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JAXPORT wants to deepen the last 13 miles of the St. Johns River from 40 to 47 feet for bigger ships. By digging a deeper channel, are we also making our communities more vulnerable to flooding and digging a deeper hole for taxpayers and the St. Johns River?
St. Johns RIVERKEEPER has serious concerns that:
- The impacts to the river have been significantly underestimated,
- The economic and environmental risks have been ignored or downplayed,
- The projected economic benefits have been dramatically overstated,
- The proposed mitigation is woefully inadequate, doing nothing to offset the damage to the river,
- The Army Corps of Engineers (ACOE) analysis is incomplete, failing to fully assess tributary impacts or conduct a multi-port analysis or flood analysis, and
- The project has not been been thoroughly evaluated and publicly vetted.
- Thirteen miles of the river would be deepened, from the mouth of the St. Johns River to just west of the Dames Point Bridge near Blount Island.
- Two areas of the channel close to Chicopit Bay and Ft. Caroline National Memorial would be widened.
- The project requires the removal of 18 million cubic yards of dredged material, the equivalent of over 1.6 million dump truck loads, that will be placed in a newly created Offshore Dredged Material Disposal Site (ODMDS), located in the Atlantic Ocean southeast of the mouth of the river.
- The Environmental Impact Study (EIS) was fast-tracked by President Obama’s “We Can’t Wait Initiative,” reducing the timeframe by 14 months and limiting the ability of the Corps to thoroughly evaluate this complex issue.
- The Army Corps of Engineers says the dredging will cost over $684 million, but "when other associated costs are included (e.g. local service facilities and aids to navigation are included) the total project cost is $766 million." Additional infrastructure needed by JaxPort to meet its growth goals will increase the total cost of the project to well over $1 billion.
- JaxPort began dredging in February 2018, without any guarantee that future funding will be available to complete the project.
The St. Johns River currently suffers from numerous unresolved pollution problems. The Deep Dredge would cause significant additional harm to the health of the St. Johns, while providing no mitigation to offset the damage. This would only make it much more expensive and difficult to restore the health of our river.
- Salinity will move farther upstream, impacting hundreds of acres of wetlands and submerged aquatic vegetation (SAVs) and killing or stressing numerous trees in some sections of the river. Critical habitat for fisheries and pollution filters for our river will be lost. Read this article to learn more about the impacts of increased salinity on wetlands, riparian forests, and floodplains. Also, watch this short video with wetland scientist, Robin Lewis.
- The most significant impacts to wetlands are expected to occur along the St. Johns, within the Ortega River, Julington, Durbin, and Black Creeks.
- Dredging will increase the risk of flooding in low-lying areas. Increased flooding will result in more sewage spills and pollution events in the river. The Army Corps has determined that storm surge and water levels in the river will increase after dredging, yet the agency refuses to conduct a flood analysis to assess the impacts from flooding. Read the special report, As the Ocean Creeps In, by the Florida Times-Union.
- As water remains in the river longer, concentrations of pollutants and toxic algal blooms will likely increase.
- Larger ships will create larger wakes, increasing the likelihood of shoreline erosion. This will impact riverfront property owners and conservation areas, such as the Timucuan Preserve.
- The mitigation plan is woefully inadequate, failing to offset the damage incurred from dredging.
- The U.S. Fish and Wildlife Service and the Florida Fish and Wildlife Conservation Commission have expressed concerns regarding the potential impacts to threatened and endangered species from the blasting that will be necessary.
- The Army Corps acknowledges the limitations of its models: "Actual conditions will deviate from those used to drive the models. These deviations introduce additional uncertainty in the models’ ability to predict future conditions and impacts."
- The models estimate the exact same impact to wetlands (394.57 acres) and submerged aquatic vegetation (180.5 acres) for every depth analyzed (44, 45, 46, 47, and 50-ft deep channel).
- The Independent Expert Peer Review (IEPR) of the Environmental Impact Statement (EIS) raised significant concerns stating that the analysis of salinity results “provide an incomplete understanding of the impacts of channel enlargement" and the sediment modeling results “do not provide a reliable estimate of the annual sedimentation rates” and “are assumed to be unreliable indicators of future conditions."
