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COASTAL USES WORKING GROUP STATUS REPORT

This Interim Working Group Report is considered a working document, subject to review, discussion, addition and amendment by the federal, state and territorial members of the United States Coral Reef Task Force.

Fishing Pressures
Coastal Development and Shoreline Modification
Vessel Traffic


Introduction - Coastal Use Impacts on Coral Reefs

The large El Nino event of 1997-98 brought attention to many of the natural stressors to coral reefs worldwide. Unprecedented coral bleaching, widely believed to be associated with El Nino events, was evidenced throughout the world, from the Red Sea eastward to the Caribbean. The associated increase in severity and numbers of tropical and extra tropical storms due to the El Nino event further stressed coral reef systems in certain parts of the world. Although coral reef ecosystems have long proven their resiliency to natural stressors, many of these unique ecosystems are under an increasing amount of pressure from anthropogenic, or human induced, influences. Burgeoning population growth worldwide has reached unsustainable levels in certain areas of the tropical and sub-tropical world, further threatening coral reef systems and decreasing their ability to rebound from natural stressors such as bleaching and storm events.

Coral reefs in the United States (specifically in Florida, Puerto Rico, the US Virgin Islands, Hawaii, Guam, American Samoa, and the Northern Marianas) are increasingly susceptible to coral reef degradation from land- and water-based coastal uses. American Samoa, which consists of 5 small volcanic islands with fringing reefs and two coral atolls, has witnessed the both the resiliency of its coral reef systems to natural stressors as well as the negative, human induced effects caused by an annual population growth rate of close to 4% in recent years (DOI/Office of Insular Affairs). The Territory’s coral reefs have suffered crown of thorns starfish infestation (1978-80), several strong hurricanes (Val, 1991) and a wide-spread bleaching event (1994). While near shore reefs have shown a healthy recovery to these natural perturbations, man’s influence on the system continues to slow recovery in certain areas. On the island of Tutuila, the recovery of Pago Pago Harbor’s reefs are hampered by chronic sedimentation from nearshore development, small but frequent oil spills and the groundings of nine abandoned long line fishing vessels on the harbor reef flat. Even American Samoa’s Rose Atoll, one of the most remote atolls in the Pacific (240 km north-east from Pago Pago) and protected as a National Wildlife Refuge, was damaged in 1993 by a ship grounding which released 100,000 gallons of diesel oil on to the reef.

Increased tourism and its associated effects on coral reefs has also been identified as one of the major coastal use threats to the health of coral reefs in the United States. The 76 square mile island of Saipan in the Commonwealth of the Northern Marianas (CNMI) had nearly 700,000 tourist arrivals in 1996, most of whom came to enjoy the recreational opportunities and beauty of the island’s coral reefs. Deleterious impacts from tourism on Saipan’s coral reefs came not just from direct recreational impacts by divers and snorkelers on the reef, but more significantly from the indirect impacts of tourism industry. These impacts include increased runoff and sedimentation from resort development, increased recreational boat groundings and anchor damage, damage to benthic habitat from personal water craft and increased recreational and commercial fishing pressure.

Charge of the Coastal Uses Working Group

The Coastal Uses Working Group has been charged by the United States Coral Reef Task Force with developing strategies to mitigate anthropogenic stressors on coral reef ecosystems throughout the United States. Primarily, these stressors can be defined as impacts from population increase, development, commerce, recreation and tourism in the coastal zone.

This interim working group report will detail three major anthropogenic threats to coral reefs throughout the United States, including:

  • Fishing Pressures — Coral reefs and associated habitats Coral reefs and associated sea grass, algal plain, and mangrove habitats provide fishery resources that represent a critical source of food, both commercial and subsistence, for the US and world populations. Reefs contain over 4,000 species of fishes as well as crustaceans, molluscs, and other edible invertebrates. Major threats from fishing pressures identified in this report include the following (not in order of priority): (1) Overfishing, (2) Destructive Fishing Techniques, (3) Bycatch, (4) Aquaruim Species Collection, and (5) Aquaculture.

  • Coastal Development and Shoreline Modification— Shoreline modification, coastal development and their associated effects on coral reef health are the unwanted result of modernization and an increasing population in the coastal zone. Major threats from shoreline modification and coastal development identified in this report include the following (not in order of priority): (1) Dredging, (2) Port and Harbor Development, (3) Undersea Energy Extraction and Utility Siting, (4) Undersea Cable and Pipeline Siting, and (5) Shoreline Modification.

  • Vessel Traffic — Increased development and tourism, especially in island environments, is dependent on vessels of differing size and shapes. Near coastal and coastal vessel traffic range from commercial tankers, cruise ships and containerships to personal watercraft to longline fishing boats, all of which have the potential to significantly impact coral environments. Major threats from vessel traffic identified in this report include the following (not in order of priority): (1) Direct Vessel Impacts, (2) Recently Abandoned Ships, and (3) Vessel Pollution.
  • Government response to anthropogenic threats to coral reef health is varied and complex. Numerous federal and state and territorial statutes attempt to mitigate these threats by (among other things) regulating the take and use of coral species, establishing special management areas to protect coral ecosystems and pursuing civil and criminal penalties for damage to coral reefs. Members of non-governmental organizations and marine conservation organizations have engaged in public education campaigns to influence user behaviors towards the reef. Despite these efforts, impediments remain to effective management and mitigation of coastal use threats to coral reefs.

    Mitigation of anthropogenic threats to coral reef health requires managing human behaviors and uses. Overcoming the impediments to management requires that short and long term actions bridge jurisdictional boundaries at the federal and local level. Actions must be support by a broad range of interests and constituent bases. Most importantly, actions must achieve measurable environmental benefits.

    The members of the Coastal Uses Working Group are encouraged by the tool of inter-agency cooperation established under the President’s Executive Order on Coral Reef Protection. Demonstrable work towards this end has already been addressed at the state/territorial level by the Summary Report of the US Islands Coral Reef Initiative Workshop (1997). The following interim report from the Coastal Uses Working Group adds to the Islands Report by beginning the process of identifying issues, impediments and potential actions to protect coral reef ecosystems from threats by our Nation’s coastal uses.

    Coral reefs and associated habitats provide important recreational and commercial fishery resources to the United States and the world. Reefs contain over 4,000 species of fishes as well as crustaceans, molluscs, and other edible invertebrates. The annual values of U.S. reef fisheries off the Florida Keys and Hawaii are estimated at $48.4 million and $20 million, respectively. No less important is the cultural value of the fisheries to the indigenous populations of the Pacific and Caribbean islands.

    These fishery resources and the ecosystems that sustains them are increasingly at risk. The Coastal Uses Working Group identified the following fishing-related issues on U.S. reefs that require additional management to sustain the benefits of fishery resources.

    1. Overfishing is widespread on U.S. reefs and has been implicated in changes in the ecological balance of reefs that threaten the integrity of the ecosystem.
    2. Pelagic drift nets, trawls and other marine fishing debris on coral reefs, especially in the Pacific, are causing severe damage to otherwise pristine reefs.
    3. Other indirect fishery impacts to reefs include anchor damage from fishing boats, trawling damage to coral areas (especially in the Gulf of Mexico), and lobster traps or debris from poorly designed artificial reefs thrown up on reefs during storms.
    4. Destructive fishing techniques (such as illegal use of dynamite or bleach) are still reported in remote areas, while legal techniques such as trap fishing or gill nets hauled by boat damage corals.
    5. Fisheries bycatch of protected species, such as hawksbill and green sea turtles continues.
    6. Collection of aquarium fishes, corals, and other reef organisms is growing rapidly and is poorly regulated.
    7. Aquaculture holds the promise of relieving fishery pressure on coral reefs, but if poorly planned, aquaculture can harm habitat and introduce diseases or invasive species into coral reef ecosystems.

    In the United States, both federal and state/territorial governments have management responsibilities for coral reef fisheries. States and territories regulate fishing within their territorial waters. For certain areas, local communities may exercise traditional fishing rights as well, and federal agencies, such as the National Park Service may have specific responsibilities within the areas they manage. Management of fisheries between 3 and 200 nautical miles from shore is largely the responsibility of NOAA’s National Marine Fishery Service through fishery management plans (FMPs) developed by the Regional Fishery Management Councils. The living marine resources that are managed often extend across these jurisdictional boundaries and mechanisms for coordinated management are largely ad hoc.

    In most cases, the legislation needed to address overfishing and destructive fishing problems on U.S. coral reefs is in place. Indirect impacts of domestic fisheries are also manageable - e.g., FMPs can ban anchoring of fishing vessels under the Magnuson-Stevens Act, and the installation of mooring buoys can help reduce anchor damage and the U.S. Coast Guard has fisheries enforcement authorities in the Exclusive Economic Zone of the U.S. which can assist with the issues of fisheries debris and use of destructive fishing gear. Problems arise due to the complexity of coral reef ecosystems and because: a) only a few coral reef fisheries are actively managed, even though the state or federal legislation provides for more comprehensive management; b) management, when it occurs is often not coordinated across jurisdictional borders; and c) enforcement of existing regulations by National Marine Fisheries Service, the U.S. Coast Guard and local fisheries agencies is difficult and often underfunded.

    Proposed Actions and Strategies

    Fishing Pressures

    1. Zone marine areas for resource management and "no-take" fishery reserves. Coral reefs and associated habitats (e.g., sea grass beds and mangroves) should be zoned for appropriate activities, including management of fishing and collection of other resources. The largest existing example of no-take zones in the US are found in the Northwest Hawaiian Islands. Such zoning should be compatible among, and coordinated across Federal, state and other jurisdictions. Zoning should include areas of permanent "no-take" fishery reserves to protect both multispecies fisheries (e.g., through maintenance of an adequate source of fishery recruitment and protecting spawning fishes) and associated essential fish habitat and biodiversity. Such reserves complement traditional fishery management techniques.
    2. Schedule: High priority - long-term strategy. There is an immediate need to begin monitoring of existing and planned "no-take" zones and identify appropriate areas for new zones. The goal should be to protect a significantly larger coral reef area by 2002.

