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A Letter from Glen Coffee to Commissioner Gunter Guy,
Alabama Department of Conservation and Natural Resources,
Regarding BP Oil Spill Settlement Restoration Funding

February 12, 2012

Mr. N. Gunter Guy, Jr., Commissioner
Alabama Department of Conservation and Natural Resources
64 North Union Street
Montgomery, AL  36130

Dear Mr. Gunter:

I am submitting my comments on the “Deepwater Horizon Draft Phase 1 Early Restoration Plan and Environmental Assessment” (DERP/EA) directly to you in your capacity as the Natural Resources Damage Assessment Trustee for Alabama – the state in which I live and within which the estuarine and marine ecosystems I am most concerned occur.  I am also copying your fellow Trustees to assure they are made aware of my comments.  I apologize up front for the length of this letter, but the issues at stake that need to be addressed are significant and this may be my only opportunity to voice them for the record.

Comments on DERP(EA)

The DERP/EA addresses only eight early restoration projects, two of which are located within Alabama.  While both Alabama projects certainly have merit, I am concerned that the Marsh Island Creation and Protection Project proposed for Portersville Bay north of Dauphin Island is: (1) too small in scope and (2) would not provide sufficient environmental benefits to justify the high costs of implementation.

The proposed project would only benefit 74 acres of marsh and 5,000 feet of tidal creek habitat at a cost of $9,400,000.  From an admittedly limited perspective, those figures result in an average cost of around $127,000 per acre of marsh created and/or $1,800 per foot of tidal creek involved.  On the surface the unit costs appear to be excessive when compared against the small amount of habitat involved.  Looked at another way, this small scale project would affect a relatively small area of Alabama’s portion of Mississippi Sound.  Considered from even another perspective this small project would consume almost 10 percent of the $100 million of the NRDA funds presently allocated to Alabama which appears to be a disproportionately high amount given the small quantity of habitat involved.  Lastly, this particular project seems more suited for implementation under the ongoing Coastal Impact Assistance Program (CIAP) or Gulf of Mexico Security Act (GOMESA) Program, the funds for which are generated by revenues received from offshore oil and gas leasing and production activities in the Gulf.

While I realize it may probably be too late to influence the priorities of NRDA funding targeted for the eight early restoration projects, I strongly encourage you and your fellow NRDA Trustees to think more broadly when developing the follow-up restoration projects that will be considered and to place priority on those projects that could benefit large areas of Alabama’s coastal environment.  Since the Deepwater Horizon disaster affected an expansive area of the northern Gulf of Mexico, the NRDA projects selected for implementation should have the potential to positively affect the environment in equally large areas in Alabama’s portion of Mississippi Sound and Mobile Bay that were in the direct path of the spill.  One such project would involve the restoration of Dauphin Island’s significantly eroded shoreline. 

Erosion Threat to Dauphin Island

Presently, Dauphin Island, Alabama’s only barrier island, is “sick” from a geophysical standpoint due to persistent unchecked erosion that is weakening the island’s entire Gulf shoreline.  This fact is recognized and accepted as a fact by all coastal geologists and engineers familiar with Dauphin Island.

The ongoing erosion of Dauphin Island and Sand Island, its companion inlet islet, has been evident for the last 40 years.  Over that period, Sand Island has nearly vanished, leaving the historic Sand Island Lighthouse as an isolated sentinel as evidence of that island’s former eastern limit.   As Sand Island began to disappear, beginning in the 1970s, the effects of erosion also increasingly impacted Dauphin Island.  The consequences of the ongoing erosion stretch from Dauphin Island’s eastern end where another one of Alabama’s significant historic resource is located, Fort Gaines, throughout the entire 14-mile length of the island.  Erosion of Dauphin Island’s already narrow elongated western end has reduced the island’s width and overall elevation to such an extent that even moderate tropical systems now frequently wash over this area.  As the island continues to weaken, breaching of the island during storms and hurricanes has become more commonplace, with these breaks in the island threatening to become permanent features as evidenced by Katrina Cut that was created in 2005.

Presently, three factors have acted together to temporarily ameliorate the seriousness of the erosion affecting Dauphin Island: (1) the absence of a severe tropical event since 2005; (2) the ongoing merging of Sand Island with Dauphin Island and the addition of its sand to Dauphin Island; and (3) the berms constructed during the oil spill clean-up activities added much needed sand to Dauphin Island’s Gulf shoreline.  However, the positive effects of these events are only temporary in nature since a major hurricane could erase these improvements in a single event that could occur as early as the upcoming 2012 Tropical Season.  Further, once the reservoir of sand being delivered by the rapidly eroding Sand Island is completely absorbed within Dauphin Island, the supply of sand coming from the east will be greatly reduced if not essentially exhausted.

