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August 7, 2009
TO: The Council on Environmental Quality
FROM: The American Society of Civil Engineers
RE: The Interagency Ocean Policy Task Force
The American Society of Civil Engineers* (ASCE) is pleased to comment on the administration’s proposal to establish a national policy to preserve the ecological functions and economic utility of the oceans, the nation’s coasts, and the Great Lakes.
ASCE supports the overall policy aims contained in the President’s June 12 memorandum, which committed the federal government to a process designed to “protect the oceans, coasts, and Great Lakes . . . within a unifying framework under a clear national policy, including a comprehensive, ecosystem-based framework for the long-term conservation and use of our resources.”
II. ASCE POLICY
ASCE supports the implementation of waste-reduction programs that can significantly decrease the quantity of deleterious wastes disposed in ocean and coastal waters. ASCE further urges the continued study of the environmental effects of disposing wastes into ocean and coastal waters. ASCE is concerned that long-term ocean disposal may cause irreparable damage to the ocean and coastal areas, and therefore supports investigative programs that achieve a greater understanding of the transport and fate of wastes disposed of in ocean and coastal waters.
Rising environmental concerns and costs associated with land disposal of wastes have placed increasing emphasis on marine disposal options; yet engineering and scientific consensus does not exist related to the assimilative capacity of the ocean and the ultimate fate of wastes introduced into the marine environment.
Ocean and coastal waters provide vast resources of enormous ecological and economic value. In the past, disposal of large quantities of wastes in ocean and coastal waters was practiced without adequate knowledge of the ultimate fate of these wastes and their effect on the marine environment. Waste dumping has been indiscriminate and has resulted in incidents of marine pollution and poisoning of marine biota with chemicals that can ultimately be toxic to humans. In addition, bacterial contamination has resulted in an increase in the number of incidences of beach closures, infections in marine wildlife, and suspensions of harvesting from shellfish beds.
In order to develop adequate marine management programs, more information is needed regarding the assimilative capacity of the ocean and coastal waters and of the ultimate fate of pollutants and chemicals introduced into these waters. In addition, more research on effective methods of reducing the quantity of wastes’ being disposed of in coastal and ocean water environments is recommended.
Moreover, the responsible use and development of coastal and offshore resources, the exercise of sound conservation practices and protection of the public health and environment are consistent with sustainable development. ASCE recognizes the need for regulatory control of coastal and offshore regions. Protection of public health, safety, and welfare and protection of the environment require consideration of the potential impact of storm events in planning for all coastal and offshore development. ASCE supports the improvement of regulatory procedures in order to streamline the lengthy and often duplicative approval processes. From the ranks of involved agencies, a lead agency should be charged with initiating and coordinating the needed communication and consultation.
Use of coastal and ocean resources can embrace a wide range of activities such as development of oil, gas and minerals, wastewater disposal, fishing, recreation and conservation. Viable projects in coastal and continental shelf locations have had costly delays and/or abandonment, caused by poorly defined and conflicting permitting processes. There is a need for an improved, streamlined regulatory process to address issues in a timely way, and develop solutions which balance environmental and societal needs.
The establishment of a lead federal agency to coordinate the interests of multiple federal and state agencies, much like the agency coordination process used for wetland permitting under section 404 of the Clean Water Act, is needed. The impact of recent hurricanes and emerging concern over global warming and its potential impact on ocean levels and coastal development reinforce the need for planning, practices, and regulation consistent with sustainable development.
Finally, ASCE supports the basic coastal data collection programs of the National Oceanic and Atmospheric Agency (NOAA), the U.S. Army Corps of Engineers (USACE) and other government agencies as essential for planning storm-protection systems and coastal restoration. ASCE urges continued support for the climate change and estuarine science programs, including the status and trends program of NOAA, and the National Wetlands Inventory programs of NOAA, USACE, the Environmental Protection Agency (EPA) and the U.S. Fish and Wildlife Service (FWS).
ASCE also supports the USACE Coastal Field Data Collection Programs, which provide critical understanding of waves and currents that are the driving forces of coastal erosion. These data are essential to monitor, model and forecast storm surge and other natural disaster events so that we may adequately assess the risk to our coastal communities. ASCE recommends that USACE and NOAA organize and operate basic coastal data collection programs in all coastal and Great Lakes states to ensure uniform quality and continuous collection of data and coordinate these with long-term hydrologic data collection programs for major watersheds. ASCE encourages state and local governments to initiate, support and participate in these programs.
The basic coastal data collection programs of NOAA, USACE, EPA and other agencies are vitally important to sound coastal zone planning, design, construction and management. Coastal environmental problems continue to increase in number and complexity, thus increasing the need for additional coastal-zone data collection and research. The NOAA, USACE, EPA and other government agencies provide the necessary data, which are the basis for the wise use and protection of coastal wetlands, marshes, estuaries and coasts. New areas of national concern such as climate change and wetlands preservation increase the need for coastal data collection and research, yet these new program directions compete directly with the continuation of longterm basic coastal data collection programs
The federal government must take the lead in collecting and making available all necessary data to monitor, model, and forecast storm surge and other natural disaster events if we are to avoid a repetition of the problems of Hurricane Katrina. There must be adequate funding on a continuing basis sufficient to allow prediction of storm surges, sediment transport, and risk assessment to allow effective management of changes to established hydrogeomorphological processes (the interaction of the sea with river systems along the coast and in estuaries).
America's coasts are an important asset. The coast is a vital natural component of our natural hurricane and storm protection systems. A majority of our citizens live, work, and recreate within 50 miles of coasts. Coastal wetlands, marshes and estuaries provide essential nurseries and feeding grounds for an abundance of marine life, birds and other animals. Ports, coastal-related industry, and commerce are vital to our economic survival.
Moreover, there are serious problems that threaten the continued value of the coastal zone to the nation. These problems include beach erosion, loss of coastal wetlands, unmitigated development, degradation of water quality in estuaries and coastal waters, sea level rise and sedimentation. Solutions to these problems are needed. In many instances, the necessary information required for solutions to these problems is lacking or incomplete. Accurate and complete data, collected in a consistent manner over the long-term, is the basis of accurate modeling of coastal changes and storms and their consequent risk to public health and safety.
To provide the necessary data for solutions to these problems, long-term sufficiently funded programs in observation, monitoring, research and development, and prediction are needed. Sound management and conservation decisions require a thorough understanding of the environment; including coastal processes. Such an understanding can only be developed after thorough observation, through research and assessment programs based on good data.
THE AMERICAN SOCIETY OF CIVIL ENGINEERS