    3. Resources Needed: Modest additional resources are needed in FY2000 to develop baselines and monitor existing or planned "no-take" zones. Significantly more resources would be needed to implement more extensive zoning activities in FY2000 and beyond.

    4. Participants: States and territories; Federal and local government, protected area and fishery management authorities; fishery commissions and regional management councils; fishers, divers, aquarium collectors, and local communities.
    5. Identify and conserve essential habitat for fishery resources. The health of fishery resources depends on the health of their habitat. This goal is closely tied to the mapping goals developed by the Mapping Working Group, and will help set the framework for federal and state activities in other areas as well, such as protecting these habitats from land-based pollution. This activity contributes to the "gap analysis" of current marine protected areas proposed by the Ecosystem Science & Conservation Working Group.

    6. Schedule: Essential Fish Habitat (EFH) identification, as required by the Magnuson - Stevens Act, began in FY98 and expanded activities are expected to begin in FY-2000, in part with the request for a NOAA biodiversity initiative and the Aquatic Restoration and Conservation (ARC) Partnership of NOAA, Dept. of Interior and other partners.

    7. Resources Needed: Limited resources for coral reefs and other regions have been included in the NOAA FY-2000 budget request. Additional resources will be required in FY-2001 and beyond.

    8. Participants: NOAA, USGS, USFWS, EPA, States and territories, NGOs and other partners.
    9. Enhance enforcement capacity: Many of the fishery problems identified are a result of insufficient enforcement capacity. There is a clear need to strengthen this capacity.

    10. Schedule: Immediate, high priority. Should begin immediately.

    11. Resources Needed: Additional human and financial resources are needed beginning in FY-99.

    12. Participants: States and territories; Federal, state and local/tribal fishery management authorities; fishery commissions and regional management councils; fishers, aquarium collectors, and local communities.
    13. Address the problem of marine fishery debris on coral reefs. There is an immediate need for clean-up of the more than 6000 metric tons of nets currently on the coral reefs of the Northwest Hawaiian Islands (NWHI), and for monitoring the impacts of such debris on other reefs. The National Marine Fisheries Service, U.S. Fish and Wildlife Service, Coast Guard and Hawaiian partners - both State and NGO - have begun this work at several sites and are developing a proposals to expand these efforts. This will be a long-term effort, but removing this debris will address the most severe threat to these otherwise pristine U.S. reefs. In parallel, international negotiations could provide a mechanism to identify the source of abandoned fishing gear and take action to reduce the use of the most damaging gear types.

    14. Schedule: Immediate - high priority. Small-scale removals have begun in the Hawaiian Islands in FY-98 & FY-99, which should be increased significantly in FY2000 and expanded to other Pacific islands in following years.

    15. Resources Needed: $1-2 million is required in FY2000 to begin high-priority net removal/restoration activities in the NWHI, with increased resources in following years.

    16. Participants: NOAA, USFWS, Coast Guard, states and territories, and NGOs. International negotiations will include State Dept., NMFS, FAO, and other countries fishing in the Western and Central Pacific.
    17. Monitor and if necessary limit collection for aquarium trade. Limitations can be placed on the levels of harvest for the aquarium trade, as well as on the species harvested, gear used in harvesting, or on the areas open for harvest. Hawaii has developed an ambitious plan to place 1/3 of the leeward coast of the Big Island off limits to aquarium collection. Puerto Rico plans strict limitations on aquarium fish harvest.

    18. Schedule: Near to medium term. There is an immediate need to enforce existing restrictions, monitor the existing level of collection and begin to determine its impact on the ecosystem.

    19. Resources Needed: Additional enforcement resources at the state and territorial level are probably the first priority in FY-2000.

    20. Participants: States and territories; Federal, state and local/tribal fishery management authorities; fishery commissions and regional management councils; fishers, aquarium collectors, and local communities. Academic researchers to determine and monitor impacts.
    21. Apply additional fishing gear regulations. Where specific gear types have been identified as a problem, Regional Fishery Management Councils, States and territories may institute additional restrictions, e.g., banning the use of fish traps or large gill nets set from boats. The Caribbean Fishery Management Council is considering a trap reduction program for waters off Puerto Rico and the U.S. Virgin Islands. The Council also intends to further limit fishing gear that impacts reefs such as gill nets (used in combination with divers who herd whole schools of fish into the nets) and long lines. Puerto Rico is developing comprehensive new fishing regulations for territorial waters, based on a new fishing law and compatible with Council FMPs.

    22. Schedule: Ongoing - near to medium term.

    23. Resources Needed: Establishment of regulations will not require additional resources, but its enforcement likely will.

    24. Participants: States and territories; Federal, state and local/tribal fishery management authorities; fishery commissions and regional management councils; fishers, aquarium collectors, and local communities.
    25. Address fishery impacts on deeper reefs. New technologies and increased consumer demand are driving fisheries and aquarium collection into deeper waters, where there are few baseline studies and little monitoring of harvest impacts. The ability to monitor and manage such fisheries will become increasingly important.

    26. Schedule: Medium to long term. In FY-99 NMFS will approve amendments to Fishery Management Plans (many dealing with deeper reefs). The Western Pacific Regional Fishery Management Council is considering additional regulations to ban the use of non-selective gear in precious coral collection.

    27. Resources Needed: Additional resources will be needed in FY-2000 to begin initial assessments in high priority areas where impacts are feared.

    28. Participants: States and territories; Federal, state and local/tribal fishery management authorities; fishery commissions and regional management councils; fishers, aquarium collectors, and local communities.
    29. Goal to expand the use of "no-take reef reserves." The U.S. Coral Reef Task Force should commit to working with fishers and other stakeholders to identify and protect coral reefs in a network of permanent "no-take" reserves that are open to non-destructive use only. A primary goal of protecting at least 5 percent of U.S. coral reefs by 2002 should be sought. In this regard, the Task Force may wish to highlight the following steps taken by the Hawaii, Puerto Rico, and the Caribbean Fishery Management Council.

      • The State of Hawaii has developed a plan to place a significant portion of the west coast of the Big Island into "no take" areas for aquarium collection.
      • Puerto Rico is designating a "no-take" marine reserve between Culebra Island and Luis Peña cayo and considering two others.
      • Last year, the Caribbean Fishery Management Council voted unanimously to establish its first coral reserve under the Magnuson-Stevens Fishery Conservation and Management Act, a 13 square nautical mile area called "Hind Bank" southwest of St. Thomas, U.S. Virgin Islands. The reserve, where fishing and anchoring are prohibited, was identified in close partnership with fishers, and is designed to protect coral habitat and preserve declining reef fish stocks.
      • Schedule: High priority - long-term strategy. There is an immediate need to begin monitoring of existing and planned "no-take" zones and identify appropriate areas for new zones. The goal should be to protect a significantly larger coral reef area by 2002.

      • Resources Needed: Modest additional resources are needed in FY2000 to develop baselines and monitor existing or planned "no-take" zones. Significantly more resources would be needed to implement more extensive zoning activities in FY2000 and beyond.

      • Participants: States and territories; Federal and local government, protected area and fishery management authorities; fishery commissions and regional management councils; fishers, divers, aquarium collectors, and local communities.

    30. Development of the Coral Reef Ecosystem Fishery Management Plan. The Task Force should support the efforts of the Western Pacific Regional Fishery Management Council to craft the first coral reef management plan that takes an ecosystem approach to the conservation and utilization of coral reef fishery resources.
    31. Schedule: The new FMP should be completed in FY-2000.

    32. Resources Needed: Enforcement of and monitoring for the new FMP will require additional resources beginning in FY-2001.

    33. Participants: Western Pacific Regional Fishery Management Council; NMFS, states and territories, fishers and others.

    Coastal Development and Shoreline Modification

    Summary of Key Issues/Threats/Problems

    The Coral Reef Protection Executive Order directs Federal agencies to ensure that any actions they authorize, fund, or complete will not degrade the condition of coral reef ecosystems. Given the dependence of coastal, and specifically island, communities on navigation and trade, this policy requires the careful consideration of federal agencies, states, and territories. The challenge of the Task Force is to protect coral reefs in perpetuity while meeting the growing demands on coastal resources. Brief descriptions of dredging, port and harbor development, and other issues considered by this working group follow.

    1. Dredging
      Federal Dredging Activities: The U.S. Army Corps of Engineers (Corps) dredges and disposes about 300 million cubic yards of dredged material annually from congressionally authorized navigation improvement and maintenance projects. Blasting coral for dredging rojects in State waters require State permits, including water quality certification and coastal zone consistency.

      Other Dredging Activities: In addition, permit applicants (e.g., port authorities, terminal owners, industries, and private individuals) dredge an additional 100 million cubic yards annually from navigation projects (i.e., ports, berths, and marinas).

    2. Port and Harbor Development
      Growing Demand: In October 1998, the U.S. Department of Transportation published A Report to Congress on the Status of the Public Ports in the United States. The report outlines dredging and dredged material disposal, other environmental regulations, and the need for expanding ports and harbors to meet growing demands. The report suggests that "With foreign trade expected to double by 2010, ports must continue to expand terminal facilities and related infrastructure." In addition, there is also the possibility of developing new harbors because urban growth around existing ports may preclude continued expansion.

      Different Types of Port and Harbor Development: Port and harbor development occurs for a variety of reasons; each may require different approaches for coral reef conservation. Examples include deep draft commercial ports; recreational small boat harbor ports; protected landings and shelter-type harbors; military harbors; and sole ports, or ports of entry to small islands.

    3. Undersea Cable and Pipeline Siting
      Expanding Use: Off the Florida coast, underwater cable for communications have been extensively sited. At this point, it is unclear if the cable adversely affects coral reefs or other organisms. In Hawaii, undersea cables may be used to transfer electricity generated from geothermal energy in the future. Past sitings of undersea cable in Hawaii have adversely affected reefs.

