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HomeMy WebLinkAboutAgenda 02.21.2023LUIl EROSION DISTRICT AGENDA ST. LUCIE COUNTY Regular Meeting Tuesday, February 21, 2023 9:01 AM St. Lucie County Commission Chambers 2300 Virginia Avenue 3rd Floor of Roger Poitras Building Fort Pierce, FL 34982 BOARD MEMBERS District No. 1, Chair CHRIS DZADOVSKY District No. 5, Vice -Chair CATHY TOWNSEND District No. 2 LARRY LEET District No. 3 LI N DA BARTZ District No. 4 JAMIE FOWLER Mission Statement St. Lucie Works to deliver superior service that enhances our quality of life Page 1 of 148 Regular Meeting Tuesday, February 21, 2023 9:01 AM WELCOME All meetings are televised. All meetings provided with wireless internet access for public convenience. Please turn off all cell phones and pagers prior to entering the commission chambers. Please mute the volume on all laptops and PDAs while in use in the commission chambers. GENERAL RULES AND PROCEDURES —Attached is the agenda, which will determine the order of business conducted at today's Board meeting. INVOCATION -PLEDGE —To bring order and decorum to its meeting, the Board begins its meetings with an invocation followed by the Pledge of Allegiance. Participation is voluntary. CONSENT AGENDA — These items are considered routine and are enacted by one motion. There will be no separate discussion of these items unless a Commissioner so requests. REGULAR AGENDA — Proclamations, Presentations, Public Hearings, and Department requests are items, which the Commission will discuss individually, usually in the order listed on the agenda. PUBLIC HEARINGS — These items are usually heard on the first Tuesdays at 6 p.m. or as soon thereafter as possible. However, if a public hearing is scheduled for a meeting on the third Tuesday, which begins at 9 a.m., then public hearings will be heard at 9 a.m. or as soon thereafter as possible. These time designations are intended to indicate that an item will not be addressed prior to the listed time. The Chair will open each public hearing and asks anyone wishing to speak to come forward, one at a time. Comments will be limited to five minutes, and must be pertinent to the agenda item being considered by the Board. As a general rule, when issues are scheduled before the Commission under department request or public hearing, the order of presentation is: (1) County staff presents the details of the Board item (2) Commissioners comment (3) if a public hearing, the Chair will ask for public comment, (4) further discussion and action by the Board. ADDRESSING THE COMMISSION — Please state your name and address, speaking clearly into the microphone. If you have backup material, please have eight copies ready for distribution. NON -AGENDA ITEMS — These items are presented by an individual Commissioner or staff as necessary at the conclusion of the printed agenda. PUBLIC COMMENT — Time is allotted at the beginning of each meeting for general public comment. Please limit comments to three minutes. Comments may pertain to any matter related to the Board's duties as the County's governing body. Comments in support or opposition to candidates for public office are not pertinent to the Board's duties. This includes any speaker identifying himself or herself as a candidate for public office. DECORUM — Please be respectful of others' opinions. MEETINGS — All Board meetings are open to the public and are held on the first Tuesdays of each month at 6 p.m. and on the third Tuesdays at 9 a.m., unless otherwise advertised. Meetings are held in the County Commission Chambers in the Roger Poitras Administration Annex at 2300 Virginia Ave., Fort Pierce, Fla. 34982. The Board schedules additional workshops throughout the year necessary to accomplish their goals and commitments. Notice is provided of these workshops. Anyone with a disability requiring accommodation to attend this meeting should contact the St. Lucie County Community Services Manager at 772-462-1777 or TDD 772-462-1428 at least 48 hours prior to the meeting. z1P,: Page 2 of 148 Regular Meeting Tuesday, February 21, 2023 9:01 AM 1. CALL TO ORDER 2. GENERAL PUBLIC COMMENT 3. APPROVAL OF MINUTES A. Board of County Commissioners minutes for the Erosion District Meeting of January 24, 2023. 4. CONSENT AGENDA A. WARRANTS 1. Warrant Lists 16 - 19 B. PUBLIC WORKS 1. FDEP Grant Agreement 22SL1 - Amendment No. 1 - Work Authorization No. 07 (Taylor Engineering) Staff recommends Board approval of: (1) Amendment No. 01 to FDEP Project Agreement 22SL1 (Fund # 184239), including $150,000.00 in new grant funding, requiring a $150,000.00 local match share contribution (totaling $300,000.00); (2) A supporting budget resolution, provided separately by OMB; (3) Work Authorization No. 07 with Taylor Engineering for $264,409.00; and authorization for the Erosion District Chair to sign documents as approved by the county attorney. 2. Work Authorization No. 08 (Taylor Engineering) — Fort Pierce Shore Protection Project, Section 203/403 Letter Report Support Staff recommends Board approval of Work Authorization No. 08 with Taylor Engineering ($63,009.00) and authorization for the Erosion District Chair to sign documents as approved by the County Attorney. 3. Work Authorization No. 08 (G.E.C., Inc.) - St. Lucie County, Florida, Coastal Storm Risk Management (CSRM) Project: Year 1 Post -Construction Physical and Biological Monitoring Staff recommends Board approval of Work Authorization No. 08 with G.E.C./Coastal Tech, Inc. ($452,834.90), and authorization for the Chair to sign documents as approved by the County Attorney. 3 1 P, : Page 3 of 148 Regular Meeting Tuesday, February 21, 2023 9:01 AM 4. St. Lucie County, Florida Coastal Storm Risk Management (CSRM) Project - USACE Project Partnership Agreement (PPA) - Amendment No. 1 - I 111"M II'N„fl..l.Ell) II'')Ri011't ""ro ME FDEP Grant Agreement 18SL1 - Amendment No. 04 Board approval of: (1) Amendment No. 04 to FDEP Project Agreement 18SL1 (Fund # 184231), accepting an additional $1,107,500.00 from the state of Florida, requiring a $387,500.00 local match share; (2) A supporting budget resolution, provided separately by OMB; and authorization for the Erosion District Chair to sign documents as approved by the county attorney. S. REGULAR AGENDA There are no items scheduled. 6. MOTION TO ADJOURN 4 1 P, : Page 4 of 148 3ro LUCK BOARD OF COUNTY COMMISSIONERS ST. LUCIE COUNTY, FLORIDA Erosion District Meeting January 24, 2023 1. CALL TO ORDER Convened: 9:01 AM Adjourned: 9:02 AM The meeting was called to order at 9:01 AM by Chair Chris Dzadovsky, District No. 1. Commissioner Cathy Townsend District 5, Commissioner Linda Bartz District 3, Commissioner Chris Dzadovsky District 1, Commissioner Larry Leet District 2, Commissioner Jamie Fowler District 4 Also Present Dan McIntyre, County Attorney Caroline Valentin, Asst. County Attorney Jennifer Hill, Office of Management & Budget Director Karen Kozac, Public Safety Assistant Director Rangel Guerrero, Public Safety Director Barbara Guettler, MSBU Coordinator Pete Tesch, Economic Development Council President Katherine Barbieri, Assistant County Attorney III Mayte Santamaria, Planning & Development Services Director George Landry, Solid Waste Director Patrick Dayan, Public Works Director Benjamin Balcer, Planning & Development Services Assistant Director Larry Price, Wire Utilities Project Manager Vera Smith, Deputy Clerk Recording Secretary 2. GENERAL PUBLIC COMMENT Chair Dzadovsky opened the meeting for public comment at this time. With no one wishing to address the Board, Chair Dzadovsky closed public comment. 3. APPROVAL OF MINUTES A motion was made to approve all minute sets, and it passed unanimously. RESULT: APPROVE MOVER: Commissioner District 3 Linda Bartz SECONDER: Commissioner District 4 Jamie Fowler AYES: Cathy Townsend, Linda Bartz, Chris Dzadovsky, Larry Leet, Jamie Fowler Page 5 of 148 Erosion District Meeting Tuesday, January 24, 2023 9:01 AM NAYS: None EXCUSED: None A. Board of County Commissioners minutes for the Erosion District Meeting of January 10, 2023. 4. CONSENT AGENDA A motion was made to adopt the consent agenda, and it passed unanimously. RESULT: APPROVE MOVER: Commissioner District 5 Cathy Townsend SECONDER: Commissioner District 3 Linda Bartz AYES: Cathy Townsend, Linda Bartz, Chris Dzadovsky, Larry Leet, Jamie Fowler NAYS: None EXCUSED: None A. WARRANTS 1. Warrant Lists 14 - 15 Adopted by Consent Vote 5. REGULAR AGENDA There are no items scheduled. 6. MOTION TO ADJOURN With no other information to be brought for consideration before the Board, the meeting was adjourned at 9:02 AM. Please note: Final minutes are recorded in the official minute's books filed with the Clerk of the Circuit Court and available for inspection upon request. 2 1 gm Page 6 of 148 01/20/23 ST. LUCIE COUNTY - BOARD FZABWARR WARRANT LIST #16- 14-JAN-2023 TO 20-JAN-2023 FUND SUMMARY- EROSION FUND TITLE EXPENSES 184 Erosion Control Operating Fund 22,037.50 GRAND TOTAL: 22,037.50 PAGE 1 PAYROLL 4,496.80 4,496.80 121 Page 7 of 148 01/27/23 ST. LUCIE COUNTY - BOARD FZABWARR WARRANT LIST #17- 21-JAN-2023 TO 27-JAN-2023 FUND SUMMARY- EROSION FUND TITLE EXPENSES 184 Erosion Control Operating Fund 50,826.90 GRAND TOTAL: 50,826.90 PAGE 1 PAYROLL 0.00 0.00 81 Page 8 of 148 02/03/23 ST. LUCIE COUNTY - BOARD FZABWARR WARRANT LIST #18- 28-JAN-2023 TO 03-FEB-2023 FUND SUMMARY- EROSION FUND TITLE EXPENSES 184 Erosion Control Operating Fund 0.00 GRAND TOTAL: 0.00 PAGE 1 PAYROLL 4,496.80 4,496.80 110 Page 9 of 148 02/10/23 ST. LUCIE COUNTY - BOARD PAGE 1 FZABWARR WARRANT LIST #19- 04-FEB-2023 TO 10-FEB-2023 FUND SUMMARY- EROSION FUND TITLE EXPENSES PAYROLL 184 Erosion Control Operating Fund 2,000.00 0.00 GRAND TOTAL: 2,000.00 0.00 93 Page 10 of 148 TO: Erosion District AGENDA REQUEST 2023-58555 DATE: 2/21/2023 PRESENTED BY: Joshua Revord, Senior Coastal Engineer SUBMITTED BY: Public Works SUBJECT: FDEP Grant Agreement 22SL1 - Amendment No. 1 - Work Authorization No. 07 (Taylor Engineering) BACKGROUND: The Florida Department of Environmental Protection (FDEP) administers the Beach Management Funding Assistance (BMFA) Program, which provides funding opportunities to assist eligible local governments with their beach erosion control projects. The Florida Legislature appropriated a total of $2,519,379.50 in State funding during FY-2021/22 for tasks associated with the Fort Pierce Shore Protection Project (SPP). A large portion of those grant funds ($1,137,000.00) went towards the next federal nourishment event at Fort Pierce Beach (scheduled for Spring 2023). In addition, the grant also included 50% reimbursement ($1,182,379.50) for the 2020 Fort Pierce Beach Emergency Truck Haul project. The balance of the previously approved state funding is currently being used for annual physical and biological monitoring efforts associated with beach restoration. Amendment No. 1 to FDEP Grant 22SL1 (184239) includes an additional $150,000.00 from FDEP for Task 4 (Monitoring) efforts. The new funding required a 50% local match share of $150,000.00, for a total grant increase of $300,000.00. Work Authorization No. 07 (Taylor Engineering, $264,409.00) was provided to FDEP for consideration/approval under these new grant funds, and the effort was subsequently pre -approved (contingent on the execution of Amendment No. 01). Work Authorization No. 07 includes the 2023 Fort Pierce Shore Protection Project physical and biological monitoring efforts required by permit. PREVIOUS ACTION: October 20, 2020 - Board approval to submit a Beach Management Funding Assistance (BMFA) Program application request to FDEP in FY-2021/22 for multiple efforts associated with the Fort Pierce Shore Protection Project (2020-50463). September 21, 2021— Board approval of FDEP Grant Agreement 22SL1, including $2,519,379.50 in state funding for efforts associated with the Fort Pierce Shore Protection Project (2021-52338). January 20, 2023 — FDEP pre -approval of Work Authorization No. 07 with Taylor Engineering for the proposed 2023 physical and biological monitoring event(s) at Fort Pierce Beach. FINANCIAL IMPACT: Page 11 of 148 FDEP Grant Agreement 22SL1 (184239) - Amendment No. 01 includes an additional $150,000.00 from the Florida Department of Environmental Protection (FDEP) and requires a 50% local match share of $150,000.00, (total increase of $300,000.00). Local matching funds for Amendment No. 01 are currently available in the Erosion District Reserves 184-9910-599300-910000. Work Authorization No. 07 (Taylor Engineering, $264,409.00) will be funded with this new grant funding. RECOMMENDATION: Staff recommends Board approval of: (1) Amendment No. 01 to FDEP Project Agreement 22SL1 (Fund # 184239), including $150,000.00 in new grant funding, requiring a $150,000.00 local match share contribution (totaling $300,000.00); (2) A supporting budget resolution, provided separately by OMB; (3) Work Authorization No. 07 with Taylor Engineering for $264,409.00; and authorization for the Erosion District Chair to sign documents as approved by the county attorney. COMMISSION ACTION: RESULT: MOVER: SECONDER: None AYES: None NAYS: None EXCUSED: None Coordination/Signatures 5E7:)tl� oel Date: January 25, 2023 Patrick Dayan, Public Works Director a� 'kYN-Y tA Lu"" Date: January 26, 2023 Jennifer Hill, Office of Management &Budget Director j Date: January 27, 2023 Daniel McIntyre, County Attorney i Date: January 27, 2023 Mayte Santamaria, Planning & Development Services Director Page 12 of 148 AMENDMENT NO. 1 TO AGREEMENT NO. 22SL1 BETWEEN FLORIDA DEPARTMENT OF ENVIRONMENTAL PROTECTION AND ST. LUCIE COUNTY EROSION DISTRICT This Amendment to Agreement No. 22SL1 (Agreement) is made by and between the Department of Environmental Protection (Department), an agency of the State of Florida, and St. Lucie County Erosion District, 3071 Oleander Avenue, Fort Pierce, FL 34982 (Grantee), on the date last signed below. WHEREAS, the Department entered into the Agreement with the Grantee for the Ft. Pierce Shore Protection Project effective October 1, 2021; NOW THEREFORE, the parties agree as follows: 1) The total amount of funding of the Agreement is increased by $150,000.00 to $2,669,379.50. 2) The Agreement is extended for a 12-month period to begin January 1, 2025, and remain in effect until December 31, 2025. The Department and the Grantee shall continue to perform their respective duties during this extension period pursuant to the same terms and conditions provided in the Agreement. 3) Attachment 3, Grant Work Plan, is hereby deleted in its entirety and replaced with Attachment 3-A, Revised Grant Work Plan, as attached to this Amendment and hereby incorporated into the Agreement. All references in the Agreement to Attachment 3 shall hereinafter refer to Attachment 3-A, Revised Grant Work Plan. 4) Attachment 5, Special Audit Requirements, Exhibit 1, is hereby deleted in its entirety and replaced with Exhibit 1-A, attached and hereby incorporated into the Agreement. All references in the Agreement to Attachment 5, Special Audit Requirements, Exhibit 1, shall hereinafter refer to Exhibit 1-A. 5) All other terms and conditions of the Agreement remain in effect. If and to the extent that any inconsistencies may appear between the Agreement and this Amendment, the provisions of this Amendment shall control. The parties agree to the terms and conditions of this Amendment and have duly authorized their respective representatives to sign it on the dates indicated below. St. Lucie County Erosion District M. Title: Date Florida Department of Environmental Protection C Secretary or Designee Date: LIST OF ATTACHMENTS/EXHIBITS INCLUDED AS PART OF THIS AMENDMENT: Specifv Type Letter/Number Attachment 3 -A Attachment 5, Exhibit 1-A Agreement No.: 22SL1 Description Revised Grant Work Plan (5 pages) Revised Special Audit Requirements (3 pages) Amendment No.: 1 Rev. 3/6/2020 1 of 1 Page 13 of 148 ATTACHMENT 3-A REVISED GRANT WORK PLAN PROJECT TITLE: Ft. Pierce Shore Protection Project PROJECT LOCATION: The Project is located between Department of Environmental Protection (Department or DEP) reference monuments R34-160' and R41 along the Atlantic Ocean in St. Lucie County, Florida. PROJECT BACKGROUND: The Project includes the maintenance of 1.3 miles of shoreline in St. Lucie County. The restoration of the project was completed in 1971 and later nourished in 1981. The Project was authorized by the USACE in 1986 and again in 2018. Fifteen nourishments have been completed since 1999. The next federal nourishment is scheduled for 2022-2023 with monitoring to follow. PROJECT DESCRIPTION: The Project consists of design, construction, USACE multiphase, and monitoring. PROJECT ELIGIBILITY: The Department has determined that 100 percent of the non-federal Project cost is eligible for state cost sharing. Therefore, the Department's financial obligation shall not exceed the sum of $2,669,379.50 for this Project or up to 50 percent of the non-federal Project cost, if applicable, for the specific eligible Project items listed, whichever is less. Any indicated federal cost sharing percentage is an estimate and shall not affect the cost sharing percentages of the non-federal share. The parties agree that eligibility for cost sharing purposes will be maintained pursuant to 62B-36, Florida Administrative Code (F.A.C.). The Local Sponsor will be responsible for auditing all travel reimbursement expenses based on the travel limits established in Section 112.061, Florida Statute (F.S.). Pursuant to Sections 161.091 - 161.161, F.S., the Department provides financial assistance to eligible governmental entities for beach erosion control and inlet management activities under the Florida Beach Management Funding Assistance Program. Pursuant to 62B-36.005(1)(d), F.A.C., the Local Sponsor has resolved to support and serve as local sponsor, has demonstrated a financial commitment, and has demonstrated the ability to perform the tasks associated with the beach erosion control project as described herein. The Project shall be conducted in accordance with the terms and conditions set forth under this Agreement, all applicable Department permits and the eligible Project task items established below. All data collection and processing, and the resulting product deliverables, shall comply with the standards and technical specifications contained in the Department's Monitoring Standards for Beach Erosion Control Projects (2014) and all associated state and federal permits, unless otherwise specified in the approved scope of work for an eligible Project item. The monitoring standards may be found at: 1lttpsall�loridade�.�ovlsitesldefaultl�l�ileslPh�rsicalMonitorin�Standards.pdf One (1) electronic copy of all written reports developed under this Agreement shall be forwarded to the Department, unless otherwise specified. DEP Agreement No. 22SL1, Attachment 3-A, Page 1 of 5 Page 14 of 148 Acronyms: DEP — Florida Department of Environmental Protection F.A.C. — Florida Administrative Code F.S. — Florida Statutes FWC — Florida Fish and Wildlife Conservation Commission USACE — United States Army Corps of Engineers TASKS and DELIVERABLES: The Local Sponsor will provide detailed scopes of work or a letter requesting advance payment if authorized by Attachment 2, for all tasks identified below, which shall include a narrative description of work to be completed, a corresponding cost estimate and a proposed schedule of completion for the proposed work and associated deliverables. Each scope of work shall be approved in writing by the DEP Project Manager to be included into this work plan for reimbursement. Task 1: Design Task Description: The Local Sponsor will acquire professional services for the engineering and design of the Project such as coastal engineering analyses, preparation of plans and specifications, physical and environmental surveys, cultural resource surveys, design -level geotechnical services, sediment studies, inlet studies, environmental analyses, orthophotography, plan formulations and for obtaining environmental permits and other Project -related authorizations. The Local Sponsor will submit work products to the appropriate State or Federal regulatory agencies as requested by the DEP Project Manager in order to be eligible for reimbursement under this task. Deliverable: Certification of Completion including documentation of submittal affirming that the final design document was completed and submitted to the Department. For interim payment requests, a Task Summary Report signed by the Local Sponsor must be submitted detailing work progress during the payment request period. The Task Summary Report must include the dates and descriptions of all activities, surveys and reports completed or in progress during the time period of the interim payment request. Performance Standard: The DEP Project Manager will review the task deliverable and any associated work products as necessary to verify they meet the specifications in the Grant Work Plan and this task description. Payment Request Schedule: Payment requests may be submitted after the deliverable is received and accepted and may be submitted no more frequently than quarterly. Task 2: Construction Task Description: This task includes work performed and costs incurred associated with the placement of fill material and/or the construction of erosion control structures within the Project area. Project costs associated with eligible beach and inlet construction activities include work approved through construction bids and/or construction -phase engineering and monitoring services contracts. Eligible costs may include mobilization, demobilization, construction observation or inspection services, physical and environmental surveys, beach fill, tilling and scarp removal, erosion control structures, mitigation reefs, dune stabilization measures and native beach -dune vegetation. Construction shall be conducted in accordance with any and all State or Federal permits. The Local Sponsor will submit work products to the appropriate State or Federal regulatory agencies as requested by the DEP Project Manager in order to be eligible for reimbursement under this task. DEP Agreement No. 22SL1, Attachment 3-A, Page 2 of 5 Page 15 of 148 Deliverable: Certification of Completion by a Florida -registered Professional Engineer with documentation of submittal to the Department affirming the construction task was completed in accordance with construction contract documents. For interim payment requests, a Task Summary Report signed by Local Sponsor must be submitted detailing activities completed during the payment request period. The Task Summary Report must include the dates and descriptions of all activities, surveys and reports completed or in progress during the time period of the interim payment request. Performance Standard: The DEP Project Manager will review the task deliverable and any associated work products as necessary to verify they meet the specifications in the Grant Work Plan and this task description. Payment Request Schedule: Payment requests may be submitted after the deliverable is received and accepted and may be submitted no more frequently than quarterly. Task 3: USACE Multiphase Project Task Description: The USACE in coordination with the Local Sponsor will provide professional services for any and all phases of work where advance payment is required by the USACE. The task may include activities such as preliminary engineering design, coastal engineering analyses, preparation of plans and specifications, physical and environmental surveys, cultural resource surveys, geotechnical services, sediment studies, inlet studies, environmental analyses, orthophotography, plan formulations, post - construction monitoring and for obtaining environmental permits and other Project -related authorizations. The USACE will provide for construction and construction -phase services such as development of bid specifications, construction plans, advertising and awarding of the construction bid. Deliverable: The Local Sponsor will provide a USACE letter of request (demand letter) and a Certification of Completion by a Florida -registered Professional Engineer with documentation of submittal to the Department of the immediate post -construction monitoring report affirming the construction task was completed in accordance with construction contract documents. For interim payment requests, a Task Summary Report signed by Local Sponsor must be submitted detailing activities completed during the payment request period. The Task Summary Report must include the dates and descriptions of all activities, surveys and reports completed or in progress during the time period of the interim payment request. The Department will withhold retainage up to 5 percent contingent upon the submittal of the final cost reconciliation from the USACE by the Local Sponsor to the Department Performance Standard: The DEP Project Manager will review the deliverable to verify that it meets the specifications in the Grant Work Plan and this task description. Payment Request Schedule: Payment requests may be submitted after the deliverable is received and accepted and may be submitted no more frequently than quarterly. Task 4: Monitoring State and federal monitoring required by permit is eligible for reimbursement pursuant to program statute and rule. In order to comply with Florida Auditor General report 2014-064 regarding conflicts of interest and to be consistent with Section 287.057(17)(a)(1), F.S., all monitoring data and statistical analysis must be provided directly and concurrently from the monitoring contractor to the Department/Local Sponsor permittee/engineering consultant. The Local Sponsor's engineering consultant must provide an adequate mitigation plan, consistent with Section 287.057(17)(a)(1), F.S., including a description of organizational, physical, and electronic barriers to be used by the Local Sponsor's engineering consultant, that addresses conflicts of interest when contracting multi -disciplinary firms for Project engineering and post -construction environmental monitoring services, or when the Project engineering consultant firm subcontracts for post - construction environmental monitoring. Environmental monitoring includes hardbottom, seagrass, and DEP Agreement No. 22SL1, Attachment 3-A, Page 3 of 5 Page 16 of 148 mangrove resources. Department approval of the consultant's mitigation plan will be required prior to execution of this Agreement. If at any time the Local Sponsor and/or its engineering consultant fails to comply with this provision, the Local Sponsor agrees to reimburse the Department all funds provided by the Department associated with environmental monitoring for the Project listed. Task Description: This task includes activities associated with permit -required monitoring conducted in accordance with the conditions specified by state or federal regulatory agencies. All monitoring tasks must be located within or adjacent to the Project area and follow the Department's Regional Coastal Monitoring Program and FWC's marine turtle and shorebird monitoring programs. Guidance for monitoring of nearshore resources is available in the Department's Standard Operation Procedures For Nearshore Hardbottom Monitoring Of Beach Nourishment Projects. The Local Sponsor must submit work products directly to the appropriate state or federal regulatory agencies in accordance with permit conditions to be eligible for reimbursement under this task, unless otherwise directed. Deliverable: For each interim or final payment, the Local Sponsor will provide a Task Summary Report signed by Local Sponsor containing; 1) An itemized listing of all monitoring activities completed or in progress during the payment request period and, 2) Documentation of submittal to state and federal regulatory agencies of completed monitoring data, surveys and final reports for permit -required work under this task description. Performance Standard: The DEP Project Manager will review the task deliverable and any associated work products as necessary to verify they meet the specifications in the Grant Work Plan and this task description. Payment Request Schedule: Payment requests may be submitted after the deliverable is received and accepted and may be submitted no more frequently than quarterly. Estimated Eligible Project Cost State Federal Task # Eligible Project Tasks Cost Estimated DEP Local Total Share Project Costs 1 Design and Permitting 50.00% $50,000.00 $50,000.00 $100,000.00 2 Construction 50.00% $1,198,153.50 $1,198,153.50 $2,396,307.00 3 USACE Multiphase Project 50.00% $7,776,000.00 $1,112,000.00 $1,112,000.00 $10,000,000.00 4 Monitoring 50.00% $309,226.00 $309,226.00 S618,452.00 TOTAL PROJECT COSTS $7,776,000.00 $2,669,379.50 $2,669,379.50 $13,114,759.00 PROJECT TIMELINE & BUDGET DETAIL: The tasks must be completed by, and all deliverables received by, the corresponding deliverable due date. Task Task Title Budget Category Budget Task Start Deliverable No. Amount Date Due Date 1 Design Contractual Services $50,000.00 01/01/2018 06/30/2025 2 Construction Contractual Services $1,198,153.50 01/01/2018 06/30/2025 3 USACE Multiphase Contractual Services $1,112,000.00 01/01/2018 06/30/2025 Project 4 Monitoring Contractual Services $309,226.00 01/01/2018 06/30/2025 Total: $2,669,379.50 DEP Agreement No. 22SL1, Attachment 3-A, Page 4 of 5 Page 17 of 148 Note that, per paragraph 8.h. of the agreement, authorization for continuation and completion of work and any associated payments may be rescinded, with proper notice, at the discretion of the Department if the Legislature reduces or eliminates appropriations. Extending the contract end date carries the risk that funds for this project may become unavailable in the future. This should be a consideration for the Local Sponsor with this and future requests for extension. 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LUCIE COUNTY EROSION DISTRICT, a dependent taxing district of the State of Florida, hereinafter referred to as the "County' and TAYLOR ENGINEERING, INC., hereinafter referred to as the "Consultant". WITNESSETH: WHEREAS, on September 15, 2020, the County entered into a Consulting Agreement (Contract No. C20-09-772) hereinafter referred to as "Contract" with the Consultant to provide continuing professional coastal engineering services; and, WHEREAS, pursuant to the Contract, the Consultant is to provide the professional services as outlined in this individual work authorization; and, WHEREAS, the Legislature of the State of Florida amended Section 448.095(2)(a) Florida Statute to provide that any contract by a local government entity must contain a provision for the use of the Federal E-Verify System to confirm the work authorization status of new employees hired on or after January 1, 2021. NOW, THEREFORE, in consideration of their mutual promises made herein, and for other good and valuable consideration, receipt of which is hereby acknowledged by each party, the parties who are legally bound, hereby agree as follows: 1. PROJECT: The County has determined that it would like to complete a project described below: Fort Pierce Shore Protection Project 2023 Physical and Biological Monitoring (hereinafter referred to as "the Project".) 2. SERVICES: The County has determined that it would like to utilize the services of the Consultant in the completion of the Project, to provide professional engineering services for the Project under the pricing, terms and conditions of the continuing contract (C20-09-772). The services to be provided by Consultant on the Project shall be for those as outlined in the Scope of Work attached hereto as Exhibit "A" and according to the schedule which are attached hereto and made a part of this work authorization and incorporated herein. Page 1 of 3 Page 22 of 148 3. COMPENSATION: The cost to perform all services as described in the attached Scope of Services shall not exceed a total amount of $264,409.00 (two hundred sixty-four thousand four hundred nine and 00/100 dollars), as further detailed in Exhibit "B". No reimbursable expenses will be paid pursuant to this work authorization. Any sub -consultant fees associated with this work authorization will be paid as a direct pass through without any additional mark-up or administrative fee. This work authorization shall meet the definition of "Construction Services" as defined in F.S. §218.72. Payment to the Consultant shall be made within 20 business days of the County's receipt of the application. 4. CONTRACT DOCUMENT: Except as amended hereby, all of the original terms and conditions in the Continuing Contract shall remain in full force and effect. 