  These rocks would be dropped to the bottom
          in the area to be  retrieved mechanically later and deposited on
          the diked disposal island.  After removal of the rocks, the finer
          silt could then be pumped from the barge onto the diked disposal
          area.  This double handling of dredged material for diked disposal
          alternative would  result in increased costs.  In addition, the use
          of diked disposal  islands could result in adverse environmental
          effects including:  increased turbidity during construction,
          increased turbidity from post-construction erosion, changes in
          circulation and flushing characteristics, reduction in aquatic
          productivity, destruction of benthic organisms, and possible
          increased levels of pollutants in the water column.  In summary,
          both upland disposal and diked disposal island alternatives have
          been found to be economically and environmentally unacceptable,
          because of increased costs and adverse environmental impacts.

5-5       Acknowledged; correction made in text.

5-6       Hard bottom is more appropriate terminology here, because fine or
          coarse sand and shell hash also have a living biotic component.
          The biological assemblages cited are associated with hard
          substrate; therefore, it is more appropriate to differentiate
          between "hard" substrate types and "soft" substrate types.

5-7       Intensive surveys  conducted by EPA in February, March, and April
          1983 in the area of Site 4 supported the conclusion that there is
          little hard- bottom habitat in this area.  Less than 17% of the
          site was found to  have hard-bottom, and less than 1% is densely
          populated hard-bottom.

5-8       Acknowledged.  Description of existing site has been expanded.

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                                    -3-

5-9       Existing bottom at and in the vicinity of Site 4 is composed
          primarily of fine and coarse sands, coarse sand and gravel, and
          coarse sand and shell hash, as evidenced by recent February,
          March, and April  1983 surveys.  Since the area consists primarily
          of these types of sand bottom, the Dredged Material Research
          Project (DMRP) studies are applicable to the area of
          consideration.

5-10      Recent February,  March, and April  1983 surveys address this issue.
          A large percentage (83%) of the area is "soft" bottom.

5-11      The coralline species noted in this area were seen in depths
          between 35 and 90 feet of water during the February, March, and
          April  1983 surveys.

5-12      The three fish species found most often during the February,
          March, and April  1983 surveys in the study area were the Caesar
          grunt, cusk eel,  and sand perch.

5-13      The small, scattered patches of hard bottom consist of algae,
          sponges, corals,  bryozoans, tunicates, and a motile fauna of
          crustaceans, polychaetes, molluscs, echinoderms and fish.

5-14      Little evidence of commercially or recreationally important uses
          of the area of Site 4 was seen during EPA surveys.  The Corps of
       •   Engineers conducted an aerial surveillance of Site 4 between
          March  19 and June 5, 1983.  During the twelve survey flights over
          twelve weeks of observation, no commercial activity was observed
          and no vessels were observed in the Site 4 area, with the
          exception of one  dive boat on June 1.  No other source has
          provided any reliable information concerning the commercial or
          recreational uses of Site 4 or its vicinity.

5-15      Since  a large percentage of Site 4 is sedimentary habitat
          (approximately 83%), comparisons can be made to evaluate the
          impact of dredged material on the site.  (See also Comment 5-9).

5-16      No sea turtles were observed during any of the EPA or Corps
          surveys.  Turtles lay their eggs on beach areas; therefore, no
          effect on turtle  breeding success is anticipated by the disposal
          of dredged material at Site 4 (see DEIS, p. xx, para. 3).

5-17      The conclusion is supported by analysis of liquid phase elutriate
          samples discussed in DEIS page xx, paras. 2 and 4.  In addition,
          monitoring will be conducted at Site 4 to detect long-term effects
          occurring at or near the site.

5-18      Adverse environmental effects of the action include "smothering of
          the benthos within a designated site" which would include minimal
          hard bottom and fish habitats.

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                                    -4-

5-19      The hazards of marine commerce are far outweighed  by  the  benefits
          expected from the Tampa Harbor Project.  Moreover,  substantial
          civil penalties may be assessed against those  responsible  for oil
          spills or other accidents, which should encourage  caution.   Costs
          incurred in clean-up may also be recovered  by  the  Government.

5-20      Results from intensive surveys during February,  March,  and April
          1983, indicate that Site 4 has less than 17% hard  bottom  and less
          than 1% of the site is densely populated.

5-21      The intensive surveys discussed above and additional  Corps work
          are sufficient to select and designate an acceptable  disposal
          site.

5-22      Existing dredged material disposal islands  were  eliminated from
          consideration for disposal because of the nature of the dredged
          material.  Rocks would necessitate double handling  (see response
          to Comment 5-4).  Abandoned phosphate pits  were  considered and
          found to have insufficient capacity (CE, 1976).

5-23      Dredged material disposal at a mid-Shelf site  is considered  to be
          more likely to have long-term adverse effects  on the  benthos than
          disposal at a shallow water site, because shallow  water, high-
          energy benthic communities recover more quickly  from  such  adverse
          impacts according to Oliver et_ a]_., (1977).

5-24      Collard and D'Asaro's terminology is adequate  for  the discussion
          of the alternative site under consideration.

5-25      The statement referred to is that the "Shallow-Shelf  Alternative
          Sites are in a high-energy environment influenced  by  wave  action,
          freshwater and storms."  The magnitude or duration  of that
          influence is not discussed.  The fact that  there are  low average
          winds and seas at the nearshore sites has little bearing on  the
          influence of periods of high winds and seas on the  Shallow-Shelf
          marine environment.

5-26      The purpose of the EIS is to determine an acceptable  disposal
          site.  The Corps of Engineers considered land-based alternatives
          and found them economically and environmentally  unacceptable (see
          response to Comment 5-4).

5-27      See DEIS, p. 2-5, para. 2, continuing to p. 2-6.

5-28      Even if "currents are generally less than 1 Kn," this does not
          preclude the effect of periodic strong currents.   The cited
          reference refers to the effect of strong currents  on  resuspension
          of sediment, which is relevant to the study area.

5-29      Dominant live bottom flora and "fauna are discussed  in the DEIS
          (see pp. 3-30 through 3-46, especially p. 3-43,  para. 4).

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                                    -5-

5-30      See DEIS, Appendix C.  See also February, March, and April  1983
          surveys, Appendix F of the FEIS.

5-31 a.   Benthic communities in shallower waters are adapted to periodic
          stresses and therefore likely to recover more rapidly from  burial
          than a community in a deeper, more stable, low energy environment
          (Oliver et _a]_., 1977).

     b.   Shallow-waters are defined as depths less than 30m, and  located
          within 25nmi of shore; mid-Shelf waters are defined as depths  from
          30 to 200m, from 25 to 75nmi offshore; deepwater Slope waters  are
          defined as depths greater than 200m, approximately 105nmi offshore
          (DEIS, p. x).

     c.   Areas in depths of 16-30m are considered areas of higher energy,
          because wind-driven currents affect bottom characteristics  and
          maintain a dynamic environment.

     d.   Because the mid-Shelf site is an area of lower energy, the  dredged
          material could be expected to remain in place for a longer  period
          of time, and therefore, would have a longer adverse effect  on
          benthos.

     e.   Both shallow water (depths less than 30m), and mid-Shelf (30 to
          200m), have characteristic benthic communities, either of which
          will be impacted by dredged material disposal.

5-32      This is discussed in DEIS, p. 3-50 Marine Recreation (see also
          response to Comment 5-14).

5-33      Hard bottom communities are not termed unstable or sedimentary;
          rather, the statement describes the bottom and sediment
          characteristics of a shifting, dynamic environment, to which
          nearshore biota have adapted.

5-34      These are two different issues.  The deposition of dredged
          material over time will preclude complete recolonization of the
          site.  Only on cessation of disposal at the site would complete
          recolonization occur, and this would depend on the mix of disposed
          and in situ sediments in the area.

5-35      There were indications (hard bottom remnants on the fringes of
          Site A) that there may have been hard bottom areas located  within
          Site A.

