RICK SCOTT

Governor

KEN DETZNER

Secretary of State

Division of Historical Resources

R.A. Gray Building • 500 South Bronough Street• Tallahassee, Florida 32399

850.245.6300 • 850.245.6436 (Fax) flheritage.com

Promoting Florida’s History and Culture VivaFlorida.org

U.S. EPA, Region 4 November 12, 2014

Jennifer S. Derby, Chief

Coastal and Ocean Protection Section

Sam Nunn Atlanta Federal Center

61 Forsyth Street

Atlanta Georgia 30303

RE: DHR Project File No.: 2014-04710/ Received by DHR: October 15, 2014

Final Environmental Impact Statement (FEIS) for Designation of an 

Ocean Dredged Material Disposal Site (ODMDS) offshore Jacksonville, Florida

Dear Ms. Derby:

Our office reviewed the referenced project for possible impact to historic properties listed, or eligible for listing, in the

National Register of Historic Places. The review was conducted in accordance with Section 106 of the National 

Historic Preservation Act of 1966, as amended, 36 CFR Part 800: Protection of Historic Properties, and the National 

Environmental Policy Act of 1969, as amended. 

This office has reviewed the above referenced FEIS and notes that Alternative 1a is identified as the preferred 

alternative for the ODMDS. We concur with the selection of Alternative 1a as the preferred alternative. 

However, if another alternative is selected, it should have (or have had) an underwater cultural resource assessment

survey conducted of the area and all anomalies should be diver verified to determine if any are significant. Any 

significant cultural resources that are identified should be buffered and avoided by project activates. Survey activities

should be coordinated with this office. 

For any questions concerning our comments, please contact Robin Jackson, Historic Preservationist, by phone at 

850.245.6333, or by electronic mail at robin.jackson@dos.myflorida.com. We appreciate your continued interest in 

protecting Florida’s historic properties. 

Sincerely

Robert F. Bendus, Director

Division of Historical Resources

and State Historic Preservation Officer
To: Debby Tucker

Environmental Administrator

Department of Environmental Protection

3900 Commonwealth Boulevard, MS 47

Tallahassee, Florida 32399-3000

From: Daniel C. Phelps, P.G. 

Geological Investigations Section

Florida Geological Survey

Florida Department of Environmental Protection

903 W. Tennessee St.

Tallahassee, FL 32304-7700

Date: October 16, 2014

Subject: 

U.S. Environmental Protection Agency (EPA) has released for comment the Final EIS 

(Publication Number: 904K14002) for the designation of an ocean dredged material disposal site 

(ODMDS) offshore of Jacksonville, Florida (SAI# FL201410147065C – Jacksonville ODMDS). 

The geographic area of concern related to this final EIS would include the seabed offshore of 

Duval County and to a lesser extent the seabed offshore of the northern and southern portions St. 

Johns and Nassau counties, respectively. All of the sites under consideration lie in federal waters 

approximately four nautical miles offshore. Alternative Sites 1a and 2 lie north of but proximal to 

the Duval – St. Johns county line. Alternative Site 3 lies south of but proximal to the Duval –

Nassau county line. These sites are shown in Figure 1 below as Alternatives 1a, 2 and 3. 

Alternative Site 1a is a slightly smaller version of Alternative Site 1 as presented in the draft EIS 

reviewed in 2012.

Figure 1. OSMDS locations as shown in the final EIS

Memorandum

Florida Department of 

Environmental Protection
Please see, for comparison of the areas of Alternative 1 and Alternative 1a, Figure 1 above and 

Figure 2 below.

Figure 2. OSMDS locations as shown in the draft EIS

Per the text of the final EIS “...the boundaries of Alternative 1 were modified in the Final EIS 

(FEIS) to remove a 0.26-nautical mile triangular shaped area in the northeast corner of the site 

that contained 3.4 acres of rubble.”