It also significant to note that what happens to Dauphin Island also influences the physical condition of its sister barrier island’s in Mississippi to the west.  Much of the sand that naturally nourishes these islands originates from Dauphin Island.  As Dauphin Island has diminished in size, so have Petit Bois, Horn, Ship, and Cat Islands since the same deficiency of sand in the littoral drift system is also influencing those islands as pointed out in the scientific literature.

Causes of Dauphin Island’s Erosion

Sea level rise, storms, and development are blamed to varying degrees for coastal erosion nationwide.  However, in the case of Dauphin Island, most coastal experts agree that disposal practices associated with maintenance of the Mobile Harbor Outer Bar Channel are directly responsible for a significant portion of Dauphin Island’s erosion problems.  Regardless of the exact cause of the erosion, Dauphin Island is literally being “starved” of sand.  Sand removed from the channel during dredging is deposited at locations outside of the major zone of influence affected by the natural littoral drift system that is driven by waves and longshore currents.  The natural littoral drift system is responsible for the movement of sand particles along the shoreline.  Removal of sand by dredging from the littoral drift system results in other sand being picked up and carried away.  This results in the erosion of Sand Island and Dauphin Island to the west of the channel.  Among the factors influencing the degree of erosion is the amount and frequency of sand removed by each dredging event.

Settlement of a major lawsuit involving the Federal government in 2010 over dredging practices and changes in the location at which dredged material is now disposed have not measurably reduced the ongoing erosion or replaced the significant quantities of sand that Dauphin Island has lost over the last 40 years.  Unfortunately, to date, Alabama’s State legislative and Federal congressional representatives have been reluctant to push efforts to provide the funds needed to correct the erosion problem.  Their reluctance appears to be based in large part on the belief that such an action would be perceived as primarily benefiting beachfront property owners.  The environmental benefits that would result from a strengthened Dauphin Island have essentially been ignored by Alabama’s lawmakers at all levels.  Further, neither the U.S. Army Corps of Engineers which is directly responsible for maintaining the Mobile Harbor Ship Channel nor the Alabama State Port Authority which directly benefits from the channel project has initiated actions to pursue a solution to the erosion problems affecting Dauphin Island.  In short, all of Alabama’s politicians and both State and Federal governmental entities having the ability to address the erosion problem continue to ignore the issue because of the expense of a solution and the shared narrow belief that only a few private beachfront owners are being impacted.  They and the wider universe of interests fail to understand the immense environmental benefits Dauphin Island provides to Alabama by its very presence and to appreciate the threats posed to the continued realization of these benefits if erosion is allowed to further weaken the island.

Importance of Dauphin Island to Alabama’s Estuarine Ecosystems

This brings us to the question: Why is Dauphin Island important enough to Alabama that its erosion problem should be addressed with NRDA funds?  The value that a strong Dauphin Island provides to the coastal mainland communities of Alabama Port, Coden, and Bayou la Batre by protecting them from the full force of major tropical storm events is well understood.  However,  Hurricane Katrina in 2005 and the Deepwater Horizon disaster in 2010 also demonstrated the importance of Dauphin Island from environmental perspectives.

The Katrina Cut created in 2005 by the hurricane of the same name allowed higher saline waters of the open Gulf to modify the salinity regime in a large portion of Mississippi Sound and lower Mobile Bay.  The increased salinities were just high enough to contribute to the essential elimination of all oyster production from Alabama’s principal reefs for at least six years.  It was not until the Cut was closed as part of the emergency recovery oil clean-up efforts that commercial oyster harvest on some of these reefs was allowed to resume.  If not for that fortuitous by-product of the Deepwater Horizon disaster, Katrina Cut would still be open today and commercial oyster production would still be non-existent on Alabama’s historically most productive reefs.

The impacts of the oil spill also demonstrated another aspect of the role that a strong Dauphin Island can play as a barrier in protecting Alabama’s important western estuarine resources.  During the Deepwater Horizon disaster, Dauphin Island served as the principal bulwark that prevented the spread of surface and subsurface oil contaminants into and throughout Mississippi Sound and lower Mobile Bay.  Serving as the “first line of defense”, Dauphin Island’s shorelines absorbed both the direct effects of the contaminants, as well as the recurring impacts associated with the resulting clean-up efforts.

Lastly, the shelter from the waves of the open Gulf provided by Dauphin Island is essential to creating the physical conditions conducive for the existence and maintenance of Alabama’s most extensive expanse of continuous salt marsh in the State.  The potential benefits of the proposed Portersville Bay Marsh Island Creation and Protection Project pale in comparison to the adverse impacts that could occur should an extensive breach be formed in an erosion-weakened Dauphin Island during a future large hurricane event.  Such a breach would expose the State’s mainland marshes to the full force of the waves from the open Gulf and erode large areas of coastal marsh.  This is far from a hypothetical possibility as evidenced by Katrina Cut that severed the island in half in 2005.  The well-documented deficiency of sand in the Alabama’s coastal littoral drift system indicates a storm-created breach condition can approach a permanent condition as shown by events during the 2000 decade.

