The following is FIE's reaction to the NPS's July 2003 environmental assessment.

Fire Island Ecology

PO Box 5288, Fire Island Pines, New York 11782-0940

David Spirtes, Superintendent

Fire Island National Seashore

120 Laurel St.

Patchogue NY 11772-3596

Dear Dave:

The following are our comments regarding FINS' environmental assessment: Short-term Community Storm Surge Protection Plan.

First, we would like to express our appreciation for the superb report which your people have written. It is balanced and informative. We applaud the comprehensive, holistic approach. It is good to have all the information and policies laid out in one publication. The EA should lay to rest the misinformation which has been spread among some of the communities.

Our over-all reaction is that we could accept either your Alternative A (no action except for emergency purposes, pp. 31-32), or your preferred Alternative, D (combination of scraping and nourishment, pp. 49-50). We are not persuaded that the latter is preferable to the former.

We appreciate the seriousness with which FINS takes the Congressional mandate, that "conserving the natural resources located there" must be the "primary aim" of those administering the park. This requires acceptance of the reality that this barrier island is inherently dynamic and mobile. While we do not oppose reasonable efforts to protect private structures, we believe that when it comes to houses on the southern-most dunes, they should be understood as a part of the problem, and there is a limit to how much responsibility the public has to protect home owners from the costs of their mistakes. Those living behind (north of) such houses are threatened by the fact that no dune-protecting dune grass can grow where a house stands.

Local leaders lash out at this or that demon to explain the difficulties the communities now face from the elements. However, your EA points out that the rate of shoreline retreat observed at Fire Island is consistent with observed levels of sea level rise. So the ultimate problem is global warming, and the ultimate solution is to get serious about adopting the Kyoto Protocol. Beyond that, of course, Fire Island has always had a tendency to "drift" slowly northward, so attempts to completely and permanently protect the south side of the island are exercises in futility. There is only one sensible way to slow this natural process, and that is encourage natural dunes, laced with dune grass rhizomes.

Your report contains ample evidence that scraping and replenishment are dubious options. "Beach nourishment and scraping...has led to non-functional dune ecosystems, which no longer provide the benefits of natural dunes, and often decreased the beach width along with its storm protection features" (p. 11). Thus, scraping and replenishment would seem to be out of step with the NPS goal of restoring "a more effective, natural and self-sustaining dune system and natural barrier island ecosystem" (p. 28).

With regard specifically to scraping, the middle paragraph on p. 35 pretty well lays out the case against it, and we heartily agree with the concluding sentence: "The impacts of beach scraping should be studied more fully as some coastal experts have indicated that the effects are, at best, neutral...." We would add to the reasons given that the dunes created by this process tend to be made of relatively coarse sand, which is a poor medium for growing dune grass. "The beach scraping process may actually retard the growth of strong, more resilient dunes" (p. 93). Secondly, it is difficult to imagine any scraping regime that does not steepen the beach, in which case there will be less dissipation of the wave energy (compared to what would be the case with a more horizontal beach), resulting in either greater damage to the beach/dune system, and/or transfer of that energy to adjacent beaches.

With regard to beach nourishment, many of the same considerations apply. It would be much better to encourage the natural dune building process than to permit these artificial dunes, which will "revert to near pre-project conditions over time" (p. 37). We urge that any permits for replenishment be granted only after a determination that the benefit of replenishment will not be outweighed by the damage to the rhizome systems caused by heavy equipment and by burial. We note that "relatively course sands" will be dredged (p. 89), and that the sand in the borrow area "consists primarily of fine to medium sands (<90 percent)" (p. 56). We assume that the other >10 percent is clay and other materials. It is thus safe to infer that most of the material that would be transported is unsuitable for dunes (which should be made of fine sand) and some of it is of questionable suitability for a beach.

Page 39 mentions "socioeconomic constraints." We would add that often these constraints have been improperly muted. For example, within the past year, pro-replenishment forces in Fire Island Pines conducted a ballot asking property owners to endorse a special tax to finance replenishment. Accompanying the ballot was much pro-replenishment propaganda. Those conducting the ballot later announced that the proposal had won by 52 percent, and it appears that the tax will be levied. Assuming that the vote count is correct, it means that with little more than a single percentage point shift in the vote, it would have failed. It is safe to say that if the voters had been presented with more balanced information, that is just what would have happened. Even leaving environmental issues aside, readers of the accompanying propaganda might easily have inferred that a "yes" vote was for lower taxes, and a "no" vote was for higher taxes, when the opposite was the case. We urge the NPS to bear in mind the flawed nature of the local approval process when permit applications are considered.

Even more importantly, we believe that any replenishment proposal should be weighed in the context of the long-term implications. It is ironic that the sand is to be taken from in front of Cherry Grove. The Grove has always eschewed these artificial beach maintenance measures, and instead has limited building to well back from the front dunes and has maintained a large area of beach grass between the houses and the beach. The report notes that "Mining this resource of sand repeatedly for beach nourishment projects may deplete this sand source leading to enhanced erosion of the barrier island" (p. 90). Presumably, it is precisely Cherry Grove, the community that has acted most responsibly, which would be punished by the irresponsibility of others.

Finally, we would oppose any scraping or nourishment unless great weight is paid to limiting future building on forward dunes. We note with approval that "no project can be approved unless adequate mechanisms are in place to prevent currently unbuildable lots from qualifying as buildable ones" (p. 128). Our willingness to go along with Alternative D (rather than press for Alternative A) is conditional upon the rigorous implementation of this principle.

We hope that these comments will be helpful.

Sincerely

James D. Seymour, Executive Director

Return to FIE main page.