Potential Risks and Concerns:

The final EIS states that:

“Only sediments determined to be suitable for ocean disposal pursuant to EPA and USACE 

testing criteria will be permitted for ocean disposal, with no unacceptable adverse impacts to the 

seabed inside or outside the ODMDS disposal site boundary. However, physical sediment 

characteristics would be altered within the site boundaries from a predominantly sand bottom to a 

mixture of sand, silt, clay, and rock.” 

The final EIS further states that:

“The designation of a new ODMDS offshore of Jacksonville is not expected to result in adverse 

cumulative impacts although short-term, temporary impacts may occur such as topographic 

change, changes in sediment composition, burial of organisms in the disposal area, changes in 

the benthic community, and potential changes to the local food web. Such temporary changes 

have been ongoing at existing sites for decades. The evaluation conducted in this EIS did not, 

however, find evidence that any of these changes has resulted in significant unacceptable 

adverse impacts to the region’s resources.”

As discussed in the draft EIS we reviewed in 2012 and stated in the final EIS:

“Offshore of Fernandina Beach and Jacksonville, quartz sand is thick (up to 8.2 feet) and uniform

in lateral extent...” and 
“Results of grain size analyses for these alternative sites indicate a predominance of sand (70.1% 

to 98.6%).”

As was previously noted in our review of the draft EIS in 2012: 

“Use of any of these alternative sites will preclude their use as borrow sites for the extraction of 

beach replenishment quality sand. None of these sites are under consideration for use as 

borrow sites.” 

Figure 3 below shows that the currently designated Duval sand borrow areas A and B1 lie to the 

northeast and the east of Alternative Site 1a respectively.

Figure 3. Alternative Site 1a in relation to Borrow areas A and B1.

Figure 4 below shows that Alternative Site 2 lies adjacent to the south and west of borrow area 

B1 and southwest of borrow area A. 
Figure 4. Alternative Site 2 in relation to Borrow areas A and B1.

Scope of Comments:

The Florida Geological Survey’s (FGS) comments relate to the mission of the FGS to collect, 

interpret and provide objective quality geologic information about Florida.

General Comments:

As was written before in our comments regarding the draft EIS, “lacking any other suitable 

disposal alternative, the deposition of dredge material at any of the sites under discussion would 

seem the most reasonable and practical solution to the problem of dredge material disposal.” 

Our review of the final EIS suggests that the placing of dredge material on the seafloor at any one 

of the three alternative sites presents minimal potential risk to the natural resources of Florida. 

It is our opinion that as long as dredged material is managed to ensure that sand borrow areas A 

and B1 are not affected by disposal operations, the use of either of Alternative Site 1 or 2 would 

present little or no potential impact on the extraction of beach restoration quality sand from either 

borrow area.

As part of the site designation process, the U.S. Environmental Protection Agency (EPA) 

developed a Site Monitoring and Management Plan (SMMP) which was included as Appendix F 

of the final EIS. It is our opinion that the SMMP provides reasonable assurance that:
• environmental impacts of the proposed placement of the dredged material will remain 

insignificant,

• that dredged material will be properly managed within the site selected and 

• that beach restoration quality sand borrow areas proximal to alternatives 1 and 2 will not 

be adversely impacted. 

These conclusions are consistent with the conclusions stated in our review of the draft EIS in 

2012.

As was stated in our previous review: “The FGS suggests that the ODMDS site selected be 

operated in a manner that might facilitate, or at least not preclude, its potential future utilization as 

a site for renewable energy development via the installation of offshore wind turbines.”

It is requested that the FGS be given access to any geological, geochemical and geophysical 

data, to include bottom samples, borings and stratigraphic test information as well as high 

resolution shallow penetration sub-bottom profiler, side scan sonar, swath bathymetry, and 

traditional bathymetric survey data collected in conjunction with the investigation of the 

ODMDSs. Review of the final EIS indicates that two extensive side scan sonar surveys were 

conducted offshore of Jacksonville during preparation of the EIS. It is requested that access to 

those data be provided.