A NRDA Project to Restore Dauphin Island’s Shoreline is Needed

The NRDA Trustees have it within their power the ability to develop and recommend a restoration project offering the scope of broad, diverse, and large scale environmental benefits that are justified to mitigate for the equally large scale impacts that resulted from the oil spill disaster.  Such a project would involve restoration of Dauphin Island’s significantly eroded shoreline to enhance the island’s strength to allow it to continue to serve as an effective barrier between the Gulf of Mexico and the Mississippi Sound and Mobile Bay.  Such a project would provide great long-term benefits to Alabama’s and Mississippi’s estuarine resources occurring within Mississippi Sound.

To summarize, implementation of a Dauphin Island restoration project would provide the following environmental benefits:

  • Strengthen Alabama’s only barrier island.

  • Contribute to maintaining the integrity of Mississippi’s neighboring barrier islands through sand moved westward via littoral drift.

  • Protect Alabama’s largest continuous salt marsh habitat in Mississippi Sound.

  • Protect Alabama’s most significant oyster reefs occurring in Mississippi Sound.

  • Contribute to the protection of Mississippi’s neighboring marsh and oyster habitats
    Protect the shallow inshore estuarine habitats of Mississippi Sound, that serve as important nursery areas for a wide range of commercially and recreationally valuable species that dependent upon this habitat.

  • Assist in blunting the full force of tropical storms and hurricanes that impact upon the mainland’s coastal communities.

  • Provide improved habitats for endangered and threatened nesting sea turtles on Dauphin Island.

  • Enhance shoreline habitats required by the endangered piping plover and other shore birds.

Design Information Essential for a Shoreline Restoration Project Already Exists

Information essential to developing and pursuing a shoreline restoration project is already available.  The Town of Dauphin Island completed a $1.9 million study in 2011 that developed the necessary engineering and design data and information, including the location of suitable offshore sand sources.  The Town’s study evaluated three alternatives, having costs ranging from a low of $26 million to a high of $71 million.  The ready availability of recently completed design information would allow a shoreline restoration project to be pursued for Dauphin Island with a minimum of upfront engineering work of the scope typically required for such projects.  Further, the Town has also begun the permit application process to better prepare a shoreline restoration project for immediate construction should funding become available.  All that is needed for construction to begin is funding.  One last point that should also be made is that the Dauphin Island Property Owners Association has almost $1.5 million under its control that could potentially be added to any NRDA funds made available for a shoreline restoration project. 

Considering the above costs and other information, it is apparent that compared to the $9.6 million proposed for the relatively small Portersville Bay marsh creation project, a shoreline restoration project for Dauphin Island would produce much greater environmental benefits that would positively affect a greater area of Alabama’s estuarine environment in Mississippi Sound and lower Mobile Bay.  Thus, such a project should provide from an environmental standpoint a greater return on investment for the NRDA dollars that would be required. 

Request

This is to request the NRDA Trustees to include a project entitled “Restore the Dauphin Island Gulf Shoreline” in the array of restoration projects selected for implementation.  Sufficient NRDA funds are available to accommodate such a worthy project and the environmental benefits that would be produced should justify their expenditure for that purpose.

Thanks in advance for considering this letter.  I very much appreciate the opportunity to provide these comments and I am grateful for the important and difficult work the NRDA Trustees and your respective staffs are doing. 

Sincerely,

Glendon L. Coffee
Dauphin Island Property Owner and Resident

cc:

Mr. Ben Frader
NRDA Field Office
U.S. Fish and Wildlife Service
P.O. Box 2099
Fairhope, AL  36533

Mr. David G. Westerholm, Director
Office of Response and Restoration
National Oceanic and Atmospheric Administration
1305 East West Highway, SSMC 1 Room 10102
Silver Springs, MD 20918

Dr. Barry H. Tew, Jr.
Geological Survey of Alabama
P.O. Box 86999
Tuscaloosa, AL  35486-6999 

Ms. Cynthia K. Dohner, Southeast Regional Director
U.S. Fish and Wildlife Service
1875 Century Blvd NE, Suite 400
Atlanta, GA  30345 

Ms. Patti Powell, Director
State Lands Division
Alabama Department of Conservation and Natural Resources
64 North Union Street
Montgomery, AL  36130 

Mr. Will Brantley
State Lands Division – Coastal Section
Alabama Department of Conservation and Natural Resources
31115 Five Rivers Blvd
Spanish Fort, AL  36527

Mr. Chris Blankenship, Director
Marine Resources Division
Alabama Department of Conservation and Natural Resources
P.O. Box 189
Dauphin, AL  36528

 

Copyright © Dauphin Island Restoration
 

 

 

 

Copyright © Dauphin Island Restoration