- The surficial aquifer could potentially be exposed to saltwater intrusion from the blasting and removal of bedrock.
- The Army Corps study is incomplete, failing to fully assess the potential impacts to the river and its tributaries.
The Army Corps of Engingeers has a long track record of environmental miscalculations. Read more. The recent dredging of Biscayne Bay by PortMiami resulted in widespread damage to threatened coral. A study found that sediment spread across an area about 14 times bigger than what was allowed under a Corps permit, causing coral to die. The Florida Times-Union also recently released a special report, The Cautionary Tale of Mill Cove – How a crown jewel of the St. Johns River vanished after engineers redrew its course.
How Will Dredging Impact Fisheries? by Dr. Clay Montague
How Will Dredging Impact Sea Level Rise? by Dr. Jeremy Stalker
How Will Dredging Impact Algal Blooms? by Robert Burks
A recent economic analysis found that the economic benefits projected by the Army Corps of Engineers' are unrealistic and overstated, concluding that the proposed dredging is "economically infeasible." The prospects of Jaxport outcompeting its competitors, like Savannah, for the bigger ships is also highly unlikely. With a total price tag of well over $1 billion, taxpayers could be left with a boondoggle and irreversible damage to the St. Johns River.
- Dr. Asaf Ashar, an independent consultant and Research Professor (emeritus) with the National Ports & Waterways Initiative at the University of New Orleans, analyzed the proposed dredging project and calculated estimated economic benefits that are substantially less than those calculated by the Army Corps. According to Dr. Ashar, JaxPort is likely to remain a secondary port, with or without dredging.
- Based on JaxPort's own strategic plan, it will likely cost well over $1 Billion for JaxPort to potentially achieve its growth goals. In addition to the dredging, JaxPort must invest heavily in landside infrastructure and relocation costs in order to accommodate larger ships and future growth.
- The only job projections are from a study conducted by Martin & Associates, a paid consultant of JaxPort. Nearly 81% of the jobs cited by the study are "related jobs." Yet, Martin clearly states: “It is to be further emphasized that when the impact models are used for planning purposes, related jobs should not be used to measure the economic benefits of a particular project. Related jobs are not estimated with the same degree of defensibility as direct, induced and indirect jobs.”
- Based on the comprehensive analysis by an independent expert, the job and economic projections for the dredging project appear to be unrealistic and significantly overblown. Click here to learn more about the work of Dale Lewis and to watch a compelling video about the challenges Jacksonville faces to compete for market share.
- The Army Corps only evaluated the benefits of larger vessels having access to a deeper harbor. These transportation cost savings would accrue primarily to the shippers and carriers, not the local economy.
- The Independent Expert Peer Review (IEPR) concluded that "The Regional Economic Development (RED) benefits are incorrectly attributed to the harbor deepening and therefore overemphasize regional benefits of the Jacksonville Harbor Project."
- The Army Corps has failed to conduct a multi-port analysis. As a result, the IEPR identified this omission as a “showstopper” issue.
- In its 2012 Panama Canal impact study, the Army Corps wrote that Savannah, Charleston and Miami would be the critical southeastern ports for handling Post Panamax vessel traffic. Other regional ports, such as Jacksonville, should be “cascade ready”.
- According to “The Great Port Mismatch” from the Brookings Institution and JPMorgan Chase & Co., Jacksonville is not one of the top 25 port complexes in the U.S. in terms of total exports and imports by value. However, seven other metropolitan areas on the East Coast made the list, including all of Jacksonville’s major competitors.
- The Savannah Morning News reported that "The ports of New York/New Jersey, Norfolk and Savannah each had 31 calls from 10,000-plus TEU vessels between July 1 and Dec. 31 last year. Charleston saw seven of the big ships during the same time period, while Jacksonville and Miami had none."
- The Army Corps has a poor track record of accurately estimating costs. According to the Florida Times-Union, “The most recent project, which deepened about five miles of the harbor from 38 to 40 feet, cost almost four times what was planned, according to Army Corps documents. In 2003, the corps predicted the project would cost $16.4 million, but when it wrapped up in 2010 the cost ran to $64.8 million." Just recently, the price tag for the Savannah port dredging project that is already underway rose by 38 percent to $973 million.