5. TIME OF COMPLETION: a. It is hereby understood and mutually agreed by and between parties hereto that the time of completion is an essential condition of this Contract, time being of the essence. b. Consultant shall commence work per the written Notice to Proceed and shall complete all work as further described in the Scope of Work Exhibit "C" Deliverable/Invoicing Schedule. C. The period herein above specified for project completion may be extended by such time as shall be approved by the County Administrator or designee, or the Contract may be cancelled by the County Administrator with the County invoking all rights and remedies thereof. d. Where any deductions from or forfeitures of payment in connection with the work of this Contract are duly and properly imposed against the Consultant, in accordance with the terms of the Contract, State Laws, governing ordinances or regulations, the total amount thereof may be withheld from any monies due or to become due the Consultant under the Contract; and when deducted, shall be deemed and taken as payment in such amount. e. SCRUTINIZED COMPANIES TERMINATION: The County may immediately terminate the Contract without cause at any time upon ascertaining that pursuant to § 287.135, Florida Statutes, a company is ineligible to, and may not, bid on, submit a proposal for, or enter into or renew a contract with an agency or local government entity for goods or services if at the time of bidding or submitting a proposal for a new contract or renewal of an existing contract, or at any time thereafter, the company: (1) is on the Scrutinized Companies that Boycott Israel List, created pursuant to § 215.4725, Florida Statutes, or is engaged in a boycott of Israel; (2) is on the Scrutinized Companies with Activities in Sudan List or the Scrutinized Companies with Activities in the Iran Petroleum Energy Sector List, created pursuant to § 215.473, Florida Statutes; or (3) is engaged in business operations in Cuba or Syria. Furthermore, the County may immediately terminate the Contract if it is determined that the company submitted a false certification stating that it was not (1) on the Scrutinized Companies that Boycott Israel List or engaged in a boycott of Israel; (2) was not on the Scrutinized Companies with Activities in Sudan List or the Scrutinized Companies with Activities in the Iran Petroleum Energy Sector List; (3) or was not engaged in business operations in Cuba or Syria when in fact the company was engaged in such activities at the time of the bid or proposal, or at the time of entering into or renewing the Contract. Page 2 of 3 Page 23 of 148 6. E-VERIFY/ VERIFICATION OF EMPLOYMENT STATUS Effective January 1, 2021, As required by Section 448.095(2)(a), the Consultant and subcontractor shall register with and use the E-Verify System to verify the work authorization status of all newly hired employees. The County, Consultant, or subcontractor may not enter into a Contract unless each party to the Contract registers with and uses the E-Verify System. The Consultant shall provide documentation of their compliance of this requirement to the County upon request. If the Consultant enters into a contract with a subcontractor, the subcontractor must provide the Consultant with an affidavit stating that the subcontractor does not employ, contract with, or subcontract with an unauthorized alien. The Consultant shall maintain a copy of such affidavit for the duration of this Contract. The County will not intentionally award contracts to any consultant who knowingly employs unauthorized alien workers, constituting a violation of the employment provisions of the Immigration and Nationality Act ("INA"). The County shall consider the employment by the Consultant of unauthorized aliens a violation of 8 U.S.C. Section 1324a(e) [Section 274A(e) of the INA]. The Consultant agrees that such violation by the Consultant shall be grounds for the unilateral cancellation of this Contract by the County. IN WITNESS WHEREOF, the parties hereto have executed this Work Authorization effective the date first written above. ATTEST: BY: ST. LUCIE COUNTY EROSION DISTRICT ST. LUCIE COUNTY, FLORIDA BY: DEPUTY CLERK CHAIR APPROVED AS TO FORM AND CORRECTNESS: COUNTY ATTORNEY TAYLOR ENGINEERING, INC. BY: PRINT NAME: Page 3 of 3 Page 24 of 148 EXHIBIT A Scope of Work Fort Pierce Shore Protection Project 2023 Physical and Biological Monitoring The U.S. Army Corps of Engineers (USAGE) plans to nourish the entire Fort Pierce Shore Protection Project beach during winter/spring 2023 using beach quality material from Capron Shoal. Physical and biological project monitoring requirements for 2023 (post -construction), addressed in this scope of work, are based on Florida Department of Environmental Protection (FDEP) Permit No. 0327791- 001-JC and associated monitoring plans. The Physical Monitoring Plan, Ft. Pierce Shore Protection Project (revised March 2017) covers collection of topographic and bathymetric data. The Ft. Pierce Inlet Sediment Impoundment Basin Biological Monitoring Plan (revised April 2017) covers hardbottom data collection. Specific conditions in FDEP Permit No. 032779 1 -00 1 -JC detail sea turtle monitoring requirements. The Fort Pierce Beach Shore Protection Project area extends from the Fort Pierce Inlet south jetty (200 ft north of FDEP profile R-34) to T-41. The physical monitoring control area extends 5,000 ft south of the project area, from T-41 to R-46. As such, all physical monitoring analyses address the beach reach from the inlet south jetty to R-46. Tasks 1 — 4 address physical monitoring. Tasks 5 — 9 address biological monitoring. Task 1 Beach and Borrow Area Survey Data Acquisition and Quality Control Within 60 days of construction completion, Morgan & Eklund, Inc., as a subcontractor to Taylor Engineering, will collect post -construction topographic and bathymetric profile surveys of the project and control areas. These surveys will include profiles at FDEP reference monuments R-34 through R-46A and intermediate profiles at R-34.5 and R-35.5 (15 profiles total) in St. Lucie County. Morgan & Eklund will perform all work activities and produce deliverables in accordance with the October 2014 (or later) FDEP Division of Water Resource Management's Monitoring Standards for Beach Erosion Control Projects; Section 01000, Beach Profile Topographic Surveying; Section 01100, Offshore Profile Surveying; and Section 01200, Borrow Site, Shoal, and Other Bathymetric Surveying. (Document available on the web at https://floridadep.gov/sites/default/files/PhysicalMonitoringStandards.pdf). Upon receipt, we will perform a quality control check of the data. M Page 25 of 148 EXHIBIT A Prior to the survey, we will coordinate with M&E to execute a subcontract agreement and to specify the details of the survey scope. Upon receipt of the survey data files, we will perform quality control review and coordinate with M&E as necessary to address any issues with the survey data. Upon receiving the final survey deliverables, including all FDEP-required supporting documentation and FDEP-specific file formats, we will submit the deliverables to both the FDEP JCP Compliance Officer and FDEP Grants Manager. At approximately the same time as the survey, a senior engineer from our Jacksonville office will visit the beach to observe and photograph beach and dune geometry and general beach conditions. The physical monitoring report will include photographs from the site visit. We assume USACE will conduct the pre -construction beach profile survey and will provide pre - and post -construction bathymetry survey of the borrow area. We will provide the USACE survey data files to the FDEP. If the above assumption proves incorrect, we will submit a proposal for Morgan & Eklund, as subcontractor to Taylor Engineering, to conduct any additional beach profile or borrow area surveys. Task 2 Beach and Borrow Area Survey Data Analysis Taylor Engineering will perform beach profile -based analyses for each reference monument from R-34 through R-46A and intermediate profiles at R-34.5 and R-35.5 — a total of 15 lines — to determine project performance. We will make the following comparisons at each reference monument. • 1999 pre -construction data versus 2023 post -construction data • 2021 post -fill data versus 2023 pre -construction data • 2022 Year 1 (2021 nourishment) data versus 2023 pre -construction data • 2023 pre -construction data versus 2023 post -construction data We will convert the data to range/elevation profiles and develop profile plots. We will calculate volume changes and mean high water (MHW) position changes for the above comparison periods. We will prepare profile plots and tabulate shoreline positions and shoreline and volume changes. We will calculate beach volumes over three vertical compartments: dune to MHW, MHW to 700 ft seaward of the survey monument (1000 It at R-34.5—R-36), and from 700 ft to -32.5 ft-NAVD88. We will integrate beach volume changes alongshore to develop sediment pathways and to identify areas of accretion and erosion. Of note, prior analysis of the landward edge of hardbottom and convergence of the beach profiles identified 700 ft from the monument as a suitable location for a volume compartment boundary, except at R-34.5-36 where 1,000 ft is more appropriate; the rapidly varying elevation characteristics seaward of this boundary may limit the utility of this portion of analysis. We will analyze the pre- and post -dredge borrow area data A - 2 Page 26 of 148 EXHIBIT A provided by USACE to determine the excavation quantity and locations and verify that dredging activities remained within the authorized dredging template. Task 3 Aerial Photography GPI Geospatial, Inc. (GPI), as a subcontractor to Taylor Engineering, will collect aerial photography concurrently or as close as possible to the post -fill beach profile survey. The aerial photography will cover FDEP reference monument R-34 through R-46A in St. Lucie County. GPI will conduct work activities and deliverables in accordance with the October 2014 (or later) FDEP Division of Water Resource Management's Monitoring Standards for Beach Erosion Control Projects, Section 02100, Environmental Aerial Photography. (Document available on the web at https://floridadep. gov/sites/default/files/PhysicalMonitoringStandards.pdf). Task 4 Physical Monitoring Report Taylor Engineering will prepare a report documenting the results of the above analyses. The report will present and discuss the data (including any potential sources for errors in the dataset) and identify erosion and accretion patterns within the entire area monitored. Appendices will include plots of survey profiles and graphical presentations of volumetric and shoreline position changes for both the construction and control areas. The report will satisfy requirements contained in FDEP Permit No. 0327791-001-JC. We will submit an electronic copy of the report for St. Lucie County staff review and comment. To the maximum extent possible, we will modify the report to incorporate county comments and will submit one electronic copy of the final report and survey data to St. Lucie County and one electronic copy to FDEP. Task 5 Post -Construction Sea Turtle Monitoring Our subcontractor, Ecological Associates, Inc. (EAI), will provide all sea turtle related monitoring services as required by the FDEP permit. The contractor will be responsible for construction -phase sea turtle nest monitoring and protection. Once the construction -phase monitoring and nest protection program has ceased, EAI will leave all nests in the project area in place and marked to evaluate nest fate and reproductive success. EAT will resume early morning sea turtle nesting surveys upon completion of construction and will continue uninterrupted A - 3 Page 27 of 148 EXHIBIT A through November 11, 2023. Monitoring will include daily nest monitoring, marking and evaluating a representative sample of nests (not to exceed 175 total marked nests), and determining reproductive success. The turtle monitor will also determine and record false crawls and nests by species. Monitoring will occur within the re -nourished beach and an adjacent control area, of equal length, immediately south of the re - nourished beach. Task 6 Nesting Season Weekly Escarpment Monitoring Upon completion of construction, EAI will conduct weekly escarpment surveys through October 31, 2023. As necessary during the monitoring period, Taylor Engineering will notify the FDEP and Florida Fish and Wildlife Conservation Commission (FWC) of the presence of persistent escarpments to determine if escarpment leveling or other action is required. Task 7 Post -Construction Shorebird Monitoring Upon completion of construction, EAI will conduct weekly shorebird surveys until all breeding activity has concluded, or July 15, 2023 if no breeding has taken place. During each survey, a qualified shorebird nesting biologist will inspect all potential nesting habitat within the project area in accordance with FWC protocols. Task 8 Lighting Surveys In compliance with the FDEP permit, EAI will monitor beachfront lighting within the project area. The monitoring area will extend from the jetty south to the end of the 2023 nourishment area. Following the completion of construction, EAI will conduct two nighttime surveys. The first will occur immediately following construction between May 1 and June 7 and the second will occur between July 15 and August 1. EAI will identify lights visible from the beach and complete standard lighting report forms noting light characteristics with respect to the local lighting regulation. We will provide the lighting survey reports to St. Lucie County, City of Fort Pierce, and FWC. We will prepare a summary report of the surveys including any corrective actions taken for submittal to FWC by December 15. Following submittal of the summary report, we will coordinate a meeting with FWC, FDEP, EAI, City of Fort Pierce, and the county to discuss the results of lighting surveys. Page 28 of 148 EXHIBIT A Task 9 Hardbottom Monitoring Our subcontractor, CSA Ocean Sciences, Inc., will conduct hardbottom monitoring as required by FDEP Permit No. 0327791-001-JC and the April 2017 Biological Monitoring Plan. Hardbottom monitoring shall consist of video transects, still photographic transects, sediment measurements, and quadrat sampling along specifically identified and marked transect lines. Hardbottom biological monitoring transects occur directly offshore FDEP Reference Monuments R-35, R-37, R-39, R-41, and R-43. Sediment measurement only transects occur offshore FDEP Monuments R-36, R-38, and R-40. In addition, CSA will monitor the nearshore edge of hardbottom from FDEP Monuments R-34 to R-43. CSA will follow hardbottom monitoring and data analyses protocols required by the above -referenced FDEP permit and biological monitoring plan. We will submit digital copies of the final hardbottom monitoring report to the FDEP and digital and hard copies to the county. — END OF SCOPE OF WORK — We will complete the above scope of work for a fixed lump sum fee of $264,409. Exhibit B details the proposed costs and Exhibit C contains the proposed schedule. 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COST SUMMARY BY TASK P2022-200: 2023 FORT PIERCE PHYSICAL & BIOLOGICAL MONITORING TASK 1: Beach and Borrow Area Survey Data Acquisition Labor Days Cost ($) Task Totals Senior Professional 1.8 2,668.00 Total Labor -Days 1.8 Labor Cost 2,668.00 Non -Labor Units Cost ($) Morgan & Eklund, Inc. 1.0 9,450.00 Total Non -Labor Cost 9,450.00 Total Task 1 $ 12,118.00 TASK 2: Beach and Borrow Area Survey Data An Principal 0.9 1,533.00 Senior Professional 6.5 9,516.00 Project Professional 15.0 16,560.00 Senior CAD/GIS 2.0 2,400.00 Staff CAD/GIS 1.0 608.00 Administrative Support 1.5 804.00 Total Labor -Days 26.9 Labor Cost 31,421.00 Total Task 2 $ 31,421.00 TASK 3: Aerial Photo Senior Professional 0.3 440.00 Total Labor -Days 0.3 Labor Cost 440.00 Non -Labor Units Cost ($) GPI Geospatial, Inc. 1.0 8,800.00 Total Non -Labor Cost 8,800.00 Total Task 3 $ 9,240.00 EXHIBIT B Page 31 of 148 Page 2 EXHIBIT B P2022-200: 2023 FORT PIERCE PHYSICAL & BIOLOGICAL MONITORING TASK 4: Physical Monitoring Report Labor Days Cost ($) Task Totals Principal 0.8 1,314.00 Senior Professional 5.5 8,052.00 Project Professional 8.5 9,384.00 Staff Professional 2.0 1,632.00 Senior CAD/GIS 1.0 1,200.00 Staff CAD/GIS 2.5 1,520.00 Administrative Support 2.0 1,072.00 Total Labor -Days 22.3 Labor Cost 24,174.00 Total Task 4 $ 24,174.00 TASK 5: Post -Construction Sea Turtle Monitoring Labor Days Cost ($) Task Totals Senior Professional 3.0 4,392.00 Total Labor -Days 3.0 Labor Cost 4,392.00 Non -Labor Units Cost ($) Ecological Associates, Inc. 1.0 87,858.00 Total Non -Labor Cost 87.858.00 TA r%1/ - KI__I:.--. n Total Task 5 $ 92,250.00 Total Labor -Days Labor Cost Non -Labor Ecological Associates, Inc. Total Non -Labor Cost Total Task 6 0.1 Units Cost ($) 1.0 3,150.00 156.00 n , Gf1 /1/1 $ 3,306.00 Page 32 of 148 Page 3 EXHIBIT B P2022-200: 2023 FORT PIERCE PHYSICAL & BIOLOGICAL MONITORING TASK 7: Post -Construction Shorebird Surveys Labor Days Cost ($) Task Totals Senior Professional 0.1 89.00 Total Labor -Days 0.1 Labor Cost 89.00 Non -Labor Units Cost ($) Ecological Associates, Inc. 1.0 1,782.00 Total Non -Labor Cost 1,782.00 Total Task 7 $ 1,871.00 TASK 8: Liahtina S Senior Professional 0.2 332.00 Total Labor -Days 0.2 Labor Cost 332.00 Non -Labor Units Cost ($) Ecological Associates, Inc. 1.0 6,641.00 Total Non -Labor Cost 6,641.00 Total Task 8 $ 6,973.00 TASK 9: Hardbottom Monitoring Senior Professional 2.7 3,955.00 Total Labor -Days 2.7 Labor Cost 3,955.00 Non -Labor Units Cost ($) CSA Ocean Sciences, Inc. 1.0 79,101.00 Total Non -Labor Cost 79,101.00 Total Task 9 $ 83,056.00 Project Total $ 264,409.00 Page 33 of 148 TO: Erosion District AGENDA REQUEST 2023-58559 DATE: 2/21/2023 PRESENTED BY: Joshua Revord, Senior Coastal Engineer SUBMITTED BY: Public Works SUBJECT: Work Authorization No. 08 (Taylor Engineering) — Fort Pierce Shore Protection Project, Section 203/403 Letter Report Support BACKGROUND: On June 7, 2018, the County submitted a final copy of the Fort Pierce, St. Lucie County, Florida Shore Protection Protect, Section 203 Integrated Feasibly Study and Environmental Assessment (the "Report") to the Assistant Secretary of the Army's (ASA) Civil Works (CW) office in Washington D.C. This Report was the product of decades of work towards improving the management of beach erosion south of the Fort Pierce Inlet. The County's southern beaches (including Fort Pierce Beach) are heavily impacted by the Inlet (a federal inlet) and have historically required special attention to maintain natural sediment pathways for a healthy Atlantic shoreline. The Report proposed a modified federal beach project, including strategically placed coastal structures (a T-groin field) and a new 50-year federal project life extension with the U.S. Army Corps of Engineers (USACE). The modifications to the existing federal beach project were initially envisioned in a General Reevaluation Report (GRR) initiated by the County, USACE (Jacksonville), and Taylor Engineering in 1999. By 2005, a framework for the Report was created, and the USACE received partial funding to begin compiling report content. Ultimately, progress towards the completion of the Report was hindered by limited federal funding and most formulation efforts came to a halt. A provision in the 2014 Congressional Water Resource and Development Act (WRDA), signed into law, provided local sponsors with a legal pathway to complete federal feasibility level reports/assessments and submit them directly to the ASA(CW) office for consideration. Seizing the opportunity, the County directly employed Taylor Engineering to complete the Report (2016) and it was submitted to the ASA(CW) office on March 13, 2017. The County subsequently engaged in many meetings with the ASA(CW) office to better refine the Report for future Congressional authorization, and it was finally packaged for consideration under Section 203 Authority (at ASA(CW) request). The final copy of the Section 203 Report was submitted on June 6, 2018. The report received conditional authorization by Congress in WRDA 2018, with final authorization pending resolution of the outstanding ASA(CW) Review Assessment comments. Since receiving the conditional authorization, the USACE (Jacksonville) was provided further guidance in WRDA 2020 (Section 403) on initiating a path forward with comment resolution. A scope summary table and project management plan were drafted in response to the new Section 403 guidance and have been provided for reference purposes. These documents are currently being reviewed by USACE (South Atlantic Division) for approval and helped in the development of a draft cost share agreement (also attached for reference) Page 34 of 148 between the USACE and St. Lucie County ( pending). The end goal being, to satisfy the outstanding ASA(CW) comments, attain proper authorization of the Section 203/403 Report, and move the proposed project into the planning, engineering and design (PED) phase of development. Work Authorization No. 08 (Taylor Engineering) includes: (1) compensation for efforts previously undertaken (in good faith) by Taylor Engineering to better refine the scope summary table and draft PMP (Task 1), ensuring that the County's interests were considered during initial scope summary negotiations with the USACE; and (2) compensation for future efforts associated with the resolution of the outstanding ASA(CW) Review Assessment comments. PREVIOUS ACTION: April 5, 2016 - Informal meeting to update the BOCC on the Ft. Pierce General Re-evaluation Report (GRR) and the recommended action plan moving forward (consistent with the 2014 Federal WRDA Bill). May 17, 2016 — Board approval of Work Authorization No. 5 with Taylor Engineering, Inc. to move forward with completing the Ft. Pierce GRR (ID #3533). March 13, 2017 — St. Lucie County formally submits the completed GRR to the ASA(CW) office (letter attached). February 9, 2018 — Initial ASA(CW) Review Assessment of the Section 203 Feasibility Study received by the County. Decision to modify GRR into a Section 203 Report determined by the ASA(CW) office during follow-up discussions. May 01, 2018 - Board approval of Work Authorization No. 14 with Taylor Engineering, Inc. to modify the GRR into a Section 203 Report and address the ASA(CW) office's outstanding comments (ID #5210). June 6, 2018 — St. Lucie County formally submits the Fort Pierce, St. Lucie County, Florida Shore Protection Project - Section 203 Integrated Feasibility Study With Environmental Assessment to the ASA(CW) office. (letter attached). July 1, 2018 — Draft ASA(CW) Review Assessment of the Section 203 Integrated Feasibility Study received by the County (Review Assessment attached). December 27, 2020 — Section 403(a) of WRDA 2020 provides for Conditional Authorization of the St. Lucie County, Florida Fort Pierce Shore Protection Project - Section 203 Feasibility Study, consistent with the ASA(CW) office Review Assessment. March 31, 2021— St. Lucie County officially request funding to move the Section 203 Study into the Planning, Engineering, and Design Phase (PDE), requesting out of cycle funding to begin resolution of the ASA(CW) Review Assessment. September 1, 2021— Initial USACE (Jacksonville) Project Management Plan (PMP) team kick-off meeting to determine the approach to resolving ASA(CW) Review Assessment comments. February 16, 2022 — Follow-up PMP team meeting to discuss differences in resolution approach and establish a scope summary table for the development of a future cost share agreement between USACE and the County. March 15, 2022 — Consolidate Appropriations Act of 2022 signed into law, including a $400,000.00 earmark appropriated for the Section 203/403 Review Assessment resolution effort. September 14, 2022 — County support letter submitted to USACE (Jacksonville) for the Section 203/403 resolution effort (letter attached). September 15, 2022 — Final PMP resolution conference meeting to confirm a team approach to addressing the outstanding Review Assessment comments. The scope summary table was completed and utilized to draft a draft cost share agreement (currently being considered). FINANCIAL IMPACT: Page 35 of 148 Funding for Work Authorization No. 08 with Taylor Engineering ($63,009.00) is currently available and proposed from the Erosion District Reserves (184-9910-599300-910000). RECOMMENDATION: Staff recommends Board approval of Work Authorization No. 08 with Taylor Engineering ($63,009.00) and authorization for the Erosion District Chair to sign documents as approved by the County Attorney. COMMISSION ACTION: RESULT: MOVER: SECONDER: None AYES: None NAYS: None EXCUSED: None Coordination/Signatures Date: January 27, 2023 Patrick Dayan, Public Works Director Date: January 30, 2023 Jennifer Hill, Office of Management &Budget Director j Date: February 01, 2023 Daniel McIntyre, County Attorney Date: February 01, 2023 Mayte Santamaria, Planning & Development Services Director Page 36 of 148 WORK AUTHORIZATION NO.08 CONTRACT C20-09-772 COASTAL ENGINEERING SERVICES THIS WORK AUTHORIZATION is made as of the day of , 2023, by and between the ST. LUCIE COUNTY EROSION DISTRICT, a dependent taxing district of the State of Florida, hereinafter referred to as the "County' and TAYLOR ENGINEERING, INC., hereinafter referred to as the "Consultant". WITNESSETH: WHEREAS, on September 15, 2020, the County entered into a Consulting Agreement (Contract No. C20-09-772) hereinafter referred to as "Contract" with the Consultant to provide continuing professional coastal engineering services; and, WHEREAS, pursuant to the Contract, the Consultant is to provide the professional services as outlined in this individual work authorization; and, WHEREAS, the Legislature of the State of Florida amended Section 448.095(2)(a) Florida Statute to provide that any contract by a local government entity must contain a provision for the use of the Federal E-Verify System to confirm the work authorization status of new employees hired on or after January 1, 2021. NOW, THEREFORE, in consideration of their mutual promises made herein, and for other good and valuable consideration, receipt of which is hereby acknowledged by each party, the parties who are legally bound, hereby agree as follows: 1. PROJECT: The County has determined that it would like to complete a project described below: Fort Pierce Shore Protection Project Section 403 Letter Report Support Develop Responses to 2018 ASA(CW) Comments (hereinafter referred to as "the Project".) 2. SERVICES: The County has determined that it would like to utilize the services of the Consultant in the completion of the Project, to provide professional engineering services for the Project under the pricing, terms and conditions of the continuing contract (C20-09-772). The services to be provided by Consultant on the Project shall be for those as outlined in the Scope of Work attached hereto as Exhibit "A" and according to the schedule which are attached hereto and made a part of this work authorization and incorporated herein. Page 1 of 3 Page 37 of 148 3. COMPENSATION: The cost to perform all services as described in the attached Scope of Services shall not exceed a total amount of $63,009.00 (sixty-three thousand nine and 00/100 dollars), as further detailed in Exhibit "B". No reimbursable expenses will be paid pursuant to this work authorization. Any sub -consultant fees associated with this work authorization will be paid as a direct pass through without any additional mark- up or administrative fee. This work authorization shall meet the definition of "Construction Services" as defined in F.S. §218.72. Payment to the Consultant shall be made within 20 business days of the County's receipt of the application. 4. CONTRACT DOCUMENT: Except as amended hereby, all of the original terms and conditions in the Continuing Contract shall remain in full force and effect. 5. TIME OF COMPLETION: a. It is hereby understood and mutually agreed by and between parties hereto that the time of completion is an essential condition of this Contract, time being of the essence. b. Consultant shall commence work per the written Notice to Proceed and shall complete all work on or before December 31, 2024. C. The period herein above specified for project completion may be extended by such time as shall be approved by the County Administrator or designee, or the Contract may be cancelled by the County Administrator with the County invoking all rights and remedies thereof. d. Where any deductions from or forfeitures of payment in connection with the work of this Contract are duly and properly imposed against the Consultant, in accordance with the terms of the Contract, State Laws, governing ordinances or regulations, the total amount thereof may be withheld from any monies due or to become due the Consultant under the Contract; and when deducted, shall be deemed and taken as payment in such amount. e. SCRUTINIZED COMPANIES TERMINATION: The County may immediately terminate the Contract without cause at any time upon ascertaining that pursuant to § 287.135, Florida Statutes, a company is ineligible to, and may not, bid on, submit a proposal for, or enter into or renew a contract with an agency or local government entity for goods or services if at the time of bidding or submitting a proposal for a new contract or renewal of an existing contract, or at any time thereafter, the company: (1) is on the Scrutinized Companies that Boycott Israel List, created pursuant to § 215.4725, Florida Statutes, or is engaged in a boycott of Israel; (2) is on the Scrutinized Companies with Activities in Sudan List or the Scrutinized Companies with Activities in the Iran Petroleum Energy Sector List, created pursuant to § 215.473, Florida Statutes; or (3) is engaged in business operations in Cuba or Syria. Furthermore, the County may immediately terminate the Contract if it is determined that the company submitted a false certification stating that it was not (1) on the Scrutinized Companies that Boycott Israel List or engaged in a boycott of Israel; (2) was not on the Scrutinized Companies with Activities in Sudan List or the Scrutinized Companies with Activities in the Iran Petroleum Energy Sector List; (3) or was not engaged in business Page 2 of 3 Page 38 of 148 operations in Cuba or Syria when in fact the company was engaged in such activities at the time of the bid or proposal, or at the time of entering into or renewing the Contract. 