F9 to update TOC!

[Appendix A1 Construct Artificial Reefs and Fishing Access Improvements
A1-1](#construct-artificial-reefs-and-fishing-access-improvements)

[A1.1 Goals and Nexus to Injury A1-1](#goals-and-nexus-to-injury)

[A1.2 Background A1-1](#background)

[A1.2.1 Relevant Models for Reefs That Would Meet MSRP Restoration
Objectives
A1-2](#relevant-models-for-reefs-that-would-meet-msrp-restoration-objectives)

[A1.2.2 Designing for Sustainability
A1-4](#designing-for-sustainability)

[A1.3 Project Description and Methods
A1-5](#project-description-and-methods)

[A1.3.1 Reef Development A1-7](#reef-development)

[A1.3.2 Fishing Access Improvements A1-12](#fishing-access-improvements)

[A1.4 Environmental Benefits and Impacts
A1-12](#environmental-benefits-and-impacts)

[A1.4.1 Biological A1-13](#biological)

[A1.4.2 Physical A1-14](#physical)

[A1.4.3 Human Use A1-14](#human-use)

[A1.5 Likelihood of Success/Feasibility
A1-15](#likelihood-of-successfeasibility)

[A1.6 Performance Criteria and Monitoring
A1-16](#performance-criteria-and-monitoring)

[A1.7 Evaluation A1-16](#evaluation)

[A1.8 Budget A1-17](#budget)

Figures

A1-1 Artificial reefs in the Southern California Bight

A1-2 Fish assemblage adjacent to the Los Angeles Breakwater

A1-3 DDT in fish fillet between Malibu and Dana Point

A1-4 Potential zones for deployment of artificial reefs

Appendix A1

Construct Artificial Reefs and Fishing Access Improvements

## Construct Artificial Reefs and Fishing Access Improvements

### Goals and Nexus to Injury

As a result of the historical releases of DDTs and PCBs by the Montrose
defendants, several species of fish, particularly those associated with
soft sediments, in certain coastal areas continue to accumulate levels
of contamination that make it advisable for people to avoid or limit
their consumption. The goal of constructing artificial reefs and fishing
access improvements is to restore lost fishing services by changing the
species composition of fish in selected fishing areas. In this appendix,
we categorize fish species based on the habitats with which they are
most commonly associated. The term "bottom" is commonly used to describe
the substratum. Thus, soft-bottom fishes are those that are commonly
associated with sand or mud substrata, and hard-bottom fishes are those
that are commonly associated with reef or rocky substrata. An additional
category of fish, water-column-feeding fish, refers to pelagic fishes
that feed on prey that is suspended in the water column (e.g., pelagic
zooplankton).

The premise of this restoration action is that fish, particularly white
croaker, that are associated with soft-bottom habitats feed on benthic
organisms from the contaminated sediments and are consequently the most
highly contaminated species. In contrast, fish associated with
hard-bottom or pelagic habitats feed on organisms that are either living
in the water column or attached to hard substrate and are consequently
less contaminated. This premise is supported both by (1) data collected
by the Los Angeles County Sanitation Districts, which demonstrate a
repeated pattern of lower contamination levels in kelp bass and black
surfperch relative to white croaker, and (2) the current fish
consumption advisories, which are broader and more restrictive for white
croaker than for hard-bottom species.

The construction of a reef is likely to change the types of fish in an
area because soft-bottom species do not typically inhabit reef habitats
(Allen 1999). The primary benefit of these projects will be to displace
these highly contaminated, soft-bottom fishes with water-column-feeding
and hard-bottom species, which tend to be lower in contamination.
Building reefs will also provide ecosystem benefits by increasing the
production of fish whose tissues contain lower concentrations of
contaminants (Dixon and Schroeter 1998). Reef construction may be
complemented at some sites by improvements to fishing access (e.g.,
piers or other amenities) to promote the use of the enhanced fishing
sites, to heighten awareness of how habitat affects the concentration of
contaminants in different species of fish, and to provide compensatory
restoration for past losses in fishing opportunities due to limitations
imposed by fish consumption advisories.

Both elements of this restoration action (using artificial reefs to
replace contaminated soft-bottom fishes with hard-bottom species and
constructing improved public access to such sites) have a strong
relationship to the lost fishing services of the Montrose case and act
as both primary and compensatory restoration of lost fishing
opportunities. The reef element also addresses the objective of
restoring fish and the habitats on which they depend.

### Background

Artificial reefs have been employed extensively throughout the world,
including California coastal waters, as a means to improve fishing,
diversify fish communities, and increase productivity. Artificial reefs
may be broadly classified according to their fundamental purposes:
fishing reefs and fish production reefs. A fishing reef (sometimes
referred to as a Fish Aggregation Device \[FAD\]) typically provides
little or no fish production value itself, functioning instead to
aggregate certain species for the purpose of recreational or commercial
catch. A production reef is constructed to promote settlement, growth,
and survival of resident reef species over a long time frame for the
purpose of increasing fish production. It is also possible to design
projects that incorporate both elements, for instance by placing fishing
reefs in proximity to production reefs or by restricting fishing to a
limited portion of a reef that is sufficiently large to allow the
remaining areas to function undisturbed as production sites and to
sustain the fishing portion. Natural reef habitats act both to aggregate
and to produce fish.

