RICK SCOTT

Governor KEN DETZNER Secretary of State

Division of Historical Resources R.A. Gray Building • 500 S outh Bronough Stre et• Tallahassee, Florida 32399

850

. 245

. 6 30 0 • 850

. 245

. 6 436 (Fax) flheritage.com Promoting Florida’s History and Culture VivaFlorida

. org 

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

J e n n i f e r S

. D erby, Chief

Coastal and Ocean Protection Section

Sam Nunn Atlanta Federal Center 61 Forsyth Street

Atlanta Georgia 30303

RE: DHR Project File No.: 201 4

- 0 4710 / Received by DHR: October 15, 2014

Final Environmental Impact Statement ( F EIS) for Designation of an Ocean Dredged M aterial Disposal Site (ODMDS) offshore Jacksonville

, Florida

Dear M s. Derby :

Our office reviewed the referenced project for possible impact to historic properties listed, or eligible for listing, in the National Regis ter of Historic Places . The review was conducted in accordance with S ection 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 amende d

.

This office has reviewed the above referenced FEIS and note s that Alternative 1a is i dentified as the preferred

alte rnative for the ODMDS

. We concur with the select ion of Alternative 1a as the preferred alternative.

However, if another al ternative 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 OfficerTo: 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 f inal EIS would include the seabed off shore 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 S ites 1 a 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 1 a , 2 and 3

. Alternati ve S ite 1a is a slightly smaller version of A lternative S ite 1 as presented in the draft EIS

reviewed in 2012.

Figure 1. OSMDS l ocations as shown in the f inal EIS 

# Memorandum 

# Florida Department of

Environmental ProtectionPlease see

, for comparis on of the areas of Alternative 1 and Alternative 1a

, Figure 1 above and Figure 2 below.

Figure 2 . OSMDS l ocations as shown in the d raft 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 f inal 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, ph ysical sediment characteristics would be altered within the site boundaries from a predominantly sand bottom to a mixture of sand, silt, clay, and rock.”

The f inal 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 r egion’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:

“ U se of any of these alternative sites will preclude their use as borrow sites for the extraction of beach replenishment quality sand

. N one of these sites are under consideration for use as

borrow sites

. ”

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

northeast and the east of Alte rnative Site 1 a respectively.

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

Figure 4 below shows that A lternative S ite 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

, “l acking 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. ”

O ur review of the f inal EIS sugges ts 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

. I t is our opinion that the SMMP provides reasonable assurance that :• environmenta l 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

.

Th ese conclusion s 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 bat hymetry, 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.