5-36      Extensive video camera work, side-scan sonar, and supporting
          physical, chemical, and biological sampling was conducted during
          EPA's February, March, and April 1983 surveys.

5-37      Disposal of dredged material at Site 4, 18 nmi seaward of these
          amenity areas, will not impact any of these species, because of
          the distance involved.

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                                    -6-

5-38      Hard bottom habitat within the area studied are not true coral
          reefs; however, grunts are often found in hard bottom areas.

5-39      The February, March, and April 1983 EPA surveys provided extensive
          data to adequately characterize the bottom habitat  in the  vicinity
          of Site 4.  Less than 17% of the site is hard bottom, and  less
          than 1% is densely populated.

5-40      Technical Report:  Rice, Patton, and Mahadevan, 1981, p. 18;  see
          Appendix E of DEIS.

5-41      The mounds at disposal sites will disperse at a rate based on the
          volume and composition of the disposed material.  Larger rocks
          will remain longer than the finer sands and silts; however, they
          make up only a small percentage of the composition of the  disposal
          material.  The rocks remaining will also provide hard substrate to
          encourage recolonization of the site.  Further, there is no
          evidence of any mound remaining at Site B, despite the deposition
          of over 1 million yds^ at that site.

5-42      Storm- and wind-generated currents do contribute to the high
          energy environment in these depths, and thereby resuspend  and
          disperse sediments at depths of 40 feet (Ichiye et^ ^1_., 1973).

5-43      It is more appropriate to compare sandy bottom recovery to the
          current and proposed sites, because the high ratio of sandy bottom
          to hard bottom habitat.  Comparison with recovery from lava flows
          has no validity to a dredged material disposal site.

5-44      Construction and maintenance of a multipurpose, deepwater  port
          requires dredging with subsequent disposal of dredged material;
          this is the environmental impact being evaluated, and therefore,
          should have bearing on the Tampa Bay disposal sites.

5-45      References cited refer to the "region containing the alternative
          sites", and are not presented as site-specific water quality
          studies.

5-46      See lines 4-8 of the cited paragraph.  The Holliday report
          discusses the general processes affecting the fate of dredged
          material; such processes apply in the Tampa Bay area.

5-47    -  Video camera transects in the Site 4 area during the February,
          March, and April 1983 surveys revealed that less than 17%  is  hard
          bottom and less than 1% is densely populated.

5-48      Monitoring guidelines to be established by EPA will address
          effects of disposal on hard bottom biota.  Both Courtney et al.,
          (1974) and Griffin (1974) guidelines will be considered. HFcr
          further guidelines, see pp. 2-31 through 2-35 of the DEIS.

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                                    -7-

5-49   .   The February, March, and April 1983 EPA Surveys address these
          issues.  The disposal  of dredged material is not expected to
          destroy stony corals or sea fans within the area of Florida's
          jurisdiction, and is expected to have a minimal impact on hard
          bottom communities in  general.

5-50      The predominant substrate in the area is sand, occasionally
          intermixed with shell  hash; this substrate has a benthic infaunal
          component.  With the sporadic occurrence of sessile benthic
          epifauna, the infauna  remain the better organisms to monitor
          changes at the site.

5-51      Although organisms on  hard bottom can be observed in situ and
          monitored for change,  only a relatively small area could be
          covered practically by use of this method.

5-52      Although these species are not reported to be common to the
          proposed site, they will be considered if the study of trace
          metals is included in  the monitoring plan.  Indications from EPA
          analyses are that trace metal levels in the vicinity of Site 4 are
          extremely low.

5-53      The creation of sediment is not being discussed here, but rather,
          the redistribution of  existing sediments by tidal currents.

5-54      Sessile epibenthic organisms may be better indicators in some
          areas.  However, because of the sparse and sporadic occurrence of
          epibenthic organisms in and near the Site 4, the more uniformly
          distributed infaunal organisms are a better choice of indicator
          organisms.

5-55      The change has been effected.

5-56      Corals are predominantly colonial and solitary within the study
          area (see DEIS, p. 3-43, para. 4).

5-57      The change has been effected.

5-58      Information on the economics of fishing and boating are included
          in the DEIS, p. 3-50,  Marine Recreation (see also response to
          Comment 5-14).

5-59      The spotted sea trout  is reported to occur in association with
          rock outcrops and artificial reefs located offshore and
          approximately 3 nmi. north of Sites A and B.

5-60      Paragraph 2, line 3, has been changed to read as follows:  "Pink
          and rock shrimp comprised 97% of the total shellfish tonnage
          (2,066 tons) and represented 96% of the commercial  value.  Some of
          the landings at the Tampa-St. Petersburg area were reported taken
          from waters outside the immediate area" (letter from Florida
          Department of Natural  Resources to EPA, December 10, 1982).

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                                    -8-

5-61      The change has been effected.

6-1       Non-ocean alternatives were considered by the U.S. Army Corps of
          Engineers (CE, 1976).  However, non-ocean alternatives were found
          to be economically and environmentally unacceptable  (see  response
          to Comment 5-4).  The EPA is responsible for evaluating
          alternative ocean disposal sites based on the five general and
          eleven specific criteria of 40 CFR 228.5 and 228.6 (see DEIS, pp.
          2-5 and 2-6).

6-2       Data from intensive site specific surveys conducted  by EPA during
          February, March, and April 1983, provide a basis for evaluating
          the impacts of the proposed dredged material site designation.

6-3       The comparison of similar environments allows a degree of
          predictive judgment for evaluating potential impacts on sandy-
          substrate habitats off the coast of Florida.

6-4       See DEIS, p. 3-4, para. 4, "Currents".  Information  is based on
          appropriate tide gauge stations in the region,

6-5       A detailed monitoring program will be established at Site 4 by EPA
          with input from members of State and local technical and
 >        scientific staffs.

6-6       No significant impacts on migratory fish are expected, since fish
          are mobile and will avoid areas of temporary turbidity (see DEIS,
          pp. 3-47 through 3-50).

6-7       Sufficient baseline information is available to evaluate the
          potential impacts of the long-term dispersion of disposed
          material, outside the site boundaries.  Designation  of the release
          zone can minimize the dispersion of dredged material outside the
          boundaries of the site.

6-8       The area in the vicinity of Site 4 is not a wetland, but open sea.
          A comprehensive monitoring program will be initiated following the
          site designation.

6-9       Designation of Site 4 as a dredged material disposal site will not
          preclude maintenance of Class III Waters to allow body-contact
          water sports and propagation of fish and wildlife.   In any event,
          Site 4 is not within the territorial sea.

7-1       Acknowledged.  We thank the U.S. Department of Commerce, National
          Oceanic and Atmospheric Administration' for their comments.
          Suggestions are well-taken, and are incorporated in  the Final
          EIS.

8-1       No significant ecological impacts including long-term effects are
          expected, because of the characteristics of the dredged material

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                                    -9-

          and the lack of densely populated hard bottom within Site 4  (less
          than 1%).  The appendices were distributed with the DEIS.

8-2       Many organisms adapted to soft bottoms are capable of recovering
          from burial  following disposal operations, and are capable of
          recolonization of the site.  Biological components of the Site 4
          bottom habitat are discussed in the DEIS, pp. 3-37 through 3-46.

8-3       The time required for recolonization of a dredged material site
          following the termination of dredging operations depends in  part
          on the similarity in composition of the original site sediment
          with that of the dredged material.  Existing bottom sediments at
          Site 4 contain some of the geological components common to the
          dredged material, which makes recovery of Site 4 more probable
          within a reasonable period of time.

8-4       Although distribution of an ocean discharge at sea cannot be
          specified with 100% accuracy, a reasonable prediction based  on
          prevailing currents can provide a sound basis for evaluating
          potential impacts.  Continued site-specific studies will allow
          more accurate distribution predictions.  In most cases, dredged
          material planned for disposal at sea must pass the Ocean Dumping
          Regulations' elutriate, bioassay, and bioaccumulation test
          procedures,  found at 40 CFR Section 227.  Anthropogenic
          contaminants in harmful levels are not anticipated; however,
          monitoring of the dredged material and the dredged material  site
          will be conducted.  Disposal operations are not expected to
          promote red  tide blooms, or to cause damage to biological
          populations  outside the site through chemorecept'ion interferences,
          because of the character of the dredged material and dilution
          factors.

