Don't Allow Dredging of Seagrass Meadows

Open Letter To South Florida Water Management District:

I am writing in regards to the ERP permit application 080610-13 to dredge an entrance channel to Walker’s Island. I am vehemently opposed to such a proposition. The area surrounding Walker’s Island is a seagrass meadow, rich in biodiversity, and its waters are within the Florida Keys National Marine Sanctuary (FKNMS) which prohibits dredging.

US Fish and Wildlife states that “from the 1920s to the 1960s, Florida’s coastal zone underwent tremendous alterations as a result of the lack of proper management of its explosive population increase…Channels were dredged through seagrasses to provide navigational access to and from waterfront properties…Such rampant dredge and fill activities resulted in the destruction of seagrass beds throughout South Florida”.[1] 

In response, US Fish and Wildlife adapted a Multi-Species Recovery Plan for South Florida that included implementation of several protective and restorative measures to reduce the rate of habitat loss within South Florida. Such measures include the regulation of dredge and fill activities by establishing management entities designed to preserve and protect biologically unique areas such as national marine sanctuaries.[2]

The FKNMS 2011 Condition Report reports that  “The Florida Keys and their environs have a long history (>100 years) of exploitation, thus many pressures on sanctuary resources are chronic…  Resource managers are working to conserve pieces of the former system so that it can be restored to an improved (pre-exploitive) state.”  [3] The applicants argument  that this area was dredged 60 years ago (but then abandoned)  and therefore has some sort of right to be “re-dredged” again is in direct conflict with this mission. The very reason the sanctuary came into existence  was to stop such “historical” activities and provide enhanced resource protection.

US Fish and Wildlife also has concerns for seagrass communities in private ownership because they do not have the unique resource designations that other areas have within South Florida and therefore require even greater attention. [4] Although this submerged land is privately owned it is still within the waters of the FKNMS.

In addition to sanctuary protections this area has a  designation  as an “Outstanding Florida Water (OFW)… worthy of special protection because of its natural attributes. Waters are designated OFW to prevent the lowering of existing water quality and to preserve the exceptional ecological and recreational significance of the waterbody.” [5] Dredging and induced boat traffic would have a negative impact on this objective. Seagrass meadows are essential in maintaining  water quality, supporting fisheries, and are necessary to the health of coral reefs.[6]

This applicant presents this dredge project as necessary to avoid prop scarring and cites the Everglades  National Park (ENP) prop scar study for support. But in fact the study found that prop scarring took place near marked as well as unmarked channels.[7]   The ENP general management plan that is presently under review has recommended (based on the prop scar study) to close down seagrass flats to motorized boating activity. [8]

The area targeted for dredging has a natural tendency to restore itself and  the applicant recognizes a need to dredge again and again every so many years to keep the channel open.

Not only will the initial dredging project unavoidably destroy the continuity of the existing seagrass meadow but the never-ending need to dredge repeatedly will generate chronic stress on this valuable and productive ecosystem that I doubt it can tolerate.

The Florida Keys chronic mismanagement of their natural resources is why they were designated an Area of Critical State Concern in 1974 and of which they are still designated. This status provides the Governor and Cabinet oversight on local land use decisions made by the local government. The purpose being to protect wildlife refuges, state parks, aquatic preserves, coral reef systems, and wetlands from adverse impacts. Monroe County today does not allow dredging of submerged lands with benthic resources as a result. In order to get around Monroe County restrictions to dredge, this applicant is pursuing a text amendment change to the Monroe County Comprehensive Plan.

If these efforts (SFWMD permit & Monroe County Comp Plan amendment) were to succeed it would  provide a procedure for others within the FKNMS to also dredge submerged lands with benthic resources effectively wiping out all the efforts to date to stop the destruction and exploitation of  our coastal habitats.

I cannot see how this permit can be issued without violating every county, state and federal law. We have come far but have farther to go in protecting our vulnerable and declining marine ecosystem. Please do not allow the Florida Keys to go backwards in this effort. Do not issue this permit and return the Florida Keys to the days of dredge and destroy.

Thank You

Dottie Moses

Island of Key Largo Federation of Homeowners Association

Environmental Committee