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May 7 2005  

Comments on Delray Beach Sewage Effluent Permit

 Thomas J. Goreau, Ph.D.
President, Global Coral Reef Alliance

Florida Department of Environmental Protection
Southeast Regional Office

400 North Congress Avenue
West Palm Beach, Florida 33401

Attention: Linda Horne, Water Resource Management Administrator
United States Environmental Protection Agency,
Atlanta Federal Center
61 Forsyth Street, S.W.
Atlanta, Georgia 30303-3104

Attention: Roland E. Ferry, Ph.D.
Marine Ecologist, USEPA/Region 4
Coastal and Oceans Protection Team

Re: NPDES Permit FL0035980 Renewal

Dear Ms. Horne and Dr. Ferry,

         I call on you to not permit the renewal of ANY sewage nutrient pumping into the coastal reef environment from ocean outfalls at Delray Beach or anywhere else in Florida or US waters.  

 I am a scientist who has worked on algae overgrowth of coral reefs in relation to nutrient sources in Florida, Jamaica, the Cayman Islands, the Grenadines, Mexico, Panama, Turks and Caicos Islands, Antigua, Aruba, Bonaire, Curacao, Seychelles, Mauritius, Maldives, Sri Lanka, India, Indonesia, Thailand, Papua New Guinea, Palau, Saipan, Fiji, Samoa, French Polynesia, Taiwan, Tuvalu, the Marshall Islands, Federated States of Micronesia, Australia, and many other places around the globe. I have personally examined the changes in algae abundance and species composition down nutrient gradients in these places and have also worked on measuring nutrients in the water and their physiological effects on algae growth.

 No ecosystem is more sensitive to excess nutrients than coral reefs. I recently wrote a long review of the impacts of nutrients on coral reefs and fisheries and the methods that can be used to control and eliminate them for the United Nations Expert Meeting on Waste Management. This review summarized the controversy over whether algae are caused by excessive nutrients or by lack of herbivores, and came down solidly on the side of excess nutrients as being the major cause. I concluded: "A strict policy of zero waste nutrient discharge to the coastal zone is needed. When nutrients are reduced, the algae quickly die off. Waste nutrients in the coastal zone not only destroy the ecological and economic value of coral reefs for fisheries, tourism, shore protection and biodiversity, they represent a wasteful loss of fertilizers that are badly needed on land" (United Nations Development Program, Capacity 2015 Resilience Series, Volume 3, 30p, 2003, "Addressing the Challenges of Waste Management in Small Island Developing States", T. Goreau quote, p. 17).

 It is astonishing that Federal and State agencies still deny the reality of the linkage between nutrients and weedy algae killing reefs, and permit their discharge into reef habitats. The studies of Dr. Brian Lapointe and Dr. Larry Brand have clearly established the link between excess nutrients and excess algae all around South Florida.  The studies of Ed Tichenor at the reefs downstream of the Delray Beach Sewage outfall leave no doubt that this outfall is seriously destroying the marine habitat of Gulf Stream Reef, and that it can recover if these damaging releases are stopped in time.

         I urge you to revoke the existing permit and prevent its renewal. I also appeal to you to urge the US Coral Reef Task Force to live up to its mandate to protect corals by calling for a complete ban on direct or indirect anthropogenic nutrient discharges into reef habitats in ALL waters where US laws apply.  

Sincerely yours,

Thomas J. Goreau, Ph.D.
President, Global Coral Reef Alliance