The Town staff recently responded to a series of questions & answers sent by Save Our Shores (SOS) organization. Town responses are in italics.
1. What is included in the Town of Palm Beach $22.8M project?
SOS ANSWER: The Town of Palm Beach proposal for the 2014 Mid-Town Beach Nourishment Project with the estimated cost of $22.8M has many unanswered questions.
This project will extend north of Mid-Town beach into Reach 2. It is important to note that Reach 2, which contains hardbottom of 60 acres, will receive sand from Reach 1 according to the plan for this project.
The cost of this Project will be paid with Town of Palm Beach “cash at hand”, Reserve money, etc.!
Included in this 2014 Project is “supplemental sand” for Reach 7 (which now extends as far as Lake Worth pier) and dune restoration for Reach 8. This is the Town’s plan for addressing the needs for the critically eroded Reach 7 and the critically eroded Reach 8. Supplemental sand and dune restoration do not provide the required protection of upland properties of Reaches 7 and Reach 8 that would otherwise be provided by beach nourishment with dunes.
TOWN STAFF COMMENTS: The entire FY 2014 Proposed Coastal Management Program Budget has an estimated cost of approximately $22.8 million. This is not a singular “project,” but rather a group of projects and other activities. The budget includes construction of a replacement North Ocean Boulevard seawall in Reach 2, full-scale beach nourishment in Reaches 3 and 4 of Mid-Town (approximately 800,000 cubic yards), interim beach and dune sand placement in Reach 7 (approximately 100,000 cubic yards), dune restoration in Reach 8 (approximately 50,000 cubic yards), and various Townwide and project-specific monitoring efforts.
During FDEP’s Palm Beach Island Beach Management Agreement (BMA) process, Town staff, consultants, stakeholders, FDEP, and other state and federal regulatory and advisory agencies participated in a series of meetings that refined projects in the BMA. The fill densities for the Mid-Town project were reduced to further reduce potential indirect hardbottom impacts. To compensate for density reductions and to maintain project performance, the north-south taper limits of the Mid-Town project were extended. Specific to Reach 2, the Mid-Town project is to extend north by approximately 1,500 linear feet from FDEP range monument R-90.5 (El Mirasol) to R-89 (just north of Casa Bendita). Approximately 60,000 cubic yards of sand will be placed in this area.
One of the short-term recommendations from the Woods Hole Group (WHG) Technical Review of the Coastal Program was to “maintain the Mid-Town project to directly protect Reaches 3 and 4, and indirectly stabilize the southern portion of Reach 2 and Reach 5. Include an updated design template expanded into the southern part of Reach 2.” WHG further recommended that during the next Mid-Town project, sand be stockpiled and trucked into both Reaches 7 and 8 to provide interim storm protection until a full-scale renourishment project in Reach 7 could be constructed with a storm protection project in Reach 8, following completion of the ongoing Environmental Impact Statement (EIS) and subsequent permitting effort.
The Town is proceeding in accordance with WHG’s recommendations.
Town Council has not made its final decision regarding the funding source for the Coastal Management Program’s FY 2014 proposed budget. Additional considerations are being evaluated by a consultant at the direction of the Finance & Taxation Committee, in preparation for the August 12 (Finance & Taxation) and August 13 (Town Council) public meetings.
2. Why is it that Reach 8, south of the Lake Worth pier needs an EIS and Reach 2 does not require an EIS?
SOS ANSWER: The Town has approved a Federal Environmental Impact Study (EIS) to examine the Town’s proposed alternative plan for Reach 8, south of the Lake Worth pier.
It is necessary to be aware that Reach 8, south of the Lake Worth pier has only 2.53 acres of environmental hardbottom which is in contrast to the 60 acres of environmental hardbottom in Reach 2!
The difference in the amount of hardbottom that is contained in Reach 8 is far less than the amount hardbottom in Reach 2; therefore it is questionable why there isn’t an EIS required for Reach 2.
TOWN STAFF COMMENTS: The U.S. Army Corps of Engineers (USACE) determined that an EIS would be required before a federal permit for sand placement below the mean high water line in Reach 8 could be considered.
The Town is currently working with the USACE to modify the existing federal Mid-Town permit to extend the north taper of the project by approximately 1,500 linear feet. The USACE has not made a final determination on the modified limits of the Mid-Town project.
Reach 2 is the longest of the eight reaches – 13,580 ft (2.5 miles). The proximity of hardbottom to the shoreline in the southern portion of Reach 2 is not the same as the condition in the central portion of Reach 2. The Town fully anticipates that an EIS will be required by the USACE before any sand from Lake Worth Inlet maintenance dredging projects can be extended toward the center of Reach 2, so we have included $1 million in the Town’s FY 2015 Coastal Management Program for that purpose. (This is the same amount previously budgeted for the Reach 8 EIS.)
3. Has the Town made the best choice of an engineering firm to do the EIS?
SOS ANSWER: The Town has selected the firm of Coastal Planning and Engineering (CPE) to do the EIS. The facts are that this firm, CPE, served as the Town’s consultant in 2007 which designed the failed Reach 8 plan that was struck down by the Administrate Law Judge because of the utilization of poor quality sand among other reasons.
