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Final Integrated General Reevaluation Report II

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APPENDIX K PUBLIC AND AGENCY COMMENTS ON JACKSONVILLE HARBOR NAVIGATION STUDY DRAFT INTEGRATED GENERAL REEVALUATION REPORT II AND SUPPLEMENTAL ENVIRONMENTAL IMPACT STATEMENT INCLUDES USACE RESPONSES TO COMMENTS JACKSONVILLE HARBOR NAVIGATION (DEEPENING) STUDY DUVAL COUNTY, FLORIDA THIS PAGE LEFT INTENTIONALLY BLANK USACE Responses to Public and Agency Comments on the Jacksonville Harbor Navigation Study Draft Integrated General Reevaluation Report II and Supplemental Environmental Impact Statement (IGRR II/SEIS). Please note that some comments have been summarized or consolidated. All comments received on the IGRR II/SEIS are included in this appendix. Public Comments (Non-Governmental Organizations [NGO]) St. Johns Riverkeeper • The Draft Supplemental Impact Statement (DSEIS) underestimates the environmental Impacts (including salinity, residency time, threatened and endangered species, sedimentation, storm surge, aquifer impacts, shoreline erosion, offshore disposal expansion, air quality). Salinity RESPONSE: The effects of proposed project alternatives on salinity are based on application of a Lower St. Johns River (LSJR) hydrodynamic model developed, calibrated, and verified by the St. Johns River Water Management District (SJRWMD). The model, refined for the Jacksonville Harbor deepening evaluations, provides the best available estimate of salinity changes that may occur with any of the project alternatives. As the results of additional modeling and analyses were compiled, it became apparent that salinity impacts reported in the DSEIS had overestimated potential impacts not underestimated potential impacts. Residency Time RESPONSE: The effects of proposed project alternatives on water residence time are based on application of a LSJR hydrodynamic model developed, calibrated, and verified by the SJRWMD. The model, refined for the Jacksonville Harbor Deepening evaluations, provides the best available estimate of water residence time changes that may occur with any of the project alternatives. Threatened and Endangered Species RESPONSE: In compliance with Section 7 of the Endangered Species Act, the USACE prepared a biological assessment that assesses the potential effects of the proposed project and is coordinating the effects of the proposed deepening with the US Fish and Wildlife Service (USFWS) and National Marine Fisheries Service (NMFS). The deepening would be constructed in accordance with the terms and conditions established by these agencies. Additional information on the US Army Corps of Engineers (USACE) effects determinations on threatened and endangered species can be found in Chapter 7 of the Supplemental Environmental Impact Statement (SEIS). 1 Sedimentation RESPONSE: The effects of the project on currents and sediment transport, shoaling, and erosion are presented in the Adaptive Hydraulics (AdH) hydrodynamic and sediment transport modeling and analysis located in Appendix A- Engineering, Attachment G. Hydrodynamic Modeling for Ship Simulation, Riverine Channel Shoaling and Bank Impacts. The AdH sediment transport model simulated the bed level changes for both existing and with-project (47-ft depth) conditions. The with-project condition results in an overall increase in shoaling volume by approximately twenty percent. The AdH hydrodynamic and sediment transport modeling and analysis provides the best available estimate of accretion/erosion changes that may occur with the project. Storm Surge RESPONSE: The effects of the proposed project on storm surge are based on the Federal Emergency Management Agency’s (FEMA) Georgia Northeast Florida storm surge study methodology. The application of the Advanced Circulation (ADCIRC)+Simulating Waves Nearshore (SWAN) hydrodynamic and wind-wave models, refined for the Jacksonville Harbor Deepening evaluations, represents the best available estimate of storm surge changes that may occur due to the proposed project. Aquifer Impacts RESPONSE: The USGS groundwater modeling looked at several possible geologic scenarios to test the susceptibility of the surficial aquifer to salinity impacts. The geologic scenarios ranged from simple to complex based on uniform subsurface conditions and available information, not actual conditions. We know that the rock for the surficial aquifer is not uniformly distributed throughout the area and that the permeability varies. Therefore, the modeling using the simplified geology over estimates the impact compared to actual conditions. Even using the uniform distribution of rock and permeability, the modeling shows a maximum impact that extends an additional 75 feet to the north on USGS section d. This area is adjacent to the channel and has been exposed to high salinity over a very