8-5       No unacceptable adverse environmental long-term effects are
          expected inside or outside the designated site.  Short-term
          impacts to non-motile benthic organisms may occur from smothering
          and burial within the site.

8-6       The combined results of all the potential effects of the proposed
          disposal are not expected to have any significant effect on  the
          ecosystem or on fishery resources.  Estuarine spawning and nursery
          areas, none  of which are at Site 4, are more susceptible to
          damage.  Adults can avoid areas of high turbidity, whereas eggs
          and fry often may not survive.

8-7       In satisfying the five general and eleven specific criteria  for
          selecting sites for disposal of dredged material found at 40 CFR
          'Sections 228.5 and 228.6, all of the factors discussed must  be
          taken into account and carefully evaluated.  That was done in this
          case.

8-8       The Corps considered in detail the use of upland disposal and
          diked disposal  areas (CE, 1976) but later found these alternatives

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                                    -10-

          to be economically and environmentally  unacceptable  for  disposal
          of dredged material from the construction phase of the Tampa
          Harbor Project  (see response to Comment  5-4).

8-9       EPA has determined that the site designation will have no
          appreciable direct effect on the coastal zone.  Nevertheless,  a
          consistency determination has been completed and  submitted to  the
          State of Florida.  In addition, under 40 CFR 222.3,  State agencies
          responsible for the Coastal Zone Management Act are  to receive
          notice of applications for ocean dumping permits.

9-1 through 9-7  Identical to Comments 6-1 through 6-7.

9-8       Intensive surveys conducted during February, March,  and  April  1983
          were specifically designed to determine the nature and extent  of
          bottom habitats within and near the site.  The paucity of hard
          bottoms at the site was confirmed, with  less than 17% hard bottom
          and less than 1% densely populated hard  bottom found at  Site 4.

9-9       The low incidence of hard bottom in the  Site 4 area  (estimated at
          less than 17% of the bottom) makes comparisons allowable with
          other, essentially soft bottom habitats.

9-10      Dr. Henry Bokuniewicz of the State University of  New York Marine
          Sciences Research Center discussed siltation and  turbidity caused
          by resuspension of fine particles by waves, storms and tides
          (Bokuniewicz, 1982) as it pertains to the Tampa Bay  area.  He
          concluded that between 3 and 10% of the material  would be
          dispersed from a site, depending on long-term erosion of sediment.
          Material leaving the site will most likely be widely dispersed and
          diluted.  In addition, the Corps of Engineers Waterways  Experiment
          Station is conducting a site-specific study of Site  4 to determine
          the probable fate of dredged material disposed of at Site 4 and
          the distribution of resuspended sediments.  It is expected to  be
          completed in November 1983.  This baseline data will provide
          information for the direction of the monitoring program.

9-11      Resuspension of disposal  material will cause temporary,  localized
          turbidity in the immediate area of disposal until the material is
          dispersed.  The EPA Ocean Dumping Regulations and Criteria do  not
          require quantification of the amount and frequency of siltation,
          or the direction of sediment transport based on site-specific
          ocean information; however, a study being conducted  by the Corps
          of Engineers will address many-of these concerns  (see response to
          Comment 9-10 above).

9-12      The proposed action is not expected to cause unacceptable adverse
          effects on fisheries of the region.  Based on the paucity of hard
          bottom habitat within the Site 4 area (estimated  at  less than  17%
          of the area, with less than 1% densely populated), the commercial
          and recreational value of Site 4 is negligible.   DEIS, p. 3-47:

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                                    -11-

          "Fisheries (Recreational  and Commercial)".  See also response to
          Comment 5-14.

9-13      EPA has no evidence indicating that Site 4 is a significant marine
          recreational  area.  See also response to Comment 5-14.

9-14      EPA believes  that the public has had adequate opportunity to
          comment on the proposed site designation.

9-15 through 9-24  We have responded specifically to the Manatee County and
          Hillsborough  County Environmental Protection Commission comments
          (see response to Comments 10, 13, 14, and 15.

10-1      The February, March, and April 1983, intensive EPA surveys address
          this issue comprehensively.  Over 50 hours of video camera
          observation were conducted on Site 4.  While no area will be
          completely devoid of life or even hard bottom habitat, Site 4 has
          less hard bottom habitat than any other site studied in this area.
          The hard bottom in this area is characterized by low relief flora
          and fauna.  The widely scattered hard bottom habitats within Site
          4 may support some corals, sponges and algae; however, few
          colonies attain heights over six inches.  The characteristic biota
          in this area  does not indicate a highly productive ecosystem.   It
          is estimated  that the widely scattered hard-bottom habitat
          represents less than 17% of the bottom area on Site 4 and less
          than 1% is densely populated.

10-2      See response  to Comment 9-10.  See also DEIS, pp. 2-24, 4-7, and
          4-17 for descriptions and assessment of siltation and turbidity.
          Precise quantification of the siltation is not feasible and is  not
          necessary for the designation of a dump site.

10-3      Available information does not indicate that the Site 4 area is
          heavily used  by commercial or recreational fishermen, or sport
          divers.  An aerial survey by the Corps of Engineers indicates that
          use of the area is minimal (see response to Comment 5-14).

10-4      Burial  and smothering of benthic populations by dredged material
          disposal were considered carefully (see DEIS, pp. 4-17 through
          4-19).

10-5      The Corps developed an estimate of 15f/cu. yd. as average for
          transporting  the dredged material (letter from J. Wall  to J.
          Amson,  August 19, 1983).   Comparison of sites based on economic
          and environmental criteria are found in the DEIS.

10-6      The direct and indirect economic benefits generated by the
          recreational  use of Site 4 are negligible based on available
          information (see response to Comment 5-14).  See also DEIS, p.
          4-21:  "Effects on Recreations, Economics and Aesthetics."

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                                    -12-

10-7      The Corps of Engineers did not "expressly and unequivocally"
          reject ocean dumping as an alternative.  They stated that  "This
          plan [ocean disposal] produced the highest costs of all
          alternatives considered."  Lack of sufficient suitable  land for
          disposal and the unsuitability of the dredged material  for diked
          disposal areas lead to the ocean disposal alternative  (see
          recponse to Comment 5-4).  In any event, the availability of
          land-based alternatives must be considered by the Corps  in each
          authorization for disposal.

10-8      The Corps of Engineers considered several types of dumping in
          detail, including in-Bay disposal, upland disposal, and  dredged
          material island disposal (CE, 1976).  See also  response  to Comment
          5-4.

10-9      Acknowledged; the EIS has been corrected.  The  actual  distance is
          approximately 18nmi.

10-10     The primary reason that the "No-Action Alternative" is
          unacceptable is the adverse economic impacts to the area.  The
          Port of Tampa is one of the leading ports in the United  States,
          ranking seventh in total tonnage and third in export tonnage.  The
          Tampa Port Authority has estimated that about 36,000 persons were
          directly or indirectly employed in port industries through the
          Tampa Bay region (DEIS, p. 1-5).  The Corps is  required  to
          consider both economic and environmentally feasible alternatives
          of accomplishing the proposed objective.  The Corps has  found
          non-ocean disposal alternatives not to be economically  or
          environmentally feasible (see response to Comment 5-4).
          Therefore, EPA, in cooperation with the Corps,  initiated the
          necessary studies/required by 40 CFR 228.4(e) to select, evaluate,
          and designate (if feasible) acceptable site(s)  for the  ocean
          disposal of dredged material.

