Colonel Terry Rice
District Engineer, Jacksonville District
Department of the Army, Corps of Engineers
P.O. Box 4970
Jacksonville, Florida 32232-0019

Dear Colonel Rice

The National Marine Fisheries Service (NMFS) investigated concerns expressed by commercial
fishermen, recreational fishermen, and recreational sport divers regarding the dredging activities in
Ft. Pierce Harbor and Inlet. It has been reported to us that the impacts from dredging, sedimentation,
and turbidity may be substantial because important fisheries habitats may have been impacted.

The Ft. Pierce navigation study involves the widening and deepening of the inlet and deepening of
the turning basin. According to local sources, project dredging began about March of last year
(1995) extending perhaps into October 1995. Of the 815,000 cubic yards of material needing
disposal 590,000 cubic yards were to be dumped at the Environmental Protection Agency
designated offshore dredged material disposal site (ODMDS). The remaining material was to be
used for both beach nourishment and wetland creation or restoration activities. The NMFS's
concerns for the project are on record with the Corps of Engineers (COE) and are reflected in the
draft and final Fish and Wildlife Coordination Act Reports prepared for the Navigation Study for
Ft. Pierce Harbor, Florida - 10196, General Reevaluation Report and Supplement to the Final
Environmental Impact Statement (SEIS). To recap, we consistently recommended the no action
alternative, as did many other resource agencies. However, none of the Federal resource agencies,
including the NMFS, chose to exercise its option to elevate this project. We relied on the COE's
assurances in the SEIS that impacts to NMFS's trust resources would be minimal

It is the NMFS's understanding that Great Lakes Dredge and Dock (GLDD) was the contractor for
the Federal project dredging and perhaps the follow-up maintenance dredging. It was reported to
us that GLDD may have overfilled their hopper barges, causing turbidity problems, and may have
discharged dredged material outside the ODMDS (short-dumping). Several fishermen we contacted
witnessed the short-dumping by the GLDD vessel SUGAR ISLAND. According to these fishermen,
short-dumping occurred just offshore of the sea buoy, and about one mile offshore of the inlet. We
also learned that a Florida Marine Patrol (FMP) officer may have video taped the short dumping and
has Loran and/or GPS coordinates. The FMP office in Jupiter could be contacted by the COE to
confirm this information, if needed.

Of additional concern to the NMFS is the possibility that the fine silt and clay material dredged from
the Ft. Pierce Harbor turning basin is now migrating from wherever it was disposed of by the
contractor. Sediment migration was described as a possible adverse environmental impact within
the ODMDS in the COE's SEIS and in an environmental survey conducted by the Harbor Branch
Oceanographic Institution under contract to the St. Lucie County Port and Airport Authorltv for a
port expansion project. It is our concern that the adverse environmental impacts associated with
sediment migration out of the ODMDS may have been greatly underestimated. Several concerned
individuals have contacted the NMFS regarding this possibility. Below are accounts we have
received and documented. We submit them to the COE, for consideration.

Dwight Blackwelder, a commercial fisherman who dives for crawfish, has observed a "pudding" like
material covering Oculin sp. banks, worm reefs, and rock ledges. His observations are supported
by several others who are discussed below. Mr. Blackwelder has lived in the Ft. Pierce area for more
than 30 years. He claims the material is burying ledges and reefs and filling crevices that both
crawfish and other ground fish use as habitat. The phenomenon has been slow to develop beginning
about early summer (June). Since the material arrived, crawfish have virtually disappeared from
areas affected by the material. He describes the area of influence as being from St. Lucie Inlet north
to Bethel Shoal, but the coverage is not uniform. Mr. Blackwelder provided names of other
individuals ir, Ft. Pierce that have also observed this phenomenon.