6. E-VERIFY/ VERIFICATION OF EMPLOYMENT STATUS Effective January 1, 2021, As required by Section 448.09S(2)(a), the Consultant and subcontractor shall register with and use the E-Verify System to verify the work authorization status of all newly hired employees. The County, Consultant, or subcontractor may not enter into a Contract unless each party to the Contract registers with and uses the E-Verify System. The Consultant shall provide documentation of their compliance of this requirement to the County upon request. If the Consultant enters into a contract with a subcontractor, the subcontractor must provide the Consultant with an affidavit stating that the subcontractor does not employ, contract with, or subcontract with an unauthorized alien. The Consultant shall maintain a copy of such affidavit for the duration of this Contract. The County will not intentionally award contracts to any consultant who knowingly employs unauthorized alien workers, constituting a violation of the employment provisions of the Immigration and Nationality Act ("INA"). The County shall consider the employment by the Consultant of unauthorized aliens a violation of 8 U.S.C. Section 1324a(e) [Section 274A(e) of the INA]. The Consultant agrees that such violation by the Consultant shall be grounds for the unilateral cancellation of this Contract by the County. IN WITNESS WHEREOF, the parties hereto have executed this Work Authorization effective the date first written above. ATTEST: BY: ST. LUCIE COUNTY EROSION DISTRICT ST. LUCIE COUNTY, FLORIDA BY: DEPUTY CLERK CHAIR APPROVED AS TO FORM AND CORRECTNESS: COUNTY ATTORNEY TAYLOR ENGINEERING, INC. BY: PRINT NAME: Page 3 of 3 Page 39 of 148 Exhibit A Scope of Work Ft. Pierce Shore Protection Project Section 403 Letter Report Support Develop Responses to 2018 ASA(CW) Comments Overview The following scope of work is based on our understanding of the project as follows. Taylor Engineering submitted a General Reevaluation Report (GRR) for the Ft. Pierce Shore Protection Project (SPP) to St. Lucie County on March 1, 2017. As the non-federal local sponsor of the SPP, the County submitted the GRR directly to the Assistant Secretary of the Army (Civil Works) (ASA(CW)) for review on March 13, 2017. The ASA(CW) provided a letter with their initial review comments on August 18, 2017. After attending a meeting in Washington D.C. with ASA(CW), USACE, and County representatives and upon receiving guidance from the County, we provided a written response to ASA(CW)'s review comments on November 7, 2017. On February 9, 2018, ASA(CW) provided a letter with comments regarding our written response•, the letter identified the initial review comments that the Taylor Engineering/St Lucie County written response resolved and the comments that required further action by the County to satisfactorily address. In addition, the February 9, 2018 letter included additional comments. During sporadic conversations in 2022, Taylor Engineering staff coordinated with USACE Jacksonville District staff via several teleconferences and an in -person meeting to develop a joint approach to address ASA(CW)'s review comments (details in tasks listed below). The end product of this effort is a Section 403 Letter Report titled "Review of Assessment of the St. Lucie County, Florida, Fort Pierce Shore Protection Project Section 203 Integrated Feasibility Study and Environmental Assessment." The USACE will author the letter report with significant input from St. Lucie County and Taylor Engineering. The tasks outlined below generally follow those set out in the USACE's Project Management Plan dated 9/29/2022. The tasks below identify the additional work required to prepare and submit a revised GRR per ASA(CW)'s review comments and subsequent coordination. Of note, the additional work includes modifications to convert the GRR into a Section 203 Integrated Feasibility Report as directed by ASA(CW). Task 1: Work Completed in 2021/2022 to Coordinate with the USACE and Develop the Plan to Address the ASA(CW) comments and Develop Responses The task list below details the work completed by Taylor Engineering in 2021/2022 to coordinate with the USACE and St Lucie County during virtual and in -person meetings to understand the USACE planned path forward and support the County's effort to address the ASA(CW) questions with robust responses. • September 1, 2021; Taylor Engineering participated in a virtual meeting with USACE Jacksonville District staff where USACE staff provided a status update and potential next steps for the Project Development Team (PDT) path forward for the Ft. Pierce SPP Section 203/403 work. o Total effort related to the September 2021 meeting and document review: 9 hours. February 16, 2022; Taylor Engineering participated in a virtual meeting with USACE Jacksonville District staff to restart the efforts and to perform an initial review of the USACE planned scope of work to address the ASA(CW) comments. o This effort included a pre -call with St Lucie County staff and post -call work to review the funding memo submitted by the USACE and perform post -meeting planning. o Total effort related to the February 2022 meeting and document review: 10 hours. Page 40 of 148 Exhibit A September 15, 2022; Taylor Engineering hosted a 5-hour in -person meeting with USACE Jacksonville District staff and St Lucie County staff. Additional efforts related to the 5-hour in - person meeting included: o Prior to the in -person meeting, the USACE Jacksonville District hosted virtual meeting on August 11, 2022 with Taylor Engineering staff and St Lucie County staff to discuss the basics of the draft USACE scope, schedule and budget related to the Ft Pierce Section 203 study efforts. o Between the August meeting and September meeting Taylor Engineering staff had internal meetings and coordinated with St Lucie County staff to review the draft USACE documents and plan for the September 15 meeting. These efforts included developing a matrix of each ASA(CW) comment, the proposed USACE Jacksonville District response, and a St Lucie County/Taylor Engineering plan for the path forward. o Coordination of hosting meeting and meeting logistics o Following the September 15 meeting, Taylor Engineering developed and submitted to St Lucie County staff a summary matrix that included notes on the in -person meeting discussion and agreed upon path forward for each comment/item. o Total hours for efforts related to the in -person meeting with associated pre- and post - meeting activities: 63.5 hours Task 2: Assistance on Specific Items Related to the ASA(CW) Comments and Development of the USACE/St. Lucie County Cost Share Agreement Taylor Engineering will support St Lucie County in addressing specific comments created by the ASA(CW) as detailed in the introduction to this scope of work. Task 2.1: Taylor Engineering will support St. Lucie County in addressing ASA(CW) Unresolved 2018 Comment #4 related to the review of Beach-Fx results and support the development of estimates of total project costs for the various shore protection alternatives. Total effort 29 hours. Task 2.2: Taylor Engineering will support St. Lucie County in addressing ASA(CW) Unresolved 2018 Comment #6 related to the support and development of contingency values and documentation for prior Ft. Pierce SPP project analyses. Total effort 11 hours. Task 2.3: Taylor Engineering will support St. Lucie County in addressing ASA(CW) Unresolved 2017 Comment #1) related to support of report edits to include additional discussion of how the project meets the Executive Order (EO) 11988. Total effort 11 hours. Task 2.4: Taylor Engineering will support St. Lucie County in addressing ASA(CW) Unresolved 2017 Comment #2 and #4 related to the review of the Ft. Pierce Inlet sediment basin history and function. Total effort 24 hours. Task 2.5: Taylor Engineering will support St. Lucie County in addressing ASA(CW) Unresolved 2017 Comment 43 related to the review of the plan formulation language and the development of revised text to address the ASA(CW) comment. Total effort 14 hours. Task 2.6: Taylor Engineering will support St. Lucie County in addressing ASA(CW) Unresolved 2017 Comment #5 related to the review of the alternative shore protection alternative screening language and the development of revised text to address the ASA(CW) comment. Total effort 11 hours. 2 Page 41 of 148 Exhibit A Task 2.7: Taylor Engineering will support St. Lucie County in addressing ASA(CW) Unresolved 2017 Comment #6, #7, #8, #9) related to the environmental assessment and related aspects with coordination with the USACE efforts and development of additional text. Total effort 29 hours. Task 3: Attend Meetings and Review Documents on As -needed Basis to Support St Lucie County's Response to USACE Plans/Submittals Taylor Engineering will support St Lucie County's response to USACE Jacksonville District plans and submittals related to the Ft. Pierce Section 203 work and response to the ASA(CW) comments. Due to the uncertain nature of the future submittals and required support activities, the Task 3 work will occur on an "as needed" basis with work authorized by St Lucie County in 20-hour sub -tasks. Each sub - task will have a defined scope of work that Taylor Engineering will submit to St Lucie County for approval before a 20-hr sub -task is approved. END OF SCOPE OF WORK 3 Page 42 of 148 Exhibit B Page 1 TAYLOR ENGINEERING, INC. COST SUMMARY BY TASK P2021-143: FT PIERCE SPP SECT2031403 WORK TASK 1: Review of USACE Plan for Response to ASA(CW) Comments and Meeti Labor Hours Cost ($) Tas4 'irtual and In -Person) 7- President 27.0 8,343.00 Principal 23.0 5,037.00 Program Manager 30.5 6,039.00 Administrative Support 2.0 134.00 Total Labor -Hours 82.5 Labor Cost 19,553.00 Total Task 1 $ 19,553.00 TASK 2: Assistance on Specific Items Related to the ASA(CW) Comments Labor Hours Cost ($) Task Totals President 12.0 3,708.00 Principal 28.0 6,132.00 Program Manager 40.0 7,920.00 Project Professional 28.0 3,864.00 Staff Professional 17.0 1,734.00 Administrative Support 4.0 268.00 Total Labor -Hours 129.0 Labor Cost 23,626.00 Total Task 2 $ 23,626.00 TASK 3: On As -Needed Basis Support St Lucie County's Response to USACE Plans/Submittals Labor Hours Cost ($) Task Totals President 15.0 4,635.00 Principal 25.0 5,475.00 Program Manager 30.0 5,940.00 Project Professional 20.0 2,760.00 Staff Professional 10.0 1,020.00 Total Labor -Hours 100.0 Labor Cost 19,830.00 Total Task 3 $ 19,830.00 Project Total $ 63,009.00 Page 43 of 148 AGREEMENT BETWEEN THE DEPARTMENT OF THE ARMY AND ST. LUCIE COUNTY EROSION DISTRICT FOR CONDUCTING THE FEASIBILITY LEVEL ANALYSIS FOR ST. LUCIE COUNTY, FLORIDA FORT PIERCE SHORE PROTECTION PROJECT THIS AGREEMENT is entered into this day of , by and between the Department of the Army (hereinafter the "Government'), represented by the District Commander for Jacksonville District (hereinafter the "District Commander") and the St. Lucie County Erosion District (hereinafter the "Non -Federal Sponsor"), represented by the Chair. WITNESSETH, THAT: WHEREAS, pursuant to Section 203 of the Water Resources Development Act (WRDA) of 1986, as amended (33 U.S.C. 2231), the Non -Federal Sponsor submitted a feasibility study report (hereinafter the "Section 203 Report") to the Assistant Secretary of the Army (Civil Works) for review; WHEREAS, the Assistant Secretary of the Army (Civil Works) completed a review assessment of the Section 203 Report (hereinafter "the Review Assessment') and identified a number of concerns, recommendations, and conditions that must be addressed; WHEREAS, Section 403(a) of WRDA of 2020 provided conditional authorization for construction of the St. Lucie County, Florida Fort Pierce Shore Protection Project based on the Review Assessment, with project implementation subject to the requirements of Section 403(b) of WRDA 2020 (hereinafter "Section 403(b)"); WHEREAS, pursuant to the requirements of Section 403(b), the Government will undertake analysis necessary to address the outstanding issues identified in the Review Assessment, including preparation of a Letter Report to document such analysis; WHEREAS, using Federal funds in the amount of S 49,999, the Government, in consultation with the Non -Federal Sponsor, completed a scope of work that provides a detailed description, cost estimate, and schedule for each task required to conduct the analysis, including preparation of a Letter Report, necessary to address the outstanding issues in the Review Assessment, with the non -Federal share of the cost of the scope of work to be recovered under this Agreement; and WHEREAS, the Government and the Non -Federal Sponsor have the full authority and capability to perform in accordance with the terms of this Agreement. Page 44 of 148 NOW, THEREFORE, the parties agree as follows: ARTICLE I - OBLIGATIONS OF THE PARTIES A. In accordance with Federal laws, regulations, and policies, the Government, using funds appropriated by the Congress and funds provided by the Non -Federal Sponsor, shall undertake the analysis identified in the scope of work, dated 30 SEPTEMBER 2022, to address the outstanding issues identified in the Review Assessment. The Government will summarize the results of such analysis in a Letter Report, with supporting documentation, for submission to the Assistant Secretary of the Army (Civil Works). B. The total cost of the analysis identified in the scope of work is projected to be $700,000, which includes the Government's costs for preparation of the scope of work and the Letter Report. No later than 30 calendar days after the effective date of this Agreement, the Non -Federal Sponsor, in accordance with Article II, shall provide to the Government funds in the amount of $350,000 to cover its 50 percent share of the total cost of the analysis. In the event the Government determines that additional funds are needed from the Non -Federal Sponsor to complete the analysis, the Government shall provide the Non -Federal Sponsor with a written estimate and justification for the additional funds required, and no later than 60 calendar days after such notification, the Non -Federal Sponsor shall provide the full amount of such funds to the Government. C. To the extent practicable and in accordance with Federal laws, regulations, and policies, the Government shall afford the Non -Federal Sponsor the opportunity to review and comment on solicitations for contracts prior to the Government's issuance of such solicitations; proposed contract modifications, including change orders; and contract claims prior to resolution thereof Ultimately, the contents of solicitations, award of contracts, execution of contract modifications, and resolution of contract claims shall be exclusively within the control of the Government. D. The Non -Federal Sponsor shall not use Federal program funds to meet any of its obligations under this Agreement unless the Federal agency providing the funds verifies in writing that the funds are authorized to be used for such purpose. Federal program funds are those funds provided by a Federal agency, plus any non -Federal contribution required as a matching share therefor. ARTICLE II - PAYMENT OF FUNDS A. The Government shall provide the Non -Federal Sponsor with monthly reports setting forth the estimated total cost of the analysis and the Government's and Non - Federal Sponsor's estimated shares of such costs; costs incurred by the Government, using both Federal and Non -Federal Sponsor funds, to date; the amount of funds provided by the Non -Federal Sponsor to date; and the estimated remaining costs. 2 Page 45 of 148 B. The Non -Federal Sponsor shall provide to the Government required funds by delivering a check payable to "FAO, USAED, Jacksonville District (K3)" to the District Commander, or by providing an Electronic Funds Transfer of such required funds in accordance with procedures established by the Government. C. The Government shall draw from the funds provided by the Non -Federal Sponsor to cover the non -Federal share as those costs are incurred. If the Government determines at any time that additional funds are needed from the Non -Federal Sponsor to cover the Non -Federal Sponsor's required share of costs, the Government shall provide the Non -Federal Sponsor with written notice of the amount of additional funds required. D. Upon completion of the analysis and resolution of all relevant claims and appeals, the Government shall conduct a final accounting and furnish the Non -Federal Sponsor with the written results of such final accounting. Should the final accounting determine that additional funds are required from the Non -Federal Sponsor, the Non - Federal Sponsor, within 60 calendar days of written notice from the Government, shall provide the Government with the full amount of such additional funds. Should the final accounting determine that the Non -Federal Sponsor has provided funds in excess of its required amount, the Government shall refund the excess amount, subject to the availability of funds. Such final accounting does not limit the Non -Federal Sponsor's responsibility to pay its share of costs, including contract claims or any other liability that may become known after the final accounting. ARTICLE III - TERMINATION OR SUSPENSION A. Upon 30 calendar days written notice to the other party, either party may elect at any time, without penalty, to suspend or terminate future performance under this Agreement. B. In the event of termination, the parties shall conclude their activities under this Agreement. To provide for this eventuality, the Government may reserve a percentage of available funds as a contingency to pay the costs of termination, including any costs of resolution of contract claims, and resolution of contract modifications. C. Any suspension or termination shall not relieve the parties of liability for any obligation incurred. Any delinquent payment owed by the Non -Federal Sponsor pursuant to this Agreement shall be charged interest at a rate, to be determined by the Secretary of the Treasury, equal to 150 per centum of the average bond equivalent rate of the 13 week Treasury bills auctioned immediately prior to the date on which such payment became delinquent, or auctioned immediately prior to the beginning of each additional 3 month period if the period of delinquency exceeds 3 months. ARTICLE IV - DISPUTE RESOLUTION 3 Page 46 of 148 As a condition precedent to a party bringing any suit for breach of this Agreement, that party must first notify the other party in writing of the nature of the purported breach and seek in good faith to resolve the dispute through negotiation. If the parties cannot resolve the dispute through negotiation, they may agree to a mutually acceptable method of non -binding alternative dispute resolution with a qualified third party acceptable to the parties. Each party shall pay an equal share of any costs for the services provided by such a third party as such costs are incurred. The existence of a dispute shall not excuse the parties from performance pursuant to this Agreement. ARTICLE V - MAINTENANCE OF RECORDS AND AUDIT To the extent permitted under applicable Federal laws and regulations, the Government shall allow the Non -Federal Sponsor to inspect books, records, documents, or other evidence pertaining to costs and expenses maintained by the Government, or at the request of the Non -Federal Sponsor, provide to the Non -Federal Sponsor or independent auditors any such information necessary to enable an audit of the Non - Federal Sponsor's activities under this Agreement. The costs of non -Federal audits shall be paid solely by the Non -Federal Sponsor without reimbursement or credit by the Government. ARTICLE VI - RELATIONSHIP OF PARTIES In the exercise of their respective rights and obligations under this Agreement, the Government and the Non -Federal Sponsor each act in an independent capacity, and neither is to be considered the officer, agent, or employee of the other. Neither party shall provide, without the consent of the other party, any contractor with a release that waives or purports to waive any rights a party may have to seek relief or redress against that contractor. ARTICLE VII - NOTICES A. Any notice, request, demand, or other communication required or permitted to be given under this Agreement shall be deemed to have been duly given if in writing and delivered personally or mailed by certified mail, with return receipt, as follows: If to the Non -Federal Sponsor: Chair St. Lucie County Erosion District. 2300 Virginia Ave., Fort Pierce, FL 34982 If to the Government: M Page 47 of 148 District Commander U.S. Army Corps of Engineers, Jacksonville District P.O. Box 4970 Jacksonville, Florida 32232-0019 B. A party may change the recipient or address for such communications by giving written notice to the other party in the manner provided in this Article. ARTICLE VIII - CONFIDENTIALITY To the extent permitted by the laws governing each party, the parties agree to maintain the confidentiality of exchanged information when requested to do so by the providing party. ARTICLE IX - THIRD PARTY RIGHTS, BENEFITS, OR LIABILITIES Nothing in this Agreement is intended, nor may be construed, to create any rights, confer any benefits, or relieve any liability, of any kind whatsoever in any third person not a party to this Agreement. IN WITNESS WHEREOF, the parties hereto have executed this Agreement, which shall become effective upon the date it is signed by the District Commander. DEPARTMENT OF THE ARMY I:• James L. Booth Colonel, U.S. Army District Commander DATE: 5 ST. LUCIE EROSION DISTRICT :• Frannie Hutchinson Chair DATE: Page 48 of 148 CERTIFICATE OF AUTHORITY I, Daniel S. McIntyre, do hereby certify that I am the principal legal officer of the St. Lucie Erosion District, that the St. Lucie Erosion District is a legally constituted public body with full authority and legal capability to perform the terms of the Agreement between the Department of the Army and the St. Lucie Erosion District, and that the person who executed the Agreement on behalf of the St. Lucie Erosion District acted within their statutory authority. IN WITNESS WHEREOF, I have made and executed this certification this day of 20_ Daniel S. McIntyre County Attorney St. Lucie County 2 Page 49 of 148 CERTIFICATION REGARDING LOBBYING The undersigned certifies, to the best of his or her knowledge and belief that: (1) No Federal appropriated funds have been paid or will be paid, by or on behalf of the undersigned, to any person for influencing or attempting to influence an officer or employee of any agency, a Member of Congress, an officer or employee of Congress, or an employee of a Member of Congress in connection with the awarding of any Federal contract, the making of any Federal grant, the making of any Federal loan, the entering into of any cooperative agreement, and the extension, continuation, renewal, amendment, or modification of any Federal contract, grant, loan, or cooperative agreement. (2) If any funds other than Federal appropriated funds have been paid or will be paid to any person for influencing or attempting to influence an officer or employee of any agency, a Member of Congress, an officer or employee of Congress, or an employee of a Member of Congress in connection with this Federal contract, grant, loan, or cooperative agreement, the undersigned shall complete and submit Standard Form-LLL, "Disclosure Form to Report Lobbying," in accordance with its instructions. (3) The undersigned shall require that the language of this certification be included in the award documents for all sub -awards at all tiers (including subcontracts, sub -grants, and contracts under grants, loans, and cooperative agreements) and that all sub -recipients shall certify and disclose accordingly. This certification is a material representation of fact upon which reliance was placed when this transaction was made or entered into. Submission of this certification is a prerequisite for making or entering into this transaction imposed by 31 U.S.C. 1352. Any person who fails to file the required certification shall be subject to a civil penalty of not less than $10,000 and not more than $100,000 for each such failure. Frannie Hutchinson Chair St. Lucie County Erosion District DATE: 3 Page 50 of 148 9/30/2022 FEASIBILITY LEVEL ANALYSIS FOR ST., LUCIE COUNTY., FLORIDA, FORT PIERCE SHORE PROTECTION PROJECT PROJECT MANAGEMENT PLAN Project No. 496400 a U.S. ARMY CORPS OF ENGINEERS JACKSONVILLE DISTRICT Page 51 of 148 FEASIBILITY LEVEL ANALYSIS FOR ST. LUCIE COUNTY, FLORIDA FORT PIERCE SHORE PROTECTION PROJECT USACE JACKSONVILLE DISTRICT PMP 496400 . aNe of Contents 1. Executive Summary..............................................................................................................................1 2. Project Information...............................................................................................................................2 3. Project Scope........................................................................................................................................ 3 4. Project Team Members........................................................................................................................4 S. Work Breakdown Structure..................................................................................................................5 6. Resource Management Plan.................................................................................................................5 7. Project Cost Estimate Budget............................................................................................................... 5 8. Project Schedule................................................................................................................................... 5 9. Quality Management Plan....................................................................................................................7 10. Risk Management Plan.........................................................................................................................8 11. Change Management Plan....................................................................................................................9 12. Communications Plan...........................................................................................................................9 13. Data Management Plan......................................................................................................................11 14. Project Closeout Plan..........................................................................................................................12 15. Project Acceptance.............................................................................................................................12 AttachmentA: Project Map........................................................................................................................13 Attachment B: Risk Management Plan.......................................................................................................15 Attachment C: Change Log/Register...........................................................................................................17 Page 52 of 148 FEASIBILITY LEVEL ANALYSIS FOR ST. LUCIE COUNTY, FLORIDA FORT PIERCE SHORE PROTECTION PROJECT USACE JACKSONVILLE DISTRICT PMP 496400 9/30/2022 1.„ IE.'xecu.u-dve Summary Project Name: Feasibility Level Analysis for St. Lucie County, Florida, Fort Pierce Shore Protection. Project Purpose and Intent: Completion of a Section 403 Letter Report, with supporting Environmental Assessment, to resolve the remaining Office of the Assistant Secretary of the Army for Civil Works (OASACW) comments of the St. Lucie County, Florida, Fort Pierce Shore Protection Project (SPP) Section 203 Integrated Feasibility Study and Environmental Assessment. The Letter Report would be used to support full authorization of a new modified Ft. Pierce, FL SPP with an improved project design to improve project performance and cost savings over a 50-year authorization period. The currently authorized Ft. Pierce, FL SPP includes beach nourishment at a two-year frequency interval to mitigate the erosion effects from the Federally maintained Ft. Pierce Inlet. Federal participation in the current Ft. Pierce SPP is scheduled to end in December 2026. Management Approach: The Project Manager, Christopher Ren, has the overall authority and responsibility for managing and executing this project in accordance with this Project Management Plan and associated subsidiary management plans. The Project Delivery Team will include personnel from USACE Jacksonville District, the St. Lucie County Erosion District, and their Consultant, Taylor Engineering. Funding Source: Civil Works funded and cost shared 50/50 with St. Lucie County Erosion District. Actual Start Date: 10/3/2022 Scheduled Completion Date: 11/21/2024 PMP Version and Date: Version 1; 9/30/2022 Approvals: Christopher Ren ® Project Manager � 9/29/2022 Page 53 of 148 FEASIBILITY LEVEL ANALYSIS FOR ST. LUCIE COUNTY, FLORIDA FORT PIERCE SHORE PROTECTION PROJECT USACE JACKSONVILLE DISTRICT PMP 496400 2. Project Mforrnatbn Project Authorities. The Fort Pierce SPP was originally authorized by the River and Harbor Act of 1965 (PL 89-298, 79 Stat. 1089, 1092) in accordance with the recommendations of the Chief of Engineers in House Document (HD) 84, 89th Congress. The authorization provided for the restoration of 1.3 miles of shoreline south of Fort Pierce Inlet and for periodic nourishment as needed for a period of 10 years following initial construction of the project. The U.S. Army Corps of Engineers (USACE) completed the initial project construction in 1971 and conducted the first nourishment in 1980. St. Lucie County, FL, the non -Federal Sponsor, performed a feasibility study in 2018 under the policy guidance for implementation of Section 203 of the Water Resources Development Act (WRA) of 1986, as amended by Section 1014(a) of the Water Resources Reform and Development Act (WRRDA) of 2014 (33 U.S.C. § 2231). Section 403 of WRDA 2020 provided conditional construction authorization of the non-federal interest's recommended plan subject to resolution of all outstanding concerns and conditions delineated in the OASACW's Review Assessment. Background. The currently authorized Fort Pierce SPP includes beach nourishment at a two-year frequency in Fort Pierce, St. Lucie County, FL to mitigate the erosion effects from the Federally -maintained Fort Pierce Inlet and provide coastal risk damage reduction. The current project experiences highly non -uniform erosion, largely due to inlet effects, with the greatest amount of erosion occurring at the north end of the project area and the erosion rate decreasing towards the south end. Consequently, the authorized design template breaches relatively quickly in the north segment, triggering the need for frequent nourishment. Correcting the imbalance in project evolution can lead to longer nourishment intervals which, in turn, would benefit the socio-economic and environmental elements of the project, more effectively mitigating the inlet -induced beach erosion. St. Lucie County conducted a feasibility study to address hurricane and coastal storm damages in the area of Ft. Pierce. OASACW conducted a concurrent Review Assessment of the submitted study with the purpose of determining federal interest and that the study demonstrates engineering, economic and environmental feasibility that all reports seeking construction authorization must demonstrate. Based on the results of the OASACW review process, the Secretary has made the determination that the project is feasible. The plan was authorized for federal participation by Section 403 of WRDA 2020, however it is expected that all unresolved concerns contained within the Review Assessment would be addressed prior to project implementation. Unresolved concerns with the recommended plan are Page 54 of 148 FEASIBILITY LEVEL ANALYSIS FOR ST. LUCIE COUNTY, FLORIDA FORT PIERCE SHORE PROTECTION PROJECT USACE JACKSONVILLE DISTRICT PMP 496400 related to incremental analysis, nourishment intervals, screening of nonstructural measures, Executive Order 11988 compliance, environmental consequences, design sustainability, and cost estimates. Conditions for construction of the project also includes completion of NEPA and environmental compliance activities. Selected Plan Description. The selected plan provides storm damage reduction benefits to 2.4 miles of shoreline of St. Lucie County, FL, from FDEP reference monument R-34 to R-46.6, immediately south of the federal Fort Pierce Inlet. The plan includes beach and dune nourishment along 7,000 ft of shoreline from the inlet's south jetty (R-34) to R-41. The design includes construction of a 120 ft-wide equilibrated berm from R- 34 to R-36, a 130 ft- wide equilibrated berm from R-36 to R-41, and a dune feature with a 20-ft wide dune crest at an elevation of 12.4 ft relative to the 1988 North American Vertical Datum (NAVD88). The project berm will have an elevation of 7.4 ft NAVD and a 1V:10H foreshore slope. The feeder beach design distributes sand downdrift to provide storm damage reduction benefits for the R-41 to R-46.6 segment. A hopper dredge will be used to fill the template with sand from Capron Shoal, an offshore source located approximately 4 miles from the project site. The plan also includes construction of shoreline stabilization structures at the project's north end to address severe non -uniform erosion rates. The plan includes construction of five T- head groins within approximately 1,570 ft from the south jetty, a T-head weir approximately 1,800 ft from the south jetty, and a detached breakwater approximately 2,070 ft from the south jetty. Project maps are provided as Attachment A. 3. Project ,Scope Project Goals and Objectives. The goal of the Project is to resolve unresolved concerns contained within the OASACW Review Assessment of the St. Lucie County, Florida, Fort Pierce Shore Protection Project Section 203 Integrated Feasibility Study and Environmental Assessment, dated June 2018, results in a Ft. Pierce CSRM Section 403 Letter Report by the Director of Civil Works. Specified Tasks and Deliverables. Many of the unresolved concerns call for additional details and information already contained within the existing Section 203 Study report. Prior analysis and existing data will be used as the primary means to address the unresolved comments. A more detailed summary of the scope by OASA(CW) comment is attached below. The PDT plans to conduct the following tasks and deliverables in order to resolve the remaining unresolved OASA(CW) concerns: • Execution of Cost Share Agreement with non -Federal Sponsor • Sea Level Change (SLC) Analysis Update • Future Without Project (FWOP) Assumptions Update • Verify Alternatives Analysis • Alternatives Cost Update • Recommended National Economic Development (NED) Plan Validation 3 Page 55 of 148 FEASIBILITY LEVEL ANALYSIS FOR ST. LUCIE COUNTY, FLORIDA FORT PIERCE SHORE PROTECTION PROJECT USACE JACKSONVILLE DISTRICT PMP 496400 0 Recommended Plan Cost Update 0 Recommended Plan Economics Update 0 Environmental Analysis and Environmental Assessment (EA) * Sec 403 Letter Report and Directors Report 111, Ft Pierce 203 LetterRpt&EAScope Project Organizational Roles and Responsibilities. Milestones. Project milestones are identified in the P2 schedule, available in the ePMP. 4... 1' roject Team Members US ARMY CORPS OF ENGINEERS, JACKSONVILLE DISTRICT Christopher Ren (Project CESAJ-PM-WC ..0 h i 1 904-570-4519 Manager) Martin Durkin (Planning CESAJ-EN-WC Martin F...Qu..r.ki.n 3 us c ....a L m y mil .......... 904-232-2190 Tech Lead) Patrick Snyder CESAJ-EN-DW Patrick....J Siny gr.@ 1 904-232-1578 (Engineering Tech Lead) Jocelyn Croci (Office of CESAJ-OC Jj2.c.pi n....P C c y , ro i.@ ..m i 1 . ............................. .. any: ............ 904-232-3739 Counsel) Christopher Bukolt (Real CESAJ-RE-A ..0 h ri.s.tqp h.g.r D B!1.k.211 1 904-232-3401 Estate) Gabriel Todaro (Coastal CESAJ-EN-WC G a b 904-232-3284 Engineer) Michael Andrews (Cost CESAJ-EN-TC Micha I...A d e sC i 1 904-232-2798 Engineering) Erik Adamiec CESAJ-PD-D E.r.i.k...I....A.d.a mig.c..@ ui��g.cp a rmy. rr 11 ... .. . ... . . .. . .... ... ..... . ... ... ... .. .. 904-232-3757 (Economist) Graceann Sparkman CESAJ-PD-EC Q r-a-c-e-a rhn R.....Sn.a rkm.2.0 .... . ... .. ... ... . ... .... ... ... . ...... 