10-11     It is EPA's responsibility to designate an environmentally
          acceptable ocean dredged material disposal site.  The  Corps of
          Engineers examined upland disposal in detail (CE, 1976).  This
          alternative proved to be economically unacceptable-(see  response
          to Comment 5-4).  Presumably, land is even less available and more
          expensive today than in 1977, making upland disposal even less
          feasible economically.  However, the Corps must consider non-ocean
          disposal alternatives before authorizing ocean  disposal  at Site
          4.

10-12     The site designated is for disposal of dredged material  from the
          Tampa Harbor Project, which is described in detail in the Corps of
          Engineers Final EIS (CE, 1976).

10-13     Rocks in the dredged material cause unexpected  problems  making
          this alternative economically and environmentally unacceptable
          (see response to Comment 5-4).  The recent February, March, and

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                                    -13-

          April 1983, intensive EPA surveys address the feasibility and
          suitability of the designated site.

10-14     The fact that an EPA contractor recommended a course of action
          does not mean the Agency is bound to follow that course.  In fact,
          the contractor's recommendation was based on limited data, which
          EPA later supplemented by re-investigating the existing and
          alternative disposal  sites, and found that Site 3 was
          environmentally unacceptable for dredged material  disposal.

10-15     Note the final conclusion:  "Further studies should be conducted
          to validate the preliminary findings."  Note also that the wording
          of the statement in question states that "...Sites 1 and 3 are
          probably more environmentally acceptable..."

10-16     Diver observations can be an effective site-specific method to
          characterize small localized areas; however, they are a very
          ineffective tool for characterizing large areas, such as Site 4.
          In fact, the divers found little evidence of hard bottom habitat
          at Site 3; however, EPA's May 1982 survey found considerable
          evidence of hard bottom.  Thus, videotape transects are capable of
          more accurately determining the presence of hard bottom habitats.
          An in-depth videocamera survey of Site 4 has been completed,
          recording approximately 80nm of bottom during the February, March,
          and April 1983 EPA surveys.

10-17     Divers observations are limited to a small localized area at each
          station.  Videocamera transects cover a much larger area in a
          continuous line, thereby giving far more conclusive evidence as to
          the extent of hard-bottom communities.  In fact, EPA's initial
          reconaissance survey of Site 3 (where divers were used
          extensively) first indicated a potentially suitable disposal site;
          this was later proved to be an invalid assumption, based upon
          extensive videocamera observation and sample collection.

10-18     The assessment of impact does not require a quantification of all •
          factors.  EPA must make a determination on site designation based
          on reasonably available information.  Further, the natural marine
          environment is dynamic; currents are not static either in
          direction or speed.  A site-specific study, expected to be
          completed by November 1983, is being conducted by the Corps to
          assess currents and sediment transport to provide additional
          baseline data.  The site designation will  be for 3 years.  See
          also response to Comment 9-10.

10-19     Detailed quantification of the rates of dilution of the turbidity .
          plume and the distance the deposited materials will  be transported
          are not required for site designation.  Examination of available
          facts and information using best professional  judgment is
          sufficient to determine whether a site is  suitable for designation
          as an ocean disposal  site.  Site 4 is 4nmi  square, and no movement

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                                    -14-

          of sediment is expected from the site that will cause  significant
          adverse environmental harm.  See also response to Comment  9-10.

10-20     There are two reasons the Mid-Shelf was not  considered  feasible:
          1) the Corps indicated that sites located in excess of  18nmi were
          not economically feasible; and 2) a Mid-Shelf site, considered a
          low energy environment, is likely to sustain more severe
          environmental impacts of longer duration from dredged material
          disposal than alternative higher energy sites.  The most distant
          portion of the Mid-Shelf (i.e., 70 miles offshore) was  selected as
          the alternative Mid-Shelf site, because this was the area
          recommended by the State of Florida.

10-21     The sentence clearly does not state or imply that Oliver et  al.,
          (1977), recommended ocean dumping in hard bottom areas  raTKer than
          deep waters.  The statement was that "...shallow-water, high
          energy benthic communities recover more quickly from disturbances,
          such as the disposal of dredged material, than communities in
          deeper water."  Since about 83% of Site 4 is soft bottom,  the
          basic concept of recovery that 01 iver et ji]_., (1977), described
          applies in this case.

10-22     According to the Corps (letter from J. Wall  to J. Amson,
          August 19, 1983) the average cost to transport dredged  material is
          15|/cu. yd.  The basic premise here is still logically  true; it
          will cost considerably more to transport dredged material  70nmi
          than to transport it 18nmi.

10-23     The Agency is unaware of any evidence of that demonstrates that
          Site 4 is an area of high commercial and recreational activity
          (see response to Comment 5-14).

10-24     The economic feasibility of a dump site is determined on the basis
          of project costs.  According to the Corps of Engineers, sites in
          excess of 18nmi from Egmont Key are not economically feasible,
          based on project costs for the Tampa Bay Harbor Deepening  Project.
          The sites described by the commenter were used for disposal  of
          sewage sludge and industrial waste, not dredged material.

10-25     It is well known that the primary productivity of deep  waters is
          less than that of shallower waters.  This is due, in part, to the
          decreased influx of nutrients and decreased  light penetration.
          Productivity decreases with increasing distance from land, and
          with, increasing depth.  Benthic organisms adapted to the
          relatively constant environment in deeper water are less adaptable
          to change.  Those benthic organisms adapted  to the more dynamic
          inshore waters tend to be more adaptable to  environmental  changes,
          either as individuals or as a species (Oliver et jal_., 1977).
          Although EPA has not conducted studies in the area of the
          Mid-Shelf or Deep Water Sites, the Florida Department of Natural
          Resources did study a site approximately 15nmi to the northwest of
          these sites during the Hourglass Cruise studies in 1969.

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                                    -15-

10-26     The Mid-Shelf site is a more dynamic environment than the Deep
          Water site, and therefore, more resilient to impact from dredged
          material  disposal  (see also response to Comment 9-10).

10-27     Precise quantification is not necessary to make a comparison.  In
          addition, the term "small effect" in this context did not refer
          specifically to hard-bottom organisms.

10-28     The basic point here is that deeper water organisms are less
          adaptable to perturbations such as dredged material disposal than
          shallow water, inshore organisms.  Therefore, recovery from
          dredged material disposal would generally be more rapid at a
          shallow water site than at a deep water site.  Immediate impacts
          would be more severe at the deeper water sites, and recolonization
          would be slower.

10-29     During the recent  February,-March, and April 1983 intensive EPA
          surveys,  there was already some evidence of recolonization noted
          at Sites A and B.   We are unaware of "scientific literature" which
          clearly demonstrates that hard-bottom communities will not recover
          to their pre-dumping state for 25 to 50 years, even after hard
          substrate is available.  The increased entrainment of water during
          the descent phase  of disposal operations at deep water sites will
          increase both the  amount and duration of turbidity, as well as the
          distance from the  discharge point the material is transported,
          thus potentially increasing the extent of environmental damage.

10-30     The increased percentage of silt in the dredged material compared
          to the disposal site sediments can be expected to change the
          characteristics of the infauna accordingly.  The composition of
          the biota would be expected to shift to those organisms more
          adapted to these sediments.  As these finer sediments disperse,
          leaving coarser material, the composition of the biota will
          gradually shift back towards biota that are adapted to the
          original  substrate.

10-31     The same considerations apply to the Deep Water Site as to the
          Mid-Shelf Site (see  response to Comment 10-22).  Increased
          distance increases the costs of transportation.

10-32     Intensive surveys  by EPA during February, March, and April 1983
          were conducted throughout the area with extremely detailed
          examination of Site  4.  More than 50 hours of underwater video
          camera work was obtained, to extensively study the character and
          extent of various  bottom types, both inside and outside of Site 4.
          The video camera technique was found to be- an excellent tool for
          this type of data  collection effort, and covered far more area
          more rapidly with  a  greater degree of veracity than could be
          accomplished by divers in the same amount of time.

10-33     See response to Comment 10-32, above.