The California Department of Fish and Game (CDFG) administers the
California Artificial Reef Program (California Fish and Game Code
Sections 6420--6425), which has a long history of designing and
constructing artificial reefs for purposes of increasing local
production and abundance of fishes that are targeted by recreational
anglers. To date, approximately 30 artificial reefs have been
constructed involving over 100 modules and a broad range of designs and
goals (Figure A1-1). Although some reefs in California have been called
"fishing or fishing opportunity reefs," the California definition of
artificial reef requires that fishing reefs be designed and constructed
to function as habitat that supports a productive and sustainable marine
community typical of natural reef habitats rather than simply
functioning as a FAD. This approach has generated a large amount of
information regarding species composition, community succession, and
productivity for artificial reefs (Ambrose 2000, Dixon and Schroeter
1998).

The CDFG program has developed a specific definition of artificial reefs
that includes the contingency that they simulate natural reef habitats:

"Artificial reef" means manmade or natural objects intentionally placed
in selected areas of the marine environment to duplicate those
conditions that induce production of fish and invertebrates on natural
reefs and rough bottoms, and that stimulate the growth of kelp or other
mid-water plant life which creates natural habitat for those species.
(California Fish and Game Code Section 6421a)

Additional information on reef productivity and community structure has
been generated in the past two decades by construction of a series of
"developmental" reefs specifically designed to evaluate and compare how
various design elements affect biological productivity and community
structure. Developmental reefs have been built at Pendleton, Pitas
Point, Santa Monica Bay, Marina Del Rey #2, Oceanside #2, Pacific Beach,
Carlsbad, and Topanga. These developmental reefs generally consist of a
series of rock modules with different rock sizes, relief profiles, and
depths in paired replicates. The California Fish and Game Code states
that "production" reefs would ultimately be built based on the
information gained from the study of these "developmental" reefs
(California Fish and Game Code Section 6420). However, due to cuts in
funding for the CDFG artificial reef program, the intended studies of
the existing developmental reef sites have not occurred (Parker, pers.
comm., 2004).

#### Relevant Models for Reefs That Would Meet MSRP Restoration Objectives

Increasingly, artificial reefs have been constructed to replace or
mitigate for aquatic resources impacted by human activities (Ambrose
1994). Mitigation reefs have been constructed in recent years at several
sites within the Southern California Bight, including Bolsa Chica, Long
Beach Harbor, near the Angels Gate entrance to Los Angeles Harbor, in
San Diego Bay, and offshore of Camp Pendleton. To mitigate for impacts
to a kelp forest caused by releases of warm water by the San Onofre
Nuclear Generating Station (SONGS), the utilities that operate SONGS are
currently developing near San Clemente what may eventually be the
largest mitigation reef in the United States (SCE 2004).

The study design and findings of the SONGS[^1] reef pilot program are
particularly relevant to the development of a reef construction program
for the Montrose Settlements Restoration Program (MSRP). Although the
primary goal of the SONGS reef program is to replace lost kelp forest

![](media/image1.png){width="6.495833333333334in"
height="4.784722222222222in"}

Figure A1-1. Artificial reefs in the Southern California Bight.

habitat, the changes in fish community structure that occur would be
relevant to the MSRP goal of providing cleaner fish for anglers. The
utilities operating SONGS have developed a series of standards that the
constructed reef must meet to achieve the desired level of mitigation
and a 5-year pilot program to study how different reef designs perform
in achieving these standards.

After reviewing the findings of previous studies, the SONGS parties
designed and constructed an experimental modular reef system to
investigate the importance of substrate (quarry rock versus concrete)
and reef material coverage density (40 percent, 60 percent, and 80
percent) on kelp recruitment and growth as well as a more general
analysis of community structure. Other issues evaluated in the SONGS
pilot study will include the differences between high-relief and
low-relief reefs (i.e., the variations in the sizes of the materials
making up the reef), kelp out-planting versus natural recruitment, and
several other considerations.

The SONGS 5-year evaluation study is scheduled to end in 2005. The
Trustees will use the information generated by this and other
developmental reefs to optimize the design of new artificial reefs to
create a sustainable means for providing cleaner fish in the areas
impacted by the contamination associated with the Montrose case.

#### Designing for Sustainability

Artificial and natural reefs both attract fish and contribute to fish
production under the right conditions (Ambrose 1994, Dixon and Schroeter
1998). Reef-based production can be estimated using several models, but
most production estimates are based on estimating the standing stock on
the reef at one or more points in time (Dixon and Schroeter 1998). Such
estimates of changes in the overall biomass of fish do not differentiate
between new fish production (i.e., gonadal production) and recruitment
of fish from other areas (e.g., MEC Analytical Systems 1991).