      Underwater Pipelines: The impacts of underwater pipelines on corals can be severe. Placement of both potable water supply and sewer outfall pipelines on the ocean floor can harm coral reefs and seagrass beds.

    4. Shoreline Modification
      Shoreline Modification (Certain issues in this section are shared with the Air and Water Quality Working Group): Shoreline development often accelerates coastal erosion. Many States and Territories face growing threats from erosion, which can adversely affect coral reefs (e.g., sedimentation, alteration of currents, changes in turbidity). For example, from 1989 to 1993, the miles of critically eroding shoreline in Florida increased from 217.6 to 232.9 (Florida Center for Public Management, 1997). Complicating the problem, the amount of development along the coastline is expected to increase in the future. Future erosion control measures should be designed to avoid or minimize negative effects on coral reefs.

      Beach Renourishment: In a number of areas, eroding beaches are resupplied with sand from offshore bars. Evidence indicates that offshore dredging for beach renourishment can, in some cases, adversely affect coral reefs (Blair, et al., 1990). Examples of damages to coral reefs that may occur from beach renourishment are physical impacts from dredging and sediment deposition from beach erosion.

      Hard Erosion Control Techniques: Seawalls, bulkheads, sheet pilings, groins, and moles are all structural mechanisms used to control erosion in particular areas. These techniques typically cause the accretion of sediment in one location, and the erosion of sediment in another. Unless hard erosion control structures are carefully designed and located, they can cause as many shoreline problems as they solve, and can degrade coral reefs (Maragos, 1993).

    5. Oil/Mineral/Gas Extraction

      International Implications: A moratorium is in place on leasing off the Florida coast. Working with the National Oceanic and Atmospheric Administration (NOAA), the Minerals Management Service implemented measures to protect coral reefs and their associated species in Florida. In the U.S., the impacts of extraction on coral reefs may be minimal; however, the international implications of extraction on coral reefs require consideration.

    Current Actions to Address Threats

    Environmental Review

    The aforementioned threats are addressed through various environmental review processes conducted by Federal, State, and local governments. The Corps reviews projects and issues permits for many of the above actions in accordance with the Rivers and Harbors Act (RHA), the Clean Water Act (CWA), and the Marine Protection, Research and Sanctuaries Act (MPRSA). Congressionally authorized projects conducted by the Corps do not receive permits but must comply with the same substantive permitting procedures and requirements and from state coastal zone management policies applied through the federal consistency provision of the Coastal Zone Management Act.

    Under the CWA and MPRSA, the Environmental Protection Agency (EPA) is responsible for developing the environmental criteria used by the Corps to evaluate proposed discharges of dredged material and for environmental oversight. EPA also has review and concurrence authority over Corps-issued permits. Under the Fish and Wildlife Coordination Act, the U.S. Fish and Wildlife Service (FWS) comments on projects in U.S. waters that will affect fish and wildlife resources. Several other project development and environmental compliance statutes, regulations and policies at the Federal, State, and local levels usually apply to many projects.

    Impediments to Addressing Threats

  • Lack of a Uniform, Vision for Ports and Harbors Expansion: Clearly, the demand for port and harbor expansion is increasing. Given the need for expansion, future port and harbor development should attempt to avoid or minimize negative impacts on coral reefs. However, for those ports and harbors which contain coral reef resources, it is not known to what extent potential coral reef impacts have been considered in future development plans. What is clear is that the issue over port and harbor expansion spans, federal, state and local interests and often includes public and private capital, thus complicating an already complex issue.

  • Lack of a Plan for Coral Reef Avoidance and Mitigation: In project review, the goal should be to avoid negative impacts on coral reefs. In cases where coral reefs are adversely affected by port and harbor development, what should be considered appropriate mitigation? Federal, state and territorial agencies have not developed consistent, acceptable mitigation standards for actions that degrade coral reefs.

  • Lack of Understanding of the Economic Value of Coral Reefs: Few economic valuations of coral reefs have been completed (see Florida Keys example on p.14). Because of this lack of information, it is difficult to weigh the true costs and benefits of individual projects.

    Proposed Actions and Strategies to Address Threats

    1. Encourage Growth Management Plans for Ports and Harbors with Coral Reefs: Federal, State, and Territorial governments could encourage growth management plans for ports and harbors near coral reefs. Plans could (1) consider the implications of growth on coral reefs, (2) attempt to avoid or minimize negative impacts, and (3) identify appropriate mitigation measures.

    2. Schedule: Medium to long term priority.
    3. Resources Needed: Financial incentives to ports. Technical assistance of Federal, State, and Territorial agencies.
    4. Participants: NOAA, FWS, Corps, States, Territories, Port Authorities.
    5. Develop a Plan for Coral Reef Avoidance and Mitigation: Clear avoidance/ mitigation guidelines could help guide projects that may affect coral reefs. An interagency Federal team could develop and recommend acceptable guidelines. The recommendations could be presented to the U.S. Coral Reef Task Force for consideration. Acceptable mitigation may vary depending on the type of expansion (e.g., commercial, recreation).

    6. Schedule: Medium term priority. The Task Force could identify a team to begin working on guidelines. The team could provide a progress report at the next Task Force meeting. Developing acceptable guidance may require 1-2 years. Guidance, once developed, could be implemented through a variety of means including coral reef legislation, regulation or voluntary means.
    7. Resources Needed: Technical assistance of Federal, State, and Territorial agencies. Could require 1-2 FTEs per agency.
    8. Participants: NOAA, FWS, Corps, States, Territories, Port Authorities.
    9. Develop Regional Economic Valuations of Coral Reefs: A valuation of coral reefs in the Florida Keys National Marine Sanctuary has been completed ($2,833/m3). Federal agencies could provide grants to assess the economic value of coral reefs in the Gulf of Mexico, the South Atlantic, the Caribbean, and the Pacific. Valuations of coral reefs can help managers assess the true costs and benefits of projects that affect these resources. These valuations could become a required part of the cost-benefit analysis for individual projects. In addition, the costs for short and long term mitigation could be included in cost-benefit calculations.

    10. Schedule: Medium term priority.
    11. Resources Needed: Some amount of resources will be needed to fund valuations.
    12. Participants: NOAA, States, and Territories.

    Vessel Traffic

    SUMMARY OF KEY ISSUES/ THREATS/ PROBLEMS

    Direct Vessel Impacts: Vessel Groundings, Propeller Scarring, Anchor Damage and the Like

    Coral reefs and sea grass beds often grow in shallow water and therefore are susceptible to a variety of direct impacts from vessels. These impacts include damage from the propeller, hull, engine and keel of both commercial and recreational vessels. They also include damage caused by anchors, unmanned barges, dredge lines and dredge cutter heads, and cables used to tow barges and dredges. When ships ground on coral, the impact can dislodge, fracture, or destroy corals and related structures. If a boat’s hull ruptures, oil spills may further damage corals. Salvage operations or attempts to dislodge a boat from a reef or seagrass bed, if done improperly, may also exacerbate damages. Boat groundings, anchoring, propeller scarring (caused when a propeller cuts sea grass while a boat motors over a shallow flat), and other vessel impacts occur with frequency and may cause damage such that the reef and grass beds do not have time to recover. The bulk of this section focuses on the nature and extent of vessel groundings, because these are better documented.

    Damages to seagrass beds are included in this report due to the ecological relationship between seagrass beds and coral reef communities. Coral reefs occur adjacent to extensive turtle grass-dominated grass beds along the full extent of the oceanic margin of the Florida Keys. The most prominent interaction between the two communities involves nocturnally active coral reef fishes of several families feeding over grass beds at night. (Zieman, 1982). Randall (1963) noted that grunts and snappers were so abundant on some isolated patch reefs in the Florida Keys that it was obvious that the reefs could not provide food, nor possibly even shelter, for all of them. To the extent that seagrass beds are damaged, the existence of those creatures that depend on the seagrass beds and the coral reefs is jeopardized. Seagrass beds also serve as a nursery for the young and that they cleanse the water, both functions beneficial to the coral reef communities.

    The National Parks, Marine Sanctuaries, the U.S. Coast Guard, and the States of Hawaii and Florida have reported a significant number of vessel groundings. The following information about vessel groundings and other vessel-related damages affecting coral reef resources was obtained separately from different agencies. Because these agencies collect the information for different purposes and use different methods, it is difficult to generalize about the nature and frequency of vessel groundings and other impacts.

    National Marine Sanctuaries (NOAA). Marine Sanctuaries with coral reef habitat include: Florida Keys National Marine Sanctuary (FL); Flower Garden Banks National Marine Sanctuary (TX); Hawaiian Islands Humpback Whale National Marine Sanctuary (HI); Fagetele Bay National Marine Sanctuary (American Samoa); and Puerto Rico’s National Estuarine Research Reserve (Jobos Bay NERR) and six Natural Reserves. In the Florida Keys National Marine Sanctuary alone, there are over 500 reported vessel groundings per year. These figures include both commercial and recreational boat groundings, though most of groundings are recreational. Of the over 1,000 groundings that occurred in 1997 and 1998, approximately half affected coral and half affected seagrass). Of these groundings, approximately 35 cases were forwarded to Legal Counsel for action under Section 312 of the National Marine Sanctuary Act (which authorizes civil actions for response costs and damages). A chart of some major grounding cases in the FKNMS follows: (Source: NOAA, Marine Sanctuaries Division).

