October 13, 2006
Beth Dieveney
U.S. Coral Reef Task Force Coordinator
Coral Reef Conservation Program
1305 East-West Highway
Silver Spring, Maryland 20910
via fax to 301-713-4389, email to beth.dieveney@noaa.gov and by U.S. Mail
Re: Public Comments for U.S. Coral Reef Task Force Meeting October 25, 2006 in St. Thomas, U.S. Virgin Islands
Dear Ms. Dieveney:
The following comments are presented to the U.S. Coral Reef Task Force on behalf of the thousands of members of Reef Relief , a non profit grassroots membership organization dedicated to “Preserve and Protect Living Coral Reef Ecosystems through local, regional and international efforts.” Reef Relief has been a watchdog for coral reefs for the past 20 years and hopes that you will consider and act on the following recommendations for saving endangered coral reefs in Florida and around the world:
1. Keep Offshore Oil Drilling away from Florida’s Coast. Consider the attached Resolution to Protect the Coral Reefs of the Florida Keys and Florida’s Coast from the Threat of Offshore Oil & Gas Development. For the past 25 years, fragile coral reefs and beaches in Florida have been protected from such development and are currently under Presidential and Congressional moratoria. But dangerous new legislation in the U.S. Congress proposes to open up Lease Sale 181 and coastal areas to offshore oil and gas development.
This area of the Eastern Gulf of Mexico is subject to the Gulf Loop Current, which oceanographers tell us would carry routine and very toxic drilling muds, along with any accidental oil spills, right into the nursery and breeding grounds for conch, spiny lobster and shrimp in the Lower Florida Keys. The current–and any pollutants it carries--would join the mighty Gulfstream around the southern tip of Florida and flow north over the reef tract where our endangered coral reefs are struggling to survive. Please add your name to the list of concerned citizens, elected officials, chambers of commerce, tourism and lodging associations, and newspaper editorials recommending against this ill-advised course of action.
2. Prevent the Everglades Restoration Plan from destroying Florida’s coral reefs. Recommend that an enforceable nitrogen standard be established and implemented into the Comprehensive Everglades Restoration Plan designed to save the Everglades. Reducing nitrogen is the only way to save the downstream coral reefs of the Florida Keys. Current plans to address only phosphorus are incomplete. Just as for sewage treatment, nitrogen and phosphorus must be removed from the agricultural and stormwater runoff that reaches Florida Bay and North America’s only living coral barrier reef.
The nutrient loading running into the Bay and onto the reefs from the Everglades is the largest regional source of pollution to the coral reefs of the Florida Keys. It dwarfs the nutrient inputs from inadequate wastewater treatment, yet citizens of the Keys are paying big dollars to upgrade their sewage treatment to advanced, nutrient-stripped levels to protect our surrounding coral reefs. The actions of our federal/state partnership to save the Everglades should not come at the expense of the downstream coral reefs. Please issue a recommendation to clean up the runoff before it reaches our endangered coral reefs.
3. Reduce the pollution that degrades Florida’s coral reefs and coastal waters. Last year, there were 677 closing and health advisory days posted for beaches in the Florida Keys, compared to 398 in 2004 and 346 in 2003, according to the annual NRDC beach report entitled Testing the Waters. In Florida, for the first time this year, red tides occurred at Keys coral reefs and there were more fish kills and discolored waters attributed to red tides in the first three months of 2005 than during the same time period in four of the previous five years. The blooms are worsening and are linked to wastewater discharges and other nutrient sources linked to nearshore sources of man-made pollution, rather than offshore, as previously thought.
Please do your part to encourage Florida’s state and federal leaders to halt efforts to weaken water quality standards. In particular we should upgrade and enforce water quality standards for treatment of wastewater and stormwater to advanced nutrient removal for any area near coral reefs. Any wastewater injected underground into wells should be treated to this same high standard. Corals cannot tolerate nutrients from such pollution and the harmful algal blooms and toxic red tides they sponsor threaten Florida’s coral reefs.
These first three recommendations are included in the recently-released Florida’s Coastal and Ocean Future: A Blueprint for Economic and Environmental Leadership, authored by eight leading marine conservation organizations, including Reef Relief. It is available online at reefrelief.org. We fully endorse all of the recommendations of this paper and urge you to review and endorse it.
