Sierra Club Issues Statement on South Atlantic Coastal Study Draft Report
Sierra Club and the Center for Biological Diversity sent the following letter to the U.S. Army Corps of Engineers regarding the South Atlantic Coastal Study (SACS) Final Draft Report and its Florida Appendix.
Nov. 16, 2021
Before the SACS report is finalized and during subsequent phases, we ask the Corps to conduct more inclusive and meaningful outreach to low income, underrepresented, and marginalized communities that are affected directly or indirectly by coastal flooding. This outreach would ensure these communities' environmental justice concerns are accounted for and that they will benefit from SACS recommendations rather than being disproportionately and negatively impacted by them. Doing so will also align the SACS report recommendations with USACE's October 2021 Climate Action Plan, which included a goal of "providing meaningful engagement on technical issues, including specific engagement to low-income communities, minority communities, and tribal communities in USACE’s project development process,"[2] as well as Executive Order (EO) 13990 aimed at protecting public health and the environment and advancing environmental justice.[3] EO 13990 also encourages seeking input from the public and stakeholders, including "labor unions, environmental advocates, and environmental justice organizations."[4]
We recognize the challenge the coronavirus pandemic has presented since 2020 and appreciate the Corps providing opportunities for virtual attendance. However, even in 2019, public engagement within environmental justice (EJ)-focused communities was absent or minimal. For instance, USACE held four in-person workshops in the Fall of 2019 in various parts of Florida. However, according to the SACS draft report (Outreach Appendix), in-person participation in each meeting varied from only 10 to 38 participants and from 3 to 12 attending remotely. Most of the participants were government officials. These workshops should have been used as opportunities to engage EJ communities in coastal communities and non-profit organizations that work closely with them.
We strongly recommend that the Corps extends the public comment period on the voluminous SACS report and related products before finalizing it and submitting it to Congress. This would provide, at a minimum, a window of opportunity to engage environmental and community grassroots organizations and coalitions focused on environmental and climate issues in the South Atlantic and Gulf regions who work closely with traditionally marginalized, underrepresented frontline and fenceline communities. These groups will be able to provide viewpoints that are not guaranteed to be conveyed by government representatives. For instance, in Florida, we recommend intentional outreach to the Miami Climate Alliance, Everglades Coalition, Gulf South for a Green New Deal, and the Southeast Climate & Energy Network. Collectively, these coalitions represent hundreds of organizations working on the ground with communities most impacted by coastal flooding and disasters that are increasing due to human-induced climatic changes.
Nature-Based and Equitable Coastal Resilience
We also ask the Corps to consider the recommendations in the attached Everglades Coalition comment letter dated August 19, 2020 to the Corps' Norfolk District regarding the Back Bay Coastal Storm Risk Management Draft Integrated Feasibility Report and Programmatic Environmental Impact Statement. In particular, we ask the Corps to include and prioritize recommendations that provide opportunities to enhance Everglades restoration efforts for greater nature-based coastal resilience. We also ask the Corps to include and prioritize recommendations for other natural and nature-based features (such as coral reef restoration, living shorelines, and mangrove plantings). The SACS report should also include recommendations to account for the costs of mitigating negative impacts to the natural environment from grey infrastructure-based solutions that may cause permanent losses of corals, hardbottom habitat, mangrove, and open water benthic habitats. We also recommend alternative valuation methodologies that do not exacerbate inequalities, which tend to happen when cost-benefit analyses put more emphasis on protecting high-valued properties than on improving quality of life, public health, and preventing gentrification.
We also encourage the Corps to discuss and highlight recommendations made by the Corps' Chief's Environmental Advisory Board in a April 9, 2020 memorandum[5] regarding "Capturing Environmental Benefits in Civil Works Projects," which could improve the selection of federally-funded coastal resilience project alternatives in the South Atlantic coastal region with locally important environmental, ecological, and other socio-economic benefits to coastal communities.
Species and Habitat Impacts
We also urge the Corps to take a more holistic and comprehensive approach when considering impacts to listed species and their habitats and providing recommendations. The Endangered Species Act requires each federal agency to, in consultation with the U.S. Fish and Wildlife Service and NOAA Fisheries, utilize its authorities in furtherance of the purposes of the Endangered Species Act by carrying out programs for the conservation of listed species.[6] Consistent with that statutory mandate, the Corps should consider how its own recommendations will affect listed species.