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                                    -16-

10-34     See response to Comment 10-32, above for discussion of February,
          March, and April 1983 EPA surveys.  Site 4 is not devoid of
          hard-bottom habitat; however, less than 17% of the site is
          estimated to have this type of habitat.  This is far less than any
          other site studied in this area, and therefore less productive.
          We have no information that Site 4 is an area heavily used for
          shrimping, recreational fishing, or scuba diving (see response to
          Comment 5-14).

10-35     Disposal of dredged material at Site 4 is not expected to have
          unacceptable adverse environmental impacts to beaches, hard bottom
          areas, artificial reefs, sunken vessels, shrimping, commercial or
          recreational fishing, or other amenity areas of the region because
          of the distances from the proposed disposal site.  There has been
          no evidence presented to EPA that Site 4 is an important fishing
          or diving site  (see response to Comment 5-14).

10-36     See DEIS, pp. 3-4 to 3-11 for consideration of storms and
          currents.  A site-specific current and sediment transport study is
          being conducted by the Corps of Engineers to augment available
          information, and is scheduled to be completed in November 1983
          (see also response to Comment 5-14).

10-37     Since approximately 83% of the bottom at Site 4 is "soft bottom",
          comparison with other soft bottom areas such as the Galveston dump
          site is appropriate.

10-38     Quantification  of the amount and frequency of resuspension of
          sediment and impacts to hard bottom habitats and organisms is not
          specifically required by 40 CFR 228.6(a)(7).  However,
          resuspension of sediment is discussed in response to Comment 9-10
          (see DEIS, p. 2-11, para. 3 for discussion of Sites A and B, and
          pp. 3-4 to 3-11 for discussion of currents).

10-39     Dredged material disposal at Site 4 is not expected to interfere
          with shipping,  fishing, recreation, mineral extraction,
          desalination, fish and shellfish culture, areas of special
          scientific importance or other legitimate uses of the ocean.
          Site 4 may be located in a general area used for sport fishing,
          shrimping, party and charter boat fishing, and scuba diving;
          however, Site 4 and its immediate vicinity have not been
          identified with these uses (see also response to Comment 5-14).

10-40     An intensive site-specific study of Site 4 was conducted by EPA in
          February, March, and April 1983.  A monitoring program will  be
          designed to detect unacceptable adverse environmental effects.  If
          it appears that those effects are or will become unacceptable, EPA
          will take appropriate steps to limit or halt dumping operations.

10-41     The intensive EPA survey of Site 4 in February, March, and April
          1983 revealed a minimum of hard-bottom areas within and

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                                    -17-

          surrounding Site 4, and no ledges in or near the site.  No
          unacceptable adverse environmental effects from disposal
          operations are anticipated outside the immediate vicinity of the
          designated disposal site.

10-42     During EPA surveys in February, March, and April 1983, less than
          17% of Site 4 was found to contain hard bottom, and less than 1%
          of the site was found to be densely populated hard bottom.

10-43     Bioassays of dredged material  are designed to insure that the
        -  material  will not cause unreasonable acute or chronic toxicity, or
          other sublethal adverse effects, or cause accumulation of toxic
          materials in the human food chain (see 40 CFR §227.27(b)).  These
          tests are not designed to predict direct impacts from burial or
          siltation on hard-bottom organisms.

10-44     Less than 17% of the site is hard bottom and less than 1% is
          densely populated, so the impact of dredged material disposal on
          hard-bottom organisms would be minimal.  The site will be
          designated for a three-year period, and if monitoring detects
          unacceptable adverse environmental impacts, the Agency will move
          to halt disposal operations.

10-45     During EPA surveys in February, March, and April 1983, detailed
          examination of the area of Site 4 was conducted to identify areas
          of hard-bottom normally associated with this type habitat.

10-46     No evidence has been provided to EPA or the Corps to indicate that
          Site 4 is a heavily used commercial or recreational fishing site
          (see response to Comment 5-14).

10-47     Impacts within and immediately surrounding Site 4 from
          resuspension of fine particles will be negligible (see DEIS, p..
          3-2, para. 6, and p. 3-8, para. 3).  See also response to Comment
          9-10.

10-48     Resuspension of dredged material will cause temporary localized
          turbidity in the immediate vicinity of the disposal area until the
          material  is dispersed and diluted (see response to Comment 9-10).

10-49     Much of the commercial fishery in the area is dependent on pelagic
          species,  which are not generally associated with or dependent on
          hard-bottom areas.  These species tend to be highly mobile, and
          avoid areas of high local turbidity.  Dumping of dredged material
          at Site 4 is not expected to significantly affect hard bottoms in
          any case.

10-50     See response to Comments 5-14 and 10-39.

10-51     See DEIS, pp. 3-47 through 3-51.  No spawning or nursery grounds
          are known to occur in the immediate vicinity of Site 4, and since

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                                    -18-

          there is minimal hard-bottom habitat within Site 4  (estimated at
          less than 17%),  it is unlikely that fish dependent  on hard-bottom
          habitat for spawning and/or nursery areas would be  severely
          impacted by dredged material disposal at this site.

10-52     Sport diving at  Site 4 is an unlikely site for sport diving, since
          there are a minimum of hard-bottom areas at the site, with a
          concomitant reduction in abundance and diversity of marine
          species.  Resuspension of dredged material during severe storms is
          unlikely to significantly impact sport diving in the area, since
          it is too hazardous to attempt diving during such events.
          Turbidity following storms would be temporary and localized within
          the immediate vicinity of Site 4.

10-53     EPA believes that the public has had adequate opportunity to
          comment on the proposed site designation.

10-54     Intensive site-specific surveys conducted during February, March
          and April 1983 by EPA address many of these concerns, including
          the extent and nature of hard-bottom habitat in the Site 4 area.
          Additional site-specific current and sediment transport studies,
          expected to be completed in November 1983, are currently being
          conducted by the Corps of Engineers to provide baseline data.  A
          monitoring program will be formulated to assess the impacts of
          dredged material disposal during the three-year designation.

10-55     After careful evaluation of all factors including intensive
          site-specific surveys, quantification of the extent of hard-bottom
          habitats, and consultation on the subject of sediment dispersal
          during and after disposal operations with experts in the field, we
          feel that Site 4 is an environmentally acceptable ocean dredged
          material disposal site and will not result in unacceptable adverse
          environmental effects (see response to Comment 9-10).  Use of
          diked disposal areas is not preferable, for reasons discussed
          earlier (see response to Comment 5-4).

11-1      Surveys conducted during February, March, and April 1983, which
          included approximately 80 hours of video camera observation of the
          bottom throughout the area, boxcore samples, trawls, side-scan
          sonar and fathometer tracings, and water samples have provided
          sufficient data  for a site designation.  The Corps evaluated
          upland and other alternatives to ocean disposal (CE, 1976).  These
          alternatives were found to be economically and environmentally
          unacceptable (see response to Comment 5-4).  The economic and
          recreational resources of the area are discussed in the DEIS, pp.
          3-47 through 3-52 (see also response to Comment 5-14).  Disposal
          of maintenance dredged material is not expected to permanently
          destroy or degrade hard-bottom communities or associated fishery
          values.

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                                    -19-

11-2      The additional  intensive surveys conducted with the video camera
          during February, March, and April 1983, confirm that there are few
          hard-bottom areas within the site, and those observed are sparse
          and of low relief.  Less than 17% of Site 4 is estimated to
          contain hard- bottom communities and less than 1% is densely
          populated.

11-3      According to available information (Moe, 1963, see Figure 3-18,
          DEIS, p. 3-48)  and EPA 1983 survey results (see response to
          Comment 3-2), there are no artificial reefs or concentrations of
          hard-bottom areas which would attract large numbers of divers or
          recreational and commercial fisherman to the immediate vicinity of
          Site 4.

11-4      Intensive surveys utilizing a towed video camera during February,
          March, and April 1983, provided considerable information for
          evaluation of potential dredged disposal sites to augment the
          earlier survey.