For a constructed reef to add more fish to a total population, the fish
population must be limited by the availability of reef habitat (Dixon
and Schroeter 1998). Although it is uncertain whether fish populations
are limited by the availability of reef habitat in Southern California,
it is clear that reef habitat is rare relative to soft-bottom habitat
(Cross and Allen 1993). Relative scarcity does not prove habitat
limitation, but it is possible that building reefs will increase the
number of potential settlement sites for juvenile reef fishes. Given the
growing awareness that the settlement and early juvenile period is a
significant mortality bottleneck for many marine fishes (e.g., Bailey
and Houde 1989), particularly for reef-dwelling species (Victor 1986),
an increase in potential settlement sites may increase survival through
the early juvenile period.

The question of the relative importance of recruitment versus production
remains unanswered for most marine reef fishes and for both natural and
artificial reefs, but it is likely that both processes play a role
(Dixon and Schroeter 1998). For example, certain artificial reef
habitats in Southern California have supported self-sustaining
populations of fish over more than a decade (Pondella et al. 2002) and
have acted as a source of larval production that contributes
significantly to the larval supply in the Southern California Bight
(Stephens and Pondella 2002) However, the ability to confirm recruitment
versus production is typically complicated by the high level of
inter-annual variability in recruitment that occurs for most marine
fish, the multiple recruitment bottlenecks that are likely to exist
during early life history (e.g., first-feeding and settlement), and the
difficulty in measuring the abundance of early-stage juveniles.

Because the focus of an MSRP reef program is to provide cleaner fish to
anglers, the critical element is the degree to which the composition of
fish species at a fishing site changes in favor of those that are less
contaminated, rather than whether the reef increases the overall biomass
of fish available. Nevertheless, the question of how reefs affect fish
production is still relevant to this restoration effort, as the
construction of new reefs may lead to increased local fishing pressure
on fishing sites. This pressure could be addressed in a number of ways.
A sufficiently large reef could be constructed to be sustainable despite
the anticipated increase in fishing pressure. Alternatively, a reef
could be placed in proximity to existing reefs where fishing is
restricted or to Marine Protected Areas , thus incorporating into the
reef design a source of fish to replace those caught at the fishing reef
by anglers.

A fishing site enhancement program in Washington state provides one way
of increasing the sustainability of fishing on artificial reefs. In
1974, the Washington Department of Fisheries began a marine fish
enhancement program that involved building shore-based fishing
structures (i.e., piers) and construction of "habitat enhancement"
(reefs) around the structures to increase production/density of fish
around them (Buckley 1982). These projects found that fishing structures
that included habitat enhancement were much more productive and
sustainable than those that did not. Also, the design of the enhancement
was such that approximately 20 percent of the enhanced habitat was
available to anglers using the fishing structure. The remaining 80
percent of the enhanced habitat was established as "production" zones
and was protected against fishing from boats. This design resulted in
sustainable fishing over a 50- to 10-year evaluation period.

The Washington study described a successional pattern in community
structure where the reef community shifted from juveniles who appeared
to be seeding unoccupied habitats to adults that appeared to be more
resident. The conclusions of this study also suggested that the
continuing availability of fish for fishing from pier structures was
maximized via three mechanisms: (1) enhancement of the habitat
surrounding structure to increase aggregation/production of fish; (2)
episodic aggregation events producing periods of high catches; and (3)
the presence of local resident fish that maintained catches during
periods of low levels of aggregation. The third mechanism was promoted
and sustained largely because significant components of the resident
fish populations were protected from fishing.

Reefs can have substantial impacts on the local availability of fish
that are lower in contamination. Although species that occur on a
constructed reef are not the same as those that occur on soft-bottom
habitats, constructed reefs support a diverse and productive community,
and the species that occur on reefs perform many of the same ecological
roles as those that occupy soft-bottom habitats (Ambrose 1994). Also, in
a review of the literature pertaining to white croaker, Allen (1999)
found that this species is never associated with any hard-bottom
substrate, including natural or constructed reefs. Figure A1-2 is a
schematic showing the fish assemblage associated with the rocky habitats
adjacent to the Los Angeles breakwater (from Froeschke et al. 2005).

### Project Description and Methods

The construction of artificial reefs and fishing access improvements is
evaluated in this appendix at a non-site-specific, conceptual level for
the MSRP Restoration Plan and programmatic Environmental Impact
Statement/ Environmental Impact Report. The Trustees will further
develop and design the details of the program as described below during
the implementation phase of restoration and will prepare additional
environmental documentation pursuant to the National Environmental
Policy Act (NEPA) and the California Environmental Quality Act (CEQA)
prior to final site selection and construction for each reef project.