While the Corps does look at priority environmental areas (PEAs) and generally recommends ecosystem restoration,[7] these analyses focus on areas that are or will be directly impacted by sea level rise and storm surge.[8] Absent from the Corps' analysis is a broader assessment of how species and their habitat will be impacted by human populations migrating away from and acclimating to sea level rise, increased storms, and other natural hazards. For instance, in the Florida Appendix, the Corps recommends limiting future development in high-risk coastal locations,[9] and yet it fails to acknowledge that this recommendation will divert human populations to inland areas out of harm’s way and put additional pressure on existing inland habitat and populations of listed species that are most vulnerable.
Coastal species face significant risks from coastal squeeze that occurs when habitat is pressed between rising sea levels and coastal development that prevents landward movement.[10] Human responses to sea-level rise including coastal armoring and landward migration pose significant risks to the ability of species threatened by sea-level rise to move landward, if other suitable habitats were even available.[11] With significant projected human population growth and development in Florida,[12] coastal squeeze and inland habitat loss to migrating human populations is a significant threat to species that warrants the Corps’ analysis and thoughtful recommendations.
The Corps rightly notes that Florida’s coasts contain "vast natural resources supporting threatened and endangered species as well as providing a wealth of ecosystem goods and services."[13] These species and natural resources face the same or worse threats from climate change and sea level rise and will only put at further risk if they are not prioritized in comprehensive planning. Therefore, in addition to assessing direct effects to species and habitat from sea level rise and climate change, the Corps should also assess how its own recommendations will affect species and habitat and provide recommendations that avoid, minimize, or mitigate those effects.
Thank you for the opportunity to provide comments to help improve the SACS report recommendations and to advance equitable and ecologically-beneficial coastal resilience in Florida from the impacts of sea level rise.
Sincerely,
[1] U.S. Army Corps of Eng’rs, South Atlantic Coastal Study (SACS), Main Report, Final Draft Report, October 2021 [hereinafter Main Report]; U.S. Army Corps of Eng’rs, South Atlantic Coastal Study (SACS), Florida Appendix, Final Draft Report, October 2021 [hereinafter Florida Appendix].
[2] U.S. Army Corps of Engineers, USACE Climate Action Plan, October 2021, available at https://www.sustainability.gov/pdfs/usace-2021-cap.pdf.
[3] Exec. Order No. 13990, 86 Fed. Reg. 7,037 (Jan. 20, 2021), https://www.govinfo.gov/content/pkg/FR-2021-01-25/pdf/2021-01765.pdf.
[4] Id. at 7,039.
[5] Memorandum from Mary C. Barber, Ph.D., Chair, Environmental Advisory Board, to Gen. Todd T. Semonite, Commanding General and Chief of Engineers, U.S. Army Corps of Eng’rs, Capturing Environmental Benefits in Civil Works Projects (Apr. 9, 2020), available at https://usace.contentdm.oclc.org/utils/getfile/collection/p16021coll11/id/4570.
[6] 16 U.S.C. § 1536(a)(1).
[7] Florida Appendix at 7-2.
[8] Florida Appendix at 3-1, 4-17–4-18 (defining priority environmental areas as natural areas that are at medium to high risk to storm surge inundation or sea level rise).
[9] Florida Appendix at 7-5.
[10] Scavia, D. et al. 2002. Climate change impacts on U.S. coastal and marine ecosystems. Estuaries, 25: 149–164; Fitzgerald, D.M., M.S. Fenster, B.A. Argow, and I.V. Buynevich. 2008. Coastal impacts due to sea level rise. Annual Review of Earth and Planetary Science, 36: 601–647, at 601–634; Defeo, O., A. McLachlan, D.S. Schoeman, T.A. Schlacher, J. Dugan, A. Jones, M. Lastra, and F. Scapini. 2009. Threats to sandy beach ecosystems: a review. Estuarine, Coastal and Shelf Science, 81: 1-12, at 6–7; LeDee, O.E. K.C. Nelson, and F. Cuthbert. 2010. The challenge of threatened and endangered species management in coastal areas. Coastal Management, 38(4): 337–353; Menon, S., J. Soberon, X. Li, and A.T. Peterson. 2010. Preliminary global assessment of terrestrial biodiversity consequences of sea level rise mediated by climate change. Biodiversity and Conservation, 19(6): 1599–1609; Noss, R. 2011. Between the devil and the deep blue sea: Florida’s unenviable position with respect to sea level rise. Climate Change, 107(1): 1–16.
[11] Defeo et al. (2009) at 1–9.
[12] Carr, M.H. and P.D. Zwick. 2016. Florida 2070 mapping Florida’s future – alternative patterns of development in 2070. GeoPlan Center at the University of Florida, Gainesville, Florida.
[13] Florida Appendix at 3-1.