Dan Nelson is a local citrus grove owner who regularly dives outside of Ft. Pierce inlet. He
confirmed many of the observations of Mr. Blackwelder. The material being observed occurs at
many depths, but seems to be concentrated at the 50- to 60-foot contour and at reefs that lie in an
east-west orientation. These observations would support hypotheses of longshore drift transport or
a northerly current transport of dredged material. Both longshore drift and northerly currents are
typical in the area. Mr. Nelson has observed that the material is up to three feet deep on east-west
oriented reefs. North-south oriented reefs may have the material on them as well, but it is much less
pronounced. Additionally, visibility in areas where the material occurs is typically very poor and
often zero.

David King is a charter captain who takes out bottom fishermen. His target species are primarily,
snapper and grouper. He is considered one of the best bottom fishermen in the area. Mr. King
observed a muddy line of water moving north begining about June. The line of muddy water
progressed steadily north throughout the summer. The impacts on his fishing were dramatic. His
target species, as well as typical bycatch such as grunts and vermillion snapper which are commonly
used as bait, disappeared from the muddy waters. Other baitfish such as Spanish sardines and cigar
minnows also have disappeared. These types of baitfish are regularly caught at the Ft. Pierce whistle
buoy. Occasionally fish that were caught had visible mud on their gills that could be removed by
one's finger. Migratory fish such as king mackerel are still taken, but resident species are mostly
absent. Mr. King stated that he has compared this year's catch with last year's as recorded in his
logbook or calendar. He has caught no fish in the last two months. From Mr. King's point of view,
this situation is financially disastrous.

Other observations also were made by Mr. King. Water visibility in the Ft. Pierce fishing grounds
is usually good during late summer early fall. One can see the bottom for up to three months. The
bottom has been visible maybe two days this season. Water temperature is about three degrees
cooler this year. Yellowtail snappers usually begin a northerly migration into the Ft. Pierce area in
August. This "bread and butter" catch have simply not shown up this year. Recreational and
commercial fishing in areas 30 miles in either direction of Ft. Pierce have no similar effects. Mr.
King's last observations are related to increased shoaling in the Intracoastal waterway near the Ft.
Pierce turning basin and offshore of the sea buoy. Depths in the Intracoastal waterway are less that
12 feet near the Ft. Pierce Harbor turning basin. Likewise, new shoal areas have appeared southeast
of the sea buoy. These observations may relate to either improper dredging or short dumping by the
COE's contractors.

Dr. John Reed, a research scientist with 20 years of experience at Harbor Branch, has published
numerous scientific papers on various topics in the Ft. Pierce area. Dr. Reed decided to investigate
the reports of local fishermen regarding the reefs being smothered by sediments. He dove several
sites on Saturday, September 21, 1996. His observations are similar to those of Dan Nelson above.
He observed a gray-black mud accumulated on various reefs at various depths. The mud veneer was
typically 6 inches to 1 foot thick on reefs oriented in an east-west direction. In some locations, at
60 feet deep, the bottom is covered by pure mud up to "elbow deep" down to the rock pavement.
Dr. Reed collected and examined samples from several locations including the ODMDS, offshore
sites, the inlet, and the turning basin. Particles are in the fine silt to clay range. He observed no
planktonic tests or foraminifera which might support an up-welling source. (Note: A green clay and
mud exists offshore of Ft. Pierce in depths greater than 1000 feet that has planktonic tests and
foraminifers). Dr. Reed intends to hold onto the samples for further analyses. His preliminary
conclusion based on the above observations is that the material covering the reefs is very similar in
appearance and character to the turning basin silt and clay. The source of the material cannot be
definitively determined without more detailed study.

None of the resource agencies, including the NMFS, anticipated such dramatic impacts to fishery
resources such as those reported above. In fact, the COE's final SEIS indicated that impacts to
fishery resources from the selected alternative would be temporary and that differences to
commercial and recreational fish populations would not likely be detected. To the contrary,
however, it appears that fishery habitat and Ft. Pierce commercial and recreational fishermen, and
divers have been harmed by activities associated with the subject project. Accordingly, we ask that
the COE investigate this action. If it is found that NMFS's trust resources have been damaged,
remedial measures should be developed. In any case we would appreciate being informed as to the
results of your investigation.