![](media/image2.png){width="6.541666666666667in" height="4.95in"}

(Source: Froeschke et al. 2005)

Figure A1-2. Fish assemblage adjacent to the Los Angeles breakwater.

The MSRP reef program will entail two types of activities. The first
activity will be the construction of reefs to increase the availability
of fish species that are lower in DDTs and PCBs. The second activity
will be to implement improvements to fishing access and amenities to
promote the use of the newly enhanced fishing sites, heighten awareness
of the reasons why reefs were built in the vicinity of the fishing
locations, and to act as compensatory restoration for past lost fishing
opportunities.

#### Reef Development

The development of the reef-building component will follow a five-step
sequence: (1) contaminant and angler use evaluation; (2) site selection;
(3) reef design; (4) reef construction; and (5) monitoring. This
sequence is likely to be iterative, with some or all steps being applied
to each constructed reef.

Step 1: Contaminant and Angler Use Evaluation

This step involves developing a detailed understanding of the spatial
and species-specific patterns of contamination in the fishes commonly
targeted by anglers in the Southern California Bight, and combining this
information with information on fishing practices and preferences at
different locations as obtained from surveys of anglers. This analysis
will be guided by sediment contamination levels, as these levels will be
the determiners of local resuspension of contaminants during reef
construction and local bioaccumulation levels in the residents of the
constructed reef.

The results of the fish contamination survey and the angler survey will
be entered into a geographical information system (GIS) database to
facilitate analysis and to generate a first-level evaluation of
potential sites for reef construction. The fish contamination data will
come primarily from the contaminant survey that MSRP is currently
conducting in collaboration with the EPA; results are expected late in
2005. These results, coupled with those from the angler surveys that the
State of California is conducting as part of the Marine Recreational
Fishing Statistical Survey (MRFSS)[^2] as well as those conducted by the
Trustees and EPA in 2002 and 2003, will identify areas where high levels
of angler activity are coupled with a large disparity between
contamination levels in soft-bottom versus hard-bottom fishes.

Although detailed data identifying differences in contamination levels
among species and locations are not yet available to conduct this
analysis, evaluations of previous contaminant data (Figure A1-3) have
been used to provide initial indications of likely regions for
deployment of artificial reefs (Figure A1-4). Figure A1-3 displays
historical data showing levels of contamination in three species of fish
commonly collected in the Southern California Bight. At the time of
these surveys, white croaker were contaminated above the State of
California trigger levels (screening but non-regulatory concentrations
of potential concern are indicated by the reference line in Figure A1-3)
over a much broader geographic range than the other two species. These
earlier data suggest reefs constructed in areas adjacent to the Palos
Verdes Shelf may achieve MSRP restoration objectives (Figure A1-4). The
updated and more detailed data will be

![](media/image3.png){width="6.59375in" height="8.252777777777778in"}

Figure A1-3. DDT in fish fillet between Malibu and Dana Point.

![](media/image4.jpeg){width="6.495833333333334in"
height="4.790277777777778in"}

Figure A1-4. Potential zones for deployment of artificial reefs\
(indicated by gray-shaded areas).

used both to confirm the viability of these regions for restoration reef
construction and to provide the detailed information necessary to
determine specific project locations within the regions.

Step 2: Site Selection

In Step 2, the Trustees will refine and prioritize site and design
considerations for individual reef projects, building on the broader
site evaluation performed in Step 1. The Trustees will evaluate a
comprehensive set of considerations, including:

-   The potential effects of reef placement on sediment transport

-   The suitability of the existing bottom substrate for placement of
    reef material

-   The potential effects on navigation and recreational uses

-   The presence of historically important sites

-   The potential effects on essential fish habitat and species of
    concern

-   The levels of local public support or opposition

-   The proximity to other existing reef habitat or kelp beds

-   The proximity to point-sources of pollutants (e.g., wastewater
    outfalls or storm drains)

-   The potential for funding partnerships

-   Current land management plans for the location.

The site identification step will involve an iterative proposal and
review process; an initial list of a small number of candidate sites
might be developed, publicly reviewed, and further refined. This step
will include consultation with local jurisdictions and publicized
workshops for interested parties to participate and comment on potential
reef sites.

Placing new reefs adjacent to or sufficiently near existing similar
habitat to allow for migration of fish from existing to new reefs will
receive priority consideration. If new reefs are placed near existing
reefs or kelp beds or are used to bridge gaps between existing isolated
reefs, then the new reefs may generate benefits beyond those that would
accrue from isolated reef construction. Such bridge or extension reefs
could be designed to promote additional functions, such as the creation
of nursery areas or the development of diverse reef habitats containing
both high- and low-relief features, a range of depths, and structural
complexity. Proximity to kelp forest habitats would increase the
likelihood of natural recruitment of kelp to the constructed reef.

Shore-based fishing sites will receive highest priority, but offshore
sites may be considered for fish production benefits. The justification
for placing a higher priority on shore-based fishing sites is that
anglers fishing from the shore or from piers generally have fewer
choices regarding the habitats over which they fish than do boat
anglers. The outcome of Step 2 will be a limited number of sites (e.g.,
two or three) to carry forward into subsequent steps.