- Jacksonville already has a significant backlog of unfunded infrastructure projects that includes streets, bridges, sidewalks, drainage, and government buildings. The remediation of failing septic tanks alone is estimated to cost as much as $700 million.
Economic Reassessment of Port of Jacksonville’s Channel, by Dr. Asaf Ashar
Southeastern Container Port Investment and Competition: It Takes Much More than Dredging, by Dale Lewis, a former CSX Director of Strategic Analysis
Does the Deep Dredge Make Economic Sense for Jacksonville?, by St. Johns RIVERKEEPER
JAXPORT as an Urban Growth Strategy: Community Implications and Prospects, by Dr. David Jaffee, UNF Department of Sociology
INDEPENDENT EXPERTS QUESTION STUDY
A Peer Review by a panel of independent experts questions some of the modeling results and conclusions in the Environmental Impact Statement (EIS), raising significant doubts about the thoroughness and accuracy of the evaluation.
Here are some of the findings of the Panel:
- "The analysis and presentation of salinity results in the General Reevaluation Report II (GRR2) provide an incomplete understanding of the impacts of channel enlargement."
- "The adaptive hydraulics (ADH) sediment modeling results do not provide a reliable estimate of the annual sedimentation rates necessary to establish environmental effects and sediment management requirements."
- "Because the period was not shown to be representative of typical conditions and the model [ADH] is not considered validated, the results are assumed to be unreliable indicators of future conditions."
- "The Adaptive Management Plan does not include key elements such as trigger thresholds and specific actions to correct deficiencies."
The peer review experts also took issue with the economic analysis that was conducted.
- "The Regional Economic Development (RED) benefits are incorrectly attributed to the harbor deepening and therefore overemphasize regional benefits of the Jacksonville Harbor Project."
- "According to Section 3.3.4, any RED benefits resulting from increased traffic will occur under the without- and with-project conditions and are not associated with deepening of the harbor."
- "An accurate assessment of the regional economic benefits generated by the proposed project is needed to support the overall understanding of project benefits and of the project’s impact on the regional economy."
- "Federal interest has not been demonstrated in the General Reevaluation Report II (GRR2) because a multi-port analysis assessing competition among regional ports is not provided."
SPECIAL REPORT: AS THE OCEAN CREEPS IN
Florida Times-Union 5.6.18: "In chasing its dreams of a deepwater port, the city has brought the Atlantic Ocean to its doorstep….There is little doubt dredging is one of the major reasons for this….The Army Corps acknowledges in its own analysis that the latest 7-foot dredging project could increase water levels in a 100-year storm surge by 3 to 6 inches in the main stem of the river, and by 8 inches in areas closer to the ocean."
RON LITTLEPAGE: UNELECTED JAXPORT MEMBERS WANT TO WASTE YOUR MONEY ON DREDGING PROJECT
Florida Times-Union 6.20.17: "The people you did elect to make decisions on spending local taxpayer money — the members of the City Council — won’t really have a say in the matter because of the devious funding formula JaxPort is proposing."
RON LITTLEPAGE: THE BIG CON CONTINUES FOR DREDGING THE RIVER
Florida Times-Union 6.13.17: "More than $300 million was needed for the phase-out of septic tanks and another $180 million was needed for storm water improvements. Those projects would improve the health of the St. Johns River. JaxPort wants to divert money from that to dredge the channel and worsen the river’s health, all the while proclaiming how important it is to protect the river. That’s another part of the con."
A DEEP DIVE INTO $484 MILLION DREDGING OF ST. JOHNS RIVER: RETIRED TRANSPORTATION EXECUTIVE SAYS NOT SO FAST
Florida Times-Union 6.12.17 – "He said his goal is to provide city leaders with the full range of costs and benefits so they have a complete picture, not just the best-case scenario that usually gets painted to justify the huge cost of deepening the river. He said when he dug into annual reports by the Florida Ports Council, he found the state’s ports have a dismal track record when it comes to cargo container projections. Over and over again, they made eye-catching predictions that didn’t pan out, but they still kept forecasting accelerated growth."
