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Health & Fitness

Why You Should Oppose the Proposed Army Corps 50-year Shoreline Protection Program. Part 3.

More reasons why you should oppose ACOE proposed 50-yr beach protection program. Describes reasons ACOE conclusions of "No Impacts" are wrong & shows inaccuracies and errors in ACOE calculations.

Last week, the Encinitas Patch posted an article describing discussions during Wednesday’s Encinitas City Council Meeting regarding the 50-year coastal storm protection program proposed by the U. S. Army Corps of Engineers (City Council Moves Forward with Portion of Beach Sand Project).  I believe the information imparted in this article needed clarification and expansion.

As I understand it, this is the second “contribution” made by Encinitas and Solana Beach this year.  The first, nearly $100,000, was approved by the City Council as part of the Consent Calendar a couple of months ago.  According to city staff, that money was needed so the Corps could proceed with responding to comments from the public and various agencies.  That task has not been completed.  It’s not clear to me what these funds ($147,000) are supposed to accomplish.  In any event, the cities will be reimbursed for most of these funds by the State Dep’t of Boating and Waterways – they are pass-through expenditures.

I wish to address a major point raised during public comments, that is, the major inaccuracies, inconsistencies, and misrepresentations in the Corps EIS/EIR, esp. with regard to environmental issues and the Cost: Benefit Analyses resulting from the faulty conclusions that the dredging programs required to put sand on the beach will have no significant impact. 

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First off, the closest borrow site, 44 acres, is within the boundaries of the recently created Swami’s Marine Protected Area, where no dredging was supposed to be allowed.  Somehow, the Corps obtained a waiver on this restriction.  This will jeopardize the viability of the MPA system in southern California because the two adjacent MPAs (Dana Point and Scripps, La Jolla) are too far apart to interact properly with this large disruption in the middle.  This is most certainly a significant impact.

Second, with a design depth of 20 feet below the existing seafloor level, the basins dredged in the borrow sites will not recover for decades following completion of the 50 year program.  The borrow sites are located farther offshore than the zone in which sand is transported along the shore (the littoral drift zone) and so it is very unclear how long it will take before those basins can be refilled to a level where the natural native fauna can thrive.  Because water circulation in these basins will be much reduced, it is likely that ≈170 acres (44 acres in the MPA) of sediments in the local borrow sites (off San Elijo and San Dieguito Lagoons) of seafloor will become anaerobic (anoxic) and be rendered unproductive.  This translates directly to a loss in fisheries productivity because the animals living in these sediments are important as food for a number of important fisheries stocks, for example, halibut, lobsters, and crabs.  Moreover, because of the proximity of these sites to the mouths of the lagoons, which export great quantities of organic materials that are used as food by the animals living in the sediments, it is likely these sites are high-value habitats compared to sites that are farther removed from the lagoons.

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This badly flawed document and project have many inaccuracies (e.g., up to three different sets of numbers for several of the statistics used in describing/justifying its decisions).  Because of these inconsistencies, it is not possible to know what the Corps is really proposing or whether the environmental data used to make the decisions actually came from the areas that will be affected.  I sent two sets of comments, totaling 28 detailed pages, to the Corps, regarding observed errors, inconsistencies, inaccuracies, and questionable assumptions.  It is one of the poorest EIS/EIRs I have ever read.  Moreover, the Corps has yet to respond to my comments.

More recently, based on some basic geometrical calculations, I am questioning the estimated design depths proposed by the ACOE (20 feet below current level of the seafloor) for two of the borrow sites.  My initial calculations indicate that, based on the cited area of the borrow sites and the estimated volume of sand available, they would need to dig substantially deeper than the 20 feet they are proposing.  For SO-6, off San Dieguito Lagoon, the indicated area of the borrow site is 124 acres and the estimated yield for sand is 7.8 million cu. yds.  To obtain the estimated volume produced within the boundaries of the borrow site, the depth of the “dig” would have to be 39 feet, not the indicated 20 feet (Depth = Volume/Area).  In the case of MB-1, supposedly capable of yielding 5.8 million cu. yds. from an area of 107 acres, the depth of the “dig would need to be ≈34 feet. 

If the Corps used only the two northern borrow sites, it would probably have to exceed the 20-foot design depth in both borrow sites.  If they dropped the borrow site in the Swami’s MPA, it would have to dig to 29 feet if they used only the Solana Beach borrow site.  As I pointed out, if they have to resort to using sand from Mission Beach, the cost goes up dramatically, probably tilting the Cost: Benefits Analysis to negative.

The conclusions in the EIS/EIR of “No Impacts”, “No Significant Ecological Value”, and “Mitigation Not Required” for the ecosystems in the borrow sites also have a considerable impact on the Cost: Benefit Analyses, skewing them from negative to barely positive.  Moreover, with a quick-and-dirty survey of sand placed on Moonlight Beach during last winter’s beach nourishment project, we have shown the approach used to assess potential impacts and recovery and conclude “No Impacts” is incorrect.

I realize that most citizens have a hard to identifying with such hard-to-see injuries – “Out of sight, out of mind!!”, so to speak.  However, these are only a couple of many issues the Corps has swept under the rug in this poorly crafted, very inaccurate, and inconsistent document.  In addition to limited beach nourishment, we should be considering seawalls, a number of “soft” coastal engineering approaches to protecting private and public properties and facilities in the long term, re-aligning Pacific Coast Highway, and special assessment districts.  Nevertheless, the Corps has chosen to refuse to consider any alternatives except those proposed in the Draft EIS/EIR.  As currently proposed, this $170 - $200 million Band-Aid project fixes nothing.  It will leave the cities of Encinitas and Solana Beach in the same condition in 50 years, or worse, considering rising sea level, after spending between all that money that could have been used on solutions, and that is unacceptable.

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