904-232-3738 (Biologist) Jon Simon Suarez (Env— CESAJ-PD-E JonSim n...0 S ar zC .............................. 2 ...... ....... 904-232-3634 Cultural Resources) Mike Hollingsworth (Env CESAJ-PD-EQ M.I.c.b..a.g.l.....J H.211.ijag. !2[1h.0 rn i 1 904-232-1687 — Permits) Katie Carter (Budget CESAJ-PM-PA Katie.Carterd�..0 a .ar y...Mil ..................................................... L 904-232-1038 Analyst) Maria Eggers CESAJ-PM-P .......a................. .... ..Mria....g E g2.Es.@ 904-232-2119 (Scheduler) OWNER(S) / PARTNER(S) M Page 56 of 148 FEASIBILITY LEVEL ANALYSIS FOR ST. LUCIE COUNTY, FLORIDA FORT PIERCE SHORE PROTECTION PROJECT USACE JACKSONVILLE DISTRICT PMP 496400 Joshua Revord (Sponsor Primary POC) St. Lucie County Erosion District ,jky2r __fir_ ?sll_aa %ca.: Eg 772-462-1269 Kenneth Craig (Sponsor Consultant) Taylor Engineering ,leri. tayIaErgineering crrn 904-731-7040 Christopher Bender (Sponsor Consultant) Taylor Engineering l end.p L.L 12ylc r !2gine r%n.g._ om, 904-731-7040 OTHER GOVERNMENT AGENCIES Senator Rick Scott (FL-R) Senator Marco Rubio (FL-R) Bill Posey (FL-8) NON -GOVERNMENT STAKEHOLDERS CONTRACTED SERVICES AND RESOURCE PROVIDER REPRESENTATIVES S„ Work Breakdown Structure The Work Breakdown Structure (WBS) is provided in the ePMP for this project. 6„ Resource Il aireageproent If''llan Activities/Tasks List The required activities/task list has been entered into P2 and can be accessed in the ePMP. Internal Labor Requirements. Estimated internal (USACE) labor hours have been entered into P2 for each associated activity/task, by discipline and grade. The current, approved labor rates provided in the P2 system are available in the ePMP. External / Contract Services Requirements. No external contracted services are expected or planned for. 7. Project Cost E.stulmate Budget Baseline. The total cost of the analysis identified in the scope of work is projected to be $700,074, cost shared 50/50 with the non -Federal Sponsor. The resources required for all project activity/tasks will be entered into the schedule in P2 and may be reviewed in ePMP once Federal and non -Federal Sponsor funds have been received. „ If' 'urea Schedule The latest project schedule is available in the ePMP for this project and summarized below. Task # Letter Report & EA Tasks Predecessor Start Finish Duration Tasks 5 Page 57 of 148 FEASIBILITY LEVEL ANALYSIS FOR ST. LUCIE COUNTY, FLORIDA FORT PIERCE SHORE PROTECTION PROJECT USACE JACKSONVILLE DISTRICT PMP 496400 i Cost Share Agreement 10/1/2022 5/25/2023 236 1 Analysis to Resolve OASACW Comments & Start Draft Letter Report & Appendices. i 6/1/2023 6/2/2023 1 1a SLC Analysis Updates 1 6/1/2023 7/31/2023 60 1b FWOP Assumption Updates 1 6/1/2023 7/31/2023 60 1c Verify/Establish Alternatives to be Modelled 1a, 1b 7/31/2023 9/29/2023 60 1d Alternative Cost Updates 1c 9/29/2023 10/13/2023 14 1e Recommended/NED Plan Validation 1d 10/13/202 3 11/12/2023 30 1f Recommended Plan Cost Update 1e 11/12/202 3 11/26/2023 14 1g Recommended Plan Economic Update 1f 11/26/202 3 12/3/2023 7 2 Engineering DQCR & PQCR 1 11/26/202 3 1/10/2024 45 3 Complete Draft Letter Report & Appendices 2 1/10/2024 1/25/2024 15 4 Letter Report DQC 3 1/25/2024 2/24/2024 30 5 Letter Report ATR & Cost Certification 4 2/24/2024 4/9/2024 45 6 Letter Report Legal Review & Certification 5 2/24/2024 3/25/2024 30 7 Letter Report Washington Level Policy Review 6,17 8/25/2024 10/24/2024 60 8 Director's Report Signed 7 10/24/202 4 11/7/2024 14 9 Environmental Analysis and Draft EA Complete 3 9/29/2023 1/25/2024 60 10 Draft EA DQC 9 1/25/2024 2/24/2024 30 11 Draft EA Legal Review 10 2/24/2024 3/25/2024 30 12 Tech Edit of EA prior to Public Review 11 3/25/2024 4/8/2024 14 13 Draft EA Public & Agency (30 day public & agency 60CZMA) Review Period 12 4/8/2024 6/7/2024 60 14 Public & Agency Comment Responses & Revisions 13 6/7/2024 7/7/2024 30 15 Final EA DQC 14 7/7/2024 7/28/2024 21 16 Final EA Legal Review 15 7/28/2024 8/11/2024 14 17 Final EA Tech Edit 16 8/11/2024 8/25/2024 14 18 Final EA submitted to HQ for Directors Report Approval 17 8/25/2024 8/26/2024 1 19 FONSI Routing and Signature (District Engineer Approval) 8 11/7/2024 11/14/2024 7 Page 58 of 148 FEASIBILITY LEVEL ANALYSIS FOR ST. LUCIE COUNTY, FLORIDA FORT PIERCE SHORE PROTECTION PROJECT USACE JACKSONVILLE DISTRICT PMP 496400 20 Letter Report, Directors Report, EA & FONSI to 8,19 11/14/202 11/21/2024 7 ASA 4 . Qu ahty Management Han a. Objective of Quality Control Plan. The objective of the Quality Control Plan (QCP) is twofold: (1) describe the process that will be followed to ensure that all documents generated in support of the project meet the requirements of the Non - Federal sponsor; (2) consistent with appropriate laws and USACE regulations, policies, and technical requirements. The quality control process is defined as a "system of technical activities that measure the attributes and performance of a process, item, or service against defined standards to verify that they meet the stated requirements established in the PMP". The planning, environmental, and technical quality are the responsibility of the planning and engineering teams assigned to the project. The process for achieving technical quality is detailed in ER 1110-2-1150 as follows: Technical quality may be achieved through the development and implementation of realistic comprehensive work plans, definition of functional and technical criteria, adequate coordination among the project team and technical discipline, and continuous coordination with the Project Manager and Non -Federal Sponsor. b. Requirements All implementation documents (including supporting data, analyses, environmental compliance documents, etc.) shall undergo District Quality Control (DQC), Agency Technical Review (ATR), and Policy & Legal Compliance Review (P&LCR). DQC is an internal review process of basic science and engineering work products focused on fulfilling the project quality requirements defined in the PMP. ATR is a review undertaken to ensure the quality and credibility of the government's scientific information and is mandatory for all decision and implementation documents. ATR and DQC reviews are not intended to bring up other alternatives or other measures for consideration. ATR and DQC reviews focus only on the package presented to ensure that it is compliant with USACE standards and requirements for the type of work and that there are no red flags that could cause project failure. c. Agency Technical Review 1. Agency Technical Review Scope. ATR is undertaken to "ensure the quality and credibility of the government's scientific information" in accordance with EC 1165-2-217 and ER 1110-1-12. An ATR will be performed on the Letter Report final submittals. A site visit will not be scheduled for the ATR Team. If necessary, additional data and photos of the project site required by the ATR team will be gathered by PDT members during plan -in -hand site visits. This information will be disseminated to the ATR Team by the PDT. ATR will be conducted by individuals and organizations that are external to the SAJ. The ATR Team Leader will be a USACE employee outside SAD. The required disciplines and experience Page 59 of 148 FEASIBILITY LEVEL ANALYSIS FOR ST. LUCIE COUNTY, FLORIDA FORT PIERCE SHORE PROTECTION PROJECT USACE JACKSONVILLE DISTRICT PMP 496400 are described below. ATR comments will be documented in the DrChecks model review documentation database. DrChecks is a module in the ProjNet suite of tools developed and operated at ERDC-CERL (www.projnet.org). At the conclusion of ATR, the ATR Team Leader will prepare an ATR Review Report that summarizes the review. An outline for an ATR Review Report is in Attachment D. The report will include, at a minimum, the Charge to Reviewers, ATR Certification Form from EC 1165-2-217, and the DrChecks printout of the comments. 2. ATR Disciplines. As stipulated in ER 1110-1-12, ATR members will be sought from the following sources: regional technical specialists (RTS); subject matter experts (SME) certified in CERCAP; senior level experts from other districts; Center of Expertise staff; experts from other USACE commands; contractors; academic or other technical experts; or a combination of the above. The ATR Team will be comprised of the following disciplines: knowledge, skills, and abilities; and experience levels. ATR Team Leader. The ATR Team Leader shall be a professional outside SAD with experience with Navigation Projects and have performed ATR Team Leader duties. ATR Team Leader can also serve as a co -duty to one of the review disciplines. Coastal Civil Engineer/Climate Change Reviewer. The team member shall be a registered professional engineer with 5 years of experience in tidally influenced and river work projects. Experience should include sediment placement operations, excavation and barge requirements, revetments, placement of material in marine environments, and navigation project features. Geotechnical Engineering. The team member shall be a registered professional engineer and should have a minimum of 10 years of experience. Experience shall encompass geologic and geotechnical analyses that are used to support the development of P&S for coastal projects. d. Project Delivery Team Disciplines - Plan Formulation - Economics - Cost Engineering - Environmental - Coastal Engineering - Coastal Engineering, Hydrologic - Engineering/Climate Change 10. IfsiisIk Management I' Haire Risk Register is provided as Attachment C. 0 Page 60 of 148 FEASIBILITY LEVEL ANALYSIS FOR ST. LUCIE COUNTY, FLORIDA FORT PIERCE SHORE PROTECTION PROJECT USACE JACKSONVILLE DISTRICT PMP 496400 11. Change Management I' llan This document will serve as the baseline for identification of changes in project scope, schedule, and cost. Progress will be monitored using the reporting forms with the goal of identifying changes as soon as possible and forecasting new schedules and/or costs. If changes are identified, the documentation and approval process prescribed by ER 5-7-1 and the latest approved guidance of the SAJ Programs and Project Management Change Control Process that was issued in May 2017 will be utilized. A Project Schedule and Cost Change Request Form will be the instrument for documenting and obtaining approval for changes. The project schedule and cost consist of four components: baseline, current approved, forecast, and actual. These components are defined as follows: • Baseline: The Baseline Schedule and Cost Estimate are defined by the approved initial PMP. The baseline remains constant until an updated PMP is approved and is compared with projected and actual schedules and costs. • Current Approved: The Current Approved Schedule and Cost Estimate reflect changes in project scope, schedule, or cost estimates that have been approved at the appropriate levels. The approval authorities required for a specific change are defined in the CCR and are related to the magnitude of the change. Approvals for some minor changes are within the Project Managers' authority while other more substantive changes might require the approval of the SAJ District Program Manager, or higher -level authority. • Forecast: When the Project Manager initially identify changes that impact the current approved schedule and cost estimate, such changes should be reflected in the forecast schedule and cost estimate until they are approved in accordance with CCR procedures. • Actual: The costs and dates of completed milestones will be documented in the Actual Cost and Schedules, respectively. The PM and PDT are responsible for identifying and justifying the need for changes to the scope, schedule, costs, for initiating requests for approval of such changes, and tracking them in the Change Log/Register (Attachment D). Any office requesting a change will identify to the PM the anticipated schedule and cost impacts of the requested change. The PM is responsible for proper evaluation, coordination, approval, and managing of project schedule and cost change requests, and accountable for documenting impacts resulting from the change. 12. Cammu.,unacadons Han The purpose of the Communication Management Plan (CMP) is to ensure proper coordination of information intended for release internally and externally to the USACE. The Jacksonville District uses several internal communication methods to disseminate information and guidance, which provide either direct or indirect communication as described below. 0 Page 61 of 148 FEASIBILITY LEVEL ANALYSIS FOR ST. LUCIE COUNTY, FLORIDA FORT PIERCE SHORE PROTECTION PROJECT USACE JACKSONVILLE DISTRICT PMP 496400 Internal communications are most effective when indirect communications are followed up by direct communications. Direct communications provide the means to ensure that the information is understood by responding to questions and inviting ideas. Project member meetings ensure direct communication within the PDT for those that participate in these regular meetings. Other topic(s)-focused project meetings provide opportunities to share project information to participants. The monthly Program Updates and Project Review Board (PRB) meetings provides the District Commander, technical leaders, and project managers with an opportunity to discuss project issues and develop resolutions to project problems. Indirect communications use websites and emails to disseminate project information, guidance, and direction. Process execution process documents are readily accessible to all District personnel through the District Knowledge Management Environment (KME) SharePoint website and share drives. The QMS documents describe the procedures for each process. PDT Communication Requirements Each PDT member needs to have situational awareness of current events, requirements, activities, opportunities, policies, guidance, and new initiatives that may impact the project positively or negatively. The urgency and importance of the communication determines the best methods for communicating. This PMP is to be used by PDT members as a guide to deliver their products or services required for the project. Project status reports and the Project Review Board (PRB) provide the means for the District's upper management to be kept informed of project issues, so that their decisions are based on current information and are communicated to all those involved with the project. However, each PDT member is responsible for maintaining his/her management chain informed on project status and progress, particularly of the products and services the respective office is responsible. Communications required by this plan include schedules, briefings, and project controls as defined below. • Project Schedule — Detailed schedule outlining tasks in a work breakdown structure (WBS). The schedule includes updated start and end dates, baseline dates, predecessors, and successors for each task. The Project Manager manages the project plan in coordination with the Project Scheduler. This detailed schedule will be developed once the project is funded. • Project Review Board (PRB): Serves as the corporate governing body of this command in the area of project execution through review of implementation challenges that focuses on providing guidance to the PDT. • Project Delivery Team (PDT) meetings: Provides the project PDT a forum to provide updates, issues, or solutions to ensure the project stays on schedule. • Project controls track and document project progress, issues for resolution, open action items and changes to the project plan. The Project Manager will closely monitor the following documents and logs in order to manage the schedule, resources, and issues which impact successful project completion. 10 Page 62 of 148 FEASIBILITY LEVEL ANALYSIS FOR ST. LUCIE COUNTY, FLORIDA FORT PIERCE SHORE PROTECTION PROJECT USACE JACKSONVILLE DISTRICT PMP 496400 • Meeting Agendas: Will be used to communicate the meeting's purpose, topics, and deliverables during project team, group, or town hall meetings. Agendas allow participants the time to properly prepare for meetings enabling successful and timely meetings. • Meeting Summaries: Will be provided within 7 days of meetings and will capture the main discussion occurring during the meeting and any action items required after the meeting. • Monthly Activity Report Status (MARS): Documents schedule status on a monthly basis. Reports associated with the MARS include a 90-day look ahead and a milestone comparison to the current approved baseline schedule. Also included in the MARS are updated notebook topics, that summarize completed activities, current project status, and potential issues that would have an impact on the schedule. The PM will coordinate with the Project Scheduler to develop the MARS. • Monthly Expenditures Reports: Provide status of expenditures as compared to the baseline and overall costs. This document will not be shared outside of USACE. • Action Item Matrix: Provides a centralized point from which to manage project action items. The PM is responsible for updating and managing the action items matrix. 13. Data Management Nan Data Management (DM) is a process and standard for the collection and life cycle maintenance of data used by the PDT members, Owner(s), Partner(s), and Stakeholders. Data Management is also a key component to Value and Quality Management. As a minimum, the Data Management section of the PMP should include: Project Classification. This project is Unclassified. Data Description. This document provides management guidelines and instructions for the review of the Ft. Pierce, St. Lucie County, FL— WRDA 2020 (496400). Data File Structure. This PMP has been prepared using MS Word and contains some embedded Excel tables, documents, and graphics. When converted to pdf, the embedded tables and documents cannot be opened using a pdf file reader. It is therefore important that the original Word document be maintained and accessible to the PDT. Data File Storage Locations. A Word version and pdf version of this PMP should be maintained as an attachment to the ePMP. Record Retention, Archive, and Destruction Dates. This document must be retained for at least 7 years after the fiscal closeout of this project. Data Release Requirements and Instructions. The USACE Program Manager is authorized to release information, with concurrence from the project sponsor, that does not involve procurement -sensitive information. The release of procurement -sensitive information must be approved by the responsible USACE Contracting Officer. 11 Page 63 of 148 FEASIBILITY LEVEL ANALYSIS FOR ST. LUCIE COUNTY, FLORIDA FORT PIERCE SHORE PROTECTION PROJECT USACE JACKSONVILLE DISTRICT PMP 496400 Project close-out is an essential step to ensure that the team documents Lessons Learned and transfers relevant information, records, and property to the appropriate authorities. The Project Manager (PM) is responsible for ensuring that all project closeout actions are completed, while maintaining close coordination with the Owner. The Project Delivery Team (PDT) is responsible for supporting the PM by completing assigned project closeout tasks, which includes: • Review acceptance criteria. • Performance of acceptance reviews or inspection of work product / deliverable. • Closeout of project financial cost accounts. • Ensure that necessary close out documentation has been completed, approved, and delivered to the appropriate entity or archive system. • Submittal to appropriate District and Branch representatives for approval. • Provide required closeout documentation to both internal and external Owners. PMP approvals and acceptance by the Owner(s), Partner(s), primary Stakeholder(s), and the PDT must be secured in accordance with HQUSACE, SAD, and SAJ policies and regulations. Draft PMPs should be submitted to the responsible Branch Chief for final approval. PM, Owner, Partner, Stakeholder, and PDT member signatures using the following PIMP Acce�atance Sheet (or equivalent) may be electronic. PMP Acceptance Sheet.docx 12 Page 64 of 148 PMP ACCEPTANCE SHEET We have reviewed this document and certify that it contains accurate content and is sufficient to guide project execution for the Feasibility Level Analysis for St. Lucie County, Florida Fort Pierce Shore Protection Project DURKIN.MARTIN.T.1368128194Digitlly signed by DURKI Datea2022..10.0411::24:50N0400TIN.T.1368128194 Martin Durkin Planning Team Leader Date SNYDER.PATRICK.JOSEPH.1597031420Digitally signed by Date: 202 2.10.0413:05:08 0 OORICK.JOSEPH.1597031420 Patrick Snyder Date Engineering Technical Lead SPARKMAN.GRACEANN.R.1591707945 Digitally signed by SPARKMAN.GRACEANN.R.1591707945 Date: 2022.10.04 14:08:52-04'00' Graceann Sparkman Date Environmental Lead Joshua Revord Digitally signed by Joshua Revord Date:2022.10.05 12:58:31-04'00' Joshua Revord Date Senior Coastal Engineer, St. Lucie County Christopher Ren, PMP Date Project Manager Milan A. Mora, P.E. Date Chief, Water Resources Branch Page 65 of 148 FEASIBILITY LEVEL ANALYSIS FOR ST. LUCIE COUNTY, FLORIDA FORT PIERCE SHORE PROTECTION PROJECT USACE JACKSONVILLE DISTRICT PMP 496400 Attachment A- [roject I 7 7 St, Lucie County, FL FORT PIERCE SHORE PROTECTION PROJECT Figure 1.1 Fort Pierce Shore Protection Project Location Map 13 Page 66 of 148 FEASIBILITY LEVEL ANALYSIS FOR ST. LUCIE COUNTY, FLORIDA FORT PIERCE SHORE PROTECTION PROJECT USACE JACKSONVILLE DISTRICT PMP 496400 Figure 1.2 Location of T-Head Groins, Weir T-Head, and Breakwater in the Sec 203 Recommended Plan 14 Page 67 of 148 FEASIBILITY LEVEL ANALYSIS FOR ST. LUCIE COUNTY, FLORIDA FORT PIERCE SHORE PROTECTION PROJECT USACE JACKSONVILLE DISTRICT PMP 496400 Attachment Bo IRd< IManagement INain The Risk Management Plan, as a minimum, must assess and address risks associated with the following project elements; scope, quality, schedule, safety and health risk, cost, security, technical obsolescence, asset protection considerations, risk of creating a monopoly for future procurements, capability of agency to manage the investment, overall risk of investment failure, and affordability (capability of Owners)/Partner(s) to continue funding in the future). The level of detail of the Risk Management Plan should be commensurate with the project's complexity. When a project is determined to be other than low risk, the risk must be identified, and associated control procedures defined in the PMP Risk Register. Only the District or Division Commander may provide final PMP approval in the event of an overall project risk rating of high or extremely high. Risk Analysis. Briefly describe how project risks will be identified, analyzed, and prioritized project risks. Risk Monitoring. Discuss methods to be used for tracking risks. Risk Mitigation. Describe Risk Mitigation tools, techniques, and contingency plans. PROBABILITY OF RISK MITIGATION/RESPONSE IDENTIFIED RISK OCCURRENCE Updated cost and economics as a result ,STRATEGIES New plan reformulation including of addressing unresolved comments Unlikely additional analysis, modeling, show a BCR of <1:1 alternatives, etc. Thoroughly discuss and present New or additional Beach-fx runs are results from existing Beach-fx needed to address unresolved Unlikely models. Conduct additional Beach-fx comment modeling only if existing model results are not acceptable NEPA requirements result in elevated Close coordination with State and Unlikely impacts from EA/FONSI to EIS/ROD Agency representatives Coordinate comment resolution in Comment resolution not accepted by Seldom advance through the Vertical Team. OASA(CW) Conduct In Progress Reviews. Coordinate with resource Having enough staff to complete the Seldom providers/supervisors to identify work in the times allocated potential back-up team members. 15 Page 68 of 148 FEASIBILITY LEVEL ANALYSIS FOR ST. LUCIE COUNTY, FLORIDA FORT PIERCE SHORE PROTECTION PROJECT USACE JACKSONVILLE DISTRICT PMP 496400 Coordinate with HR on pending hiring actions. Coordinate with other Districts to identify potential back- up team members. Track team progress planned vs. actual, for key deliverables. Change Not meeting specified deadlines Seldom or provide additional labor, training, or other resources to expedite critical activities. .... .... .... .... .... .... Require work to be saved on server, Unscheduled USACE server shut down Unlikely and backed -up on PC/Laptops. USACE systems not accessible through Require work to be saved on server, Unlikely remote internet providers and backed -up on PC/Laptops. Require compliance with COVID health and Safety protocols. Coordinate with resource providers/supervisors to identify Staff loss due to injury, illness, or other Seldom potential back-up team members. circumstance Coordinate with HR on pending hiring actions. Coordinate with other Districts to identify potential back- up team members. .... .... .... .... .... .... Data safe guarding / protection Unlikely . Require work to be saved on server, and backed -up on PC/Laptops. Risk Register. u PMP Risk Register.xlsx 16 Page 69 of 148 FEASIBILITY LEVEL ANALYSIS FOR ST. LUCIE COUNTY, FLORIDA FORT PIERCE SHORE PROTECTION PROJECT USACE JACKSONVILLE DISTRICT PMP 496400 Attachment Co Change II....og/Re is er Responsibilities. PM Responsibilities. The PM must ensure that changes are captured and recorded in the Project Change Log/Register, and appropriate Owner, Stakeholders, and PDT members are notified as soon as they are identified. The PM then tasks the PDT to develop a risk, cost, schedule, and scope analysis to be provided to the CCB in accordance with the Change Authorization Matrix, if any of the minimum or PM - level thresholds are exceeded. The PM will serve as the interface with the CCB and will work with the PDT to secure any requested additional information. PDT Member Responsibilities. PDT members must immediately (within 24 hours) notify the PM upon the discovery of changes that exceed any of the minimum thresholds. The PDT member discovering the change requirement or condition shall then coordinate with the PM to prepare a complete Change Request Form that contains sufficient detail to support a recommendation or decision by the PM or CCB, in accordance with the Change Authorization Matrix. The Change Request will include, as a minimum: a. Description of the proposed/required change and options b. Estimate the cost to execute the change (labor, funding, equipment, etc.) c. Estimated impact to the schedule / critical path / milestones using what -if versions of the P2 schedule and budget Scope Change. Scope changes occur when unforeseen project events or conditions require additions or deletions to the project. Scope changes often require modification of the WBS, approved schedule, and approved cost/budget. Quantity, quality, size, and material specification changes are all types of scope change. Schedule Change. Significant scheduling changes require fast -tracking, crashing, formal contract modifications, or re-baselining of an approved schedule. Budget Change. Budget changes impact the approved budget or contract values and require either additional funding or the release of project funds and may require a re-baselining of the project cost baseline. Change Register / Log Decision and Change Log Templa 17 Page 70 of 148 - E9 E - a E o E a - a 2 v m'E v a E c - -_- � _ E E ➢ - c'E s ¢Q a a a 00 T 0 0 LL n 3 a 3 a 3 3a 3 0 3 wT 3 v _ E a - v3u ot- — 3 3 a o E = E a E _ x o E - E _ E 00 O N LL 00 T 0 0 LL Ezi u-- w ? a A 3 E - 3- _ 00 T 0 LO 0 ^co LL Frannie Hutchinson Cotinty Comailssioner District No., 4 March 13, 2017 Assistant Secretary of the Army (Civil Works) Attn: Douglas W. Lamont, P.E. U.S. Army Corps of Engineers Room 6591, GAO Building, 441 G. Street, N.W. Washington DC 20314 Re: Fort Pierce, St, Lucie County, Florida Shore Protection Project General Reevaluation Report with Environmental Assessment Dear Mr, Lamont, On behalf of St. Lucie County, we are pleased to submit the enclosed report titled Fort Pierce, St. Lucie County, Florida Shore Protection Project General Reevaluation Report with Environmental Assessment. As the non -Federal sponsor of the currently authorized project, St. Lucie County conducted this General Re -Evaluation Report (GRR) to evaluate management alternatives to improve project performance over a 50-year analysis period and to recommend Federal re -authorization of the project. The current authorization expires in 2020. St. Lucie County performed this GRR under the policy guidance for implementation of Section 203 of the Water Resources Development Act (WRDA) of 1986, as amended by Section 1014(a) of the Water Resources Reform and Development Act (WRRDA) of 2014 (33 U.S.C. § 2231). This guidance provides the authority for non -Federal interests to undertake feasibility studies of proposed water resources development projects for submission to the Secretary of the Army. In accordance with Engineer Regulation No. 1165-2-209, your office should have received our submittal of the 15 hardcopies and 15 CDs of the GRR on March 6, 2017. If you have any questions or require additional information, please contact Mr. Richard Bouchard, St, Lucie County's Sr. Coastal Engineer at (772) 462-1710 or via e-mail at bouchardr@stlucieco.org. Sincerely, Frannie Hutchinson, Chair St. Lucie County Erosion District FH:rb cc: St. Lucie County Erosion District Board Howard Tipton, County Administrator Dan McIntyre, County Attorney Mark Satterlee, Deputy County Administrator Glenn Henderson, Mosquito Control & CMS Director Richard Bouchard, Sr. Coastal Engineer Nick Mimms, Ft. Pierce City Manager Chris Wadovsky,, District No. I --Tod Mowery, Wstrkt No. 2 —Linda Bartz, District No. 3 — Frannie A~ utciririson, Wstrkt No. 4 ._ Cathy Townsend, Mstrict No. 5 County Administrator-- Howard Tipton 300 Virginia Avenue Fort Pierce, FL 34982..5652 (77 ) 46 -14 1 FAX (77 ) 46: - 131 ­ -rDD (' 7) 462-1428 Htafctiinsoif@st&ticieco.org Page 76 of 148 >, .. " .��.... NJainr .,, vir;rq oiP�mi�rnrp7114'mY�%��} Frannie Hutchinson, Chair County Commissioner District No, 4 June 6, 2018 Assistant Secretary of the Army (Civil Works) Attn: Mr. R. D. James U.S. Army Corps of Engineers Room 6591, GAO Building, 441 G. Street, N.W. Washington DC 20314 Subject: Fort Pierce, St. Lucie County, Florida Shore Protection Project Section 203 Feasibility Study with Environmental Assessment Dear Mr. James: On behalf of St. Lucie County, we are pleased to resubmit fifteen (15) hardcopies and five (5) CDs of the enclosed report titled Fort Pierce, St. Lucie County, Florida Shore Protection Project, Section 203 Integrated Feasibility Study with Environmental Assessment. We appreciated the opportunity to work closely with your staff to revise our March 13, 2017 report submittal in an effort to seek Congressional Authorization in this year's WRDA Bill. St. Lucie County performed this study under the policy guidance for implementation of Section 203 of the Water Resources Development Act (WRDA) of 1986, as amended by Section 1014(a) of the Water Resources Reform and Development Act (WRRDA) of 2014 (33 U.S.C. § 2231). This guidance provides the authority for non -Federal interests to undertake feasibility studies of proposed water resources development projects for submission to the Secretary of the Army. If you have any questions or require additional information, please contact Mr. Richard Bouchard, St. Lucie County's Sr. Coastal Engineer at (772) 462-1710 or via e-mail at bouchardr@stlucieco.org. Sincerely, Frannie Hutchinson, Chair St. Lucie County Erosion District St. Lucie County Erosion District Board Howard Tipton, County Administrator Dan McIntyre, County Attorney Mark Satterlee, Deputy County Administrator Jeff Bremer, Deputy County Administrator Glenn Henderson, Mosquito Control & CMS Director Richard Bouchard, Sr. Coastal Engineer Joshua Revord, Coastal Engineer U.S. Senator Marco Rubio U.S. Senator Bill Nelson U.S. Representative Brian Mast Greg Burns, Thorn Run Michael Trudnak, Taylor Engineering Chris Dzadovsicy, District No. I —Anthony k3onna, District No. 2 - Linda Bartz, District No. 3 _. Frannie Hutchinson, District No. 4— Cathy "rownsend, District No. 5 County Administrator _ Howard Tipton 2300 Virginia Avenue Fort Pierce, EL 34 R2-56 a2 (772) 462-1451 FAX (772) 462-2131 —TDD (772) 462-1428 Hutchlnsonfstlucieco,org Page 77 of 148 Review Assessment of St. Lucie County, Florida Fort Pierce Shore Protection Project Section 203 Integrated Feasibility Study and Environmental Assessment (June 2018) July 2018 Page 78 of 148 Executive Summary St. Lucie County Florida, conducted a feasibility study to address hurricane and coastal storm damages in the area of Ft. Pierce. The study was conducted under Section 203 of the Water Resources Development Act (WRDA) of 1986 (P.L. 99-662), as amended. The office of the Assistant Secretary of the Army for Civil Works (OASACW) has conducted a concurrent review of this submittal with the Headquarters, U.S. Army Corps of Engineers (Corps) with the purpose of determining federal interest and that the study demonstrates engineering, economic and environmental feasibility that all reports seeking construction authorization must demonstrate. Based on the results of the review process, the Secretary has made the determination that the project is feasible. In the event that the recommended plan is authorized for federal participation, it is expected that all unresolved concerns contained within this Review Assessment would be addressed prior to project implementation. Unresolved concerns with the recommended plan are related to incremental analysis, nourishment intervals, screening of nonstructural measures, Executive Order 11988 compliance, environmental consequences, design sustainability, and cost estimates. Conditions for construction of the project include completion of NEPA and environmental compliance activities. St. Lucie County, Florida i ASACW Section 203 — Ft. Pierce Shore Protection Project Review Assessment This is a preliminary review assessment. The Administration is still completing its internal review of the Ft. Pierce Feasibility Study. The Army requests that further distribution of the assessment be limited. Page 79 of 148 Table of Contents ExecutiveSummary......................................................................................................... i I. Background.............................................................................................................1 11. St. Lucie County's Section 203 Recommended Plan..............................................1 A. Location...................................................................................................................1 B. Congressional Interest: ........................................................................................... 