GUEST COLUMN: RIVERKEEPER SUED TO FORCE AN ADEQUATE ANALYSIS OF DREDGING PROJECT
Florida Times-Union 4.10.17 – "Unfortunately, the Corps’ evaluation remains incomplete, resulting in projected impacts to the river and its tributaries that have been significantly underestimated and a mitigation plan that fails to offset the damage. In addition, JaxPort continues to exaggerate the economic benefits of the project while downplaying the risks to our river and taxpayers. As a result, we are left with no choice but to file a legal challenge of this ill-conceived project."
ST. JOHNS RIVERKEEPER FILES FEDERAL LAWSUIT OVER DREDGING
WJXT Channel 4, 4.7.17 – "We can't afford to roll the dice with the future of the St. Johns. Once the damage is done, there is no turning back," St. Johns Riverkeeper Lisa Rinaman said. "Unfortunately, the Army Corps has failed to exercise due diligence and provide the public with assurances that our river will be protected."
RON LITTLEPAGE – JACKSONVILLE'S PORT CAN THRIVE WITHOUT DREDGING:
Florida Times-Union 3.23.17 – "To justify JaxPort’s mega-spending plan — $700 million on the dredge itself and hundreds of millions more for other infrastructure improvements — Lewis said the container business at JaxPort would have to grow 100 percent in the first nine years after dredging. Over the past five years, Lewis points out, JaxPort’s container traffic has grown 1 percent a year."
RON LITTLEPAGE – WE NEED DEEPER DIVE ON THE NUMBERS FOR DREDGING:
Florida Times-Union 3.7.17 – "Before continuing along the seemingly predetermined path to spend $700 million to deepen the St. Johns River shipping channel, someone in authority needs to pay attention to what Dale Lewis is saying….Lewis speaks with the authority of a resume that includes 30 years of experience in rail, ship and truck transportation, a graduate degree in transportation from the Massachusetts Institute of Technology and a long career with CSX."
ANALYST: JAXPORT MAY NOT SEE THE ECONOMIC IMPACT PROJECTED WITH DREDGING:
Jacksonville Business Journal, 3.6.17 – "In his presentation Friday, Lewis said he believes deepening the St. John's River will not increase Jaxport's market share in container shipping in the southeast region, nor will the deepening make Jaxport significantly more competitive with rival ports, Savannah or Charleston."
STUDY FINDS MUD STIRRED UP BY MIAMI DREDGE KILLED CORAL:
Tampa Bay Times, 11.22.16 – "Dredging at PortMiami killed far more coral than the U.S. Army Corps of Engineers predicted, scientists from the National Marine Fisheries Service and the University of Miami have concluded in a new study….The research team studied pictures taken before, during and after the dredge and said sediment spread across an area about 14 times bigger than the Corps permit allowed for."
PORT OF DREAMS:
An April 2016 article in Folio Magazine asks – If We Dredge It, Will They Come? And is it Worth the Risk?
DREDGING CHALLENGE WILL MOVE TO FEDERAL COURT:
On Tuesday, July 26, 2016, St. Johns RIVERKEEPER filed a notice withdrawing its legal challenge of the Army Corps of Engineers’ state Environmental Resource Permit (ERP) due the lack of enforceability and will now focus its efforts on a legal challenge at the federal level. Click here to read more.
RIVERKEEPER GUEST COLUMN: April 19, 2016 – "Unfortunately, the analysis by the Army Corps of Engineers remains flawed, failing to accurately and thoroughly assess the economic and environmental impacts of the dredging. To make matters worse, virtually no mitigation is being proposed or required and important water quality protections will be waived for eight years. As a result, we are now left with no choice but to seek a legal remedy to ensure the protection of the St. Johns." Read more.
DREDGING CHALLENGED FILED: On Friday, April 1, 2016, St. Johns RIVERKEEPER filed a Petition for Formal Administrative Hearing against the Florida Department of Environmental Protection (DEP) to challenge the state Environmental Resource Permit (ERP) for the proposed St. Johns River harbor deepening project. Read more.