TOWN STAFF COMMENTS: This was not the Town’s decision. The USACE staff selected Coastal Planning & Engineering, A Chicago Bridge & Iron Company (CB&I), to perform the EIS. The Town initially requested that the USACE consider another firm, but USACE legal counsel determined that the Town-recommended firm had a conflict of interest due to the project manager’s former employment with the USACE. The EIS is to include Reaches 8, 9, and 10, and CB&I has recently completed an engineering alternatives evaluation in Reaches 9 and 10 for Palm Beach County. The USACE, Palm Beach County, and the Town all believe that CB&I is well qualified for this assignment.
4. How will Reach 7 at Sloan’s Curve benefit from the EIS to be completed in Reach 8?
SOS ANSWER: The erosion solutions that are determined by the Environmental Impact Study (EIS) in Reach 8 will be used for northern Reach 7 at Sloan’s Curve, which, like Reach 8, is a declared critically eroded area that has heretofore been denied beach nourishment.
TOWN STAFF COMMENTS: Storm protection projects must be specifically engineered for each individual segment of shoreline. It is never the case that an EIS for one segment determines the solution for a different segment.
The entire Town shoreline is designated by the State of Florida as critically eroded.
The storm protection actions planned by the Town for the Sloan’s Curve area are 100% consistent with WHG’s recommendations.
5. What is the Town’s “feeder beach” alternative for Reach 8?
SOS ANSWER: The Town has referred to a “feeder beach” that would be constructed in Reach 8. However, the Town has not supplied specifics, in writing, regarding where the sand placement will occur.
In a previous, unfulfilled plan, the Town had proposed to place 65,000 cubic yards of sand as a “feeder beach” in front of 3 or 4 condominiums which are located 500 ft. south of the Lake Worth pier. This same plan which would cover only 2,000 ft. in length will become the Town’s alternative and a substitute for the placement of sand in a full nourishment project that would protect the 6,600 ft. length of the Reach 8 critically eroded shoreline.
TOWN STAFF COMMENTS: The Town spent years and millions of dollars trying to construct a full scale beach restoration project in Reach 8. We made formal application for that project in 2005 and received tentative approval from FDEP in 2008. The intended permit was challenged by several parties and after a protracted administrative hearing (tantamount to a trial) from August to October of 2008, the administrative law judge recommended that FDEP deny the permit and allow a much smaller project instead. With slight modifications, FDEP adopted the ALJ’s recommendations.
Throughout the Town’s continued efforts to obtain a permit for a storm protection project in Reach 8, regulatory authorities have repeatedly urged the Town to reduce the project’s scope and expected environmental impacts. We have made several further modifications to our proposed project design, resulting most recently in the feeder beach proposal. Due to continued concerns being expressed by the National Marine Fisheries Service and others, the USACE is requiring an EIS to be performed before regulatory permitting can resume.
In short, the Town shifted to pursuing a feeder beach concept for Reach 8 because the Town’s vast regulatory and legal experience in this area suggested that what we will be allowed to build there will be substantively smaller than what we originally planned to build.
6. Compare the Town’s “feeder beach” alternative with the SOS/Erickson Beach Nourishment Plan for Reach 8.
SOS ANSWER: The Town’s “feeder beach” plan that would provide 65,000 cubic yards of sand for Reach 8 fails to meet the criteria of the State of Florida’s Reach 8 “feeder beach” Inlet to Inlet BMA Regional Pilot Project. A Reach 8 beach nourishment plan should put sand into system to benefit the shorelines of South Palm Beach, Lantana, and Manalapan.
The SOS/Erickson plan does fulfill these state requirements for a Reach 8 “feeder beach” plan! Instead of placing 65,000 cubic yards of offshore sand on Reach 8, as the Town plan would provide, the SOS/Erickson plan would place at least 365,200 cubic yards of “offshore sand” on the entire Reach 8, south of the Lake Worth pier from the Bellaria to La Bonne Vie at the Town boundary.
The SOS/Erickson plan would also satisfy environmental issues. It recommends the use of Ortona sand. The amount of Ortona sand that would be required, according to the SOS/Erickson plan, is only 148,400 cubic yards. This Ortona sand provides more stability than “offshore” sand, longer life between nourishment intervals and would cost less, since less quantity is needed.
TOWN STAFF COMMENTS: See “Town staff comments” regarding question #6 above in #5.
7. How does the SOS/Erickson plan qualify for the EIS?
SOS ANSWER: In addition, the SOS/Erickson Reach 8 Beach Nourishment Plan will also be studied as an “alternative” in the EIS process because the SOS has the right as a stakeholder in the community. The SOS/Erickson Reach 8 plan would not only protect the upland properties of Reach 8, but it would also bring sand to the beachless shores of the southern municipalities of Palm Beach Island (PBI).
TOWN STAFF COMMENTS: The SOS/Erickson Reach 8 Beach Nourishment Plan will be considered in the EIS, along with a wide range of other alternatives. Ultimately, what the Town is allowed to construct in Reach 8 (and the County in Reaches 9 and 10) will be determined by the USACE through the EIS.
Because the prevailing movement of sand along the beaches of Southeast Florida is from north to south, the Towns of South Palm Beach, Lantana, and Manalapan will benefit from the Town of Palm Beach’s placement of sand in Reach 8. However, this is an incidental benefit and not a primary purpose of any project the Town of Palm Beach might construct in Reach 8.