    Vessel Incidents in Florida Keys National Marine Sanctuary
    Vessel Name Date of Injury Location Vessel Size Resource/ Habitat Scope of Injury Funds Recovered
    Wellwood 8/4/84 K.Largo NMS (Molasses Reef) 122 m coral reef 1500 m2 extensive biological and structural injury $5,654,228
    Mini Laurel 12/11/86 K. Largo NMS (Molasses Reef) 65 m coral reef biological & structural injury $30,000
    Alec Own Maitland 10/25/89 K. Largo NMS (near Carysfort Light) 47 m coral and flat rock 930 m2 partial destruction; 680.5 m2 total destruction $1,450,000
    Elpis 11/1/89 K. Largo NMS (near Elbow Reef Light) 143 m coral reef 482 m2 partial destruction; 2604.7 m2 total destruction $2,275,000
    Jacquelyn L. 7/7/91 FKNMS (W.Sambo Reef) 54 m coral reef 123.1 m2 total injury; .5 m2 partial injury $251,554
    Salvors, Inc. Prior to 5/22/92 FKNMS (Coffins Patch; Hawks Channel)   seagrass beds 100' blowholes, 30' x 9' deep caused by propwash deflectors (used in treasure hunting) $589,331 (on appeal)
    Miss Beholden 3/13/93 FKNMS (W. Sambo Reef) 45 m coral reef 1025.6 m2 biological destruction and physical injury $1,873,741 (judgment awarded but no collection)
    Columbus Iselin 8/10/94 FKNMS (Looe Key) 52 m coral reef 345 m2 total destruction $3,760,488
    Great Lakes 5/26/93 FKNMS (great White Heron NWR) large tug & barge seagrass and coral meadows 25776.1 m2 extensive physical and biological injury in litigation
    Petty Cache 4/1/94 FKNMS (W. Sambo Reef) 15.25 m Coral reef 17.25 m2 total destruction in litigation
    Contship Houston 2/2/97 FKNMS (Maryland Shoal) 187 m Coral Reef 2333 m2 of crushed coral reef substrate; over 3000 broken pieces of coral ER/DA cost paid. RP undertaking restoration*
    Golden Lady 2/15/97 FKNMS (W. Sambo Reef) 21.66 m Coral Reef approximately 42 m2 living coral destroyed, additional sanctuary resources injured $54,716
    Flyway 1/15/98 FKNMW (Carysfort Reef) 14.6 m Sailing vessel Coral Reef 9.3 m2 coral reef injury RP has undertaken restoration

  • (Source: NOAA, Marine Sanctuaries Division; Office of General Counsel).
    * Monitoring costs and midcourse costs to be collected upon entry of consent decree expected Spring 1999.

    Anchor damage has been documented in the Flower Garden Banks National Marine Sanctuary by researchers and sanctuary staff:

  • On the shallowest portion of the bank, there is at least one extensive area of damage by a large vessel anchoring measuring approximately 50 m in diameter, with hundreds of abraded, fractured, and toppled coral colonies and chain scars.

  • In 1983, a tug and tow barge anchored on the East Bank at 21 m depth, causing substantial damage to the coral reef measuring approximately 3 m wide and 60 m long. Over 200 coral colonies were impacted by the anchor and the attached anchor chain and cable. In addition, intermittent damage was detected along a narrow strip approximately 1.5 m wide and over 120 m long, apparently caused by dragging and bouncing by the anchor as it was hauled in by the vessel operators. (Gittings and Bright, 1986)

  • Damage to a small area of the East Bank was also documented in 1996 following anchoring by a fishing vessel. The area of impact was less than 20 m in diameter and damage was intermittent, primarily abrasions and a small number of fractured colonies.

  • In 1997, an area nearly 200 m in length was damaged by an apparent tow cable that dragged across the summit of the West Flower Garden Bank. The cable sawed dozens of coral colonies, some to a depth of roughly 10 cm. It is likely that the cable linked a barge and tug and for some reason sank to the depth of the reef for some period of time. The damaged area appeared to begin at nearly 35 m depth and continue over the shallowest parts of the reef at roughly 20 m depth.

    National Parks (DOI/NPS) National Parks with tropical coral reef resources include the Biscayne Bay NP and Dry Tortugas NP in Florida; the Virgin Islands NP, Buck Island Reef NM, and Salt River Bay NHP in the U.S. Virgin Islands; Kaloko-Honokohau NP and Kalaupapa NHP in the Hawaiian islands (the Hawaiian reefs under State management authorities), and the American Samoa NP and War-in-the Pacific NP (Guam) in the Indo-Pacific region. In Biscayne National Park, a recent aerial survey revealed that many of Biscayne Bay’s sea grass flats have already had as much as 20% of the sea grass destroyed by propeller scarring and boat groundings (BNP report, citing Sargent et al. 1995). In the Biscayne NP alone, the numbers of reported groundings over the past few years included the following:
    Year# Seagrass Coral (vessels <100ft)Coral (vessels > 100ft)
    1995 120 1   
    1996 217    2
    1997 177 4  
    1998* 155 9 1
    * One mangrove grounding. The data for 1998 is not complete.

    In Biscayne NP, seagrass grounding numbers are considered to be only 20% of all groundings. Groundings on coral reefs go unreported because rarely do vessels become stranded as a result of grounding on a reef. (Source: Biscayne National Park Report, 1996; National Park Service) As a result, damages to coral reefs caused by vessel groundings may remain undiscovered and unrestored.

    Florida Keys/Monroe County. The Florida Department of Environmental Protection (DEP) estimates that approximately 500 small vessel (less than 30 meters) groundings are reported annually in the Keys. The researchers at the Florida Marine Research Institute (FMRI), estimate that at least two to three times that number go unreported each year. The DEP does not have specific data on anchor damage, though in response to investigation of anecdotal reports, the state and federal managing partners prohibited anchoring for large vessels in a coral reef area off the Tortugas that is nicknamed "Sherwood Forest." That restriction went into place in 1998, a follow-up to an emergency rule that was initiated by NOAA. The Florida DEP conducted an assessment on propeller scarring in 1992-1993 to confirm the location of propeller scarring in Florida waters using aerial photography. The FMRI’s report concluded that more than 173,000 acres of the state’s 1.9 million acres of seagrass acreage are scarred – most of it lightly. This is a conservative estimate because the researchers mapped groups of scars rather than individual propeller scars. (Sargent et al. 1995)

    Fish and Wildlife Service (DOI/FWS) National Wildife Refuges with tropical coral reef resources include Great Heron NWR, Key West NWR in South Florida, and Hawaiian Islands NWR, Midway Atoll NWR, Johnston Atoll NWR, Howland Island NWR, Baker Island NWR, Rose Atoll NWR, Jarvis Island NWR, and Guam NWR in the Pacific. A partial list of shipwrecks that have occurred since 1970 in the Pacific Remote Islands National Wildlife Refuge and Midway Atoll NWR follows. Records of wrecks, groundings and rendering of aid by the agency to avoid disaster were found in annual refuge narratives and general files.

    Vessel Incidents in Hawaiian Islands National Wildlife Refuge

    Vessel Date Location V. Size Impacts
    Kaiyo Maru 2/7/70 Laysan 110' Parts still on island
    Good Friends 12/13/76 Pearl and Hermes Reef 51' sailing boat  
    Irenes Challenge 1977 50 mi. N. Lisianski    10.4 million gallons crude oil spilled
    Santa Ines 3/10/80 French Frigate Shoals 80 ft. Steel hull   
    Anangel Liberty 4/27/80 French Frigate Shoals 538 ft. 2200 lbs. kaolin clay dumped
    Keola 1/18/81 Little Gin Island, FFS      
    Carolyn K 2/5/85 1.5 mi S. of Tern Island, FFS    200 gallons diesel fuel spilled
    Mimi 6/26/89 Pearl and Hermes Reef 35' Salvage effort failed, vessel broke up on reef
    Hawaiian Patriot 2/24/97 S. of Necker Island 370 mi. W of Honolulu      

    Midway Atoll National Wildlife Refuge and Rose Atoll NWR

    Vessel Date Location V. Size Impacts
    Omi Yukon 10/28/86 300 mi. SE of Midway Atoll NWR Oil tanker burns and sinks
    Rabba Abba 10/3/92 Rose Atoll NWR 50' fiberglass sailboat Parts still there
    F/V Jin Shiang Fa 10/14/93 Rose Atoll NWR 120' longliner Parts still there.

  • (Source: FWS)

    Hawaiian Islands. The majority of coastal waters within the State of Hawaii consist of coral reefs, which represent approximately 85% of all U.S. coral reefs (estimate by Miller & Crosby, 1998). Between 1993 and 1997, the U.S. Coast Guard received 49 reports of commercial ship groundings, involving 31 commercial passenger boats (63%), 13 fishing boats (25%), 2 freighters (4%), 1 towboat (2%), 1 industrial vessel (2%), and 1 offshore supply vessel (2%). In that same period, there were 17 commercial ship sinkings (10 fishing boats, 6 passenger boats, 1 towboat). In 1998, the Hawaii Department of Land and Natural Resources received reports of 9 recreational vessel groundings and 5 recreational vessel sinkings. (Source: Hawaii DAR)

    U.S. Territories & Commonwealths. The U.S. Coast Guard Marine Safety Information System casualty database contains the following reported commercial vessel groundings. (Note: the numbers may not be entirely accurate due to the way the areas of responsibility are delineated. For example, St. Croix in the U.S.V.I. will be included under the San Juan PR numbers rather than under the St. Thomas (U.S.V.I.) numbers. Also, it is possible that groundings in some of these areas were reported to, or investigated by, other units. There are also gaps in the database where CG units were closed due to budget reasons (St. Croix in the early 1990s, Samoa before 1994). This database also does not show what percent of these groundings resulted in coral reef impacts.)