1 C. Senators: ................................................................................................................. 1 D. Problems: ................................................................................................................ 1 E. Project Objectives: .................................................................................................. 1 F. Recommended Plan: ............................................................................................... 2 G. Price Level: ............................................................................................................. 2 I. Total Project Cost..................................................................................................... 2 J. Benefits: ................................................................................................................... 2 K. Cost Share: ............................................................................................................. 2 III. Section 203 Review Assessment Summary............................................................ 3 A. Feasibility determination (Whether the project is feasible (i.e. technically sound, economically justified and environmentally compliant)? .......................................... 3 B. Recommendations concerning the plan or design of the proposed project ............. 3 C. Identify any conditions required for construction of the project ............................... 3 IV. Review History and Findings................................................................................... 3 A. June 2018 Feasibility Study..................................................................................... 4 B. March 2017 Feasibility Study.................................................................................. 8 St. Lucie County, Florida 1 ASACW Section 203 — Ft. Pierce Shore Protection Project Review Assessment This is a preliminary review assessment. The Administration is still completing its internal review of the Ft. Pierce Feasibility Study. The Army requests that further distribution of the assessment be limited. Page 80 of 148 I. Background St. Lucie County Florida, conducted a feasibility study to address hurricane and coastal storm damages in the area of Ft. Pierce. The study was conducted under Section 203 of the Water Resources Development Act (WRDA) of 1986 (P.L. 99-662), as amended. The office of the Assistant Secretary of the Army for Civil Works (OASACW) conducted a concurrent review of the submittal with the Headquarters, U.S. Army Corps of Engineers (Corps, also referred to as USACE) with the purpose of determining federal interest and that the study demonstrates engineering, economic and environmental feasibility that all reports seeking construction authorization must demonstrate. This Review Assessment provides the results of the Washington -level review. This review has been conducted to determine whether the study and the process under which the study was developed, each comply with Federal laws and regulations; a determination of whether the project is feasible; and identification of any conditions that the Secretary may require for construction of the project. II. St. Lucie County's Section 203 Recommended Plan This section provides a summary of the recommended project, as contained within the Ft. Pierce, Section 203 Integrated Feasibility Study and Environmental Assessment (June 2018). A. Location: The study area encompasses 2.4 miles of shoreline in Fort Pierce, Florida, from the south jetty at Fort Pierce Inlet (FDEP survey monument R-34) to approximately 600 feet south of R-46 (i.e., R-46.6). B. Congressional Interest: Brian Mast (FL-18). C. Senators: Bill Nelson and Marco Rubio (Florida) D. Problems: St. Lucie County conducted this study to investigate alternatives for improving hurricane and coastal storm damages in vicinity of the Ft. Pierce inlet. E. Project Objectives: The purpose of the study is to reduce storm damages associated with hurricane and costal storms. The recommended project seeks to improve the performance of the currently authorized shore protection project (SPP) to decrease the required nourishment frequency and, hence, reduce project costs while maintaining or improving the project benefits. Inherent in this objective is the continuation of the current SPP objectives, which include: • Maximize storm damage reduction to property and infrastructure within the project area over a 50-year planning horizon (2021 — 2070). St. Lucie County, Florida Section 203 - Ft. Pierce Shore Protection Project ASACW Review Assessment This is a preliminary review assessment. The Administration is still completing its internal review of the Ft. Pierce Feasibility Study. The Army requests that further distribution of the assessment be limited. Page 81 of 148 • Maintain environmental quality in the project area and adjacent areas, including sea turtle and nearshore hardbottom habitat and aesthetics, over a 50-year planning horizon (2021 — 2070). • Maintain recreational use of beach and nearshore areas in the project area including beach going, surfing, fishing, and wildlife viewing over a 50-year planning horizon (2021 — 2070). F. Recommended Plan: The Recommended Plan includes beach and dune nourishment along 7,000 ft of shoreline from the Ft. Pierce inlet's south jetty (R-34) to R-41. The design includes construction of a 120 ft-wide equilibrated berm from R- 34 to R-36, a 130 ft-wide equilibrated berm from R-36 to R-41, and a dune feature with a 20-ft wide dune crest at an elevation of 12.4 ft relative to the 1988 North American Vertical Datum (NAVD88). The project berm will have an elevation of 7.4 ft NAVD and a 1V:10H foreshore slope. The feeder beach design distributes sand downdrift to provide storm damage reduction benefits for the R-41 to R-46.6 segment. A hopper dredge will be used to fill the template with sand from Capron Shoal, an offshore source located approximately 4 miles from the project site. The plan also includes construction of shoreline stabilization structures at the project's north end to address severe non -uniform erosion rates. The plan includes construction of five T-head groins (T1 — T5) within approximately 1,570 ft from the south jetty, a T- head weir (W6) approximately 1,800 ft from the south jetty, and a detached breakwater (B7) approximately 2,070 ft from the south jetty. G. Price Level: October 2017 H. Interest Rate: 2.75% I. Total Project Cost: $131,066,611 J. Benefits: Benefits, in the form of reduced damages, land loss, and recreation are estimated at $168,287,623, yielding net benefits of $37,221,012 and a benefit -to -cost - ratio of 1.28 to 1. K. Cost Share: Based on an analysis of shoreline ownership and access it is expected that initial construction will be cost shared approximately 46% Federal and a non - Federal rate of approximately 54%. For periodic nourishment, the Federal participation rate is approximately 35% and non -Federal rate is 65%. St. Lucie County, Florida 2 ASACW Section 203 - Ft. Pierce Shore Protection Project Review Assessment This is a preliminary review assessment. The Administration is still completing its internal review of the Ft. Pierce Feasibility Study. The Army requests that further distribution of the assessment be limited. Page 82 of 148 III. Section 203 Review Assessment Summary In accordance with section 203 of WRDA 1986, as amended, the Secretary is required to provide a report to Congress that describes the following: A. Feasibility determination (Whether the project is feasible (i.e. technically sound, economically justified and environmentally compliant)? The Secretary has determined that the recommended plan is feasible. The study documents that the recommended plan is economically justified, but it does not provide information to defend the scale or estimated cost of the project being recommended. In the event that the recommended plan is authorized for federal participation, it is expected that unresolved issues contained within the Review Assessment would be addressed prior to implementation. B. Recommendations concerning the plan or design of the proposed project. All unresolved concerns with the plan and design of the project, as contained within this Review Assessment, would need to be addressed prior to implementation. Unresolved concerns with the plan are related to incremental analysis, nourishment intervals, screening of nonstructural measures, Executive Order 11988 compliance, environmental consequences, design sustainability, and cost estimates. Although the current analysis supports the conclusion for justification of the sponsor's recommended plan, there remains a risk that future analysis could affect project justification or further modify the recommended features of the project. In addition, cost sharing amounts cannot be calculated until additional analysis is completed to identify the national economic development (NED) plan in accordance with the Principles and Guidelines and current law. Cost sharing requirements or the identification of an NED plan may result in a change to the sponsors preferred plan. These risks have the potential to affect budgeting and implementation of the project. C. Identify any conditions required for construction of the project Conditions for construction of the project include completion of NEPA and environmental compliance activities. IV. Review History and Findings Two Washington -level review cycles were conducted for the study. The following sections document the issue resolution process from those reviews. St. Lucie County, Florida Section 203 - Ft. Pierce Shore Protection Project ASACW Review Assessment This is a preliminary review assessment, The Administration is still completing its internal review of the Ft, Pierce Feasibility Study, The Army requests that further distribution of the assessment be limited. Page 83 of 148 A. June 2018 Feasibility Study Review of the revised Feasibility Study generated new comments that had not been previously identified. The new comments pertain to the long-term sustainability of the recommended plan and the cost estimate for implementation. Resolution of these comments were not required to determine project feasibility, but are noted for future corrective action. 1. Future Without Project Conditions — Tide Gauges. Concern: The future conditions used in the report are developed using Daytona Beach Shores and Miami Beach tide gauges, which are closest to the project area, but which also have discontinuous records. Daytona Beach Shores has a discontinuous record ending in 1984, while Miami Beach has a record from 1931-1981 with a minor discontinuity. This is not mentioned anywhere, but certainly introduces uncertainty into the expected sea levels out 50 years based on these tide gauges, given that Fernandina Beach, Mayport, and Key West (long records but farther away) show increasing trends over the past 10-20 years (yr) and especially in the five-yr moving averages. Basis of Concern: Use of discontinuous records could impact elevations important in planning and design, with subsequent implications to completeness, effectiveness, efficiency, and acceptability of the alternatives. Lack of compliance with Corps policy and technical guidance ER 1100-2-8162 and ETL 1100-2-1. Significance of Concern: Moderate Action Needed to Resolve Concern: Prior to implementation, conduct analysis of all tide gauges listed above with attention to their behavior over the period covered by Daytona /Miami. Consider using interpolated or otherwise combined records to develop more realistic trend data. If there is no noticeable sensitivity when using the additional longer and continuous gauge records, provide graphical evidence and a statement to this effect. 2. Future Without Project Conditions —Application of Sea Level Change Analysis Result. Concern: There is no evidence in the Engineering Appendix or Main Report that the results of the sea level change analysis were applied in the remainder of the study. For example, there is a nice discussion of the erosion and volume reduction associated with sea level, but no mention of the additional volume required to renourish due to this erosion, which would trickle through to costs. The design of the groins would require a 100-yr life cycle per ER 1110-2-8159. There was no discussion about whether and how the 100-yr expected sea levels would impact the design, resulting elevations, or require adaptations to changing conditions over the 100 yr engineering horizon. Sensitivity to sea level was discussed on p. 18 of the Economics appendix but no backup information was provided. There is no justification for the sentence on p. 28 of the Economics Appendix that "The minimal effect of sea level rise does not alter this BCR." St. Lucie County, Florida 4 ASACW Section 203 - Ft. Pierce Shore Protection Project Review Assessment This is a preliminary review assessment. The Administration is still completing its internal review of the Ft. Pierce Feasibility Study. The Army requests that further distribution of the assessment be limited. Page 84 of 148 Basis of Concern: Not considering expected sea level conditions could impact elevations and volume important in planning and design, with subsequent implications to completeness, effectiveness, efficiency, and acceptability of the alternatives. Lack of compliance with ER 1110-2-8159, ER 1100-2-8162, and ECB 2106-25. Significance of Concern: Moderate Action Needed to Resolve Concern: Provide evidence of whether and how the results of the sea level change analysis were used in determining renourishment requirements over the 50-yr period of economic analysis. Be sure to address not only sea level itself, but the effects of se level change on tides, surge, waves, and other local factors (e.g., interannual or interdecadal variability) which impact performance and reliability. Conduct analyses to describe current and future without project conditions related to the effects of expected sea level change over the engineering horizon of 100 yrs on the design of the groins and any adaptation measures that could be required to provide continued performance and reliability over that time period. Provide data and analysis to support the discussion of sensitivity to sea level (p. 18) and support the statement on p. 28 of the Economics Appendix that "The minimal effect of sea level rise does not alter this BCR." 3. Sea Level Rise Policy and Technical Guidance. Concern: The main report refers to EC 1165-2-211 which was superseded in 2011 by EC 1165-2-212 and in 2013 by ER 1100-2-8162. The most current policy and technical guidance should be used in the planning and engineering analyses. The main report states on p. 126 that " However, policymakers have not decided whether the practice of protecting development should continue as sea level rises or be modified to avoid adverse environmental consequences and increased costs of shore protection." This may indeed be true for local policymakers — clarification is needed as to which policymakers are referred to here. Also on p. 126 is this statement: "Most shore protection structures are designed for the current sea level, and retreat policies that rely on setting development back from the coast are designed for the current rate of sea level rise (SLR). Those structures and policies would not necessarily accommodate a significant acceleration in the rate of sea -level rise." The Corps has a policy (ER 1100- 2-8162) and methods for implementation (ETL 1100-2-1) which support decision - making about potential future actions including structure design that account for significant changes in sea level. We do this to be sure that the project plan accounts for observed and expected changes over the design life in a way that supports the expected return on the Federal investment. Basis of Concern: Neglecting to consider Corps policy and technical guidance could impact elevations important in planning and design, with subsequent implications to completeness, effectiveness, efficiency, and acceptability of the alternatives. Significance of Concern: Moderate St. Lucie County, Florida Section 203 - Ft. Pierce Shore Protection Project ASACW Review Assessment This is a preliminary review assessment. The Administration is still completing its internal review of the Ft. Pierce Feasibility Study. The Army requests that further distribution of the assessment be limited. Page 85 of 148 Action Needed to Resolve the Concern: Prior to implementation, conduct a SLR/Climate Change analysis of the plan, in accordance with relevant Corps guidance, for the purpose of validating the project features/specifications and their expected performance throughout the project life -cycle (100 years). Current policy and guidance require consideration of rising sea level, including modification as necessary for major infrastructure (i.e., the groins) to continue to provide their authorized services out 100 yrs (per ER 1110-2-8159). This needs to be done prior to implementation to be sure the estimated costs and benefits are correct and that the loadings and threshold elevations are correct. Ignoring the policy and guidance may make the 4-yr renourishment interval look very optimistic, in which case the question arises, is constant renourishment an effective use of Federal cost -share funding? As for the groins, loading and threshold elevations will be driven by changing sea level, which alters tide, surge, wave, and other components of hydraulic loading. 4. Alternative Cost Estimates Concern: No cost estimates (construction or total project) are shown/detailed in the main report or the cost appendix. Basis for Concern: Without total project cost estimates developed for alternatives that are able to be compared, how do we know the correct alternative was selected? There are some tables with costs in the economic appendix but there is not a table that compares all alternatives carried forward. Significance of Concern: High Action Needed to Resolve Concern: Provide/show total project cost estimates for the alternatives carried forward from the initial screening process. 5. NED Cost Estimate Concern: Cost estimate for shoreline structures is provided, but the dredging portion is hard to discern from the documents provided. Basis for Concern: The dredging work for the NED plan is outlined briefly, but there aren't quantities input into an estimate in the cost appendix or the sub -appendix; the cost appendix just shows a mob cost a dredging unit rate. There needs to be an estimate that shows all of the planned construction costs and the non -construction costs of the contract (or contracts, if multiple are planned for initial construction). There is not a sufficient narrative for the estimate that mentions contractor structure, acquisition strategy, market conditions, etc. What are the unit prices for shoreline structures based on? Is profit included? Overhead percentages? Are any productivity factors applied? These are some of the questions that can't be answered based on the information provided. Significance of Concern: High St. Lucie County, Florida Section 203 - Ft. Pierce Shore Protection Project ASACW Review Assessment This is a preliminary review assessment. The Administration is still completing its internal review of the Ft. Pierce Feasibility Study. The Army requests that further distribution of the assessment be limited. Page 86 of 148 Action Needed to Resolve Concern: Prior to implementation, the cost estimate (appendix) should be revised with all relevant information for the project, including features, unit costs, expected breakout of construction contracts and backup documentation, outlined above and in ER 1110-2-1302, Civil Works Cost Engineering. 6. Contingency/Risk Analysis Concern: Contingency of 23% is taken from a prior risk analysis that was prepared by USACE Jacksonville District for the Fort Pierce SPP, not this particular project. Basis for Concern: The prior risk analysis was based on a different cost estimate for a different project, though it is acknowledged that the project location is the same. However, since the cost basis for the previous project was likely different than what the current estimate is, there may be existing factors that contribute to greater (or lower) uncertainty for this particular study, such as cost basis (ie, historical unit prices), quantities, availability/capacity of borrow areas, etc. Significance of Concern: High Action Needed to Resolve Concern: Prior to implementation, recommend developing a new risk analysis and associated contingency percentage based on the cost estimate presented in Appendix B. 7. Account code for Environmental Monitoring Concern: Costs included in the 30 account (PED) for environmental monitoring may need to be moved in the 06 account, Fish & Wildlife Facilities. Basis for Concern: Per ER 1110-2-1302, Civil Works Cost Engineering, the 06 account Fish & Wildlife Facilities should include "...items such as ladders, elevators, locks and related facilities for passage of fish at dams and navigation locks and maintenance of fish runs; and provision for wildlife preservation. In support of wildlife, this feature includes environmental mitigation and monitoring costs." Costs associated with the monitoring of wildlife species should be included there — so monitoring for anything like nesting birds, manatees, etc. should be covered in 06. Significance of Concern: Low Action Needed to Resolve Concern: For information only. 8. Induced Flooding costs Concern: Costs for mitigation of induced flooding beyond the Corps of Engineers standard do not appear to have been captured. Basis for Concern: Though they would be separate from construction costs, would there be any mitigation required? This should be captured if it has not already been done. St. Lucie County, Florida Section 203 - Ft. Pierce Shore Protection Project ASACW Review Assessment This is a preliminary review assessment. The Administration is still completing its internal review of the Ft. Pierce Feasibility Study. The Army requests that further distribution of the assessment be limited. Page 87 of 148 Significance of Concern: Medium Action Needed to Resolve Concern: Prior to implementation, verify and address if there would be any costs necessary, and if so, estimate the magnitude of those. B. March 2017 Feasibility Study. A GENERALCOMMENTS 1. Policy issues raised by project recommendation. Concern: Section 203 is not an appropriate authority to study the extension of the period of cost shared nourishment. However, while extension of the period of cost shared nourishment is not appropriate under 203, studying the feasibility of adding groins is acceptable. Therefore, in this particular case, this Section 203 report will be reviewed, but the report must include a discussion regarding the period of nourishment in light of the specific Congressional direction that such extended nourishment not exceed 15 years. Basis of concern: Project authorization and Section 1037 of WRRDA 2014 states: "...the Secretary shall, at the request of the non -Federal interest, carry out a study to determine the feasibility of extending the period of nourishment ...for a period not to exceed 15 additional years...." Significance of concern: High, as it affects the ability to support the recommended plan. Action needed to resolve concern: The report needs to be revised to reconcile the conflict between its recommendation to reauthorize the project for an additional 50 years of Federal participation in nourishment and the explicitly stated limitation of 15 years in Section 1037. Local Sponsor Response: During a meeting with project stakeholders on Monday, October 16, 2017, USACE and ASA(CW) representatives confirmed that Section 203 is the appropriate authority for 50- year federal participation in a new modified project that includes construction of shoreline stabilization structures, which is anticipated to greatly improve project performance by doubling the nourishment interval from two years to four years, together with beach nourishment at a reduced frequency than currently authorized, which results in significant cost savings. Under this guidance, St. Lucie County will submit a revised report requesting authorization of the new modified project with a 50-year project life, as opposed to an extension of the current project. ASACW/HQUSACE Initial Assessment: Comment is resolved. St. Lucie County, Florida 8 ASACW Section 203 - Ft. Pierce Shore Protection Project Review Assessment This is a preliminary review assessment. The Administration is still completing its internal review of the Ft. Pierce Feasibility Study. The Army requests that further distribution of the assessment be limited. Page 88 of 148 ASACW/HQUSACE Final Assessment: Comment is resolved. 2. Policy issues raised by project recommendation. Concern: As noted on page 7 of the report, shore protection at the project site was previously constructed and is currently authorized for 50 years of nourishment, ending in 2020. The draft GRR (as reflected in part 3.8.1 on page 70 of the report and elsewhere) now recommends seeking authorization by Congress of a wholly new round of initial construction, as well as a second extension of nourishment for 50 more years. However initial construction of the dune and berm for this area has been completed. The report should not refer to any further nourishment for this area as initial construction. Instead, this is an extension of nourishment. Even if the dune and berm profile were to change, this is still be treated as nourishment albeit with modified dimensions. For CSDR Congress recognized that both these features are sacrificial and that eventually the project will erode if not nourished. Thus, they provided for Federal cost sharing of the initial construction and for a limited period for cost sharing in nourishment. At the end of the period of Federal participation in nourishment, you don't start again with initial construction. Section 1037 of WRRDA 2014 dictates that Congressional authorization for an extension of the period of nourishment and other modifications to the project authorization (i.e. additional hardscapes or other project adjustments). Basis of concern: Section 1037 of WRRDA 2014. Significance of concern: High, as it affects the ability to support the recommended plan. Action needed to resolve concern: The report needs to be revised to remove references to new initial construction. Local Sponsor Response: As mentioned, during a meeting on Monday, October 16, 2017, St. Lucie County representatives received guidance from USACE and the ASA(CW) to submit a Section 203 report requesting 50-year authorization of the proposed structures and beach nourishment as a new modified project as opposed to an extension of the current project. Therefore, the revised report will retain the "initial construction" terminology for construction of the proposed structures and the associated beach fill placement (i.e., the first nourishment under the new 50-year period of federal participation). ASACW/HQUSACE Initial Assessment: Comment will be resolved pending review of the revised report. Recommend the report include language that distinguishes between the original construction and construction of the proposed modifications, such as adding a qualifiers "initial construction of the proposed modification". ASACW/HQUSACE Final Assessment: Comment is resolved. St. Lucie County, Florida Section 203 - Ft. Pierce Shore Protection Project ASACW Review Assessment This is a preliminary review assessment. The Administration is still completing its internal review of the Ft. Pierce Feasibility Study. The Army requests that further distribution of the assessment be limited. Page 89 of 148 I Policy issues raised by project recommendation. Concern: The recommendation assumes that no further nourishment of the project will occur following the currently authorized period of Federal participation in nourishment, which would appear to conflict with USACE planning policy requiring benefits to be calculated based on the most likely future without project condition. The report fails to address the apparent discrepancy between this assumption and Administration planning and budget policy as well as the current OMRR&R obligations of non -Federal interests. Basis of concern: As noted in 1.6.1.2 on page 8 of the report in the report, the Administration has not supported funding of any new phases of currently authorized shore protection projects beyond the "ongoing phase ... or to honor previous contractual agreements". Moreover, under the current ongoing nourishment period for the project, the sponsor is presumably obligated to operate, maintain, repair, replace, and rehabilitate the project following the completion of construction and all nourishment cycles contemplated under existing agreement. Significance of concern: High, as it affects the ability to support the recommended plan. Action needed to resolve concern: The report needs to be revised to reconcile the conflict between its recommendation and current limitations imposed by Administration budget policy as well as the sponsor's current OMRR&R obligations as well as its obligations under state law. Local Sponsor Response: The assumption that no further nourishment will occur is valid, as the County won't be able to financially support a non-federal project, and FDEP cost sharing, subject to annual state-wide project rankings, is not guaranteed. The County has an obligation to support the federal project by providing the non- federal cost share and complying with the FDEP permit conditions; the County does not have an obligation to fund and construct nourishment projects absent federal funding and participation. The County did not construct any nourishment projects between 1971 and 1980 (i.e., between initial construction and the first nourishment project) or between 1980 and 1999 (i.e., between the first and second nourishment projects) when federal funding was unavailable. The County's non-federal nourishment actions have been limited to small-scale emergency truck haul projects to protect public infrastructure when storm damage appeared imminent; the Future Without Project (FWOP) simulation in Beach-fx incorporates emergency nourishment, as such projects would likely occur without a federal SPP. ASACW/HQUSACE Initial Assessment: Comment is resolved. Upon review of the project agreement, Corps Counsel has determined that the OMRR&R provision does not require continued nourishment of the project. ASACW/HQUSACE Final Assessment: Comment is resolved. St. Lucie County, Florida 10 ASACW Section 203 - Ft. Pierce Shore Protection Project Review Assessment This is a preliminary review assessment. The Administration is still completing its internal review of the Ft. Pierce Feasibility Study. The Army requests that further distribution of the assessment be limited. Page 90 of 148 4. Lack of adequate technical review documentation. Concern & Basis of concern: Per ER 1165-2-209, App B, par j, the non -Federal interests "must certify the quality and technical accuracy of the feasibility study" by "documenting the quality control, quality assurance, and technical reviews that were conducted... In addition, the study must meet the requirements for independent peer review". The only certification included with the submittal was a technical review certification on a May 2007 version of the report. In addition to the problem of the certification not being for the current report, that certification also only asserts that staff members from Taylor Engineering not directly involved in the preparation of the document reviewed the report and all significant issues were resolved. However, no supporting documentation as to what these comments were and