At the July 18 Meeting of the San Francisco Bay Conservation and Development Commission (BCDC), BPC Executive Director John Coleman made the below comments regarding the 12 year review of the Long Term Management Strategy for Disposal of Dredged Materials in the San Francisco Bay Region (LTMS).
Statement by Executive Director John A. Coleman
BCDC MEETING, JULY 18, 2013
ITEM NUMBER 8
First and foremost, on behalf of the Bay Planning Coalition (BPC), I would like to thank the staff at BCDC for providing the opportunity to speak and provide written comments to the Long Term Management Strategy (LTMS) team before the Management Plan Final Report is issued in August 2013. BPC also appreciates the work of the LTMS staff in holding numerous meetings in order to look back at the last twelve (12) years on what has worked, and what improvements can be made into this decade. The finest accomplishment of LTMS is creating the Dredge Material Management Office (DMMO) to coordinate dredging permitting and authorizations.
It is important to remember we are an economic international powerhouse here in Northern California. When counting the nine bay area counties and Sacramento and the San Joaquin Valley, our GDP ranks us 17th in the world economy. Much of this is due to what we grow and manufacture here in California, and the critical infrastructure involved with the movement of goods in and out of our state. The infrastructure required to move these products requires airports, highways, rail lines and sea going ports. There is no way we can sustain, let alone grow, our Northern California economy without sufficient channel depths for ships to enter or leave our ports of call. It is a fact that, when vessels are light-loaded due to depth restrictions, manufacturers and in turn consumers pay more because the cost to move goods increases. In a worst case scenario, if our ports and harbors are not kept at authorized depths, we increase the prospect of businesses that are manufacturing goods moving elsewhere, and of goods being shipped from ports other than in Northern California.
It is accurate to state that in parts of the Bay, sediment is in short supply in order to re-establish critical wetlands for climate change and sea level rise adaptation, air and water quality, habitat restoration and the overall health of the San Francisco Bay and Delta. In addition, the lack of sediment is critical to the re-building of the levees that protect critical economic interests and infrastructure such as waste water treatment facilities, road, rail lines, ports, airports, homes, and businesses. The economic impacts to infrastructure from climate change and the potential beneficial reuse of sediment needs to be evaluated from the following perspectives: (1) Extent of exposure (2) Determining what is critical to save (3) Climate change related stresses (4) Assessing levels of vulnerability, and (5) Risk assessment.
Sediment reuse alone is not going to solve the problems that we currently face, or the pending or still unknown consequences of climate change. Reuse needs to be integrated into a Bay-wide plan that also includes funding. With the current ban on earmarks on Congressional legislation, it would be helpful if LTMS would allow dredge applicants the option to propose LTMS data gap studies as credit towards their 20-40-40 requirement until the earmark moratorium is changed. This could be achieved by the validation of current sediment transport modeling using sediment particle labeling during an in-Bay disposal event, or with additional plume monitoring. This would allow for larger projects to keep the cost of the studies significantly below the additional cost per yard necessary to haul material to SFDODS or beneficial use sites.
Importantly, greater flexibility is needed when it comes to beneficial use. Such as: (1) Allowance to amend levee maintenance permits for the Salt Ponds and other subsided areas with restoration sites that could use dredged material to widen levees as part of the restoration objectives. (2) Expand the definition of beneficial use to include Strategic in-Bay Placement in order to restore both planned projects like the Salt Ponds as well as mudflat restoration, which does not have a specific proponent, yet is in line with the Subtidal Habitat Goals Project (the Dredge Material Management Plan identified 3 historic mudflats in different areas of the bay that have eroded over the past 100 years). (3) Restoration of the Bay Farm Borrow Pit. This too is in line with the Subtidal Habitat Goals, and could possibly be the easiest and most expeditious way to substantially expand San Francisco Bay eel grass.
From a technical side, has it been determined how much needs to be dredged and over what period? In addition, how much material is needed to maintain the competitive edge of our ports, and how much sediment is needed for restoration efforts? There is maintenance dredging, periodic dredging and looking at the 50 year need for dredging. Has this been broken down by federal, nonfederal-public, and nonfederal-private? Has an evaluation for new work, sediment quantities and timing for the next 50 years been performed? In addition to the periodic maintenance dredging, has there been an evaluation of channel deepening for the WETA Ferry System, BAE Shipyards, San Francisco Bay, upstream channel deepening to Sacramento and Stockon, and potentially other new work that is non-federal?
Looking 50 years from now, what is the long term development of the San Francisco Bay and Delta, especially in light of climate change and sea level rise? 50 years may seem like a long time from now, yet given the long lead times for feasibility, planning, and assessment of environmental impacts, it is not that long or far away.
The economic costs and logistics of moving sediment further from the bay need greater consideration when approving dredging projects; this is critical without adequate federal funding and when relying on the ports or private sector to carry the financial burden. To date, ports have been able to absorb much of the increases, however, they do not have the financial capability to absorb unlimited increased costs. Without taking costs into consideration, we increase the probability of losing shipping business to other ports of entry because of the cost differentials. The BCDC Staff Report states, “allowing disposal of large volumes of clean sediment in the ocean is less desirable now because this practice results in the loss of sediment from the Bay system.” Add in the factor of loss of turbidity and Bay bottom erosion, and this presents a strong argument for more in-Bay disposal, and the potential for tidal action to naturally disperse sediment for beneficial purposes of wetland creation.
In addition, any beneficial reuse site should only be considered “available” by LTMS agencies when it is fully permitted and has all the infrastructure and equipment available onsite needed to handle the material. To identify a site which wants material is not the same as having a site which is available to accept material, of which there are not enough sites. Please also consider mitigation credits for dredges using beneficial reuse for wetland restoration.
The Bay Planning Coalition will continue to work with the LTMS agencies and all agencies that have oversight on dredging and beneficial reuse of sediment. We are asking for greater flexibility, regulatory decisions based on sound science, placing a higher economic value on sediment and its reuse, and considering the economic impacts to those who dredge and those decisions on how they relate to the overall stated objectives of the LTMS.
To conclude, the economic revival and future of our region is dependent on the movement of goods, and dredging is needed to make this happen.
John A. Coleman
Bay Planning Coalition
1970 Broadway, Suite 940
Oakland, CA 94612-2221