    Unit 1990 1991 1992 1993 1994 1995 1996 1997 1998 Total
    ASOD             1 2 1 2 1 7
    GUAMS 3 2 4 3 4 3 4 16 3 42
    HONMS 23 25 14 16 19 12 14 19 10 152
    SJPMS 16 22 7 17 11 3 17 8 16 117
    STTD   1 2 3 7 5 5 2 3 28
    Total 42 50 27 39 42 26 41 47 33 347

    ASOD= MSD American Samoa. GUAMS=MSO Guam (probably includes Saipan/CNMI) HONMS= MSO Hononulu, Hawaii. SJPMS=MSO San Juan, Puerto Rico. STTD=MSD St. Thomas, USVI
    (Source: U.S. Coast Guard, Office of Vessel Traffic Management)

    Puerto Rico. Recent significant groundings include:

    Vessel name Date length/ gross tonnage Affected Resources Grounding Area
    M/V Author 9/8/98 202 m/ 1979.95 coral reef, seagrass Ponce Bay
    M/V Kapitan Egorov 6/20/98 678.5 ft./ 32,516 coral reef, seagrass Guayanilla Bay
    M/V Fortuna Reefer 7/24/97 305.72/ 3493 coral reef Mona Island
    M/V Morris J Berman 1/7/94 coral reef, seagrass, sand beach El Escambron, San Juan

    (Source: NOAA contact in PR)

    Current Activities and Abilities to Address Threats from Direct Vessel Impacts

    Existing Administrative and Regulatory Programs.

    Agencies have taken a number of steps to address threats to coral reefs from direct vessel impacts. These efforts include management plans, installation of navigational aids, educational outreach, and enforcement. Some specific activities are described below.

    National Marine Sanctuaries. The Florida Keys National Marine Sanctuary (FKNMS) Management Plan has ten action plans, several of which apply to vessel-related impacts (Channel/Reef Marking, Education and Outreach, Enforcement, Mooring Buoy, and Regulations). The FKNMS also has authority to recover costs and natural resource damages (under Section 312 of the National Marine Sanctuaries Act) and to assess civil penalties (under Section 307) for any vessel injury to coral reef resources. NOAA recently completed a summary settlement schedule for violations within the FKNMS, which facilitates and streamlines the administrative civil penalty process. The FKNMS is also developing a response protocol for vessel groundings.

    In 1992, with the designation of the Flower Garden Banks National Marine Sanctuary, vessels larger than 100 feet in length were prohibited from anchoring on the banks. Vessels less than 100 feet in length were required to use mooring buoys, if available. If none were available, such vessels could anchor, but could not damage sanctuary resources and were required to use ground tackle with no more than 15 feet of chain or wire rope, a practice that would limit resource destruction by the ground tackle itself. The regulations further required that the anchor line be of soft fiber such as nylon or polypropylene or some similar material.

    National Park Service. Biscayne, Buck Islands, Dry Tortugas and Virgin Islands National Parks all have designated anchorage areas for certain types of boats and/or mooring buoy requirements in one of more of the popular reef areas. Other actions being taken in these parks include development of Oil Spill Contingency Plans, prohibiting certain types of boating activity such as water-skiing, and limiting the number of commercial dive boats, and limiting the size of boats using the area. The Biscayne National Park has developed a vessel grounding response protocol. It has also developed a Marker plan for the Park to determine where additional markers are needed to reduce vessel groundings. Monroe County just completed such a plan and will soon be implementing it. The Park also installed 9 new Danger Shoal markers around some of our most heavily hit seagrass shoals. The Biscayne NP has identified one major hot spot for smaller vessel groundings, where the markers in the area are too far apart and vessels have a tendency to get off course. Biscayne also has a very active educational program, which includes offsite grounding presentations, "Boating and Navigating in Biscayne NP" classes, grounding stickers that are handed out to boaters, and presentations at boat shows dedicated to groundings.

    State of Hawaii. The State of Hawaii has been implementing a mooring buoy project and a day use mooring system, though funding for maintenance continues to be a difficulty. The State, in concert with Hawaii-based federal agencies, also proposes to create a rapid response team of field biologists, enforcement and regulatory officials to quickly assess and direct response to a wide range of short-term anthropogenic events impacting coral reefs throughout the State.

    United States Coast Guard Activities: While the U.S. Coast Guard (USCG) has no activities aimed directly at coral reef protection per se, it does perform a number of functions with significant benefit to coral reefs. These include:

    • Aids to Navigation: The USCG establishes and maintains both short and long (radio) range aids to navigation to assist both recreational and commercial vessels.

    • Pollution Response: Under the Oil Pollution Act (1990) and the Navigational Contigency Plan, the USCG Federal On-scene Coordinators (FOSC) prepare area contingency plans and direct response operations for incidents which pose significant oil or hazardous materials threats to the environment. USCG’s FOSCs are assisted by NOAA scientific support coordinators as well as other agencies which insure that pertinent ecosystem factors are considered in developing and executing response operations. If the vessel owner/operator can not or will not respond properly, the USCG can activate the Oil Spill Liability Trust Fund to fund appropriate response actions.

    • Commercial Vessel Safety: The USCG enforces a wide range of domestic and international requirements on both US and foreign flag vessels. Starting in approximately 1995, Port State Control boardings of foreign freight vessels were strengthened considerably and smaller Carribean freight vessels, in particular, were brought under much stricter scrutiny.

    • Recreational Boating Safety: The USCG Auxiliary along with the US Power Squadrons is a major factor in insuring recreational boating safety in US waters. The USCG Auxiliary includes regionally specific environmental information in its basic boating safety courses.

    • Waterways Management: At the federal level, the USCG is the principal regulatory authority for navigational operations in US territorial waters. Measures under the Ports and Waterways Safety Act include (1) Regulated Navigational Areas (RNA), (2) establishment of Traffic Separation Schemes (TSS), (3) Areas to be Avoided (ATBA), and (4) establishment of anchorages. Some of these measures (TSS,ATBA) are also approved through the International Maritime Organization due the implications to the Law of the Sea Convention.

    Department of Justice Enforcement Activities. The Department of Justice, through the Civil Division, the Environment and Natural Resources Division, and the U.S. Attorneys Offices, bring enforcement actions against those who cause coral reef and reef ecosystem injuries. The Department works with agencies such as NOAA, the U.S. Coast Guard, EPA, and the National Park Services to bring civil and criminal enforcement actions to collect damages for and accomplish restoration of reefs and reef ecosystems injured by vessels, hazardous substances, or petroleum and to seek injunctive relief prohibiting or restricting activities that damage or injure coral reefs. Some examples of cases the Department has brought include:

    • In re Fortuna Reefer. The Fortuna Reefer, a 306-foot ship hauling 90,000 gallons of fuel oil, ran aground on a coral reef off the coast of Mona Island, Puerto Rico on July 24, 1997. No oil was discharged, though the grounding posed a substantial threat of discharge during the days in which the vessel remained on the reef. Significant damage occurred to the coral reef as a result of the initial impact and the time the vessel was grounded on the reef. In September 1997, the owner of the vessel agreed a settlement reached under the Oil Pollution Act (OPA), whereby the United States and the Commonwealth of Puerto Rico, as co-trustees, received $1.25 million to implement natural resource restoration and for reimbursement of past and future costs.

    • The Admiralty Section of the Civil Division has brought a number of admiralty cases involving coral reef damages. In these cases, the Civil Division has dispatched admiralty attorneys to the scene in order to file an in rem action, arrest the vessel, protect the arresting agents from potential exposure arising from the arrest and detention of the vessel, negotiate collateral security for release of the vessel and cargo, and depose multinational crew concerning a broad range of topics, including the correct use of sophisticated navigational equipment. Actions have included the groundings of the Wildwood ($6.2 million recovered); Alec Owen Maitland ($1.49 million recovered), Elis ($2.39 million recovered), Macro Vetranic ($3 million recovered) and Jacqueline L (Florida Keys National Marine Sanctuary, Western Sambo Reef )($250,000 recovered), Mini Laurel ($25,000 recovered), in God We Trust ($30,000 recovered) and M/V Cuquette (Johnson's Reef, St. John)($25,000.00).

    Existing Statutory Authorities.

    Agencies have a number of statutory authorities to address vessel damages to coral reefs. More robust authorities are found within protected areas, such as the National Marine Sanctuaries and the National Parks. Other authorities are available if a ship grounding includes oil pollution or hazardous waste discharges or the threat of these. A brief sampling of some legislative authorities include:

    National Marine Sanctuaries Act, 16 U.S.C. 1431 et seq.

    • Civil penalties to $109,000 per violation of the Act, or any regulation or permit issued under the Act. 16 U.S.C. 1437(c)(1).

    • AG may seek injunctive relief to abate risk or actual destruction, loss, or injury to a sanctuary resource, or to restore or replace a sanctuary resource, or both. 16 U.S.C. 1437(i).

    • U.S. may recover response costs and damages resulting from destruction, loss, or injury of any sanctuary resource. 16 U.S.C. 1443(c).

    • Any vessel used to destroy, cause the loss of, or injure a sanctuary resource shall be liable in rem to the U.S. 16 U.S.C. 1443(a)(2).

    • NOAA may use response costs and damages recovered to finance response actions and damage assessments (limit of 20% up to $750,000); to restore, replace or acquire equivalent resources; and to manage and improve national marine sanctuaries. 16 U.S.C. 1443(d).

    Park System Resource Protection Act, ,16 U.S.C. 19jj

    • U.S. may recover damages and response costs for any destruction, loss, or injury to park system resources. 16 U.S.C. 19jj-1.

    • DOI may use response costs and damages recovered as a result to damage to any park resource to reimburse response costs and damages, or to restore, replace or acquire equivalent resources. 16 U.S.C. 19jj-3.

      Oil Pollution Act, 33 U.S.C. 2701-2761

    • U.S. may recover removal costs and damages for discharge of oil, or for substantial threat of discharge of oil. 33 U.S.C. 2702.

    • Oil Spill Liability Trust Fund shall be available for payment of removal costs determined to be consistent with the National Contingency Plan. 33 U.S.C. 2712.

      CERCLA, 42 U.S.C. 9601-9675.

    • Owner or operator of vessel, or arranger or transporter of hazardous wastes is liable for response costs and damages for hazardous substance releases. 42 U.S.C. 9607.

    Clean Water Act, 33 U.S.C. 1251 et seq.

  • U.S. may recover removal costs and damages for discharge of pollutants or oil into water [now covered by CERCLA and OPA]. 33 U.S.C. 1321.