how they were resolved were included, nor does the documentation indicate what the relevant qualifications of the reviewers are. The documentation does not meet the standards employed by the Corps for Agency Technical Review. Additionally, it does not appear that a Type I Independent External Peer Review (IEPR) was conducted, nor was information provided as to why a Type 1 IEPR exclusion would be warranted. Significance of concern: High. Without adequate documentation the Review Team is unable to attest to or support the technical quality of the report (including cost). Action needed to resolve concern: Sponsor should include full documentation of peer review of the current report, including a) relevant qualifications of reviewers, b) individual comments and concerns raised by the review and how they were resolved, and c) documentation of Type 1 IEPR, OR documentation to support an exclusion from such a review. Local Sponsor Response: Cliff Truitt and Jerry Scarborough, highly qualified Taylor Engineering employees, are conducting an internal technical review (ITR); their qualifications are appended to this document. The revised report will include documentation of the ITR process. We understand Type I IEPR is only mandatory if any of the following are true: a) Significant threat to human life. The decision document phase is the initial concept design phase of a project. Therefore, when life safety issues exist, a Type I IEPR that includes a Safety Assurance Review is required; b) Where the estimated total cost of the project, including mitigation costs, is greater than $200 million based on a reasonable estimate at the end of the reconnaissance phase. If a project has a cost estimate of less than $200 million at the end of the reconnaissance phase, but the estimated costs subsequently increase to more than $200 million, a determination will be made by HQUSACE whether a Type I IEPR is required; c) Where the Governor of an affected State requests a peer review by independent St. Lucie County, Florida 11 ASACW Section 203 - Ft. Pierce Shore Protection Project Review Assessment This is a preliminary review assessment. The Administration is still completing its internal review of the Ft. Pierce Feasibility Study. The Army requests that further distribution of the assessment be limited. Page 91 of 148 experts; or d) Where the DCW or the Chief of Engineers determines that the project study is controversial due to significant public dispute over either the size, nature, or effects of the project or the economic or environmental costs or benefits of the project. The above criteria are not true for the NED Plan discussed in the original report; thus, an IEPR is not required. ASACW/HQUSACE Initial Assessment: Comment is unresolved. EC 1165-2-214 states that selection of technical reviewers will be based on "expertise, experience, and skills, including specialists from multiple disciplines as necessary to ensure comprehensive review". For coastal storm risk management (CSRM) projects, ATR teams generally include reviewers with expertise in plan formulation, economics, environmental compliance, geotechnical engineering, coastal engineering, cost engineering, and real estate. Based on the resumes provided, it does not appear that a complete technical review team has been developed to cover all relevant disciplines. Additional reviewers would likely need to be utilized to ensure a comprehensive technical review. The review documentation to be provided should include a discussion of why Type I IEPR should be waived. The documentation should include specific rationale on why the study does not meet any of the mandatory triggers listed above in the comment response. Note that a Type I IEPR waiver is not allowable if the project includes an EIS. At a minimum, a Type II IEPR, which includes a Safety Assurance Review (SAR), will be required for future implementation documents. Corps policy directs that an SAR be conducted for any project involving public safety. The report and/or the submittal of the report must articulate the steps taken to ensure a comprehensive technical review was conducted for the report. Local Sponsor Response: Sub -Appendix H-2 includes documentation of the technical review. The appendix includes the review comments — provided by the specialists in plan formulation, economics, environmental compliance, geotechnical engineering, coastal engineering, cost engineering, and real estate — and Taylor Engineering's responses to the comments. Additionally, the Sponsor provides the following summary of their Peer Review effort: Independent Technical Review Per ER 1165-2-209, App B, par j, the non -Federal interests "must certify the quality and technical accuracy of the feasibility study ... by documenting the quality control, quality assurance, and technical reviews that were conducted for all information presented in the feasibility study." Accordingly, Sub -Appendix H-2 includes documentation of the independent technical review conducted by specialists in plan formulation, economics, St. Lucie County, Florida 12 Section 203 - Ft. Pierce Shore Protection Project ASACW Review Assessment This is a preliminary review assessment. The Administration is still completing its internal review of the Ft. Pierce Feasibility Study. The Army requests that further distribution of the assessment be limited. Page 92 of 148 environmental compliance, geotechnical engineering, coastal engineering, cost engineering, and real estate. As documented in Sub -Appendix H-2, specialists included independent staff members from Taylor Engineering not involved in the study as well as experts external to Taylor Engineering. The peer review documentation includes the original review comments from the specialists and Taylor Engineering's responses to the comments. Independent External Peer Review (IEPR) In addition to the technical review for quality control and quality assurance, the study must meet the requirements for peer review. St. Lucie County understands a Type II IEPR, which includes a Safety Assurance Review (SAR), will be required for future implementation documents but not for Federal approval of this Section 203 feasibility study. However, a Type I IEPR is not required for this study. As discussed below, the proposed project does not meet any of the four mandatory triggers for a Type I IEPR: (a) Significant threat to human life. The decision document phase is the initial concept design phase of a project. Therefore, when life safety issues exist, a Type I IEPR that includes a Safety Assurance Review is required; Discussion: The proposed project includes beach nourishment and construction of shoreline stabilization structures for coastal storm risk management. The project does not pose a significant threat to human life. Thus, a Type I IEPR is not required. As mentioned, St. Lucie County understands a Type II IEPR, which includes a Safety Assurance Review (SAR), will be required for future implementation documents but not for Federal approval of this Section 203 feasibility study. (b) Where the estimated total cost of the project, including mitigation costs, is greater than $200 million based on a reasonable estimate at the end of the reconnaissance phase. If a project has a cost estimate of less than $200 million at the end of the reconnaissance phase, but the estimated costs subsequently increase to more than $200 million, a determination will be made by HQUSACE whether a Type I IEPR is required; Discussion: The Cost Engineering Appendix documents a total 50-year project cost of $131,066,611, well below the $200 million threshold. Thus, a Type I IEPR is not required. (c) Where the Governor of an affected State requests a peer review by independent experts; or Discussion: The Governor of Florida has not requested an independent peer review; thus, a Type I IEPR is not required. The Florida Department of Environmental Protection (FDEP) has reviewed the proposed project and has approved St. Lucie County's scope of work (for state cost sharing purposes) for preparation of this Section 203 feasibility study. The proposed project, similar to other projects that have been approved by FDEP and constructed by local sponsors, is a typical solution to address the issues at hand. Thus, the Governor has not requested a peer review. (d) Where the DCW or the Chief of Engineers determines that the project study is controversial due to significant public dispute over either the size, nature, or effects of the project or the economic or environmental costs or benefits of the project. St. Lucie County, Florida 13 ASACW Section 203 - Ft. Pierce Shore Protection Project Review Assessment This is a preliminary review assessment. The Administration is still completing its internal review of the Ft. Pierce Feasibility Study. The Army requests that further distribution of the assessment be limited. Page 93 of 148 Discussion: St. Lucie County has held numerous public meetings to inform and solicit feedback from the public and has made the draft report available for public review and comment. There has not been a public dispute over either the size, nature, or effects of the project or the economic or environmental costs or benefits of the project. Thus, a Type I IEPR is not required. Based on the above discussion, this study qualifies for a Type I IEPR waiver. Of note, a Type I IEPR waiver is not allowable if the project includes an EIS; however, the proposed project does not include an EIS. ASACW/HQUSACE Final Assessment: Comment is resolved. 5. Study authority. Concern. Page i. of the executive summary and part 1.2 on page 1 of the draft GRR do not include a complete explanation of the statutory authority which support the study or the plan recommendations. The study was prepared under the authority of Section 203 of WRDA 1986, as amended (33 U.S.C. 2231), but this is not expressly stated. Basis of concern: ER 1105-2-100, Appendix G; Exhibit G-1, para. 1 ("General Requirements for ... Feasibility Phases ... Study Conduct. Studies conducted in accordance with all applicable laws and policies."); Exhibit G-1, para. 5 ("Legal and institutional problems to project implementation are to be identified, and a plan to resolve them is to be presented"); para. G-6.h.(1)(b) ("Document compliance with applicable statutes and policies") Exhibit G-4 ("Include the full text of the study resolution(s) or other authority"); & G-5 ("Include the full text of the study resolution(s) or other authority"); G-7 ("Include the full text principle resolution(s) or other authority."). Sianificance of concern: Low. Action needed to resolve concern. The report needs to be revised to clearly cite and explain the use of Section 203 as the authority for the study and the recommended plan. Local Sponsor Response: The revised report includes the following sentence to the Study Purpose and Scope paragraph on page i of the Executive Summary and Section 1.3 on page 1 of the report: "St. Lucie County prepared this study under the authority of Section 203 of WRDA 1986, as amended (33 U.S.C. 2231). The NED Plan includes construction of shoreline stabilization structures, which is anticipated to greatly improve project performance by doubling the nourishment interval from two years to four years, together with beach nourishment at a reduced frequency than currently authorized, which results in significant cost savings. The NED Plan represents a new modified project, which falls under the authority of Section 203." ASACW/HQUSACE Initial Assessment: Comment is resolved. ASACW/HQUSACE Final Assessment: Comment is resolved. St. Lucie County, Florida 14 ASACW Section 203 - Ft. Pierce Shore Protection Project Review Assessment This is a preliminary review assessment. The Administration is still completing its internal review of the Ft. Pierce Feasibility Study. The Army requests that further distribution of the assessment be limited. Page 94 of 148 6. Credit for Federal share of study. Concern. The report does not appear to acknowledge or address the impact on the sponsor's cost share of Section 203(d) of WRDA 1986, which authorizes a sponsor to be credited toward its required cost share for construction in an amount equal to the portion of the cost of the study that would have been the responsibility of the United States if the study were developed by the Corps. Basis of concern. ER 1165-2-208 para. 5.c. ("Section 203 provides that if a project for which a feasibility study developed by non -Federal interests is authorized after the Secretary submits the report to the Congress, the Secretary shall credit toward the non - Federal share of the cost of construction of such project an amount equal to the portion of the cost of developing the study that otherwise would have been the responsibility of the United States if such study had been developed by the Secretary. The costs of the non -Federal interests are subject to audit to determine allowability, allocability, and reasonableness. Under the Corps of Engineers SMART Planning policy and the "3x3x3 rule" established by Planning Bulletin 2014-01, in general, $3 million is the maximum total cost of feasibility studies undertaken by the Corps of Engineers. Therefore, for a feasibility study undertaken by a non- Federal interest, credit may not exceed $1.5 million, which would have been the maximum Federal cost for a feasibility study, unless a greater amount for credit is specifically authorized in law."). Significance of concern: Medium, as it could affect the cost sharing for the project. Action needed to resolve concern. The report should be revised to address the impact of any credit granted for the sponsor's costs in preparing the GRR toward its required share of the project upon authorization. Local Sponsor Response: Table EA in the Executive Summary of the revised report includes the following footnote that acknowledges the County's potential credit: "1The local sponsor is potentially eligible for a credit, equal to the sponsor's cost to conduct this study, towards the non -Federal share of construction costs; this potential credit does not affect the calculated cost sharing percentages." ASACW/HQUSACE Initial Assessment: Comment is resolved. ASACW/HQUSACE Final Assessment: Comment is resolved. 7. Sponsor letter of intent. Concern. The report does not appear to include a current sponsor letter affirming its support for the recommended plan. Basis of concern: A written letter of intent is also required from the sponsor to ensure that sufficient local support for the project will enable it to be implemented, as required by ER 1105-2-100, Appendix G, at G-9 ("The non -Federal sponsor's acceptance of, or desired departures from, the terms of the applicable model PCA must be presented, St. Lucie County, Florida 15 ASACW Section 203 - Ft. Pierce Shore Protection Project Review Assessment This is a preliminary review assessment. The Administration is still completing its internal review of the Ft. Pierce Feasibility Study. The Army requests that further distribution of the assessment be limited. Page 95 of 148 including: 1) applicable cost sharing and financial policies; 2) policies regarding provision and valuation of non -Federal lands, easements, rights -of -way, and disposal areas provided by non -Federal sponsors; 3) policies governing non -Federal project construction, and 4) other provisions required by law and policy for new start construction projects."). Significance of concern: Low to medium. Action needed to resolve concern: The Sponsor should provide a current letter of intent and add a reference to it in the report as well as include it as a referenced attachment. Local Sponsor Response: Appendix J of the revised report will include the letter of intent. ASACW/HQUSACE Initial Assessment: Comment is resolved, pending back -check of the revised report. Local Sponsor Response: Sub -Appendix H-1 includes the letter of intent. ASACW/HQUSACE Final Assessment: Comment is resolved. 8. Sponsor statement of financial capability. Concern. The report does not appear to include a sponsor self -certification of financial capability. Basis of concern: See CECW-PC memorandum dated 12 June 2007, Lean Six Sigma (L6S) Actions to Improve the Project Cooperation Agreement Process — Non -Federal Sponsor's Self -Certification of Financial Capability (eliminating USACE financial analyses of sponsors) ("a non -Federal sponsor will sign the Non -Federal Sponsor's Self - Certification of Financial Capability For Decision Documents (enclosure 3) for such purpose."). Significance of concern: Low to medium. Action needed to resolve concern: A sponsor financial self -certification should be provided and cited in the report as a referenced attachment. Local Sponsor Response: Appendix K of the revised report will include the financial self - certification. ASACW/HQUSACE Initial Assessment: Comment is resolved, pending back -check of the revised report. Local Sponsor Response: Sub -Appendix H-1 includes the financial self -certification. St. Lucie County, Florida 16 ASACW Section 203 - Ft. Pierce Shore Protection Project Review Assessment This is a preliminary review assessment. The Administration is still completing its internal review of the Ft. Pierce Feasibility Study. The Army requests that further distribution of the assessment be limited. Page 96 of 148 ASACW/HQUSACE Final Assessment: Comment is resolved. 9. Executive Order 11988. Concern: The main report has a single paragraph pertaining to Executive Order (EO) 11988. ER 1165-2-26 highlights 8 steps that must be followed and properly documented to ensure project decisions are in compliance of EO 11988. Of particular concern, the early screening of nonstructural measures demonstrating that no alternatives to a project in the floodplain exist. Basis of concern: Reference ER 1165-2-26. Significance of concern: Significant. It is unclear if formulation and public involvement are sufficient to satisfy EO 11988 requirements. Action needed to resolve concern: Conduct and follow the 8-steps as outlined in ER 1165-2-26. Local Sponsor Response: We request clarification regarding specific action/documentation needed to resolve the concern. The content and organization of the report and plan formulation are very similar to other recent CSRM feasibility studies completed by USACE and satisfy the 8 steps outlined in ER 1165-2-26. As mentioned in the Executive Summary, St. Lucie County has held numerous public meetings regarding the study. ASACW/HQUSACE Initial Assessment: Comment is unresolved. A meeting with the sponsor can be held if further clarity of the guidance is needed. Typically a summary section is included in decision documents which outlines the required 8-steps and describes where and how the steps were followed in the report. The greatest concern is that nonstructural alternatives did not appear to be given appropriate consideration in lieu of a structural alternative. For example, Table 3.1 appears to screen out most, if not all, of the nonstructural alternatives based on local objectives including recreation and protection of tourism -based economy. Also, it does not appear that nonstructural alternatives were looked at as standalone given the stated planning objective, "Objective 1: Maintain the functionality of the currently authorized SPP, but increase the nourishment interval from two years to a minimum of four years by implementing shore stabilization structures." The intent of the executive order is to consider, assess, and communicate alternatives to construction in floodplains. Based on the above, it is unclear that appropriate consideration has been done. Related to the stated concerns about alternatives screening (also covered in comment B-3 below), it has been determined that in 2014 the St. Lucie County and the city of Fort Pierce submitted a proposal to the Corps of Engineers which was included in the Section 7001 (of the Water Resources Reform and Development Act of 2014) Report to Congress. The proposal was for a project to include inlet sand bypassing and shoreline stabilization structures. The proposal included a letter of support from the Florida St. Lucie County, Florida 17 ASACW Section 203 - Ft. Pierce Shore Protection Project Review Assessment This is a preliminary review assessment. The Administration is still completing its internal review of the Ft. Pierce Feasibility Study. The Army requests that further distribution of the assessment be limited. Page 97 of 148 Department of Environmental Protection, dated December 2, 2014, which generally stated that implementation of adequate sand bypassing would alleviate the need for erosion control structures and that the project would rank highly on the State's annual funding priorities. This proposal (alternative) is not discussed in the current report. Therefore it is not clear why this is no longer being considered. The current report must present a complete explanation of the plan formulation process: full suite of alternatives (structural and nonstructural) considered to address the water resource problem(s), description of screening criteria used for evaluation and rationale for rejecting any alternative. If it is too speculative whether bypassing would be conducted and therefore shouldn't be part of the FWOP (per the response to comment B-3 below) condition; then bypassing should at least be a measure considered in the formulation process. Bypassing appears to be a reasonable and practicable alternative, and by NEPA standards and 404(b)(1) guidelines standards (in addition to plan formulation standards), the report should have a valid reason to eliminate it. It is necessary to explain and justify what appears to be a discrepancy between the current project recommendation and the 2014 proposal. Local Sponsor Response: Section 3.11 of the main report addresses Compliance with Executive Order (EO) 11988. We made substantial revisions to the plan formulation discussion throughout Chapter 3, including a completely revised Table 3.1 describing the preliminary screening process. The screening process includes the sediment impoundment basin as an alternative but discusses the reasons why it cannot be considered as part of the NED Plan at this time. ASACW/HQUSACE Final Assessment: The concern remains unresolved at this time — see response to comment B1. In the event that the recommended plan is authorized for federal participation, it is expected that this unresolved issue would need to be addressed prior to implementation. B PLAN FORMULATION 1. Future Without Project Condition. Concern: The assumptions underlying the Future Without Project (FWOP) condition are unclear and the assessment of environmental conditions within the FWOP are inadequate and inappropriate. In addition to other comments that the FWOP does not consider the NFS conducting required OMRR&R or State of Florida plans/requirements for sand bypassing at the inlet, the report also makes multiple claims throughout the document that landowners will resort to armoring in the FWOP, leading to additional impacts. However, pg. 43 of the report states that "it was assumed that no local armoring would occur" in the FWOP and for Beach-fx modeling. For most of Chapter 2 the FWOP/no-action alternative is described as "not expected to differ from Existing Conditions." This inaccurate assumption does not take into consideration any reasonably foreseeable actions that are expected to occur through 2070 including trends in coastal storms (increasing frequency and/or intensity), non -Federal OMRR&R, bypassing/inlet management, or ongoing threats to or recovery/restoration of environmental resources, etc. St. Lucie County, Florida 18 ASACW Section 203 - Ft. Pierce Shore Protection Project Review Assessment This is a preliminary review assessment. The Administration is still completing its internal review of the Ft. Pierce Feasibility Study. The Army requests that further distribution of the assessment be limited. Page 98 of 148 Basis of concern: The FWOP condition/no-action alternative is critical both in terms of compliance with the P&Gs and a legally sufficient NEPA document, as the alternative that other alternative plans are compared against. Without a clear and accurate picture of the FWOP, then the benefits and environmental consequences/EQ effects of the proposed plan cannot be ascertained. See 2-4b. (3) and (4) of ER 1105-2-100; Section 3.4.7.(c)(1)-(6) of the P&G; also Question 3 of CEQ's 40 most asked questions of NEPA. Significance of concern: High, as it affects plan justification. Action needed to resolve concern: Ensure assumptions of the FWOP are clear up front in the document and consistent throughout the report. Revise discussions of the FWOP/no-action alternative in Chapter 2 considering the most -likely condition of each resource in 2070, considering any non -Federal actions that may affect the status (recovering, declining, and stable) of that environmental resource. Local Sponsor Response: The revised report corrects the inconsistency on page 43. As noted in the same paragraph on page 43, the Beach-fx FWOP simulations included emergency armoring for eligible properties; thus, the environmental reporting in Chapter 2 is correct. As mentioned in the above response to General Comment 3, the assumption that no further nourishment will occur is valid, as the County won't be able to financially support a non-federal project and does not have an obligation to do so. The County has an obligation to support the federal project by providing the non- federal cost share and complying with the FDEP permit conditions; the County does not have an obligation to fund and construct nourishment projects absent federal funding and participation. The County did not conduct any nourishment projects between 1971 and 1980 (i.e., between initial construction and the first nourishment project) or between 1980 and 1999 (i.e., between the first and second nourishment projects) when federal funding was unavailable. The FWOP analysis cannot include bypassing from the sediment deposition basin, as the basin has not been constructed and proven effective. Once the basin is constructed and proven effective, a future report can address and incorporate any resulting project changes. While the State of Florida specifies sand bypassing goals for Ft. Pierce Inlet, the Federal government is responsible for mitigating the adverse effects of the Federal Ft. Pierce Inlet; the NED plan discussed in the report, which is based on adequate and appropriate assessments and assumptions, satisfies the Federal government's responsibility and the State's bypassing objectives. ASACW/HQUSACE Initial Assessment: Comment is resolved pending review of revisions made to the report. It is recommended that the report also indicate why sand bypassing was screened as a measure for the reasons indicated above. Local Sponsor Response: As mentioned in the response to the previous comment, we made substantial revisions to the plan formulation discussion throughout Chapter 3, including a completely revised Table 3.1 describing the preliminary screening process. St. Lucie County, Florida 19 ASACW Section 203 - Ft. Pierce Shore Protection Project Review Assessment This is a preliminary review assessment. The Administration is still completing its internal review of the Ft. Pierce Feasibility Study. The Army requests that further distribution of the assessment be limited. Page 99 of 148 The screening process includes the sediment impoundment basin as an alternative but discusses the reasons why it cannot be considered as part of the NED Plan at this time. ASACW/HQUSACE Final Assessment: The Review Team cannot resolve this comment. Should the proposal be authorized by Congress, it is recommended that any post -authorization analysis of the plan consider the smaller sediment bypassing basin as part of FWOP condition, and carry forward the full sediment bypassing basin as a viable measure for further analysis and confirmation/identification of the NED plan. Information provided by the non-federal interest continues to demonstrate that the smaller sediment bypassing basin is reasonably likely to occur within the 50 year period of analysis and should therefore be considered as part of the FWOP per paragraph 2- 4.b. of ER 1105-2-100. The non-federal interest contends that bypassing is not a valid measure based on uncertainty over its effectiveness until the pilot is in place and proven effective. However, sand bypassing has been effective as part of an inlet management plan in other nearby inlets along the Atlantic coast of Florida (Jupiter Inlet, Sebastian Inlet, and Boca Raton Inlet) by at least partially mitigating the effects of the inlet on longshore transport, thereby reducing the total cubic yards of sand needed from offshore or upland sources for renourishment events or helping extend the time period between larger renourishment events. Section 161.142 of Florida Statutes supports bypassing for similar reasons and states, "Accordingly, the Legislature finds it is in the public interest to replicate the natural drift of sand which is interrupted or altered by inlets to be replaced and for each level of government to undertake all reasonable efforts to maximize inlet sand bypassing to ensure that beach -quality sand is placed on adjacent eroding beaches. Such activities cannot make up for the historical sand deficits caused by inlets but shall be designed to balance the sediment budget of the inlet and adjacent beaches and extend the life of proximate beach -restoration projects so that periodic nourishment is needed less frequently." Using principles of risk and uncertainty, it still appears that bypassing has been prematurely eliminated as a viable measure as a part of a complete plan. This lends doubt as to whether the non-federal interest's recommended plan is truly the NED plan. 2. Future Without Project Condition. Concern: The entire analysis is predicated on the assumption that the previously authorized project stops at 50-years and the non- Federal sponsor and other non - Federal entities have neither continued responsibility nor incentive for maintaining the authorized dune and berm. Section 3.4 of the Economic Appendix states, "To simulate the most- likely without project scenario, this study assumed that the existing artificial berm will completely erode in 10 years." This assumption is incorrect, as the project remains an authorized Federal project even after the period of Federal participation in nourishment ends. The assumption that, in the absence of Federal participation in continued nourishment, erosion would be allowed to continue and non -Federal entities (city, county, state) would make no effort to perform further nourishment seems unlikely as it would appear to be ignoring the threat to public and private infrastructure as well as impacts on tourism revenue. It also seems at odds with Florida laws including the Local St. Lucie County, Florida 20 ASACW Section 203 - Ft. Pierce Shore Protection Project Review Assessment This is a preliminary review assessment. The Administration is still completing its internal review of the Ft. Pierce Feasibility Study. The Army requests that further distribution of the assessment be limited. Page 100 of 148 Government Comprehensive Planning Act of 1975 and the 1985 Growth Management Act, as described on page 55 of the report. Basis of concern: ER 1165-2-130. Significance of concern: Significant. Addressing this policy concern will have a major impact on whether a plan can be recommended for authorization. Action needed to resolve concern: Update the analysis to reflect a realistic level of effort to maintain the protection provided by the project as the Future Without Project Condition and revise the plan formulation and recommended plan accordingly. Local Sponsor Response: As mentioned in the above response to General Comment 3, the assumption that no further nourishment will occur is valid, as the County won't be able to financially support a non- federal project and does not have an obligation to do so. The County has an obligation to support the federal project by providing the non- federal cost share and complying with the FDEP permit conditions; the County does not have an obligation to fund and construct nourishment projects absent federal funding and participation. The County did not conduct any nourishment projects between 1971 and 1980 (i.e., between initial construction and the first nourishment project) or between 1980 and 1999 (i.e., between the first and second nourishment projects) when federal funding was unavailable. The County's non-federal nourishment actions have been limited to small-scale emergency truck haul projects to protect public infrastructure when storm damage appeared imminent. The Beach-fx FWOP simulations included such emergency nourishments. The reference to the fill eroding in 10 years is an outdated statement that the original report failed to correct. The FWOP simulation actually assumed the fill would erode in 20 years; the revised report will update the outdated/inconsistent language that referenced 10 years". This assumption is valid based on prior project performance. As documented in Table 3.8 of Appendix A, several minor channel maintenance dredging events occurred during the 1980's and early 1990's following the 1980 federal nourishment project. These projects failed to prevent the fill from eroding away; by the early to mid- 1990's, severely eroded conditions characterized the entire study area, prompting the County to conduct emergency truck haul projects and other emergency measures while awaiting renewal of federal participation. ASACW/HQUSACE Initial Assessment: Comment is resolved. See response to comment A-3. ASACW/HQUSACE Final Assessment: Comment is resolved. 