Step 3: Reef Design

Step 3 will determine the final form of the constructed reefs. This step
will incorporate results from past and ongoing artificial reef
evaluation projects (e.g., the Pendleton Artificial Reef and SONGS), the
input of experts in the field, and the limitations associated with the
specific reef site identified in Step 2. Considerations to address
include material type, the nature of existing sediments in the area,
amount of relief, patchy versus even coverage, kelp outplanting versus
reliance on natural recruitment of kelp, the fraction of the reef that
would be available to anglers for fishing versus the fraction that would
be less available or specifically protected for production, and the
connections with existing artificial or natural reef habitats. Step 3
will also design the pre- and post-construction monitoring that will
take place to determine the effectiveness of the restoration effort. The
final result of this step will be supplemental NEPA and CEQA
documentation for one or more individual reef construction projects;
this documentation will be released for public comment. After public
comments are incorporated, permit applications will be submitted.

Step 4: Reef Construction

Step 4 will be initiated after the acquisition of appropriate permits
and final design work, including identification of specific construction
methods and sources of materials, determination of the contracting and
construction management approaches, and establishment of funding
partnerships. For planning purposes the Trustees anticipate constructing
reefs at two to three locations over a 5-year period.

Step 5: Monitoring and Long-Term Oversight

The purpose of monitoring a constructed restoration reef is to document
the abundance, species composition, size frequency, and contamination
levels of the fishes that occupy the reef as the community develops. The
following discussion provides a template for the fish contaminant
component of the monitoring that can be applied to any MSRP reef
project. The monitoring of species composition, abundance, and size
structure will follow the protocols established as part of the long-term
shallow subtidal fish monitoring programs in other parts of California
(e.g., the Partnership for Interdisciplinary Studies of Coastal Oceans
and the National Parks Service kelp forest monitoring survey).

The Trustees have two fundamental incentives for collecting fish
contaminant data from a restoration reef. The first incentive stems from
the likelihood that MSRP will be building reefs sequentially rather than
simultaneously. Thus, the information on fish species abundance, species
composition, and contamination levels gained from one reef project could
be applied to the design and location of future reef projects. In this
way, the MSRP reef program will be implemented using an adaptive
management strategy to maximize the positive impacts of each constructed
reef.

The second incentive for monitoring fish contamination levels is that
the Trustees will provide empirical confirmation that the reef has
improved fishing by increasing opportunities to catch less-contaminated
fish. There is good reason to believe that the fish that occupy the
constructed reef habitat immediately after construction may differ in
contamination levels from those that occupy the reef later because of
the successional nature of community development on created reefs. The
early inhabitants of a constructed reef are almost entirely transient
individuals that move in from other areas and that may reflect
bioaccumulation rates in areas adjacent to the reef site. The proportion
of resident individuals that reflect bioaccumulation rates more local to
the site typically increases as time passes. The monitoring of
restoration reefs should reflect the need to estimate contamination
levels in fish in both the short term and the longer term.

Contaminant monitoring will cover a suite of species that represents the
diversity of eco-types targeted by local anglers. Southern California is
home to a diverse assemblage of fishes, and anglers target many of these
fish. For example, in 2003 anglers in Southern California reportedly
landed over 120 species of fish (RecFin 2005). This taxonomic diversity
encompasses a diversity of foraging modes, home ranges, and habitat
associations, even within the subset of fish species that frequent reef
and hard-bottom habitats. The proposed contaminant monitoring scheme
will encompass this diversity by sampling representative species that
forage at different trophic levels and are associated with different
microhabitat types.

The Trustees plan to adopt a strategy of partnering with other agencies
and organizations to obtain pilot-level information on reef designs and
placement. This strategy will result in the greatest benefit in terms of
achieving MSRP restoration goals. For example, a partnership opportunity
exists in a reef project that the Port of Los Angeles (POLA) has
proposed off of Point Fermin. The application of the reef-fish
contaminant monitoring program to the proposed POLA reef would benefit
the MSRP reef planning efforts in at least two ways. First, the POLA
reef deployment is likely to occur before any MSRP reef construction.
Thus, the fish contamination data from the POLA reef would be available
to assist in the siting and design of the MSRP reefs. These data would
provide indications of contaminant levels in the fish that in succession
occupy such a reef and might be useful in obtaining public acceptance
and permitting for MSRP reefs sited in similar areas with transitional
levels of sediment contamination.

Second, reef monitoring for the POLA project will also document whether
and how fishing practices have been affected by the project. Thus,
surveys of anglers will be conducted to determine the effects of the
project on fishing practices and preferences. These surveys will
identify the fish being caught by anglers and retained for consumption
before and after reef construction. This information will aid the
Trustees in their efforts to design and construct reefs that have
positive fishing benefits.