    Florida Keys National Marine Sanctuary Protection Act (FKNMSPA). Pub. L. 101-605, § 6(a) (1990)

  • Prohibits operation of tank vessels or large vessels within the "Area to be Avoided."

    National Wildife Refuge Improvement Act of 1997, 16 U.S.C. 3101 et seq.

    • Requires that a Comprehensive Conservation Management Plan be completed within 15 years.

    • Recognizes that wildlife-dependent recreational uses involving hunting, fishing, wildlife observation and photography, and environmental education and interpretation, when determined to be compatible, are legitimate and appropriate public uses of the Refuge System.

    • Requires that the Secretary of the Interior maintain the biological integrity, diversity and environmental health of the Refuge System

      Rivers and Harbors Act, 33 U.S.C. 401, et. seq.

    • Prohibits the creation of any obstruction, not authorized by Congress, to the navigable capacity of any waters of the United States

    • Provides criminal penalties, including a fine not exceeding $2,500 nor less than $500 for violation of sections 401, 403 and 404 of Act.

    • Prohibits discharge, out of any ship, barge or other floating craft, or from the shore, any refuse matter of any kind or description into any navigable water of the United States

    • Prevents the securing or anchoring of vessels or other craft in navigable channels in such a manner as to prevent or obstruct navigation

    • Prevents sinking of vessels or other craft in navigable channels in such a manner as to obstruct or impede navigation; requires owner of sunken craft to immediately mark craft, and to commence immediate removal of same; failure to do so is considered an abandonment of the craft which subjects the same to removal by the United States. (The United States may file suit to collect removal expenses, pursuant to Wyandotte Transportation Co. v. United States, 389 U.S. 191 (1967))

    Primary Impediments to Addressing Threats from Vessel Impacts

    Knowledge Gaps. In order for agencies to more effectively address vessel-related impacts, it is necessary to know where "hot spots" of vessel activities and vessel-related damages occur, which will allow agencies to examine the main causes of vessel-related damages specific areas.

    Navigator Inexperience/ Error. Many of the causes of vessel-related damages to coral reefs stem from navigator error or inexperience, particularly among recreational vessel users. These errors may include, among other things, misuse of electronic navigational equipment, misreading navigational aids and charts, not having charts, and not knowing how to respond once a ship has been grounded (sometimes much more damage is caused by boats trying to power off a coral reef or seagrass bed). Education and public outreach is a critical component to addressing navigator inexperience and error. Because coral damaged by a grounding can take decades to recover, the prevention of groundings and other vessel-related damage is of utmost importance.

    Need for More/ Better Navigational Aids. Better navigational aids (such as charts delineating coral reefs, marine protected areas or buoys marking restricted areas) would be useful to help vessels avoid coral reef areas. This would also include better delineation on international charts. Installing and maintaining permanent anchoring buoys in areas of high recreational use can avoid anchor damage. Another technology that could potentially improve navigating in and round coral environments is electronic charts and Global Positioning System (GPS) aided navigational software. Through this technology, vessels could be alerted when they enter high hazard areas such as shallow coral environments. Automatic Identification System (AIS) marine transponders which are currently under development, will permit cost effective monitoring of high(er) threat commercial shipping in areas such as the Florida Straits. While it is unknown what effect this emerging technology will have in improving navigation and the ability to monitor shipping around coral reefs, inroads for protection should be fully exploited.

    Lack of Resources. Resources are needed across the board (to fill in knowledge gaps, to improve navigational aids and public education, and to enforce existing laws). Federal and local on-water law enforcement personnel are extremely scarce in the Pacific territories. Funds are necessary to allow trustees to do restoration activities without having to wait for years and a judicial ruling or collection. Existing resources should be better leveraged (for example, NOAA’s revolving fund used for response costs should be maintained in interest bearing accounts). Additional funding for periodic surveys of coral reef habitats would allow the Parks and Marine Sanctuaries to assess, if not repair, the damages caused by unreported groundings.

    Need for Standard Response to Vessel Groundings. Quick agency responses are necessary where groundings or other damages occur to avoid future degradation of damaged reefs. A number of agencies have response protocols, but there is a need to share information among the agencies and to develop a consistent approach to response, assessment, and collection of evidence for consistent and high quality enforcement actions.

    ABANDONED SHIPS

    Abandoned ships in U.S. territorial waters can impact coral reef resources. Where a ship grounds on coral reefs and the wreckage is not removed, damage to coral reefs continue and reef recovery may be slowed. U.S. Fish and Wildlife Service in Hawaii has documented the long-term effects of one vessel grounding where parts of the vessel were not removed. (Green et al. 1997). In October 1993, a Taiwanese longliner Jin Shiang Fa ran aground at Rose Atoll National Wildlife Refuge, spilling 100,000 gallons of diesel fuel and other contaminants onto the reef. The vessel grounding gouged large grooves in the atoll and reduced parts of the reef into rubble; killed many invertebrates such as reef-boring sea urchins, giant clams and corals; killed the dominant algal species (crustose coralline algae) causing a bloom of opportunistic algal species; and changed the distribution of herbivorous fishes and sea urchins. Salvage operations removed most of the larger pieces of wreckage and debris, but the salvage crew did not move the stern and its associated debris, or the engine block.

    Three years after the event, the reef show only limited recovery. Of most concern, the opportunistic algal species continue to dominate the wreck site, and the crustose coralline algae, which are primarily responsible for maintaining the structure of the atoll, show little sign of recovery. Preliminary studies show that iron corroding from the wreckage may be contributing to the maintenance of the algae bloom. (Green et al. 1997). Similarly, a longliner vessel ran aground on the Kure Atoll in Hawaii, in October 1998. While the vessel insurer was able to pay for some salvage, the boat remains grounded on the reef. It has been estimated that removing the Paradise Queen II from the Kure Atoll would cost $1.5 million.

    Current Activities and Abilities to Address Abandoned Ships

    If an abandoned ship is a hazard to navigation, the Army Corps of Engineers is responsible for mitigating the hazard and can seek reimbursement from the ship’s owners (sometimes the response is to mark the hazard and leave it). Unfortunately, most coral reefs and seagrass beds are in shallow areas. As a result, vessels that remain aground on coral reefs or seagrass beds are unlikely to be considered hazards to navigation, and the Corps of Engineers is therefore unlikely to conclude that it has authority to remove the vessel. If a ship poses a threat of oil pollution or hazardous waste discharge, the U.S. Coast Guard has authority to remove or address the threat. As the recent grounding of the longliner on Kure Atoll demonstrates, the Coast Guard’s response to the threatened or actual discharge of oil does not necessarily include removal of the vessel from the coral reef or seagrass bed.

    Primary Impediments to Addressing Abandoned Ships

    Lack of Resources. The primary impediment to removing abandoned ships that affect coral reefs is that such removal can be extremely costly. Many of the known abandoned ships are in remote areas of the Pacific where it would be difficult and expensive to salvage ships. The Rose Atoll, for instance, is situated more than 150 km from the nearest island, Ta’u in the Manu’a Islands, and 270 km east of the main island of Tutuila. To provide a sense of the costs of salvaging vessels, one private salvage company generally charges $25,000 per day for salvage.

    VESSEL POLLUTION

    Marine pollution stems from a variety of sources, including discharges of oil from vessels, ocean dumping of wastes, and discharge of sewage and wastes from land-based sources. Other vessel-based sources of pollution include the introduction of alien species into coral reef and seagrass habitats by vessels (i.e., through dumping of bilge contents) and fishing gear debris. Biologists at Biscayne National Park have noted that abandoned or lost lobster traps can cause substantial damage to coral reef communities as they are moved around by ocean currents. The Air and Water Working Group of the Coral Reef Task Force is addressing land-based sources of pollution as well as vessel-based pollution. The Destructive Fishing Practices Subgroup of the Coastal Uses Work Group is addressing the problem of fishing gear debris. Therefore, this section will be brief.

    Current Activities and Abilities to Address Pollution Threats from Vessels

    Statutory Authorities. A number of international and domestic regimes address marine pollution. The primary international agreement for prevention and control of marine pollution is the 1973 International Convention for the Prevention of Pollution from Ships, Nov. 2, 1973, S. Exec. Doc. E, 95th Cong., 1st Sees. 1 (1979), 12 I.L.M. 1319, as modified by the 1978 Protocol, Feb. 17, 1978, S. Exec. Doc. C, 96th Cong., 1st Sess. 1 (1979), 17 I.L.M. 546 (MARPOL 73/78). The United States has implemented MARPOL Annex V, which addresses shipboard solid waste discharge at sea, through the Act to Prevent Pollution from Ships, 33 U.S.C. 1901 et seq. This act requires U.S. public vessels, including warships, to comply with Annex V requirements by established deadlines. It also provides for criminal penalties for dumping different types of garbage and other discharges from vessel operations (i.e: not garbage transported from shore) within certain set distances from land. This applies to all waters as well as to all vessels over which the U.S. has jurisdiction.

    The primary international agreement dealing with marine disposal of wastes is the Convention on the Prevention of Marine Pollution by Dumping of Wastes and Other Matter (London Convention), Dec. 29, 1972, 26 U.S.T. 2406, 1046 U.N.T.S. 120. Countries ratifying the London Convention have agreed to prohibit the dumping of certain wastes (listed Annex I), including mercury, cadmium, organohalogens, oil, persistent plastics, and high-level radioactive wastes. Special permits are required for ocean disposal of other wastes (listed in Annex II), such as arsenic, copper, lead, cyanides, pesticides, scrap metal, and low-level radioactive wastes. All other substances require a general permit for ocean disposal. The United States implements the London Convention through the Ocean Dumping Act, 33 U.S.C. 1411 et seq., which prohibits U.S. flag ships or citizens from departing from the U.S. to dump anything into ocean without a permit (or dumping in U.S. territorial sea when transported from outside U.S. (12 nautical miles)). This Act provides for civil penalties of $ 50,000 per violation ($125,000 for medical waste), 33 U.S.C. 1415(a); criminal penalties (up to 5 years imprisonment), 33 U.S.C. 1415(b); and injunctive relief, 33 U.S.C. 1415 (d).