4. Establish an effective Habitat Conservation Plan for Elkhorn and Staghorn corals as part of the designation process for their listing on the U.S. Endangered Species List.
Acropora palmata and A. cervicornis corals were added to the Endangered Species Act’s list of threatened species on May 9, 2006. The National Marine Fisheries Service is currently developing a habitat conservation plan to save these corals.
We ask you to recommend that the following actions be included in the habitat conservation plan for A. plamata and A. cervicornis corals in the Florida Keys; Broward County and Palm Beach County, Florida; U.S. Virgin Islands and Puerto Rico:
Reduce global warming; reduce sea temperature change: Encourage renewable energy use:
* Promote solar energy especially throughout Florida
* Prevent coal burning energy plants from being built in Florida
* Encourage use of ethanol instead of gasoline; provide incentives for a distribution system
* Encourage energy conservation; car pooling, smaller energy efficient vehicles, bikes, walking, etc.
* Encourage use of energy efficient boat engines, use of fueling hydrocarbon pillows that reduce accidental spills
Prevent agricultural runoff from reaching coral reefs in the Florida Keys and other coral reefs, especially from Florida Bay and the Everglades.
* Treat the runoff to remove harmful pesticides and nutrients prior to releasing it into canals that run into Florida Bay
* Consider purchasing the areas that are most directly linked with pollutant discharges, e.g. sugar growing areas, and turn them back into natural filtering marshes/wetlands.
* Eliminate tax subsidies for sugar production
* Don’t permit any new development in South Florida and other areas near coral reefs that does not contain and treat its stormwater runoff.
Upgrade sewage treatment to advanced nutrient removal levels for any areas adjacent to coral reefs, including the Florida Keys, Broward, Dade, Palm Beach coral reef areas.
* Provide federal funding to help fund such projects. e.g. NOAA Water Quality Protection Plan,
SFWMD, USACOE
* Require tertiary nutrient-stripping wastewater treatment in all comprehensive land use plans for areas near coral reefs
* Enforce the regulations already in place that prohibit the discharge of sewage into the ocean,
e.g. Keys No Discharge Zone, FKNMS sanctuary regulations
* Stop permitting deep injection of secondarily-treated waste in South Florida and other areas near coral reefs
* Prohibit direct ocean discharge of sewage in all areas near coral reefs, especially South Florida
* Expand the Keys No Discharge Zone to the federal sanctuary waters of the Florida Keys National Marine Sanctuary. This complies with their current regulations against discharging pollutants.
Enforce current state and federal environmental regulations and fisheries management regulations, e.g. FKNMS management plan regulating recreational and commercial activities, federal and state fisheries regulations, Clean Water Act, Florida State laws for Keys Area of State Critical Concern & protection of Outstanding Florida Waters, regulations for the Keys regarding shallow injection wells (effluent discharged into any shallow injection well in the Monroe County shall meet or exceed outstanding Florida Waters designation for receiving waters).
The U.S. Coral Reef Task Force has an opportunity to help reverse the decline of the world’s coral reefs by calling on responsible parties to take meaningful action to save them. Our quality of life, our commercial fishing and tourism industries, and the many endangered species that depend upon coral reefs for habitat, are all at risk now. Your immediate attention to these recommendations are respectfully submitted for your consideration. We have no time to waste.