MIAMI DREDGING DEBACLE:
Port expansion damaged unique coral reefs, Miami Herald 9.20.15
"Rather than mitigate the negative affects of dredging and safeguard the only coral reef tract in the continental United States, the Corps and its contractor cut corners at every turn: allowing transport ships to leak sediment plumes that are strangling our reefs; refusing to replace ineffective monitoring devices; ignoring survey data that indicated, beyond doubt, that the reefs were dying; and casting aside the suggestions of local, state and federal experts. What’s worse, as the project’s sponsor, Miami-Dade County and its taxpayers, not the Corps, will ultimately bear the burden of paying for the reefs’ repair."
PLANS FOR LEGAL CHALLENGE ANNOUNCED: On Tuesday, August 11, 2015, St. Johns RIVERKEEPER filed a Notice of Intent to Sue the Army Corps of Engineers (ACOE) regarding the proposed St. Johns River harbor deepening project. Learn more about the announcement on our blog, from this Florida Times-Union article, and this letter to the editor from Lisa Rinaman, the St. Johns Riverkeeper.
MEMORANDUM OF UNDERSTANDING: In August 2015, the Jax Chamber inexplicably backed out of its MOU with St. Johns RIVERKEEPER. At the beginning of the year, St. Johns RIVERKEEPER, the City of Jacksonville, Jax Chamber, and JAXPORT had signed a Memorandum of Understanding (MOU) outlining a plan to work together for the removal or breaching of the Kirkpatrick Dam (aka Rodman Dam) and restoration of the Ocklawaha River. If the restoration of the Ocklawaha River was authorized and funded by the state, St. Johns RIVERKEEPER agreed to not legally challenge the Army Corps of Engineers' Environmental Impact Statement (EIS) for the proposed dredging project.
While the restoration of the Ocklawaha would not mitigate for all of the impacts of dredging, no other mitigation option has been identified that would provide comparable ecological benefits to the St. Johns River. St. Johns RIVERKEEPER continues to seek more mitigation to help fortify the river, should the proposed deepening project move forward. Click here to learn more about the benefits of restoring the Ocklawaha.
POSSIBLE NEW PLAN: Having difficulty securing federal funding for the proposed dredging project, JAXPORT is looking at a possible new plan that would reduce the scope of the dredging from 13 river miles to 11. According to JAXPORT, the new plan would reduce the cost of the proposed project and help improve the project's benefit-to-cost ratio (BCR) which is currently only 2.7. The minimum criteria to qualify for federal funding is a BCR of 2.5. However, several other harbor expansion projects that are vying for limited federal dollars have higher ratios, such as Savannah with a BCR of 5.7.
ARMY CORPS OFTEN UNDERSTIMATES EXPENSES: The U.S. Army Corps of Engineers consistently, and sometimes drastically, underestimated the cost of deepening Jacksonville Harbor over the past 50 years, according to documents obtained by the Times-Union from the corps and JaxPort. Read the article.
LEAD LETTER FROM RIVERKEEPER CHAIRMAN: When it comes to our city evaluating the deepening of the St. Johns River for JaxPort, the recommendation to dredge is coming from an “expert", the Army Corps of Engineers, which in project planning and estimating benefits, risks and costs has a track record that undermines its credibility. Read the entire letter.
PORT TASK FORCE: Soon after being elected in 2015, Mayor Lenny Curry decided to terminate the Port Task Force. The Port Task Force consists of community and business leaders appointed by Mayor Alvin Brown and tasked with evaluating the economic viability and environmental impacts of the proposed dredging project.
ARMY CORPS COMPLETES STUDY: In April of 2014, The US Army Corps of Engineers (USACE) completed a final Environmental Impact Statement (EIS) of the proposal to dredge the St. Johns River from 40 to 47-feet. Read St. Johns Riverkeeper's comments regarding the EIS. Florida Wildlife Federation, North Florida Land Trust, Public Trust Environmental Legal Institute of Florida, and Sierra Club Northeast Florida Group signed on to the comments, as well.