    Domestic oil pollution is addressed through the Section 311 of the Clean Water Act, 33 U.S.C. 1321, and the 1990 Oil Pollution Act, 33 U.S.C. 2701-2761. Section 311 of the Clean Water Act prohibits oil or hazardous substance discharges in navigable waters of the United States in quantities which "may be harmful to the public health and welfare or environment of the United States." 33 U.S.C. 1321(b)(3)-(4). Both civil and criminal enforcement and penalties are available to enforce Section 312, and civil enforcement is available to abate actual or threatened discharges. 33 U.S.C. 1321(e)(1). The Oil Pollution Act of 1990 provides for strict liability of responsible parties for clean up costs and natural resource damages from discharges of oil.

    Enforcement Actions. The Department of Justice has brought civil and criminal enforcement actions against polluting vessels. In one criminal prosecution, the United States secured from the violator a commitment to fund coral reef projects. In U.S. v. Royal Caribbean Cruises, Ltd.. (D.P.R.) (S.D.Fla.), the Department took action against cruise ship discharges of oily bilge water that threatened water quality in U.S. waters and in the Caribbean. The United States obtained $ 9 million in penalties, $ 1 million of which was suspended to fund coral reef projects in the territorial seas of Puerto Rico and South Florida.

    PROPOSED ACTIONS AND STRATEGIES TO ADDRESS KEY THREATS

    Understanding

    Monitoring. Agencies propose to identify "hot spots," or areas of high recreational or commercial traffic and use and high risk of damage to coral reefs, and evaluate best management practices to address the risks. Solutions may include installation of permanent mooring buoys, modification of existing charts and navigational aids, education and outreach, enforcement, or other measures. Determination of the grounding "hot spots" will enable NOAA and the Coast Guard to assess whether it is appropriate to change the existing navigational aids and charts.

    Mapping. NOAA’s National Ocean Service (NOS) proposes to prepare a prototype of an improved navigational chart that consists of a conventional chart, overlaid with boundaries noting important jurisdictional areas (such as marine sanctuaries or national parks), along with environmental data showing the location of coral reefs. Additional notes on the chart could warn the reader of potential fines and sanctions for violating marine sanctuary or other rules. The purpose of this chart would be to alert vessels in a user-friendly way of the existence of protected areas and help them avoid coral reefs. A potential drawback to this approach is the increased use of, and resulting stress to, the coral reef resources as recreational boaters are better equipped to find and take advantage of the resources. NOAA’s NOS also will work with the International Hydrographic Organization and the British Admiralty to explore ways to improve international navigational charts

    Management

    Public Education. Agencies propose to work with NGOs to help develop an educational and outreach campaign aimed at protecting coral reefs from a range of vessel-related impacts (vessel groundings, anchor damage, vessel pollution, and diver activity).

    Targeted Education. Agencies also will explore possibilities to collaborate with the boating insurance industry to have them distribute educational materials relating to vessel groundings and tips on how to avoid further damage.

    Enforcement. Prosecution of civil damage claims can send a message to the maritime industry that natural resource damage claims will be pursued. Hopefully, this will encourage commercial operators to use utmost caution when navigating in the vicinity of marine resources. Agencies propose to work to develop an enforcement protocol for vessel grounding incidents to standardize responses, damage assessments, and other elements of building an enforcement case. The Department of Justice may host a 1-2 day workshop for managers of coral reef resources and other agencies with regulatory and enforcement jurisdiction to develop this protocol.


    References

    Fishing Pressures

    1- Birkeland, C. 1997. Life and death of coral reefs. New York. Chapman and Hall. 536 pp.

    2- Jameson, S.C., J.W. McManus, and M.D. Spalding. 1995. State of the reefs: Regional and global perspectives: International coral reef initiative, executive secretariat background paper. Washington, DC.

    3- Adams, C. 1992. Economic activities associated with the commercial fishing industry in Monroe County, Florida. Staff paper SP92-27. Gainesville, FL: University of Florida, Food and Resource Economics Department, Institute of Food and Agricultural Sciences. 20 pp

    4- Grigg, R.W. 1997. Hawaii's coral reefs: Status and health in 1997, the International Year of the Reef. pp. 61-72. In: Grigg, R.W. and C. Birkeland (eds.), Status of coral reefs in the Pacific. University of Hawaii Sea Grant NA36RG0507. Washington, DC: NOAA, Office of Sea Grant. 144 pp.

    5- Bryant, D., L. Burke, J. McManus, and M. Spaulding 1998, Reefs at Risk: A Map-Based Indicator of Threats to the World’s Coral Reefs. World Resources Institute Report. 56 pp.

    6- Hughes, T.P. 1994. Catastrophes, phase shifts, and large-scale degradation of a Caribbean coral reef. Science 265:1547-1551.

    7- Reef Check ‘ 97. Summary of Results.

    8- Van Der Knaap, M. 1993. Physical damage to corals by trap-fishing on reefs in Bonaire, Netherlands Antilles. Env. Conservation 20:265-267.

    9- Maragos 1992.

    Coastal Development and Shoreline Modification

    Blair, Stephen M., Brian S. Flynn, Susan Markley, 1990. Characteristics and Assessment of Dredge Related Mechanical Impact to Hard-Bottom Reef Areas Off Northern Dade County, Florida. Published in Proceedings of the American Academy of Underwater Sciences Tenth Annual Scientific Diving Symposium, October 4-7, 1990. Edited by Walter C. Japp. St. Petersburg, FL: University of South Florida.

    Florida Center for Public Management, 1997. Florida Assessment of Coastal Trends. Tallahassee, FL: Florida Coastal Management Program.

    Maragos, James E., 1993. Impact of Coastal Construction on Coral Reefs in the U.S.-Affiliated Pacific Islands. Coastal Management, Volume 21. pp. 235-269.

    U.S. Department of Transportation, 1998. A Report to Congress on the Status of the Public Ports in the United States. Washington, DC: DOT.

    Vessel Traffic

    Biscayne National Park. 1996. Vessel Grounding Response: Policies & Procedures. Biscayne National Park Report. 28 pp.

    Green, A., J. Burgett, M. Molina, D. Palawski, and P. Gabrielson. 1997. The Impact of a Ship Grounding and Associated Fuel Spill at Rose Atoll National Wildlife Refuge, American Samoa. Honolulu, Hawaii: U.S. Fish and Wildlife Service Report. 60 pp.

    UNEP/ICUN. 1988. Coral Reefs of the World. Volume I: Atlantic and Eastern Pacific. UNEP Regional Seas Directories and Bibliographies. IUCN, Gland, Switzerland and Cambridge, U.K./UNEP, Nairobi, Kenya, 373 pp.

    National Oceanic and Atmospheric Administration. 1996. Florida Keys National Marine Sanctuary: Final Management Plan/ Environmental Impact Statement. Washington D.C. (3 volumes).

    Sargent, F.J., T.J. Leary, D.W. Crewz and C.R. Kurer. 1995. Scarring of Florida’s Seagrasses: Assessment and Management Options. Florida Marine Research Institute Technical Reports. 21 pp. Florida Department of Environmental Protection.

    Zieman, J.C. 1982. The Ecology of the Seagrasses of South Florida: A Community Profile. Prepared for National Coastal Ecosystems Team, Office of Biological Services, U.S. Department of the InteriorFWS/OBS

    ADDITIONAL COMMENTS FROM WORKING GROUP

    There were several issues which cross cut the charges of the various working groups. These issues are listed below.

    Coastal Non-point Source Pollution

    Air and Water Quality lead with support from Coastal Uses

    Oil Spill/HazMat Response

    Ecosystem Science and Conservation and Coastal Uses shared responsibility


    LIST OF WORKING GROUP MEMBERS OR CONTRIBUTORS TO THIS REPORT

    Name Agency Phone Email
    Jeff Benoit* NOAA/OCRM 301.713.3155X200 Jeff.Benoit@noaa.gov
    Michelle Delamarre DOJ/CIV/Av. & Admiralty 202.616.4037 michelle.delamarre@usdoj.gov
    Sylvia Liu DOJ/ENRD/PLSL 202.305.0639 sylvia.liu@usdoj.gov
    Nina Mendelson DOJ/ENRD/PLSL 202.514.0474 nina.mendelson@usdoj.gov
    Jon Mueller DOJ/ENRD/EES 202.514.0056 jon.mueller@usdoj.gov
    Ashley Chappell NOAA/PSP 202.482.2152 ashley.m.chappell@noaa.gov
    Eric Denny NOAA/OCRM/CPD 301.713.3121 x127 eric.denny@noaa.gov
    Lindy S. Johns NOAA/GCIL 202.482.5887 lindy.s.johnson@noaa.gov
    Lisa Symons NOAA/SRD 301.713.3141x108 lisa.symons@noaa.gov
    Steve Gittings NOAA/SRD 301.713.3125x130 steve.gittings@noaa.gov
    Ed Martin NOAA/NOS/CS 301.713.2722x112 ed.martin@noaa.gov
    Howard Danley NOAA 301.713.2732 howard.danley@noaa.gov
    Meg Danley NOAA 301.713.3078 x187 meg.danley@noaa.gov
    Sharon Shutler NOAA/OGC 301.713.1220 sharon.shutler@nooa.gov
    Michael Weiss NOAA/GCOS 301.713.2969 x216 michael.i.weiss@noaa.gov
    Capt. Bob Ross USCG 202.267.0731 RGRoss@comdt.uscg.mil
    Billy Causey FKNMS 305.743.2437
    David Gulko Hawaii D.A.R. 808.587.0318 Dgulko@dar.ccmail.compuserve.com
    Karen Battle DOI/NPS 305.230-1144 x3013 karen_battle@nps.gov
    Paula Allen Florida DEP 305.289.2330 paula.allen@laspbs.state.fl.us
    Paul Souza DOI/USFWS 703.358.2201 Paul_Souza@mail.fws.gov
    Tom Hourigan NOAA/F/PR 301.713.2319 Tom.Hourigan@noaa.gov
    George Darcy NOAA/F/SF 301.713.2341 George.Darcy@noaa.gov
    Roger Griffis DOC/NOAA 202.482.5034 Roger.B.Griffis@noaa.gov
    Andrew Shepard NOAA/OAR 301.713.2427 Andrew.Shepard@noaa.gov
    Howard Hankin USDA/NRCS 202.690.0082 Howard.Hankin@usda.gov
    Craig Vogt EPA/OCPD 202.260.1952 Vogt.Craig@epa.gov
    Macara Lousberg EPA/OCPD 202.260.9109 Lousberg.Macara@pa.gov
    Mike Ham Guam 671.472.4201 mham@saba.kuentos.guam.net
    Athline Clark Hawaii DAR 808.587.0318 Athline@aloha.net

    * Chair

    APPENDIX I

    The following comments were received by non-governmental organizations in response to this summary.