Very truly yours,
DeeVon Quirolo
Executive Director
Attached: Resolution opposing Offshore Oil & Gas near Florida
Resolution of the U.S. Coral Reef Task Force Opposing Offshore Oil & Gas Exploration and Development in areas affecting Florida’s Coral Reefs
Whereas, the Eastern Gulf of Mexico and areas south of Latitude 26 North have been under protection from offshore oil and gas exploration for the past twenty-five years through successive U.S. Congressional and Presidential moratoria; and
Whereas, legislation is pending in the U.S. Congress that would lift this protection and open up the Eastern Gulf of Mexico and areas offshore of the state of Florida to offshore oil and gas exploration and development; and
Whereas, the U.S. Minerals Management Service Five Year Plan for 2007---2012 would open up 21 lease sales in the Eastern Gulf of Mexico; and
Whereas, the Gulf Loop Current in the Gulf of Mexico would carry routine and harmful drilling muds and any accidental spills from these areas into the Lower Florida Keys where commercial shrimp and lobster breed, and then be carried by the Gulfstream up the oceanside of the Florida Keys, home to North America’s only living coral barrier reef, the 3rd longest coral reef in the world and among the most endangered; and
Whereas, the economy of the Florida Keys is dependant upon tourism and commercial fishing and this marine ecosystem enhances our quality of life through boating, diving, fishing, and nature experiences and provides habitat for many endangered species such as sea turtles and conch as well as the recently listed elkhorn and staghorn corals; and
Whereas, a large reserve has been recently discovered in another area of the Gulf of Mexico that alleviates the pressure to open up fragile marine areas in the Eastern gulf to oil and gas exploration and development; and
Whereas, energy conservation and increased fuel efficiency standards for automobiles would result in a greater savings that all the oil and gas reserves in the Eastern Gulf; and
Whereas, adoption of alternative fuels such as ethanol and biodiesel would strengthen our country and support our economy and reduce our dependence on foreign oil; and
Whereas, the U.S. Coral Reef Task Force is mandated to act upon issues of concern to coral reefs and this qualifies as an urgent concern inasmuch as offshore oil would result in significant damage to the coral reef ecosystems of the Florida Keys, if allowed to occur;
Now therefore, the U.S. Coral Reef Task Force resolves as follows:
Consistent with our mandate, we support protection for Florida’s coral reef ecosystem and express our concern by recommending against new offshore oil and gas exploration and development in the Eastern Gulf of Mexico, including additional efforts to expand exclusionary zones, extend Presidential and Congressional moratoria, and defeat legislation to open up areas near Florida’s coral reefs to offshore oil.
Florida’s coral reefs, mangroves, seagrasses, beaches, fisheries, endangered species, tourism and quality of life all depend upon clean ocean waters and healthy coral reefs. Please do your part to protect them from the impacts of drilling muds and spills, which can be carried by great distances by the Gulf Loop Current onto Florida’s coasts. Routine drilling muds release thousands of pounds of toxic chemicals into the environment and harm fish, corals and marine mammals. They place Florida at risk of a large or catastrophic spill.
We encourage you to:
*Oppose any new offshore oil and gas leasing, exploration, drilling activity and seismic inventories affecting Florida’s coast.
* Permanently cancel the 90+ existing and active leases, some as close as 11 miles from our coast. Compensate the holders of those leases through rents due and royalty forgiveness for other current drilling activity.
* Support new Congressional moratoria against offshore oil drilling near Florida and other fragile coastal areas.
* Encourage extension of the Presidential Executive Order that bans leasing off America’s east and west coasts and parts of Alaska from 2012 to 2020.
* Cancel any activity in Lease Sale 181 and establish a 150 mile buffer zone against drilling on Florida’s east coast. The Martinez/Nelson bill, otherwise know as Senate Bill 2239 has the support of many. We encourage you to work for the strongest possible protections and larger exclusionary zones via this legislation. We oppose Interior’s new 5 Year Plan for 2007—2012 that would offer 21 lease sales in the Eastern Gulf of Mexico and we oppose the Domenici bill, Senate Bill 2253.
* Encourage the adoption of renewal energy sources such as solar, ethanol and biodiesel, and further conservation of our energy use.
A copy of this resolution shall be sent to:
President George Bush, The Capitol, Washington, D.C.
Honorable Senator Bill Nelson, 716 Hart Senate Office Building, Washington, D.C. 20510
Honorable Senator Mel Martinez, 317 Hart Senate Office Building, Washington, D.C. 20510
Honorable Representative Ileana Ros-Lehtinen, 2160 Rayburn Building, Washington, D.C. 20515
Governor Jeb Bush, The Capitol, Tallahassee, Florida 32301
Renee Orr, 5 Year Program Manager, Minerals Management Service (MS-4010), Room 3120, 381 Elden Street, Herndon, Virginia 20170
Approved this _____ day of October, 2006.
By: _____________________________________