11-5      The movement of sediments is not expected to cause long-term
          unacceptable environmental impacts (see response to Comment 9-10).
          The planned monitoring program will be designed to detect any
          unacceptable adverse environmental impacts.

11-6      The majority of Site 4 consists primarily of flat sandy bottoms,
          and therefore is similar to the referenced study areas.  No
          permanent environmental impacts are expected from disposal at Site
          4.  There is no evidence that the previously designated disposal
          site has contributed to "the disappearance" of basket sponges or
          spiny lobsters  from ledges near the site.  A number of factors may
          have contributed to a decrease in lobsters, including overfishing
          by divers, seasonal changes, and large amounts of natural
          siltation, as observed in the February, March, and April 1983 EPA
          surveys.  Permanent stress to offshore habitats from maintenance
          dredged material disposal is not expected to occur.

11-7      According to the Florida Department of Natural Resources (see
          response to Comment 5-61), the fishery resources indicated in the
          DEIS may actually be overestimated, as the landings in the Tampa-
          St. Petersburg  area are not all taken from the local coastal area,
          and therefore the fishery resources may be less than indicated in
          the DEIS.  Only limited, short-term disruption of recreational or
          commercial fishing is expected to occur, if any, during actual
          dumping operations (see also response to Comment 5-14).

11-8      The Corps of Engineers examined the upland disposal of dredged
          material (CE, 1976), and were unable to locate sufficient suitable
          upland disposal areas (see response to Comment 5-4).

11-9      The Corps considered the diked dredged material disposal island
          alternative in  detail (CE, 1976).  However, with further study,

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                                    -20-

          this alternative was found to be economically unacceptable  for the
          disposal of dredged material from the construction phase of the
          Tampa Harbor Project (see response to Comment 5-4).   In addition,
          diked disposal islands may have unacceptable environmental  impacts
          by reducing circulation in the Bay and increasing turbidity during
          dredging operations and subsequent erosion of the islands after
          construction reducing productivity.

11-10     There are many reasons why a sediment sample may "fail" a
          bioassay.  Some of these reasons include high mortality in  the
          control organisms or changes in required test conditions, such as,
          level of dissolved oxygen.  Tests that are invalidated for  these
          reasons are not normally reported.  An invalid bioassay does not
          indicate "failure" of a sediment sample to pass a bioassay  for
          toxicity.  Moreover, these allegations concerning the field and
          •laboratory procedures were refuted in court proceedings.  The
          court deferred to Dr. Engler of the Corps, who testified that
          field surveys were conducted using proper scientific  procedures
          and that bioassays were conducted in strict accordance with EPA
          and Corps guidelines (Manatee County v. Gorsuch, No.  82-248-CIV-T-
          GC (M.D. Fla., December 22, 1982) (slip op. at 14 note 12).

11-11     Disposal of dredged material outside any designated site is
          occasionally a problem.  However, the U.S. Coast Guard is charged
          with monitoring dumping activities, and dumping outside of  a
          designated area is illegal.  Further, Site 4 is almost six  times
          larger in area than the previously designated disposal site (Site
          A), so incidents of dumping outside the site should be
          substantially reduced.

11-12     Disposal has been- halted at Site A.  Additional extensive studies
         • have been conducted during February, March, and April 1983.
          Transects were conducted at 1/4 mile intervals using  the video
          camera.  In addition, fathometer and side-scan sonar  tracings were
          taken.

11-13     Evidence collected during the February, March, and April 1983 EPA
          surveys indicate that siltation occurring in the area may be
          largely of natural origin because of the uniformity of sediment
          found throughout the area.  Further, a monitoring program will be
          designed to detect any unacceptable adverse environmental impacts
          caused by the potential spread of the dredged material.

11-14     No significant impact is expected to fisheries because of the
          relative small size of the site, and avoidance of the area  by fish
          during disposal operations.

11-15     Diked disposal areas proved to be economically and environmentally
          unacceptable for the disposal  of dredged material from the

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                                    -21-

          construction phase of the Tampa Harbor Project (see response to
          Comment 5-4).

11-16     Opportunity for full  and complete public comment has been afforded
          through the DEIS and  the site designation proposal.  Designation
          of Site 4 is not expected to seriously affect fisheries resources
          in any way, or cause  a serious public health hazard.

12-1      The February, March,  and April 1983 EPA surveys provided extensive
          information to evaluate the site-specific impacts of dredged
          material  disposal  (see response to Comment 3-2).

12-2      Recent intensive surveys address most of deficiencies in the
          biological  sampling.   The box core is designed to sample infauna
          on and in the bottom  and to provide information on the abundance
          and diversity of organisms.  Video camera observations are a more
          effective tool for judging the relative abundance of hard-bottom
          communities.

12-3      Recent intensive surveys in February, March, and April 1983 by EPA
          employed extensive use of the video camera on site.  Preliminary
          examination of video  tape recordings indicate that less than 17%
          of Site 4 bottom could be classified at hard-bottom, and less than
             was densely populated.
12-4      The February, March, and April  1983 EPA surveys provided adequate
          evaluation of the extent of hard-bottom habitats in the area of
          Site 4.

12-5      The recent 1983 EPA surveys discussed above confirm that hard-
          bottom habitat is.-a minor component within the Site 4 area.  Less
          than 17% is hard-bottom, and less than 1% is densely populated.

12-6      Sufficient information is now available from the February, March,
          and April  1983 EPA surveys to evaluate Site 4 under the five
          general and eleven specific criteria of the Ocean Dumping Act  (40
          CFR 220-229).

12-7      Sufficient information from EPA's February, March, and April 1983
          surveys (see response to Comment) and information from Bokuniewicz
          (see response to Comment 9-10)  is available to make a predictive
          evaluation of the impact of dredged material disposal on hard-
          bottom areas.  The monitoring program will be designed to detect
          unacceptable adverse environmental  impacts in which case, EPA will
          move to halt disposal operations at the site.

12-8      Much of this information is available and is either discussed in
          the DEIS,  or in Appendices C and F.  Further, the monitoring
          program to be established may well  include the studies on
          hard-bottom organisms that are  suggested.

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                                    -22-

12-9      Analyses for vibrio-type bacteria would not provide an indication
          of a human health threat.  Only Vibrio parahaemolyticus has been
          implicated as a public health hazard, rarely as an opportunistic
          pathogen infecting wounds, more commonly as a food poisoning
          organism when allowed to grow uninhibited in contaminated seafood
          products.  Culture and identification of Vibrio parahaemolyticus
          using an array of biochemical tests still does not positively
          identify the causative form of Vibrio in cases of acute
          gastroenteritis, making this test of questionable value.

12-10     See DEIS, p. 4-19, para. 1.  "Recolonization of dredged material
          disposal sites depends [in part] on the disparity between site and
          dredged sediments...."  As the silt/clay ratio returns to pre-
          dumping conditions, recolonization is expected to accelerate.

12-11     None of the invertebrate species listed by the Florida Game and
          Freshwater Fish Commission as threatened or endangered, have been
          identified at Site 4.

12-12     The monitoring program will provide continuous site-specific data
          on the disposed dredged material to insure the quality does not
          change.  Tissue samples, water column samples and sediment samples
          may be part of this program.  Toxic metal concentrations were not
          found in Site A post-disposal sediments.
                             >
12-13     Use of a non-endemic species in bioassays is a scientifically
          valid procedure.  In fact, it is often more valid to use test
          organisms of known uniform age and condition then to use endemic
          species which are often difficult to obtain and often not uniform
          in age or condition.  Test organisms were not pre-exposed to
          "significantly high concentrations" of toxic chemicals in control
          water.  Moreover,, these allegations concerning the field and
          laboratory data procedures were refuted in court proceedings.  The
          court deferred to Dr. Engler of the Corps, who testified that
          field surveys were conducted using proper scientific procedures
          and that bioassays were conducted in strict accordance with EPA
          and Corps guidelines (Manatee County v. Gorsuch, No. 68-248-CIV-T-
          GC (M.D. Fla., December 22, 1982) (slip op. at 14 note 12).

