Chapter activist Gregg Rosner recently attended a meeting of Delaware’s Water Infrastructure Advisory Council (formerly called the Clean Water Advisory Council) and let the council know about a letter NOAA submitted on this project. The full letter is linked here.
In summary, NOAA raised concerns over the Essential Fish Habitat close to the end of the proposed pipe. This is fish habitat important for species that live there as well as for species that migrate through, feed, mate or spawn there. As such, three different Fisheries Management Councils claim this area as Essential Fish Habitat.
A quote from their letter – “The proposed project area contains more than 30 federally managed species of fish and shellfish covered by 10 fishery management plans (FMPs), and for which essential fish habitat (EFH) has been designated by the New England Fishery Management Council, Mid-Atlantic Fishery Management Council, South Atlantic Fishery Management Council and NMFS.”
The letter then cites what is required by the Magnuson-Stevens fisheries law regarding Essential Fish Habitat. To comply with that law they recommend:
- Monitoring of the benthic (bottom) communities before construction to get a baseline of organisms and productivity.
- Mitigate for habitat degradation the outfall pipe may cause.
- Continually and comprehensively monitor the bottom communities during and after construction.
We read the above and interpret it as time and money. Millions of dollars (but who knows how many millions) in studies and possibly mitigation, and years (but who knows how many years) in delays to conduct these studies and satisfy the federal agencies.
This should give everyone pause as to the actual cost and actual timeline of the pipe. Alternatives should still be given serious consideration. Again, full NOAA letter linked here.