In the long term, it is anticipated that MSRP-constructed reefs will
become part of the existing California artificial reef program, which is
administered by the California Department of Fish and Game (California
Fish and Game Code Sections 6420--6425).

#### Fishing Access Improvements

During the reef development steps outlined above, the Trustees will also
consider whether the improvements to fishing access and amenities at the
sites under consideration for reefs would complement the restoration of
lost fishing services. Several types of improvement will be considered,
including parking improvements, construction or extension of piers to
ensure optimal fishing access to constructed reefs, and increases in the
number of or improvements in fish cleaning stations, lighting, benches,
railings, restroom facilities, etc. Interpretive signs, displays,
kiosks, or other materials may also be provided to explain to the public
the need for and the function of the fishing restoration actions.
Consideration and evaluation of improvements to access and amenities at
these locations will be conducted in parallel with reef site design and
development and will entail close consultation with local and state
jurisdictions and interested users.

The Trustees have conducted preliminary analysis of the cost of pier
construction and the construction of associated amenities. The unit cost
of pier construction appears to be on the order of \$200 per square foot
or more; thus, the cost of constructing a pier of 50,000 square foot
would likely exceed \$10 million. Because MSRP restoration funding is
limited and the primary objective of this restoration approach is reef
construction, the Trustees would likely place a cap on the proportion of
funding devoted to access improvements to ensure that sufficient funds
are available for reef construction.

### Environmental Benefits and Impacts

This analysis addresses the environmental consequences of constructing
artificial reefs and fishing access improvements at a broad conceptual
level, as no specific sites have been proposed or evaluated. Additional
NEPA and CEQA documentation will be required to address site-specific
environmental considerations.

#### Biological

Benefits

Reefs provide habitat for a multitude of marine fishes, invertebrates,
and plants. The displacement of the sandy or muddy bottom habitat with a
hard-bottom substrate would increase the diversity and may increase the
number of the animal and plant biota in the area. Reefs act as nursery
and spawning habitat for a variety of species native to the Southern
California Bight. Reefs also act as a substrate for the recruitment and
growth of giant kelp, which are also an important component of critical
nursery habitat for many fish and invertebrate species. In addition, the
fish productivity of rocky reef habitat has been estimated to be between
9 and 23 times that of sandy bottom habitat (MEC Analytical Systems
1991).

Recent declines in certain species of groundfish on the west coast,
including rockfish complexes, have led to increased restrictions on
fishing for these species. To the extent that reefs constructed under
the MSRP program function as production sites for these or similar
species (e.g., should reef design include a fish production/nursery
component that increases the abundances of rockfishes), reefs may
benefit the management and recovery of these depleted species of fish.

Because reef-associated fish typically contain lower concentrations of
DDTs and PCBs than soft-bottom species, constructed reefs would benefit
the biological organisms that prey on fish in the vicinity of the
constructed reefs, as the organisms preying on fish would be exposed to
reduced levels of these contaminants.

Once constructed, an artificial reef would provide benefits for many
decades with minimal operational and maintenance costs.

Impacts

In general, hard-bottom or reef habitat is one of the most important but
least abundant habitats in the Southern California coastal marine
environment (Cross and Allen 1993). Soft-bottom substrates (i.e., sand
and mud) predominate in an overwhelming percentage of the marine area
along the coast from Point Dume to Dana Point (Ambrose 1994). Thus,
conversion of habitat from soft-bottom to reef on the scale feasible
under this restoration program would not significantly reduce the total
available soft-bottom habitat to those species that rely on it. It is
possible that constructing reefs may impact the availability of some
other limited inshore habitat or resource, such as eelgrass beds. Also,
soft-bottom habitat in nearshore waters of California are spawning areas
for market squid (*Loligo opalescens*), which is an important commercial
species in California. In addition, sheltered, shallow soft-bottom areas
in certain locations (e.g., inside the Los Angeles and Long Beach Harbor
breakwaters) provide important nursery areas for several fish species,
including California halibut. The specific locations of each constructed
reef will be studied and selected such that limited natural habitats are
not covered or compromised.

Artificial reefs are known to be aggregators of marine life; such sites
are popular fishing and diving locations because of the large numbers of
fish and invertebrates attracted to the structures for habitat and food.
Because of the popularity of these sites for anglers, fish mortality
could increase in the vicinity of newly constructed reefs. Such an
effect might also occur as a result of improvements to fishing access
and amenities that increase the number of fishing trips to a site. Thus,
before a reef is constructed at a given site, appropriate steps will be
taken to ensure that reef design, size, placement, and long-term
management will accommodate the anticipated increases in fishing and
other uses of the reef site.

At a conceptual level, reef construction projects are not likely to
adversely affect threatened or endangered species or essential fish
habitat. However, detailed analysis will be performed at a site-specific
level before a reef is constructed.

