MerAngel Ecological Services
97 Curlew Drive
Long Bay Hills
Turks and Caicos
November 6, 2012
Turks and Caicos
Re: Response to Notice related to PR11342 Leeward YC Marina Ltd (in Receivership) for consideration of maintenance Dredging of the Leeward Channel
Dear Director of Planning:
I am writing with concerns regarding the aforementioned project (PR11342) for maintenance dredging of the Leeward Channel. My understanding of the project indicates that maintenance is necessary to reopen the channel for the Leeward YC Marina, Ltd. (aka Blue Haven Marina?) My comments and concerns are as follows:
1. First and foremost, a portion of the area to be dredged is within the Princess Alexandria National Park, which by its own mandates, deems the activity illegal.
2. I am not clear that the project can be simplified as “maintenance dredging” as nothing has been stipulated in the application to reflect the type of dredge necessary for these works. Maintenance dredging of shoaled material would warrant the use of a simple suction dredge to remove the sand that has filled into the previously dredged areas (which create sand traps so to speak), as the system is trying to achieve its sand equilibrium since the last dredging incident. Conversely, use of a cutterhead dredge would indicate that hard stubstrata, more of the coral reef and reefal hardbottom areas are to be removed—which is beyond a maintenance endeavor and would further damage the coral reef system that managed to survive the last dredging attempt.
Furthermore, excavation of hardbottom and reef would produce a pulverized, silty and clay mixture, which will create a large plume that will be difficult if not impossible to contain. There is evidence of this material along the nearshore area of Emerald Point beach and geotube groins from the last dredging incident. Please clarify the type of dredge to be used.
3.0 The previous plan included dredging to -15ftMLW for a 200ft to a 400ft expanse in the access channel. Was that ever achieved or is it part of the new “maintenance dredging”? Can you please clarify.
4.0 Where will the settling basins and discharge points for dewatering the pumped spoils be located? Will efforts be made this time to use turbidity curtains to contain suspended sediments, which is typical of all dredging projects?
5.0 Has the previous EIA been re-examined to determine if the expected impacts from the past dredging efforts are the same as what has occurred since 2008? Numerous problems have occurred with regards to sedimentation, further beach erosion and other impacts to the environment from the previous activity. Where are the post construction monitoring reports that should have been part of that previous work? Assuming that the appropriate modeling exercises were undertaken, was the frequency of this “maintenance dredging” ascertained at that time? Going forward, what frequency is now expected—will this be an annual or biannual event, every 5 years? Please clarify.
6.0 What is intended for the dredged spoils? Particularly that which is considered “beach quality” material? According to previous documents, it appears that the developer retains the rights to the sand. The Turks and Caicos Sand Mining Study (Feb 2007. Pgs 20-21) “sand from dredging of ebb tide shoals must be placed on beaches extending 1-3 miles down drift to maintain sand flows and prevent erosion.” It further states “ At Leeward Going Through entrance channel, the sand dredged from the channel must all be used to build and maintain the down drift beaches…” . What grade of sand is expected from the dredging activities and will this be used to nourish those beaches or will it be allowed to be sold as was done with much of the previous dredge product? Also, have the downdrift beaches been monitored following the last dredging incident?
7.0 A final note is with regard to the “Evaluation of Critical Nursery Habitat for Queen Conch on the Mangrove Cay Shoal”, a report that I submitted in March 2008 with regards to the dredging and dumping of spoils that were occurring at the time. Detailed surveys were undertaken, ascertaining that conch populations in this area rivaled that of West Sand Spit and harbors conch throughout all life stages. “In conclusion, the area under consideration for both dredge and fill activities and the ensuing operational phase impacts of the development will have serious deleterious effects to not only the existing conch populations found in the area, but also to the future potential recruits into the resource. The changes in the ecological and physical dynamics of the area will not only impact the conch resource, but other resources and species that depend on both the conch resource and the same processes that ensure their viability.” Further dredging will further damage this valuable resource. I have also attached this document for your consideration.
With limited knowledge of exactly what the project proposes, but having seen the unmitigated and considerable damages that have occurred since the previous dredging activity, and knowing the inherent value of the resources in this area and the adjacent Nature Preserve, I am adamantly against further “maintenance” or otherwise dredging as proposed
Thank you for your time in considering my questions and objections. I look forward to your response.
MerAngel Ecological Resources