3. Planning objectives. Concern: Plan formulation and selection is fundamentally flawed, as it was based off of one planning objective that is too specific to allow for a meaningful evaluation in terms of St. Lucie County, Florida 21 ASACW Section 203 - Ft. Pierce Shore Protection Project Review Assessment This is a preliminary review assessment. The Administration is still completing its internal review of the Ft. Pierce Feasibility Study. The Army requests that further distribution of the assessment be limited. Page 101 of 148 the P&G, an objective NEPA analysis, nor a Section 404(b)(1) guidelines alternatives analysis (40 CFR 230.11(a)). Further, the planning process for this report seems to be inappropriately skewed towards erosion abatement and maintaining a recreational beach/supporting tourism, whereas USACE's mission is focused on Coastal Storm Risk Management, with recreation being incidental (see 3-4 and 3-4 b.(2) of ER 1105-2-100). Page 47 of the report lists the planning objective as "Maintain the functionality of the currently authorized SPP, but increase the nourishment interval from two years to a minimum of four years by implementing shore stabilization structures." Therefore, any measure or alternative that doesn't include shore stabilization structures and a minimum 4 year nourishment interval would not meet the objective. This pre -maturely eliminated multiple feasible and reasonable measures from the plan formulation process including all non- structural measures (elevation, acquisition, flood proofing), dunes and vegetation, and sand covered soft structures. The formulation is also flawed in that it did not consider sand bypassing as an alternative to hard structures in the hot spot just south of the jetty, which the report acknowledges as something the State of Florida has recommended; or if there is a need for measures to address other sources of coastal storm damage such as flooding/storm surge on the back side of the barrier island. Basis for concern: See Appendix B 2.a. of ER 1165-2-209 which requires that problems and opportunities "should not prescribe a particular alternative, and should facilitate formulating all reasonable alternative that would potentially satisfy the need for a project." Also see Question 4c of CEQ's 40 most asked questions of NEPA, which states "the statement must be objectively prepared and not slanted to support the choice of the agency's preferred alternative over the other reasonable and feasible alternatives." Significance of concern: High, as it affects plan formulation and selection, as well as NEPA and CWA Section 404 compliance. Action needed to resolve concern: Revise the planning objectives for the study to address the problem(s) and opportunity(ies) related to Coastal Storm Risk Management within the study area. Conduct an objective formulation process inclusive of non- structural and structural measures, combining measures as needed to develop complete, efficient, effective, and acceptable alternative plans that can be objectively evaluated and compared consistent with the P&G, NEPA requirements, and Section 404(b)(1) guidelines. Local Sponsor Response: The recommended plan is based on Beach-fx results, which pertain to coastal storm risk management (CSRM), not recreation; recreation benefits were calculated separately after identification of the NED Plan. The analysis did not pre -determine a nourishment interval; as discussed in Appendix A, results of numerical modeling indicated structures could retain fill for 4 years, at which point the fill was completely eroded away in certain areas. The study only reports the Beach-fx results of structures with a 4-year nourishment interval, as this proved the optimum scenario. The Beach-fx model iterations included results with 2-year and 3-year nourishment St. Lucie County, Florida 22 ASACW Section 203 - Ft. Pierce Shore Protection Project Review Assessment This is a preliminary review assessment. The Administration is still completing its internal review of the Ft. Pierce Feasibility Study. The Army requests that further distribution of the assessment be limited. Page 102 of 148 intervals for scenarios with and without structures; however, the benefits and costs proved less favorable. The early screening of non- structural solutions is valid and consistent with similar recently completed USACE CSRM feasibility studies. The revised report will include additional explanation/discussion as necessary to clarify the plan formulation and screening process. The report cannot include bypassing from the sediment deposition basin, as the basin has not been constructed and proven effective. Additionally, the basin's maximum estimated annual contribution to bypassing is less than the documented annual erosion rate (and less than FDEP's recommended annual bypassing rate); thus, structures will be required regardless to meet the Beach-fx results. An effective basin could help extend the nourishment interval beyond 4 years and greatly improve the BCR, thus a future study should consider the effects of the sediment impoundment basin after construction and performance monitoring. ASACW/HQUSACE Initial Assessment: Comment is unresolved. The response provided did not address the crux of the comment that the one planning objective is too narrowly defined to allow for an objective plan formulation process, objective NEPA analysis, or objective 404(b) (1) guidelines analysis. We would be willing to meet with the sponsor to provide further assistance on this matter. As a reference, the Planning Manual (IWR report 96-R-21) provides a good discussion on planning objectives on pages 79-95. In particular, see page 86 — "Though specific, an objective should not specify an absolute target as the only level of the desired result;" and "objectives should not include solutions, i.e., neither individual management measures, alternative plans, nor programs... Objectives should not specify the measures or plans that can be used to meet the objective." Local Sponsor Response: As mentioned, we made substantial revisions to the plan formulation discussion throughout Chapter 3. We added a new Table 3.2 containing additional Beach-fx results for the incremental analysis of beach nourishment and revised the Section 3.8 discussion. Section 3.5 of the Economics Appendix also includes a revised discussion of the screening process that identified the Recommended Plan. ASACW/HQUSACE Final Assessment: The comment remains unresolved and the concern in the initial assessment still applies. In the event that the recommended plan is authorized for federal participation, it is expected that this unresolved issue would need to be prior to implementation. 4. FDEP and St. Lucie County partnership implementation actions. Concern: The implementation actions listed on Page 54 list "Evaluate possible alternatives to facilitate bypassing of sand from the shoreline north of the inlet to the down drift beaches." Later in the report on pages 101- 102, and Page7, references that the non- Federal sponsor provides local sponsorship to the State of Florida for implementing the State's Fort Pierce Inlet Management Plan. In 2004, Taylor Engineering completed a study for the non -Federal sponsor to identify an annual St. Lucie County, Florida 23 ASACW Section 203 - Ft. Pierce Shore Protection Project Review Assessment This is a preliminary review assessment. The Administration is still completing its internal review of the Ft. Pierce Feasibility Study. The Army requests that further distribution of the assessment be limited. Page 103 of 148 bypassing operation that could either meet the state adopted bypassing requirements or, at a minimum, supplement the Corps SPP just south of Fort Pierce Inlet. "The study identified two alternatives — north jetty sand tightening with mobile sand bypassing plant and north jetty sand tightening with nearshore dredging — reasonable attractive alternatives to bypass sand across the inlet." In addition, page 101 continues to state that the non- Federal sponsor has "recently" (i.e. 2010) completed a feasibility study of a third alternative — construction of a sediment basin in the inlet. Finally, on page 107 — Coastal Zone Management Act of 1972, notes "that the current State of Florida permit for shore protection project requires the local sponsor to provide the State with a sediment bypassing plan. "To that end, the State of Florida and the local sponsor are examining the potential for a sediment deposition basin within Fort Pierce Inlet." Basis of concern: The report is silent on the current (i.e. 2017) status of the State's Fort Pierce Inlet Management Plan for including a sediment deposition basin in the inlet and what assumptions with regard to the FWOP and FWP conditions were made during this study of future improvements to the Fort Pierce shore protection project. Significance of concern: High. Could impact the recommended plan and accurately estimate the project costs and benefits. It appears that the last report of bypassing report was 2010. Action needed to resolve concern: It is highly recommended that the report provide more complete discussion of the inlet management plan, an update on the status of dredging a deposition basin in the inlet, and what effects (if any) the implementation of this features would have on the recommended plan. Local Sponsor Response: As mentioned in our response to the previous comment, we cannot include bypassing from the sediment deposition basin, as the basin has not been constructed and proven effective, nor has construction funding been appropriated. The past recommendation of north jetty sand tightening and a mobile bypassing plant did not have sufficient support from the local community for implementation. The revised report will provide additional explanation to clarify these points. ASACW/HQUSACE Initial Assessment: Comment is resolved pending review of revised report. Local Sponsor Response: Chapter 3 includes a more thorough accounting of the sediment deposition basin. ASACW/HQUSACE Final Assessment: This concern remains unresolved— see assessment for Comment B1. In the event that the recommended plan is authorized for federal participation, it is expected that this unresolved issue would need to be addressed prior to implementation. St. Lucie County, Florida 24 ASACW Section 203 - Ft. Pierce Shore Protection Project Review Assessment This is a preliminary review assessment. The Administration is still completing its internal review of the Ft. Pierce Feasibility Study. The Army requests that further distribution of the assessment be limited. Page 104 of 148 5. Screening of Nonstructural Plans. Concern: The plan formulation screens out all nonstructural measures, most often using local objectives as a rationale. The purpose of a Federal project is to reasonably maximize net National Economic Development (NED) benefits. As written, the report does not provide sufficient detail for screening nonstructural measures from Federal consideration. Basis of concern: ER 1105-2-100 Paragraph 2-3.c.(5); Paragraph 2-3d.(2). Significance of concern: Significant. Could have an impact on plan recommendation. Action needed to resolve concern: Provide more sufficient and appropriate rationale for screening of nonstructural measures or fully analyze those nonstructural measures. Also, please note the overlap with the comment on Executive Order 11988. Local Sponsor Response: As mentioned, the early screening of non-structural solutions is valid and consistent with similar recently completed USACE CSRM feasibility studies. The revised report will include additional explanation/discussion as necessary to clarify the screening process. ASACW/HQUSACE Initial Assessment: Comment is unresolved. More explanation discussion is needed to resolve the concern. As noted in response to comment A-9, it appears that the nonstructural plans were not fully considered and screened based on local objectives of recreation and tourism. Local Sponsor Response: The previously mentioned revisions to Chapter 3 (particularly revisions to Section 3.6 and Table 3.1) address the above comment regarding screening of non-structural solutions. ASACW/HQUSACE Final Assessment: The comment remains unresolved. Sufficient information is not included in the report to screen out all of the nonstructural measures and make a determination if the recommended plan is truly the NED Plan. In the event that the recommended plan is authorized for federal participation, it is expected that this unresolved issue would need to be addressed prior to implementation. C ENVIRONMENTAL 1. Environmental Consequences: Concern: The environmental consequences chapter of the report is insufficient to comply with NEPA or CEQ evaluation procedures of the P&G in that it does not consider any environmental impacts from the placement of the T-groins and breakwater and only assesses the recommended plan against the no -action alternative. Even if these hard structures are proposed to be completely within the footprint of the beach fill design template, they will become exposed over time between nourishment intervals and will lead to impacts not previously considered in other NEPA documents/feasibility reports. These structures can obstruct access to nesting beaches for sea turtles, cause adverse visual/aesthetic impacts, interfere with recreation potentially creating a safety hazard for St. Lucie County, Florida 25 ASACW Section 203 - Ft. Pierce Shore Protection Project Review Assessment This is a preliminary review assessment. The Administration is still completing its internal review of the Ft. Pierce Feasibility Study. The Army requests that further distribution of the assessment be limited. Page 105 of 148 swimmers, and completely eliminate intertidal and subtidal habitat (depending on location of MHW) within their footprint. While mitigation was conducted for hard bottom impacts of the original design template, it is not clear if these hard, permanent structures would lead to new impacts not considered with just beach nourishment (in that hard bottom and other submerged resources could recolonize the area between nourishment events, but will not be able to do so within the footprint of the T-groins or breakwater). Basis of concern: Appropriate assessment of environmental consequences per 40 CFR 1502.16 "the environmental effects of alternatives including the proposed action." See Question 7 in CEQ's 40 most asked questions of NEPA; Section 3.3.5(h) of the P&G; Sections 3.4.10 and 3.4.11 of the P&G. Significance of concern: High, as it affects environmental acceptability of the recommended plan. Action needed to resolve concern: Re -write the environmental consequences chapter to assess all effects of the recommended plan and the final array of alternatives consistent with the requirements in NEPA 40 CFR 1502.16 and CEQ evaluation procedures within 3.4.11 of the P&G including the duration, location, and magnitude of those effects. Any conclusions in this chapter including whether compensatory mitigation is required should be based on all of the effects of a given alternative, paying particular attention to those impacts not previously considered for the existing beach fill template with a 2 year nourishment cycle using Capron Shoal as a borrow source. Local Sponsor Response: The revised report includes appropriate edits in Chapter 4 to address the above review comment. ASACW/HQUSACE Initial Assessment: Comment is resolved pending review of revisions made to the report. Local Sponsor Response: We revised Chapter 4 to include additional information. ASACW/HQUSACE Final Assessment: The Review Team cannot resolve this comment as satisfactory consideration to environmental consequences has not been conducted and documented. In the event that the recommended plan is authorized for federal participation, it is expected that this unresolved issue would need to be addressed and the associated environmental compliance activities must be completed prior to implementation of the project. 2 Agency Consultation. Concern: Note that updated consultation will need to be completed to comply with several environmental requirements including Section 7 of the Endangered Species Act, Fish and Wildlife Coordination Act, Essential Fish Habitat amendments to the Magnuson Stevens Fisheries Conservation and Management Act, Section 401 water quality certification, Coastal Zone Management Act, and other Federal environmental laws. The St. Lucie County, Florida 26 ASACW Section 203 - Ft. Pierce Shore Protection Project Review Assessment This is a preliminary review assessment. The Administration is still completing its internal review of the Ft. Pierce Feasibility Study. The Army requests that further distribution of the assessment be limited. Page 106 of 148 report describes how consultation/compliance was initiated for some of these requirements in the 2007-2008 timeframe. However, changed circumstances over the last 10 years including listing of new species and updated evaluation procedures will require re -initiation of consultation. It also appears that analysis of impacts to fish and wildlife including a determination that compensatory mitigation is not needed (EFH, FWCA), CZM consistency, and the proposed use of programmatic BiOps (ESA) did not consider impacts from T-groin/breakwater construction. Environmental compliance needs to cover all impacts associated with the recommended plan to be legally and policy compliant. Basis of concern: Legal and policy compliance with environmental laws and regulations. Environmental compliance requirements will need to be satisfied prior to USACE endorsement of any final report. Significance of concern: Medium/High, as it affects environmental acceptability of the plan. Action needed to resolve concern: See ER 1165-2-209, Appendix B 2.h.(1). It is recommended that the NFS enter into a MOA (per Section 1126 of WRDA 2016) with the local USACE district office to formally initiate consultation under these requirements as they are inherently governmental and compliance cannot be satisfied by a non - Federal entity. If the NFS elects to not pursue a MOA for environmental compliance, then the NFS needs to submit the necessary information to initiate these consultations (draft environmental compliance documents such as a Biological Assessment inclusive of T-groin and breakwater impacts) with a Section 203 feasibility report. Local Sponsor Response: St. Lucie County intends to enter into a MOA with USACE Jacksonville District for assistance with agency consultation. ASACW/HQUSACE Initial Assessment: No further action is required. Upon further review by Army Counsel, it was determined that section 1126 does not provide authority for the Army to enter into an MOA to accept non -Federal funds to complete inherently governmental actions, such as agency consultation. Further, since this is a non -Federal study conducted pursuant to section 203, there is no requirement for the non -Federal interest to perform these functions. However, we encourage the non -Federal interest to provide as much information regarding environmental considerations as possible to further future environmental compliance actions should this project be authorized by Congress. ASACW/HQUSACE Final Assessment: The Review Team is unable to certify environmental acceptability of the proposed project, given that environmental compliance and consultations have not occurred on the entirety of the proposal. Since at this point the Section 203 Report is not a Federal Action, NEPA and other Federal environmental compliance has been determined not to be required at this time. St. Lucie County, Florida 27 ASACW Section 203 - Ft. Pierce Shore Protection Project Review Assessment This is a preliminary review assessment. The Administration is still completing its internal review of the Ft. Pierce Feasibility Study. The Army requests that further distribution of the assessment be limited. Page 107 of 148 However, should the proposal be authorized by Congress, the proposal will become a Federal action subject to NEPA and other Federal environmental compliance. While the study includes references to multiple previous NEPA documents and environmental consultations, there appears to be multiple gaps in environmental compliance for the current proposal. Future NEPA and other environmental compliance may rely heavily on previous information and incorporate such information by reference, but updated compliance/consultation will likely be required as part of any post -authorization analysis for the following requirements: • National Environmental Policy Act • Endangered Species Act • Fish and Wildlife Coordination Act • Essential fish habitat consultation • Marine Mammal Protection Act • Clean Water Act (404 compliance and 401 certification) • Coastal Zone Management Act 3 404(b)(1). Concern: The Section 404(b)(1) analysis is insufficient to make a determination of compliance with the guidelines. Appendix G provides no discussion of impacts associated with T-groin/breakwater placement and does not include an analysis of alternatives demonstrating that the selected plan is also the least environmentally damaging practicable alternative. Appendix G also provides no discussion of actions to minimize adverse effects consistent with 40 CFR 230.10(d) and Subpart H of the 404(b)(1) guidelines (40 CFR230.70-230.77). Basis of concern: 40 CFR 230.5(c) states "Examine practicable alternatives to the proposed discharge ... or discharging into an alternative aquatic site with potentially less damaging consequences." 40 CFR 230.10(a) "no discharge of dredged or fill material shall be permitted if there is a practicable alternative to the proposed discharge which would have less adverse impacts on the aquatic ecosystem" 40 CFR 230.10(d) "no discharge of dredged or fill material shall be permitted unless appropriate and practicable steps have been taken which will minimize potential adverse impacts of the discharge on the aquatic ecosystem. Subpart H identifies such possible steps." Siqnificance of concern: Medium/High, as it affects environmental acceptability of the plan. Action needed to resolve concern: In the beginning of Appendix G, provide an analysis of the final array of alternatives' impacts on the aquatic environment to make a determination whether the recommended plan is the least environmentally damaging in accordance with 40 CFR 230.10(a)-(d) prior to going into the factual determinations. Provide an adequate description of all practicable steps that have been taken to minimize potential adverse impacts on the aquatic ecosystem, consistent with 230.10(d) and Subpart H of the 404(b)(1) guidelines. Ensure that the 404(b)(1) guidelines St. Lucie County, Florida 28 ASACW Section 203 - Ft. Pierce Shore Protection Project Review Assessment This is a preliminary review assessment. The Administration is still completing its internal review of the Ft. Pierce Feasibility Study. The Army requests that further distribution of the assessment be limited. Page 108 of 148 compliance determination includes all impacts of each of the alternatives, inclusive of the permanent loss of waters of the U.S. associated with T-groin and breakwater construction. Local Sponsor Response: The revised report includes the recommended edits to Appendix G. ASACW/HQUSACE Initial Assessment: Comment is resolved pending review of revisions made to the report. Local Sponsor Response: We added a significant amount of additional information to Appendix G and Chapter 4 of the main report. ASACW/HQUSACE Final Assessment: Comment is unresolved based on the information provided. In the event that the recommended plan is authorized for federal participation, it is expected that this unresolved issue would need to be addressed and the associated environmental compliance activities must be completed prior to implementation of the project. 4. Completeness of NEPA Documentation. Concern: Some components of a complete NEPA document are missing from the report including a NEPA purpose and need statement (40 CFR 1502.13), a list of preparers (40 CFR 1502.17), and an adequate discussion of the built environment as part of the affected environment/existing conditions in Chapter 2. The discussion of the built environment only covers hurricane evacuation routes and does not cover existing buildings, land use, and other critical infrastructure (police/fire stations, hospitals, transportation corridors, water supply/treatment facilities, power plants/substations, etc.) that are critical components in assessing coastal storm risk. Further, this discussion is lacking socioeconomic data such as demographics, population, and environmental justice that are relevant to managing coastal storm risk for that population. Basis of concern: A legally sufficient NEPA document will include all components required in the CEQ regulations (40 CFR 1500 et seq) and USACE NEPA implementing regulations at 33 CFR 230 & ER 200-2-2. Significance of concern: Medium. Action needed to resolve concern: Add a statement indicating the NEPA purpose and need for the study to Section 1.3 of the report. Add a list of preparers to the report. Develop Section 2.4 of the report to include a brief discussion of existing structures/land use including any critical infrastructure as well as a discussion on demographics within the study area. Local Sponsor Response: The revised report includes the requested information in Section 1.3 and includes a new Section 2.4.1 as shown below to address land use St. Lucie County, Florida 29 ASACW Section 203 - Ft. Pierce Shore Protection Project Review Assessment This is a preliminary review assessment. The Administration is still completing its internal review of the Ft. Pierce Feasibility Study. The Army requests that further distribution of the assessment be limited. Page 109 of 148 and existing structures. Similar to other USACE feasibility studies (e.g., South St. Lucie and Flagler County), this report includes the socioeconomic data in Appendix C — Economics. However, to address the review comment, the revised report also includes this information in Section 2.4.4 as shown below. Appendix I of the revised report includes a list of preparers. "2.4.1 Land Use and Structures Existing Conditions No structures (e.g., piers, docks) exist in the project area on the beach or in the nearshore. Three beachfront parks (Jetty Park, South Beach Park, and Kimberley Bergalis/Surfside Park) occur within the project area. The remainder of the upland along the project area is largely residential area with single family or multi -family residences and rental units. Several small commercial buildings and restaurants occur immediately south of Jetty Park at the north end of the project area. U.S. Hwy AM runs parallel to the shoreline typically about 150 to 250 ft inland of the beach. No critical public structures (e.g., police or fire stations, hospitals, power substations, water supply or treatment facilities) exist within the project area. Future Without -Project Conditions (No -Action Alternative) Further beach erosion will threaten the land uses and structures along the beach." "2.4.4 Demographic Characteristics According to the US Census Bureau, the 2010 population of St. Lucie County was 277,789 with a land area of 571.93 square miles. Over the past several years, the county has seen rapid population growth. Between 2000 and 2010, the county grew by approximately 44%. Since then, the population has grown by 7.5% to reach an estimated 298,563 in July 2015. The ethnic makeup of St. Lucie County is relatively homogeneous, with Caucasians (non -Hispanic) composing approximately 59.0% of the population. The largest minority groups are African American and Hispanic, which make up approximately 20.3% and 17.9% of the population. All other racial groups combined comprise about 2.8% of the total population. The median age for residents is 43.3 and those aged 60 years and over represent 27.4% of the population. Overall, St. Lucie County is largely an adult population with those aged 18 years and older at 77.7%. Future Without -Project Conditions (No -Action Alternative) St. Lucie County, Florida 30 ASACW Section 203 - Ft. Pierce Shore Protection Project Review Assessment This is a preliminary review assessment. The Administration is still completing its internal review of the Ft. Pierce Feasibility Study. The Army requests that further distribution of the assessment be limited. Page 110 of 148 The FWOP condition is not expected to differ from existing conditions." ASACW/HQUSACE Initial Assessment: Comment is resolved pending review of revisions made to the report. Local Sponsor Response: The revised report includes the above additions. Chapter 7 includes the list of preparers. ASACW/HQUSACE Final Assessment: Comment cannot be resolved with the information provided. In the event that the recommended plan is authorized for federal participation, it is expected that this unresolved issue would need to be addressed and the associated environmental compliance activities must be completed prior to implementation of the project, including review by the public and State & Agencies. D ECONOMICS 1. Depth Damage Functions. Concern: The Report uses depth -damage functions for large buildings that were created specifically for this study. It is unclear from the analysis whether these damage curves have been peer reviewed. Basis of concern: Appropriate site specific depth -damage functions being applied; see ER 1105-2-100 Paragraph E-24.f.(2)(f). Sianificance of concern: Minor/Moderate. Action needed to resolve concern: Provide adequate peer review documentation of the depth damage functions. Local Sponsor Response: The revised report includes documentation of an ITR, which peer -reviewed the depth -damage functions. ASACW/HQUSACE Initial Assessment: Comment will be resolved upon review of the additional information. Local Sponsor Response: Sub -Appendix H-2 includes the technical review comments regarding the depth damage functions. The economics specialist provided review comments regarding the Economics Appendix and separate review comments regarding the Sub -Appendix C-2 Christopher P. Jones Draft White Paper — Large Building Flood Damage Functions. ASACW/HQUSACE Final Assessment: Comment is resolved. 2. Interest During Construction. St. Lucie County, Florida 31 ASACW Section 203 - Ft. Pierce Shore Protection Project Review Assessment This is a preliminary review assessment. The Administration is still completing its internal review of the Ft. Pierce Feasibility Study. The Army requests that further distribution of the assessment be limited. Page 111 of 148 Concern. It is unclear from the economic analysis if Interest During Construction (IDC) was included in the economic costs. Basis of concern: IDC is an important economic cost that must be accounted for in plan selection and justification; ER 1105-2-100 Appendix D Para D-3.e. (11). Significance of concern: Moderate/Significant. If alternative plans have significantly different construction schedules then this could impact plan selection. It will also impact the benefit -to -cost ratio. Action needed to resolve concern: Update the economic analysis to appropriately include Interest During Construction (IDC). Local Sponsor Response: St. Lucie County will ensure that the economic costs in the revised report include IDC. The County intends to request USACE Jacksonville District (via a MOA) or other independent personnel to review the cost calculations. ASACW/HQUSACE Assessment: Comment will be resolved upon review of the additional information. Local Sponsor Response: As documented in Sub -Appendix H-2, the economics specialist provided the following review comment regarding IDC: Interest during construction is computed and shown for projects for which costs and benefits are expressed in present value at a point in time after initiation of construction. Costs (and benefits) occurring before this point in time must be converted to a present value equivalent in the same way that costs and benefits taking place after this point in time are converted. IDC is simply the interest part of the time value conversion equivalent. In the case of this project, all costs and benefits are converted to equivalent time values at the beginning of the 50-year period of analysis, the beginning of FY2021. There are no costs occurring prior to this point in time, so there is no "IDC." For some used to the convention of reporting and calculating IDC, who may not be familiar with the underlying concept, the absence of an IDC line item in the B/C evaluation may seem like a problem, standing out as a "red flag." It is not a problem. Any point in time can be used for these calculations. The numbers will be different, but the B/C ratio will be exactly the same, as will the alternative with the largest net benefits. The internal rate of return will also be the same, as will the rank order of alternatives, etc. The findings of the economic evaluation will also for all practical purposes be the same whether FY2017 or FY2021 prices are used throughout. The important thing is consistency in the present value calculations and in the price level used in the evaluation process. ASACW/HQUSACE Final Assessment: The Review Team cannot resolve this comment. IDC is a required component of economic analyses. In the event that the St. Lucie County, Florida 32 ASACW Section 203 - Ft. Pierce Shore Protection Project Review Assessment This is a preliminary review assessment. The Administration is still completing its internal review of the Ft. Pierce Feasibility Study. The Army requests that further distribution of the assessment be limited. Page 112 of 148 recommended plan is authorized for federal participation, it is expected that this unresolved issue would need to be addressed prior to implementation. 