#### Physical

Benefits

The benefits of artificial reefs to the physical environment would be
nominal. To the extent that the material used to construct a reef is
taken from the demolition of concrete structures, the beneficial reuse
of this material would divert it from land disposal and conserve a
corresponding increment of landfill space. Other trade-offs related to
the transportation and disposal of materials (such as reduced air
quality impacts relative to land disposal) would occur, but whether they
would have net positive or net negative consequences cannot be
determined until site-specific implementation factors are determined.

Impacts

The placement of reefs in nearshore areas has the potential to alter the
transport of sediment and affect the topography of adjacent subtidal and
beach areas. Also, depending on the nature of the soft substrate in a
given area, the depth to bedrock, and the slope, hard substrate dropped
to the marine bottom may not perform as intended. The potential physical
impacts from placing rock or rubble in a given area will be submitted to
engineering analysis and supplemental review and evaluation performed.

The placement of concrete or rock materials into marine waters would
cause short-term suspension of sediments at the site and result in
short-term water quality impacts. The principal effect would be
increased turbidity; however, depending on local conditions, the
sediments at the reef site might contain elevated contaminant levels.
The methods and timing for reef material placement may be adjusted in
consultation with regulatory agencies to address such local conditions
and reduce the short-term water quality impacts of the construction.

#### Human Use

Benefits

Artificial reef construction in areas will displace highly contaminated
soft-bottom species and replace them with less-contaminated hard-bottom
and water-column species. This result will provide direct benefits to
anglers whose fishing opportunities have been impacted by fish
consumption advisories. Artificial reefs provide human use benefits
beyond fishing, as they are also popular areas for scuba and free diving
for purposes of recreation, hunting, and underwater photography. As with
the biological benefits, the human use benefits will be sustained for a
period of decades or longer with minimal operational or maintenance
costs.

Improvements to fishing access may include the addition of various
fishing site amenities, including fish-cleaning stations, benches, pier
extensions, or parking improvements. Informational panels or kiosks
might also be included at reef sites to inform and educate the public on
the benefits of the project. Such improvements will be undertaken with
the specific intent of improving human use at the fishing site, thereby
compensating for past and ongoing lost fishing opportunities, and
efforts will be made to ensure functional and aesthetic benefits.

Impacts

Depending on its location and design, an artificial reef can impact
various human uses in an area. Potentially impacted uses include
recreation (e.g., board, body, or wind surfing) and navigation.
Constructed reefs displace soft-bottom species, so the anglers
specifically targeting these species at the site would find it harder to
catch these fish. The potential impacts to recreational and navigational
uses will be a significant consideration as candidate sites are
evaluated. One of the purposes of the survey of recreational and
subsistence anglers that the Trustees undertook in 2002 and 2003 was to
determine fishing preferences at fishing sites along the Los Angeles and
Orange County coast. The data generated by this field intercept survey
and the follow-up public involvement activities will be used to select
sites that minimize negative impacts to anglers who may be exclusively
targeting soft-bottom fishes. The survey findings will be included in
subsequent site-specific environmental documentation that will be
developed by the Trustees. It is unlikely that a reef will be
constructed in an area used by surfers (e.g., in high-energy surf areas)
because of the tendency of swells and waves to damage or destroy
artificial reefs.

Construction activities at fishing sites (e.g., construction
improvements to piers and the provision of amenities such as fish
cleaning stations, parking, etc.) may cause short-term disruption to
users of a site during the period of construction. Steps will be taken
to minimize the impacts of construction; these steps will be addressed
at the stage when site-specific plans are being considered.

### Likelihood of Success/Feasibility

Artificial reefs have been constructed in many areas along the coast of
California and elsewhere to enhance fisheries and fish production and to
replace lost habitat. Studies of previously constructed reefs (including
the 5-year pilot reef project near San Clemente) have resulted in a
substantial body of knowledge on the likely outcomes associated with
different design attributes and implementation approaches. Although the
principal purpose for an MSRP reef (i.e., displacing highly contaminated
fish and attracting/producing less contaminated fish) may be novel, the
likelihood is high that constructing reefs in suitable areas will
achieve this purpose. Sufficient data are available to develop
reasonable predictions about species abundance and composition in a
constructed reef. The degree to which the changes in species composition
will lower the contamination levels in the fish caught by anglers at a
site can be predicted from measurements of contaminants in similar fish
caught near the potential reef sites. Thus, it is feasible to design and
place a reef to achieve this purpose; it is also feasible to scale the
reef such that it will provide sustainable fishing services.

Appropriately placed artificial reefs increase the diversity of the
local marine ecosystem and often attract increased recreational use.
Where complemented with above-water enhancements (e.g., improvements to
fishing access and associated recreational amenities), reefs are well
suited for the goals of both restoring and compensating for lost fishing
services.

