Ms. Janice L. Hatter, Director
Florida State Clearinghouse
Executive Office of the Governor
Office of Planning and Budgeting
The Capitol
Tallahassee, Florida 32399-0001

RE: SAI FL9401120009C, St. Lucie County, Ft. Pierce Harbor General Re-evaluation Report and Supplement to the Final Environmental Impact Statement


Dear Ms. Batter:


The Office of Environmental Services of the Florida Came and Fresh Water Fish Commission (GFC) has reviewed the referenced document, and offers the following comments.

'The U.S. Army Corps of Engineers (COE) proposes an expansion of the ,access channel and turning basin at Fort Pierce Harbor including: deepening and widening the entrance channel from 27 feet to 30 feet deep and from 350 feet to 400 feet wide, deepening and widening the interior channel from 25 feet to 28 feet deep and from 200 feet to 250 feet wide, expanding the turning basin from 900 feet to 1,100 feet wide at a depth of 28 feet, and constructing a new channel measuring 250 feet by 400 feet and 28 feet deep north of the expanded turning basin. Following completion of the COE project, the St. Lucie County Port and Airport Authority plans to construction two new berthing areas adjacent to the expanded turning basin.

The Indian River Lagoon, an Estuary of National Significance, has been documented to have the greatest diversity of marine life of any estuary in North America. Within the lagoon. the greatest biological diversity is in the vicinity of Fort Pierce inlet where temperate and sub-tropical faunas overlap, productive estuarine habitats are in abundance, and the inlet access to the Atlantic Ocean provides critically important conduit for organisms whose life history involves utilization of both estuarine and oceanic systems. The lagoon area that is influenced by tides from Fort Pierce Inlet extends roughly north to Vero Beach and south to Jensen Beach. This segment of the lagoon is characterized by above-average water quality; mostly undeveloped shores lined with mangroves and salt marshes; abundant seagrass beds; several colonial waterbird 'rookeries; habitat utilized by 20 species classified as , endangered, threatened, or of special concern; and an extremely valuable sports fishery. The entire lagoon is a Surface Water Improvement Program priority waterbody, lagoon waters immediately north and south of Fort Pierce harbor are within the Indian River Aquatic Preserve, and the north side of the channel is bounded by Fort Pierce Inlet State Recreation Area.

After review of the General Re-evaluation report (GPR) and supplement to the final Environmental Impact Statement (EIS), we concur with the conclusions and recommendations of the U.S. Fish and Wildlife Services (USFWS) Revised Draft Fish and Wildlife Coordination Report (December 1993) included as EIS Appendix A. Our specific concerns are as follows:

1.  The proposed expansion plan would result in the loss of approximately 14 acres of rock ledge habitat that has been documented to be an important nursery area for the Florida lobster. It also provides habitat for a' number of important commercial and sport fishes including, but not limited to, snook, spotted seatrout, silver seatrout, red drum, striped and white mullet, bluefish, and several species of grouper and snapper. The COE is only proposing to create two acres of rock ledge habitat as mitigation for this impact, stating that the new channel edges will provide the same functions as the existing edge in five to ten years. As documented in the USFWS report, there is a considerable difference of opinion. as to how long it will take the channel edges to recolonize, or even if the new channel edges will have a similar profile as the old. Given the biodiversity of the existing channel edges and importance to regional fishery resources, we believe that even the most optimistic scenario (five years to reestablish similar ledge communities) would result in an unacceptable loss to these resources.

2.  Expansion of the berthing areas would result in the loss of approximately 0.71 acres of seagrasses, including Halophila Johnsonii, which is proposed for listing as a threatened species by the National Marine Fisheries Service under the Endangered Species Act. Although the COE has modified the federal project to eliminate the berthing areas, they are still proposed to be expanded by the local sponsor, and this expansion is entirely dependent on the proposed channel and turning basin improvements. In addition, we believe that turbidity resulting from dredging the turning basin and channels would have an adverse impact on these and, possibly, on other nearby seagrass beds. Therefore, we entirely concur with the USFWS that the berthing area expansion should be included as an integral part of the Federal Project assessment and riot as a separated dredge and fill project.

3.  Finally, we do not 'believe that the No Action Alternative and No Widening Alternative have been adequately evaluated in the context of the environmental sensitivity of the Ft. Pierce Harbor area and surrounding Indian River Lagoon. Our concern is that this project has the potential to impact fish and wildlife resources not only within the actual construction sites. but also over a much greater area in the vicinity of Fort Pierce Inlet. Within one mile of Fort Pierce Harbor and channel are 350 to 400 acres of highly productive seagrass beds. in' addition to the well-documented value of seagrasses as fishery habitat, these near-inlet seagrasses provide an important nursery ground for various groupers. snappers, grunts, and other fishes that return to oceanic waters as adults. In addition, the grass beds are extensively utilized 'by West Indian manatees (endangered) and a wide variety of aquatic-oriented birds.

    The most serious aspect of this project involves the potential secondary impacts to due to water quality degradation from expanded port operations. The increase in ship traffic would likely increase turbidity, wake damage, fuel spills, bilge discharges, and other port- related water quality degradation in an area of rich fish and wildlife resources. Other secondary impacts could result from the increase in water volume passing through the inlet. Turbidity and other port- generated pollutants could be carried further into 'the Indian River Lagoon, and greater volumes of beach sand would be transported into the lagoon, potentially shoaling over seagrass beds. Changes in tidal amplitude could impact intertidal communities such as seagrass beds, mangroves, and saltmarshes.

We believe that all these impacts need to be taken into account in the analysis of the cost/benefit ratio of this project. The proximity of other deep water port facilities to-Ft. Pierce, including Canaveral Harbor (70 miles north), Palm Beach Harbor (50 miles south), and Port Everglades (90 miles south) -need to be given greater analysis along with the recent southern shift in citrus production to southwest Florida.

In conclusion, we continue to believe that the Indian River Lagoon is not an appropriate place for a major port, and we recommend against the implementation of the Ft. Pierce Harbor expansion.

                                                                                                                        Sincerely,