long time so that an increase of 4 parts per thousand (ppt) is not significant. Results from testing this area reported in 1983 showed chloride concentrations over 2800 mg/L in the limestone unit. (Spechler and Stone, 1983, “Appraisal of the Interconnection between the St. Johns River and the Surficial Aquifer, East-Central Duval County, Florida). Shoreline Erosion RESPONSE: The USACE does not anticipate increased shoreline erosion as a direct result of the construction of the Jacksonville Harbor project based on analyses of the predicted changes in current velocities along the project (determined to be negligible), changes to the tide range (average of 2 inches or less), a side slope analysis of the predicted channel slopes relative to the existing shoreline (no direct impact), and an analysis of ship wake height generated by the design vessel transiting the new channel generally 2 show that the ship wake and affect on water stages at the river banks tend to diminish under the with-project condition. Offshore Disposal Expansion RESPONSE: As part of the deepening study, the USACE has determined that placement of dredged material within an Ocean Dredged Material Disposal Site (ODMDS) would be the least- cost disposal method. Dredged material may also be placed at Buck or Bartram Islands, the beach placement location south of the river mouth, and the nearshore next to the beach placement location. The USACE also continues to investigate additional beneficial uses of dredged material. The US Environmental Protection Agency (USEPA) has prepared a draft EIS on a new ODMDS that would have sufficient capacity to accept dredged material resulting from the deepening. The draft EIS can be obtained through the USEPA. Air Quality RESPONSE: The air quality analysis provides the most detailed inventory of existing conditions and the most detailed estimate of future emissions ever conducted for the Jacksonville Harbor. All available data has been used in estimating the current and future discharges. The future discharges are based on the available data, current and upcoming regulatory limits, and port growth projections developed as part of the USACE National Economic Development analysis performed for this SEIS. Air emissions were estimated from nine different sources directly associated with operations of the harbor. The total emission load included emissions from the three JAXPORT terminals and the 13 private terminals located within the harbor. The emission inventory included the ocean-going vessels that call at various terminals within the harbor, the tugs that assist these vessels, the landside equipment that moves the cargo in the terminals, ancillary vessels which operate in the harbor (dredges and river ferry boats), and equipment used to move containers out of the harbor area. The analysis considered six categories of pollutants, known as “criteria pollutants”: particulate matter less than ten microns and two and a half microns in diameter (PM10 and PM2.5), sulfur dioxide, nitrogen oxides, hydrocarbons, and carbon monoxide, carbon dioxide, and volatile organic carbons. In addition, the analysis included a limited assessment of air toxins, and assessed the presence of sensitive receptor sites within 1500 ft of the borders of JAXPORT. The Jacksonville region is in attainment of USEPA air quality standards. This means that concentrations of criteria pollutants are below the levels established by the National Ambient Air Quality Standards (NAAQS). Estimated future emissions do not alter that air quality attainment status. The analysis provided by the USACE is more than adequate to assess the likely effects of additional vessel traffic and cargo activity with a deepened Jacksonville Harbor. 3 • The DSEIS overstates the economic impacts (including overstating the benefits, created jobs, justification of the Locally Preferred Plan). RESPONSE: The regional economic development account displays changes in the distribution of regional economic activity (e.g., income and employment). It is one of the four accounts outlined in the USACE Principles and Guidelines (P&G). The first two accounts are national economic development and environmental quality, one or both of these are required for determining the recommended plan. The other two accounts, regional economic development and other social effects, are discretionary; these accounts are used to show beneficial effects of alternatives. They are not used to determine or justify a recommended plan. As such, the information on projections of jobs has been removed from the report and replaced with a qualitative analysis. • On-going maintenance costs have been ignored. RESPONSE: Section 6.5 of the main report as well as Appendix J (DMMP) discusses the on-going maintenance costs. • The DSEIS proposes a mitigation plan that is woefully
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