12-14     Evaluation of utilization of diked disposal areas has been
          discussed in detail by the Corps of Engineers (CE, 1976), but were
          found to be economically and environmentally unacceptable (see
          response to Comment 5-4).  Additional studies were undertaken in
          May 1982, and in February, March, and April 1983, to ensure that
          an environmentally appropriate disposal site is designated.

13-1      Acknowledged.

14-1      All disposal of dredged material at Site A was discontinued on
          December 24, 1982.

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                                    -23-

14-2      Acknowledged.

14-3      Site 4 has fewer hard-bottom outcrops than any other site
          examined in the Tampa Bay area, and therefore would have less
          impact on fish and other organisms.  Less than 17% of  Site 4  is
          hard-bottom and less than 1% is densely populated.

15-1      Acknowledged.

16-1      The requested meeting was held in Jacksonville,  Florida, on
          January 26, 1983; representatives from all affected Federal,
          State, and local agencies were present at that meeting.

17-1      The reduced visibility reported is highly unlikely to  have been
          caused by disposal operations at Site A.  It is  more probable  that
          the apparent reduction in visibility is caused by activities
          occurring within the Bay.  This could include nonpoint sources
          such as runoff from construction sites, or agricultural
          activities; it could also include point sources  such as discharges
          from sewage treatment plants, or industrial  wastewater treatment
          discharges.

17-2      The order of presentation of material in the DEIS does not
          necessarily reflect the order of the impact assessment.  The
          summary and conclusion, while placed before the  actual evaluation,
          were written after evaluation of all considered  alternatives.
          Site 4 was selected only after careful study showing that the  site
          has few hard bottom areas.

17-3      Additional survey work was conducted in the area with
          approximately 50 hours of video recordings taken of the bottom.
          Site 4 was surveyed in 22 runs that were 1/4 nautical  mile apart
          in both NW and SE and SW to NE directions.  Analysis of this data
          reveals that the majority of the site is soft bottom,  with
          scattered, sparse patches of hard bottom.

17-4      The Corps of Engineers (CE, 1976) considered upland disposal sites
          and found that insufficient suitable land was available for
          disposal  of the dredged material, even on McDill Air Force Base
          (see response to Comment 5-4).  This alternative must  be
          reconsidered by the Corps before individual  ocean dumping projects
          are approved.

17-5      The dredged material islands would be less environmentally
          acceptable, because of the resultant reduced circulation in the
          Bay, and increased turbidity caused by disposal  operations.

17-6      No impacts are expected on Anna Maria Island or  Long Boat Key
          beaches from disposal  of dredged material at Site 4, because of
          the distance of the site from the shore.

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                                    -24-

17-7      The DEIS has been reviewed by the National Oceanic and Atmospheric
          Administration, and the Department of Health and Human Services;
          both agencies agree that no unacceptable  long-term environmental
          effects or adverse health effects are expected to occur from
          disposal of dredged material at Site 4.

17-8      No significant adverse environmental effects are expected either
          on recreational use of the area outside the site, or to the
          commercial fishing of the area  (see also  response to Comment
          5-14).

17-9      Disposal of dredged material at Site 4 is not expected to cause
          any proliferation of the "red tide" organism.  Further, the
          primary phosphorus sources in the Tampa Bay area are probably
          attributable to phosphate industries along the Alafia River  (CE,
          1976).

18-1      Diked disposal areas were considered in detail by the Corps  of
          Engineers (CE, 1976), however, this alternative was later found to
          be economically and env-ironmentally unacceptable for the disposal
          of dredged material from the construction phase of the Tampa
          Harbor Project (see response to Comment 5-4).

19-1      Acknowledged.                      >

20-1      Hard bottom areas in this region occur only in scattered patchy
          distributions.  As a result, it is difficult, if not impossible,
          to avoid all hard bottom areas.  Those outcroppings with
          substantial  relief offer a more diverse and productive habitat to
          benthic organisms.  It is highly unlikely that dredged material
          will drift back into the Tampa Bay channel entrance in any
          si-gnificant amount.

20-2      Disposal operations at Site A have been terminated.

20-3      Depending on the composition of the dredged material as well as
          physical oceanographic conditions, suspended particulate levels
          could be expected to decline rapidly within hours, with the
          turbidity levels returning to ambient concentrations within  24-36
          hours.

20-4      The short-term avoidance referred to is over a matter of hours,
          or, at most days, thus it would not affect the seasonal migrations
          of the cited teleosts.

20-5      The turbidity plume would have temporary, localized adverse
          effects on any sport diving in the immediate area of disposal.

20-6      Commercial finfishing for pelagic species exists seaward of  Sites
          A and B and the Shallow-Water Alternative Sites.

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                                    -25-

20-7      There are no confirmed reports that Site 4 is a good shrimping
          area, nor do any EPA or Corps survey results indicate that this is
          the case (see response to Comment 5-14).

20-8      A monitoring program will be instituted at the completion of the
          site designation process and prior to initiation of disposal
          activities.  If serious adverse environmental effects are
          discovered, the Agency may terminate or limit the use of the
          site.

21-1      The Corps considered other alternatives to ocean disposal
          including upland and within Bay disposal (CE, 1976).  However,
          these alternatives were found to be economically and
          environmentally unacceptable (see response to Comment 5-4).  The
          Environmental Protection Agency is responsible for designation of
          ocean disposal  sites under the five general and eleven specific
          criteria of the Ocean Dumping Regulations  (40 CFR §220-229).

21-2      Dredged material disposal has been discontinued at Site A.
          Disposal at Site 4 is not expected to cause unacceptable adverse
          environmental effects, although temporary  impacts will occur
          during disposal operations.

21-3      Impacts from disposal of maintenance dredged material are not
          expected to cause unacceptable adverse environmental effects.  The
          volume of maintenance operations is less than the initial
          construction operations.  Most impacts are expected to be of short
          duration, and to not extend beyond the site boundaries.

21-4      The value of the site area to the diving industry is judged to be
          minimal (see response to Comment 5-14).

21-5      The U.S. Coast  Guard monitors disposal activities to prevent this
          illegal form of dumping which may result in a fine to the parties
          involved.  Persons with knowledge of short-dumping incidents
          should report such events to their local Coast Guard District.

21-6      Upland disposal alternatives were considered in detail by the
          Corps of Engineers (CE, 1976), but were found to be economically
          unacceptable (see response to Comment 5-4).  Significant economic
          losses in fisheries or in recreational uses are not expected to
          occur (see response to Comment 5-14).  Diked disposal areas were
          considered in detail  by the Corps of Engineers (CE, 1976), but
          were later found to be economically and environmentally
          unacceptable for disposal of dredged material from the
          construction phase of the Tampa Harbor Project (see response to
          Comment 5-4).

21-7      The February, March, and April 1983 intensive surveys by EPA
          provide adequate baseline data to evaluate projected impacts of
          dredged material disposal.  The Corps of Engineers is currently
          conducting an on-site current measurement study, expected to be
          completed by November 1983, to provide additional baseline data.

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                                    -26-

22-1.     The DEIS follows the five general and eleven specific  criteria
          found at 40 CFR §228.5 and §228.6 for management of  ocean disposal
          sites.  40 CFR §227.15 applies to permit applications  for ocean
          dumping, which must be reviewed  by the Corps of Engineers in
          approving disposal projects.  Section 227.15 does not  require a
          cost-benefit  ratio study.

22-2      Additional surveys conducted during February, March, and April
          1983 establish that hard bottom  accounts for less than  17% of the
          site and less than 1% is densely populated.  The DEIS  does not
          state that Site 4 is covered entirely by a sandy bottom.

22-3      Drift of dredged material is not expected to extend  beyond the
          boundaries of the site (see response to Comment 9-10).