    Cousteau Society
    E-mail response from Rick Schwabacher dated 2/23/99

    Recommendations for the Administration and Congress

    1. Approve comprehensive coral reef legislation building on proposals introduced in the 105th Congress (H.R. 2233, H. Con. Res. 8, and House Res. 87) to address the root causes of coral reef decline as determined from scientific, sociological, and economic information.

    2. Strengthen existing federal programs directed at coral reef conservation and support the implementation of the Presidential Executive Order on coral reef protection.

    3. Establish a permanent interagency working group, including scientific and policy experts, to identify adverse environmental impacts effecting U.S. coral reefs. Such a group should recognize that "rivers are the roots of the ocean" and work to address land, water and atmospheric based sources of pollution by developing comprehensive watershed management programs and effective conservation measures.

    4. Establish an independent scientific panel to review on-going activities and advise federal agencies on coral reef conservation and related efforts, including the National Marine Sanctuary Program, activities in U.S. territories, and international initiatives.

    5. Provide additional conservation incentives for States, territories, or countries with coral reefs or watersheds that affect coral reefs. Focus attentions on protecting the land-sea margin and the watersheds of coastlines and rivers by addressing issues concerning forestry, agriculture, coastal development and urbanization.

    6. Identify and establish water quality goals compatible with the maintenance of healthy reef systems. Focus attention on preserving the ecological integrity of the reef system, not simply the physical reef structure. Develop water quality standards for sediment and nutrient loading, and biological oxygen demand. Direct efforts at reducing the inputs of excessive nutrients, untreated or partially-treated sewage, sedimentation and other pollutants from forestry, industry, agricultural practices and urban development. Recognize that airborne materials (components of dust and precipitation) may impact the ecological integrity of reefs as they can contribute increased nutrient and sediment loading from distant sources.

    7. Increase efforts for coral reef restoration with emphasis on whole ecosystem restoration that includes attention to ecologically-connected watershed and airshed components. Address issues at the appropriate geographic scale, including local, regional, and global levels. Focus on the design and implementation of best practices at the regional and local levels and support appropriate demonstration projects

    8. Establish a program within NASA’s Mission to Planet Earth to map and monitor the global distribution and health of coral reef communities and identify potential hazards to their future. The information should be made widely available and distributed on the Internet. Remote sensing data should be combined with standardized field sampling and Geographical Information Systems analyses. NASA should also investigate the possibility of using Space Station Freedom to monitor reefs in equatorial areas.

    9. Promote the establishment and expansion of marine protected areas in the U.S. and strengthen support for applied scientific study and monitoring, especially in core nursery and recruitment zones, so that coral reefs can be sustained for future generations. Establish the Dry Tortugas as an ecological reserve, and expand Flower Garden Banks and Gray's Reef Sanctuaries to assure appropriate protection.

    10. Ensure that the knowledge and means for coral reef management is transferred to tropical developing nations where most of the world’s coral reefs are located. Expand efforts by the Agency for International Development and the Peace Corps to address coral reef conservation concerns in developing countries, focusing on integrated coastal area management, fisheries conservation measures, education, and community involvement.

    11. Assure that economic demands and trade do not result in further harm to reefs. Support the establishment of certification programs to eliminate the use of cyanide in fish capture, and restrict the trade in coral or coral products that threaten reef communities.

    12. Continue and strengthen U.S. support and resources for the International Coral Reef Initiative. Support full implementation of the Biodiversity Convention and the Jakarta Mandate on Marine and Coastal Biodiversity, along with other international agreements on marine protection and conservation.

    Sierra Club, Hawaii Chapter
    E-mail response from Dave Raney dated 2/22/99

    A. The most imminent threat to Maui's coral reefs at present appears to be large object with a lot of momentum behind it. It is called the United States Army Corps of Engineers and it appears determined to blast anddredge almost five acres of living coral at Ma`alaea. Where is the Corps participation in any of the Working Groups? Do they have a rep the Sierra Club could contact?

    While being a major threat to coral reefs, the Corps has the potential to also play a major role in the restoration of wetlands, de-channelization of streams, and other "green" initiatives which would help restore coral reefs and estuaries to former levels of health. Seems they should be a key player on the Task Force.

    B. Under Information Gaps, in Hawaii at present NGOs have very little to guide them as to the present condition of specific reefs, with the possible exception of Kaneohe Bay. We don't know whether the reefs are healthy, degrading, or recovering. We suspect many are gradually degrading due to sub-lethal stressors. I don't know whether this aspect of Information Gaps falls within the purview of your Working Group, but it should be acknowledged by at least one of the Working Groups. The responsibility for making such assessments may lie with state agencies, but federal assistance would be welcome. In Hawaii the state agency, DLNR, has only recently hired a coral reef expert.

    As I have mentioned earlier, NGOs are eager to work on specific projects for coral reef protection and restoration within the context of integrated watershed management ( the Ahupua`a model in Hawai`i). We seek information from state and federal agencies, and coral reef ecosystem scientists, to help us focus our efforts effectively. We will be supplementing agency and scientific information with the viewpoints of traditional users of the resources.

    My assessment of the value of the Task Force efforts will be based largely on its usefulness to NGOs interested in taking specific actions to protect or restore specific coral reef ecosystems.

    ReefKeeper International
    E-mail response from Alexander Stone Dated 2/25/99

    After reviewing the Working Group's draft list of target issues, ReefKeeper offers for consideration the following list of "Top Priority/Concern" issues in order of their importance perceived by us.

    #1- Coastal Development & Shoreline Modification
    (In the long run, the worst & broadest impact)

    1a) Dredging
    - Particularly for ship/boat channels & marinas
    - Particularly worried about USVI and CNMI

    1b) Beach Renourishment
    - Particularly in SE Florida (Palm Beach through Dade Counties)
    - Direct Impacts:Nearshore Coral Hardbottom burial (intentional!) and accidental offshore dredge gouging of reefs
    - Indirect impacts: massive sedimentation from dredge salt plumes;
    chronic long-term siltation from leaching of beach "fines"

    1c) Mangrove and seagrass removal (not on your original list)
    - threatens sustainability of reef biota since mangrove and seagrass are reef nurseries
    - particularly worried about USVI

    1d) Changes to natural sediment transport
    - causes/amplifies beach erosion, triggering beach renourishment projects
    - particularly concerned about effects of port inlet jetties (documented)
    - particularly worried about Florida

    1e) effluent outfall pipe siting (not on your original list)
    - eutrophication impacts
    - particularly worried about Puerto Rico

    #2- Fishing Impacts

    2a) Trawling
    - greatest magnitude of impacted bottom, but may actually occur mostly away from hardbottoms

    2b) destructive fishing techniques
    - Lobster & fish trap deployment and retrieval
    - grapnels dragged across reef bottom
    - particularly worried about USVI, Florida, Puerto Rico and Gulf of Mexico dome banks
    - Shallow reef nets
    - coral abrasion (chronic)
    - particularly worried about Hawaii
    - Note: Bleach and dynamite outlawed everywhere in USA

    2c) Overfishing of Herbivorous fish
    - aggravates algal shifts/ overgrowth
    - real danger in USVI and Puerto Rico (Herbivorous fish now primary catch
    - Note: Magnuson-Stevens Act/Essential Fish Habitat (EFH) regulations offer cure But fishery management councils so far are minimally responsive

    #3- Vessel Traffic
    3a) Vessel anchoring zones (Not on your original list)
    - particularly concerned about reef areas immediately adjacent to commercial and/or cruise ship ports/docks
    - particularly worried about USVI, CNMI, Guam, SE Florida (Pt. Everglades, Pt. of Palm Beach, etc.)
    - SOP for vessels to anchor to wait for port pilot or for next available berth
    - In absence of designated anchoring zones, it's Russian Roulette for the reefs

    3b) Vessel shallow water turbidity (not on your original list)
    - particularly worried about CNMI, USVI, Guam
    - massive sediment suspension and displacement from large ship propellers
    - Reef habitat chronically stressed, eventually buried

    3c) Vessel Groundings
    - Need more "area to be avoided" actions by Coast Guard (Via UN's IMO)
    - Need general compensation statute for all reefs
    - Need authority to require compensation from US-sited ships for foreign groundings (right now, RKI involved in efforts to get 2 cruise lines to compensate marine parks in Cancun & St. Maarten for reef groundings)

    Other general comments we think are pertinent include: (1) Working Group should focus intent to "build a national mitigation policy" to a precaution- based "National Damage-Prevention Policy"... (2) coastal development may be "highly regulated" in theory, but in practice the regulations are highly circumvented or compromised... (3) CZMA needs refocusing to become responsive to submerged habitat needs.. (4) there's legal precedent to place at least a $263 per sq. ft. value on reefs (consult B.Causey/ FKNMS)... (5) Vessel monitoring Systems (VMS) for commercial vessels would give a better handle on groundings prevention and compensation (Coast Guard familiar with VMS in context of fisheries regulations).

    D R A F T