Several potential reef sites exist within the regions indicated in
Figure A1-4. The Trustees have not proposed specific reef sites at this
stage. Rather, the Trustees will allocate funds for artificial reef
construction and associated fishing access improvements. Selection and
design of specific projects will be decided through further analysis,
planning, and public review of site-specific proposals. In this context,
the Trustees will seek to enter into partnerships with other parties
willing to co-fund such work to leverage the use of natural resource
restoration funds to obtain as many acres of new reef habitat as
possible within the limits of available funding.

Regulatory approval and public acceptance of reef construction projects
have been achieved in the past. However, recent efforts by POLA to
obtain approval to construct a new artificial reef offshore of Point
Fermin have been delayed pending resolution of concerns about the
proximity of the site to contaminated sediments on the Palos Verdes
Shelf. This case suggests that any proposal to construct a reef for the
MSRP objective of displacing contaminated fish will require careful
planning and coordination with interested parties. Nevertheless, there
is general support for reef construction. Fishing organizations such as
the United Anglers have expressed a desire for more artificial reef
construction, and regulatory agencies have approved reef construction as
a means for mitigating environmental impacts.

### Performance Criteria and Monitoring

Several performance criteria will be used to evaluate the effectiveness
of a constructed artificial reef in meeting the Trustees' restoration
goals: fish abundance, species composition, fish size distribution, and
the fish contamination levels. Abundance and size distribution are
important because an increase in fishing services requires sufficient
abundances of legal-size fish to replace the displaced soft-bottom fish
that occupied the fishing area prior to reef construction. The
contamination levels in the fish that occupy the reef are clearly
important because the goal is to increase the local abundance of cleaner
fish. Each of these parameters may undergo a successional sequence after
reef construction, so it will be necessary to implement a monitoring
program that includes high temporal resolution (e.g., annual or
biannual) monitoring initially followed by more infrequent monitoring
later to determine the sustainability and stability of the reef
community.

### Evaluation

The Trustees have evaluated this restoration action against the
screening and evaluation criteria developed to select restoration
actions and have concluded that this action is consistent with these
selection factors. This action will address the loss of natural resource
services provided by fish, which was one of the natural resource
injuries brought forward by the Trustees in the Montrose case. Species
composition and the contamination levels of the fish occupying the reef
site can be measured prior to and after reef construction and the net
change in the availability of cleaner fish can be estimated by combining
species distribution with species-specific contamination levels.
Artificial reef construction has been shown to have pronounced local
effects on species composition through the combined effects of
production and attraction, so a reef is highly likely to produce local
changes in species composition. Thus, larger-scale (i.e., regional)
increases in population levels will not be required to have the desired
restoration effect.

This action will require supplemental environmental documentation that
will be prepared after development of site-specific proposals pursuant
to NEPA and CEQA.

### Budget

The Trustees have previously developed estimates of the cost and amount
of artificial reef needed to replace the contaminated biomass of fish
caused by the Montrose contamination (Ambrose 2000). These estimates
ranged from \$60,000/acre to \$318,000/acre based on the construction of
1 to 9 acres of reef. This analysis revealed that the smallest reefs (1
to 2 acres) had by far the greatest per-acre construction costs
(\$318,000 and \$250,000 per acre for the smallest and second smallest
reefs, respectively). This estimate is subject to substantial
variability due to several unknowns, such as the purchase cost of
materials for reef construction. Furthermore, the density of reef
material contributes substantially to the costs associated with reef
construction. The SONGS reef project experienced a 20 percent decrease
in construction costs between its high-density and its low-density reef
treatments. The results of the SONGS analysis may help to identify the
most cost-effective design for MSRP reefs.

This restoration program will proceed incrementally, with a goal of
constructing two to three reefs in the 5-year period during the first
phase of restoration. The costs of such a program may be broadly
estimated as follows:

-   Reef design, permitting, construction, and monitoring:
    Ambrose (2000) estimated an average cost of \$170,000 per acre.
    Assuming 10 to 12 acres of coverage for each reef, each reef project
    would cost \$1 million to \$2 million. The 22.4-acre artificial
    SONGS reef cost \$2.7 million to construct, suggesting construction
    costs of approximately \$120,000 per acre.

-   Construction of fishing access improvements: The cost of this
    construction has been estimated based on several potential actions
    that could be implemented at a number of fishing sites (MSRP
    Administrative Record). The estimated costs associated with building
    a new pier are approximately \$200/ft^2^, so the total cost of
    building a new pier that is similar in size to other piers in
    Southern California (e.g., the Redondo Pier, which is 70,000 ft^2^)
    would be approximately \$14 million. Thus, matching funds would be
    critical for undertaking such a project. The cost of installing
    access improvements to existing piers has been estimated to range
    from \$92,000 to \$368,240 depending on location and the needed
    improvements.

The two estimates cited above suggest a potential range of costs for
each reef and access project of \$2 million to \$4 million.

[^1]: Much of the information regarding the SONGS reef program is based
    on a phone interview with Dr. Steven Schroeter, who has been a
    principal investigator on the project since its inception.

[^2]: The MRFSS in California is now an expanded program called the
    California Recreational Fishing Survey.