22-4      Dispersal of  dumped sediments is not expected to cause
          unacceptable  adverse environmental impacts to nearby artificial
          reefs or wrecks because of their distance from the proposed site.
          It is incorrect to conclude from the statement that  "Site 4 will
          provide a large sandy bottom area" that-Site 4 is entirely covered
          with sandy bottom.  Less than 17% of the site is hard  bottom;
          thus, approximately 83% is soft  bottom.

22-5      The thin layer of sediment is expected to disperse vrtth time,
          causing no unacceptable long-term adverse environmental effects.
          Further, evidence collected during the February, March, and April
          1983 EPA surveys indicates that  siltation noted in the  offshore
          areas may be  largely of natural  origin, because of the  uniformity
          of sediment distribution throughout the study area.

22-6      Flushing patterns- and predominant bottom characteristics off the
          west coast of Florida are similar to cited areas where  studies
          have been conducted; thus, it is acceptable to compare  this area
          with these areas.

22-7      Less than 17% of the bottom on Site 4 is estimated to  have hard-
          bottom habitat, and less than 1% is densely populated;  the site
          has less hard bottom habitat than any other area surveyed in the
          Tampa Bay area (see response to  Comment 3-2).

22-8      The parameters established for elutriate testing to  determine the
          amount of trace contaminants released by the dredged material
          disposal are  found at 40 CFR 227.13 and 227.27.

22-9      Turbidity resulting from disposal operations is expected to be of
          short duration, and not long enough to cause unacceptable adverse
          environmental effects to the loggerhead turtle's feeding or
          breeding habits.

22-10     Permit conditions can be stipulated to prevent unacceptable
          adverse environmental effects.   These conditions include, but are

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                                    -27-

          not limited to, designation of the disposal site, limitations on
          time and rate of disposal, disposal site monitoring, designation
          of release zones, limited site designation, or termination of
          designation.

22-11     Complete bathymetric studies were done in the February, March, and
          April 1983 EPA surveys.  The monitoring program will be
          sufficiently detailed to determine if unacceptable adverse
          environmental effects are being caused by dredged material
          disposal.

23-1      EPA thanks the Corps of Engineers for its concurrence with the
          recommendation of an ocean dredged material disposal site at
          center coordinates 27° 31' 27"N, 83° 04' 54"W (Site 4).

24-1      EPA thanks the National Oceanic and Atmospheric Administration for
          their comments and helpful information.  The information in the
          DEIS on whales and turtles has been revised, based on NOAA's
          suggestions.  Consultation with NOAA, pursuant to Section 7 of the
          Endangered Species Act has been accomplished.

25-1      Dredged material disposal at Site A was discontinued December 24,
          1982.

25-2      EPA believes that sufficient opportunity has been provided for
          public response to the site designation.

25-3      The Corps  of Engineers considered in detail non-ocean dredged
          material disposal (CE, 1976), but later found these alternatives
          to be economically and environmentally unacceptable for disposal
          of dredged material  from the construction phase of the Tampa
          Harbor Project (see response to Comment 5-4).

25-4      The proposed action is not expected to have unacceptable adverse
          environmental impacts to the marine environment.  The proposed
          action will have a beneficial effect on the economy of the region
          (FEIS, 1983).

25-5      Dredged material disposal at Site A was discontinued on
          December 24, 1982.

25-6      According  to information available, the proposed action will have
          no significant effect on recreational  activities of the region nor
          commercial fishing (see response to Comment 5-14).

25-7      Impacts on migratory fish are expected to be minimal, because fish
          will avoid temporary turbidity caused by disposal operations.

25-8      The many studies conducted in the Site 4 vicinity, and in
          particular, the February, March, and April  1983 EPA surveys, have
          provided considerable information on the environmental  features of
          this area.

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                                    -28-

25-9      A monitoring program will be established for Site 4 to detect
          significant adverse environmental impacts.  Should unacceptable
          adverse environmental effects be noted, EPA will move to halt
          disposal operations.

26-1      Intensive surveys were conducted by EPA during February, March,
          and April 1983 to augment the preliminary surveys.

26-2      Designation of a release point within the site may be specified  in
          the site designation.  Consequently, the Gunsmoke wreck may be one
          to two miles from actual dumping operations, and as much as three
          miles.  No unacceptable adverse environmental effects are expected
          at these distances.

26-3      Non-ocean disposal was considered in detail by the Corps of
          Engineers, but were found to be economically and environmentally
          unacceptable for disposal of dredged material from the
          construction phase of the Tampa Harbor Project (see response to
          Comment 5-4).  The potential impacts of ocean disposal, are
          presented in the DEIS, Chapter 4, "Environmental Consequences."
          (See also response to Comment 9-10.)

26-4      The use of diked disposal areas were considered in detail by the
          Corps of Engineers (CE, 1976), but was later found to be
          economically and environmentally unacceptable for disposal of
          dredged material from the construction phase of the Tampa Harbor
          Project (see response to Comment 5-4).

26-5      EPA believes that sufficient opportunity has been provided for
          public comment on the site designation.

27-1      Transmittal of Clearinghouse Review.  Identical to responses to
          Comments 9-1 through 10-55, above.

28-1      Intensive surveys conducted by EPA during February, March, and
          April 1983 included water column sampling, sediment samples (for
          infauna, grain size analysis, and trace metals), trawls (for fish
          tissue analyses), extensive video camera observations of the
          bottom, and side-scan sonar tracings.  These surveys provide
          adequate baseline data for evaluation of environmental impacts.

28-2      According to the Corps of Engineers, mid-Shelf and deepwater sites
          would not be economically feasible, due to increased
          transportation costs.  Site 3 has been judged environmentally
          unacceptable for dredged material disposal, due to the presence of
          hard-bottom areas.

28-3      Intensive surveys conducted during February, March, and April  1983
          provides sufficient evidence for designation of Site 4.  Less than
          17% is hard-bottom, and less than 1% is densely populated.

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                                    -29-

28-4      Construction of diked dredged material disposal islands could
          better be described as "a non-ocean alternative"  (see  response  to
          Comment 5-4).

28-5      The additional  studies conducted at Site 4 and vicinity by  EPA
          during February, March, and April 1983, provides  data  needed for
          designation of Site 4.

28-6      The video camera observations conducted in February, March, and
          April 1983 by EPA were transects 1/4 mile apart in both northwest
          to southeast and southwest to northeast directions.  The method
          enabled detection of any significant areas of hard bottom
          communities.  It was found that less than 17% of  Site  4 was hard
          bottom, with less than 1% densely populated.

28-7      The dissolved oxygen data for the previously designated site and
          the proposed site are not directly comparable.  The percent
          saturation of dissolved oxygen depends on the ambient  temperature.
          Therefore, the time of year and depth a sample is taken are
          important factors in evaluating dissolved oxygen  data.  The data
          presented, however, does provide baseline data on the  Tampa Bay
          area.

28-8      A stress reaction or death may have a greater environmental
          consequence to the surrounding benthic community  than  the loss  of
          the organism in question.  Loss of individual organisms is  often
          naturally high, but stresses or deaths which exceed the natural
          fecundity of a species may lead to a decline in the population.
          In the complex interrelationship of marine organisms, .decline in
          one species may lead to a decline or an increase  in a  competing
          species.  This relationship can be partly seen in the  simplified
          food web with potential adverse impact from dredged material
          disposal, presented in Figure 4-1 of the DEIS, p. 4-15.

28-9      The surveys conducted during February, March, and April 1983, have
          provided sufficient information to recommend the  designation of
          Site 4 as an ocean dredged material  disposal site (see response to
          Comment 9-10).

29-1      EPA thanks the State of Florida Department of Natural  Resources
          for the site-specific dive reports provided.  The June 4, 1981,
          dive survey by Japp and Lowery supports the conclusion that
          impacts from disposal operations will cause negligible adverse
          effects outside'the actual site.  No visible evidence  of impact
          was observed beyond 1 km inshore of a disposal site.

30-1      Transmittal of Clearinghouse Review.  See response to  Comment
          10-26, above.

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