3. Incremental Analysis. Concern: The plan formulation and economic analysis appear to have only looked at incremental analysis for various dune and berms sizes. It is unclear that incremental analysis of length of project and number and size of T-groins was conducted. For example, according to Table 2 of the Economic Appendix, Reaches 4 and 5 account for approximately 82% of the economic value. It must be demonstrated that a project in those reaches alone would not provide higher net NED benefits than the full project length. Size and number of T-Groins must also be incrementally evaluated. Basis of concern: Reference ER 1105-2-100 Paragraph f.(4) and Paragraph 2-4.e. Significance of concern: Significant. Calls into question the recommended plan. Action needed to resolve concern: Conduct an incremental analysis and clearly demonstrate that the recommended plan is incrementally justified. It is not incrementally justified, then the portions that are not must be removed from the NED Plan and taken out of the recommendation or a Locally Preferred Plan (LPP) must be approved by the ASA(CW) at 100% non -Federal sponsor responsibility. Please note that the Future Without Project Condition comment will impact the incremental analysis. Local Sponsor Response: Beach-fx is a planning tool with no capability to directly simulate the effect of structures. Thus, an incremental analysis of the number and size of structures is not feasible with Beach-fx (USACE's mandatory economic model). The structure design and numerical modeling performed is sufficient for a feasibility study. Taylor Engineering developed the current design based on accepted methodologies specified in USACE's Coastal Engineering Manual; USACE Jacksonville District reviewed and approved of the design during review of the 2008 GRR. The design and permitting phase subsequent to approval of this study would further evaluate and refine the structure design. The structures as currently designed (and cost estimated) prove more economical than nourishment only. The incremental analysis would only improve upon the design and BCR. We can run Beach-fx to analyze various project lengths. However, as mentioned in the report, the distribution of value by length is uniform throughout the project area; the lower total values for Reach 1-3 reflect the much shorter reach lengths compared to Reach 4-5. The FWOP damages in Reach 1-3 are greater than their proportional length of the project area, likely due to the higher background erosion rates in this area. Additionally, as mentioned above, Beach-fx is a planning tool, not a design tool. The extensive knowledge we have of the project's performance, particularly that the fill acts as a feeder and effectively nourishes 2.3 miles of beach with only 1 mile of fill placement, must be considered in conjunction with the Beach-fx results to identify a logical project design. The project mitigates for erosion caused by a federal inlet, St. Lucie County, Florida 33 ASACW Section 203 - Ft. Pierce Shore Protection Project Review Assessment This is a preliminary review assessment. The Administration is still completing its internal review of the Ft. Pierce Feasibility Study. The Army requests that further distribution of the assessment be limited. Page 113 of 148 and excluding the highest erosion area adjacent to the south jetty does not seem logical. ASACW/HQUSACE Initial Assessment: Comment is unresolved. Policy established in the Principles and Guidelines as well as in the Planning Guidance Notebook require an incremental analysis of separable elements. Those are defined by law as having independent hydrologic effects and stand alone benefits. For storm damage reduction projects, this includes length of sand placement (berm and dune) as well as the number of groins. The Federal objective is to maximize net National Economic Development benefits subject to protecting the environment. Without this analysis, the recommended plan cannot be supported. Although the report states that the NED plan includes the "optimized" berm and dune dimensions, there is no data presented to support this assertion. The revised report should include (in the Economics Appendix at least) summary data showing the average annual costs and benefits by reach for each of the various berm and dune alternatives that were analyzed. In addition, the report should show that a sufficient number of alternatives were analyzed in order to demonstrate that the NED plan has been properly "bracketed", ie, that there are not smaller or larger plans that would have produced higher net benefits. This is a practice that all storm damage reduction projects are held to. For example, the recently conducted St Lucie County feasibility study included numerous alternatives by length and size that demonstrated economic justification while optimizing design. Another example is the St John's County feasibility study. Those reports can be provided as reference upon request. With respect to Beach-fx, the model, a methodology has been developed by the USACE ERDC laboratory to attempt to account for the shoreline changes of groins. The groin effects would have to be estimated outside Beach-fx and then modeled as a planned nourishment, with the groin effects entered as a berm width change. The value of the groins would be demonstrated by life cycle cost savings with and without the groins. Recommend a meeting with the sponsor and the appropriate ERDC personnel to work through the issue. Local Sponsor Response: Section 3.12 includes a discussion of Incremental Justification of the Recommended Plan. As mentioned, the Economics Appendix and Chapter 3 include additional information regarding the incremental analysis of beach nourishment scenarios. Sub -Appendix A-4 includes the Incremental Analysis of Structures. Sub -Appendix A-5 includes the 2002 Design Documentation Report that provides additional information regarding the design of the structures but fell short of providing details of the incremental analysis mentioned in the document. ASACW/HQUSACE Final Assessment: The concern remains unresolved. The information provided does not adequately address the comment nor does it address St. Lucie County, Florida 34 ASACW Section 203 - Ft. Pierce Shore Protection Project Review Assessment This is a preliminary review assessment. The Administration is still completing its internal review of the Ft. Pierce Feasibility Study. The Army requests that further distribution of the assessment be limited. Page 114 of 148 Federal Interest in the plan selected based on incremental analysis. It is noted that the information shows overall justification of the project, but it does not support the scale of the project being recommended. In the event that the recommended plan is authorized for federal participation, it is expected that this unresolved issue would need to be addressed prior to implementation. 4. Nourishment Interval. Concern: The analysis appears to have only looked at 2 year and 4 year nourishment intervals. Nourishment intervals should be optimized to maximize net NED Benefits. Greater nourishment intervals than 4 years should be analyzed to demonstrate that it is not more efficient to do less frequent nourishments. This is considered equivalent to an incremental analysis. Basis of concern: Reference ER 1105-2-100 Paragraph f.(4) and Paragraph 2-4.e. Significance of concern: Significant. Could impact the recommended plan. Action needed to resolve concern: Conduct an analysis of intervals greater than 4 years to clearly demonstrate that 4 years estimates is the NED Plan. Please note that the Future Without Project Condition comment will impact the incremental analysis. Local Sponsor Response: As mentioned above, the analysis did not pre -determine a nourishment interval. As discussed in Appendix A, results of numerical modeling indicated structures could retain fill for 4 years, at which point the fill was completely eroded away in certain areas. The study only reports the Beach-fx results of structures with a 4-year nourishment interval, as this proved the optimum scenario. The Beach-fx model iterations included results with 2-year and 3-year nourishment intervals for scenarios with and without structures; however, the benefits and costs proved less favorable. Beach- fx is not capable of modeling structures; thus, the study had to mimic the effect of structures by reducing the planform change rate in Beach-fx for Reaches 1-3. The rates could be reduced even further to attempt to achieve a 5-yr nourishment interval to demonstrate the additional cost effectiveness; however, the current model results provide a BCR sufficient for federal authorization, and the numerical model results indicated nourishment appeared necessary after 4 years. Future efforts such as a subsequent design phase for the structures and construction and performance monitoring of the sediment impoundment basin will strive to decrease the federal nourishment frequency and, hence, project costs. The recommended beach fill design for the nourishment -only case is based on an incremental analysis of beach fill widths that did not limit the nourishment interval. ASACW/HQUSACE Initial Assessment: Comment is unresolved. It is unclear from the response if the concern has been addressed. It appears from the response that the criteria for a nourishment is the design berm with advanced fill rather than life cycle erosion with nourishment triggers. Follow-on discussions with subject matter experts are suggested. St. Lucie County, Florida 35 ASACW Section 203 - Ft. Pierce Shore Protection Project Review Assessment This is a preliminary review assessment. The Administration is still completing its internal review of the Ft. Pierce Feasibility Study. The Army requests that further distribution of the assessment be limited. Page 115 of 148 Local Sponsor Response: In the main report, we added a new Table 3.2 containing additional Beach-fx results for the incremental analysis of beach nourishment scenarios and revised the Section 3.8 discussion. Section 3.5 of the Economics Appendix also includes a revised discussion of the screening process that identified the optimal plan. ASACW/HQUSACE Final Assessment: The concern remains unresolved. The information provided does not adequately address the comment nor does it address Federal Interest in the plan selected based on incremental analysis. It is noted that the information shows overall justification of the project, but it does not support the scale of the project being recommended. In the event that the recommended plan is authorized for federal participation, it is expected that this unresolved issue would need to be addressed prior to implementation. 5. Parking and Access. Concern: The parking and access appendix F demonstrates very limited parking beginning at Seaway Inlet Dr and south to monument R-038. According to Figures 2.2a and 2.2b of the appendix, there are only 18 parking spaces for greater than 2,560 linear feet of shoreline; note that lengths stop on figure 2.2b show the actual length is greater than that. This minimal number of parking spaces calls into question the extent of access the public has to the shoreline. At a minimum, it must be document that parking is sufficient to meet recreational demand claimed in the project benefits. Basis of concern: Reference ER 1165-2-130 Paragraph 6.h.(2). Significance of concern: Significant. Lengths of shoreline with insufficient parking may not warrant Federal participation. Action needed to resolve concern: Clearly demonstrate that sufficient parking exists to meet recreation demand claimed or readjust the cost apportionment appropriately to the non -Federal sponsor. Local Sponsor Response: The revised report will include an updated parking and access analysis. ASACW/HQUSACE Initial Assessment: Comment will be resolved upon review of the additional information. More documentation to satisfy the minim requirements is needed. Minimum requirements must be demonstrated to support Federal cost share or those areas that do not meet requirements will be 100% non-federal cost share. Local Sponsor Response: Appendix F contains an updated Public Access and Cost Share analysis. ASACW/HQUSACE Final Assessment: Comment is resolved. St. Lucie County, Florida 36 ASACW Section 203 - Ft. Pierce Shore Protection Project Review Assessment This is a preliminary review assessment. The Administration is still completing its internal review of the Ft. Pierce Feasibility Study. The Army requests that further distribution of the assessment be limited. Page 116 of 148 E COST & COST SHARING 1. Cost Share — Use of Section 111. Concern: The cost apportionment contained in the Main Report and Appendix F adjusts the Federal cost share from 44% to 77.76% citing a Section 111 determination from 1982. Sec 111 of the Rivers and Harbors Act of 1968 is not a standing authority to adjust cost share in perpetuity. The authority allows for specific mitigation features that can be tied to Harbor Projects and has a maximum per project Federal cost of $10M as of the Water Resources Reform and Development Act (WRRDA) 2014. Basis of concern: 33 U.S.C. 426i. Significance of concern: Significant. The comment will affect the estimate of project cost sharing. Action needed to resolve concern: The recommendation should not include Sec 111 cost share to the newly recommended project. Update the cost share to reflect the legal requirements. Local Sponsor Response: St. Lucie County understands that carrying forward the prior Sec 111 determination is not appropriate for this Section 203 study; thus, the revised report will not include the Sec 111 cost share. St. Lucie County intends to pursue the Sec 111 cost share through the appropriate authority following approval of the Section 203 study. ASACW/HQUSACE Initial Assessment: Comment will be resolved when revisions can be reviewed. Updated cost share removing the Sec 111 will satisfy the concern. Local Sponsor Response: Appendix F contains an updated Public Access and Cost Share analysis. Costs shares documented in the main report (Table ESA) and used in the Cost Engineering Appendix reflect the results in Appendix F. ASACW/HQUSACE Final Assessment: Comment is resolved. 2. Cost Share for Undeveloped Public Lands. Concern: The cost apportionment contained in the Main Report and Appendix F uses 50/50 per ER1105-2-100/ER 1165- 2-130. The concern is that, due to Section 2008(c) of WRDA 2007, ER 1105-2- 100/1165-2-130's guidance on applying a 50/50 cost share for hurricane and storm damage reduction measures for undeveloped public lands is not valid if the benefits justifying the measures are hurricane and storm damage reduction benefits and not recreation benefits and should be cost shared65/35. Basis of concern: 33 U.S.C. 426i. Significance of concern: Moderate. The comment will affect the estimate of project cost sharing. St. Lucie County, Florida 37 ASACW Section 203 - Ft. Pierce Shore Protection Project Review Assessment This is a preliminary review assessment. The Administration is still completing its internal review of the Ft. Pierce Feasibility Study. The Army requests that further distribution of the assessment be limited. Page 117 of 148 Action needed to resolve concern: The cost share for undeveloped public lands should be corrected to 65/35. Update the cost share to reflect the legal requirements. Local Sponsor Response: The revised report will apply the recommended 65/35 cost share. ASACW/HQUSACE Initial Assessment: Comment will be resolved when revisions can be reviewed. Updated cost will satisfy the concern. Local Sponsor Response: Appendix F contains an updated Public Access and Cost Share analysis with the revised cost share. ASACW/HQUSACE Final Assessment: Comment is resolved. 3. Cost Share for Periodic Nourishment. Concern: The cost apportionment contained in the Main Report and Appendix F do not appear to account for the cost share of initial placement versus periodic nourishment. Initial placement is cost shared 65/35 (where justified) but periodic nourishment is cost shared 50/50 (where justified). Basis of concern: ER 1105-2-100/ER1165-2-130. Significance of concern: Significant. The comment will affect the estimate of project cost sharing. Action needed to resolve concern: For the final recommended plan, the project costs and cost apportionment should be divided into initial placement and periodic nourishment and applied appropriately. Update the cost share to reflect the legal requirements. Local Sponsor Response: The revised report will apply the recommended 65/35 and 50/50 cost shares. ASACW/HQUSACE Initial Assessment: Comment will be resolved when revisions can be reviewed. Updated cost will satisfy the concern. Local Sponsor Response: Appendix F contains an updated Public Access and Cost Share analysis with the revised cost share. ASACW/HQUSACE Final Assessment: Comment is resolved. 4. Price Level. Concern: The report uses a cost price level of FY 2021 for the recommended plan. The appropriate cost for use is the constant dollar at current price level, which is the fiscal year of thesubmission. St. Lucie County, Florida 38 ASACW Section 203 - Ft. Pierce Shore Protection Project Review Assessment This is a preliminary review assessment. The Administration is still completing its internal review of the Ft. Pierce Feasibility Study. The Army requests that further distribution of the assessment be limited. Page 118 of 148 Basis of concern: ER 1105-2-100 Appendix D D-3.d.(2) and Director of Civil Works Memorandum dated 25 August 2011 SUBJECT: Corps of Engineers Civil Works Cost Definitions and Applicability. Significance of concern: Moderate. Action needed to resolve concern: Adjust the cost estimate to the appropriate price level at the time of the submission. For example, an FY17 submission should be FY17 price level or an FY18 submission should be an FY18 price level. Note that the economic analysis must also be portrayed using the appropriate price level. Local Sponsor Response: The comment appears contradictory to the guidance provided in ER 1165-2- 209 which states the following: "All NED/NER costs (and if applicable, benefits) must be computed at their present value at the time of the base year..." Regardless, we will adjust the costs in Table ES.1, Table 3.2, Section 3.8.5, and Table 3.6. Appendix C — Economics provides costs in both FY2017 and FY2021 price levels. ASACW/HQUSACE Initial Assessment: Comment is unresolved. The comment is not contradictory to ER 1165-2-209. This comment is referring to price level for the cost estimate that will be recommended for authorization and will establish the Sec 902 Limit for the project. Costs and benefits are developed at current price levels and then discounted and annualized for the NED (Economic) costs. Additional information from subject matter experts can be provided upon request. Local Sponsor Response: The revised report reflects a FY2018 price level. ASACW/HQUSACE Final Assessment: Comment is resolved. 5. Cost sharing and items of local cooperation. Concern: Part 3.8.4 on page 72 of the report and part 6.0 on page 110 of the report include a discussion of cost sharing and a list of items of local cooperation for the project that do not appear to comply with current law and policy. For example, both these parts of the report include what appears to be a hybrid cost sharing percentage that attempts to combine full Federal funding of construction and nourishment costs asserted to be attributable to mitigation of damages from a Federal navigation project (based on a study in 1982 pursuant to Section 111 of the River and Harbors Act of 1968, 33 U.S.C. 426i) along with non- Federal cost sharing of additional work under Section 103 of WRDA 1986. As noted by other reviewers, the Federal cost of the project exceeds the current Federal participation limit under Section 111. Moreover, the cost sharing asserted for the cost- shared portion of work under Section 103 appears to be based upon the pre- WRDA 1999 authorization of the project, which presumably would not apply to a newly sought authorization for initial construction and future nourishment of the project. In addition, the list of items of cooperation appear to omit any mention of the bar on use by St. Lucie County, Florida 39 ASACW Section 203 - Ft. Pierce Shore Protection Project Review Assessment This is a preliminary review assessment. The Administration is still completing its internal review of the Ft. Pierce Feasibility Study. The Army requests that further distribution of the assessment be limited. Page 119 of 148 the sponsor of Federal funds for its share, or the requirement to provide its required cost share during the period of design as well as construction. Basis of concern: ER 1105-2-100 para. 4-3(b)(2) ("The non -Federal sponsor cost sharing requirements, including their responsibilities for implementation and operation of the project must be clearly documented."). Significance of concern: Medium. Action needed to resolve concern: Both part 3.8.4 on part 6.0 of the report should be revised to correctly reflect the required cost sharing for the project. In addition, the list of items of local cooperation should be revised in part 6.0 to reflect current law and policy. Included below is an example of a list which comports with Corps policy and statutory cost sharing requirements, which can be used as a starting point for the District to revise to the extent needed to prepare a list applicable to the project: a. Provide a minimum of 35 percent of initial project costs assigned to coastal and storm damage reduction, plus 100 percent of initial project costs assigned to protecting undeveloped private lands and other private shores which do not provide public benefits, and 50 percent of periodic nourishment costs assigned to coastal and storm damage reduction, plus 100 percent of periodic nourishment costs assigned to protecting undeveloped private lands and other private shores which do provide public benefits, and as further defined below: (1) Provide, during design, 35 percent of design costs allocated to coastal and storm damage reduction in accordance with the terms of a design agreement entered into prior to commencement of design work for the project, (2) Provide all lands, easements, rights -of -way, including suitable borrow areas, and perform or assure performance of all relocations, including utility relocations, as determined by the Federal government to be necessary for the initial construction, periodic nourishment or operation and maintenance of the project; (3) Provide, during construction, any additional amounts necessary to make its total contribution equal to 35 percent of initial project costs assigned to coastal and storm damage reduction plus 100 percent of initial project costs assigned to protecting undeveloped private lands and other private shores which do not provide public benefits; b. Prevent obstructions or encroachments on the project (including prescribing and enforcing regulations to prevent such obstructions or encroachments) such as any new developments on project lands, easements, and rights -of -way or the addition of facilities which might reduce the outputs produced by the project, hinder operation and maintenance of the project, or interfere with the project's proper function; c. Inform affected interests, at least yearly, of the extent of protection afforded by the flood risk management features; participate in and comply with applicable Federal floodplain management and flood insurance programs; comply with Section 402 of the Water Resources Development Act of 1986, as amended (33 U. S. C. 701 b-12); and publicize floodplain information in the area concerned and provide this information to St. Lucie County, Florida 40 ASACW Section 203 - Ft. Pierce Shore Protection Project Review Assessment This is a preliminary review assessment. The Administration is still completing its internal review of the Ft. Pierce Feasibility Study. The Army requests that further distribution of the assessment be limited. Page 120 of 148 zoning and other regulatory agencies for their use in adopting regulations, or taking other actions, to prevent unwise future development and to ensure compatibility with protection levels provided by the flood risk management features; d. Operate, maintain, repair, replace, and rehabilitate the completed project, or function portion of the project, at no cost to the Federal government, in a manner compatible with the project's authorized purposes and in accordance with applicable Federal and state laws and regulations and any specific directions prescribed by the Federal government, e. For so long as the project remains authorized, ensure continued conditions of public ownership and use of the shore upon which the amount of Federal participation is based, f. Provide and maintain necessary access roads, parking areas, and other public use facilities, open and available to all on equal terms; g. At least twice annually and after storm events, perform surveillance of the beach to determine losses of nourishment material from the project design section and provide the results of such surveillance to the Federal government, h. Give the Federal government a right to enter, at reasonable times and in a reasonable manner, upon property that the non -Federal sponsor owns or controls for access to the project for the purpose of completing, inspecting, operating, maintaining, repairing, rehabilitating, or replacing the project, i. Hold and save the United States free from all damages arising from the initial construction, periodic nourishment, operation, maintenance, repair, replacement, and rehabilitation of the project, except for damages due to the fault or negligence of the United States or its contractors; j. Keep, and maintain books, records, documents, and other evidence pertaining to costs and expenses incurred pursuant to the project, for a minimum of 3 years after completion of the accounting for which such books, records, documents, and other evidence are required, to the extent and in such detail as will properly reflect total cost of the project, and in accordance with the standards for financial management systems set forth in the Uniform Administrative Requirements for Grants and Cooperative Agreements to State and local governments at 32 CFR, Section 33.20; k. Perform, or ensure performance of, any investigations for hazardous substances that are determined necessary to identify the existence and extent of any hazardous substances regulated under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), 42 USC 9601-9675, that may exist in, on, or under lands, easements, or rights -of -way that the Federal government determines to be necessary for the initial construction, periodic nourishment, operation and maintenance of the project, 1. Assume, as between the Federal government and the non -Federal sponsor, complete financial responsibility for all necessary cleanup and response costs of any hazardous substances regulated under CERCLA that are located in, on, or under lands, easements, or rights -of -way required for the initial construction, periodic nourishment, or operation and maintenance of the project, m. Agree, as between the Federal government and the non -Federal sponsor, that the non -Federal sponsor shall be considered the operator of the project for the St. Lucie County, Florida 41 ASACW Section 203 - Ft. Pierce Shore Protection Project Review Assessment This is a preliminary review assessment. The Administration is still completing its internal review of the Ft. Pierce Feasibility Study. The Army requests that further distribution of the assessment be limited. Page 121 of 148 purpose of CERCLA liability, and, to the maximum extent practicable, operate, maintain, repair, replace, and rehabilitate the project in a manner that will not cause liability to arise under CERCLA; n. Comply with Section 221 of Public Law 91-611, Flood Control Act of 1970, as amended, (42 U. S. C. 1962d-5b) and Section 101(e) of the WRDA 86, Public Law 99- 662, as amended, (33 U. S. C. 2211(e)) which provide that the Secretary of the Army shall not commence the construction of any water resources project or separable element thereof, until the non -Federal sponsor has entered into a written agreement to furnish its required cooperation for the project or separable element, o. Comply with the applicable provisions of the Uniform Relocation Assistance and Real Property Acquisition Policies Act of 1970, Public Law 91-646, as amended, (42 U. S. C. 4601-4655) and the Uniform Regulations contained in 49 CFR Part 24, in acquiring lands, easements, and rights -of -way necessary for construction, operation, and maintenance of the project including those necessary for relocations, the borrowing of material, or the disposal of dredged or excavated material; and inform all affected persons of applicable benefits, policies, and procedures in connection with said act, p. Comply with all applicable Federal and state laws and regulations, including, but not limited to: Section 601 of the Civil Rights Act of 1964, Public Law 88-352 (42 U. S. C. 2000d), and Department of Defense Directive 5500.11 issued pursuant thereto; Army Regulation 600-7, entitled "Nondiscrimination on the Basis of Handicap in Programs and Activities Assisted or Conducted by the Department of the Army", - and all applicable Federal labor standards requirements including, but not limited to, 40 U. S. C. 3141-3148 and 40 U. S. C. 3701-3708 (revising, codifying and enacting without substantive change the provisions of the Davis -Bacon Act (formerly 40 U. S. C. 276a et seq.), the Contract Work Hours and Safety Standards Act (formerly 40 U.S. C. 327 et seq.), and the Copeland Anti -Kickback Act (formerly 40 U. S. C. 276c)); and q. Not use funds from other Federal programs, including any non -Federal contribution required as a matching share therefore, to meet any of the non -Federal sponsor's obligations for the project unless the Federal agency providing the funds verifies in writing that such funds are authorized to be used to carry out the project. Local Sponsor Response: The revised report will apply the cost shares discussed under comments 1-3 above and will include the recommended edits to part 6.0. ASACW/HQUSACE Initial Assessment: Comment is resolved. Local Sponsor Response: See Chapter 6. ASACW/HQUSACE Final Assessment: Comment is resolved. St. Lucie County, Florida 42 ASACW Section 203 - Ft. Pierce Shore Protection Project Review Assessment This is a preliminary review assessment. The Administration is still completing its internal review of the Ft. Pierce Feasibility Study. The Army requests that further distribution of the assessment be limited. Page 122 of 148 Frannie Hutchinson County Commissioner District No, 4 September 14, 2022 Colonel James Booth U.S. Army District Commander U.S Army Corps of Engineers, Jacksonville District 701 San Marco Boulevard Jacksonville, FL 32207 Subject: Fort Pierce, St. Lucie County, Florida Shore Protection Project Section 203 Integrated Feasibility Study and Environmental Assessment (June 2018) WRDA 2022 - Section 403 Conditional Authorization - ASA Comment Resolution Dear Colonel Booth For more than 50 years St Lucie County has partnered with the USACE to address coastal erosion immediately downdrift (south) of the federally maintained Fort Pierce Inlet. Over this time, upwards of 5.0 million cubic yards of sand have been placed (including 12 federal beach nourishment events, approaching 13) to mitigate for the inlet's negative impact (Section I 11) on the County's southern beaches. The inlet and its jetties disrupt regional coastal processes, which in turn severely limits natural sand movements along our coast (ultimately leading to chronic, annual downdrift sand deficits). Considering this, and the ramifications of not addressing this chronic issue, has led the County to always prioritized this project (Fort Pierce Beach SPP) with the understanding that the project's benefits span well beyond the immediate construction area. This project's location and function is unique, which separates it from other shore protection projects. It is located at the start of a critically impacted coastal system, which if not maintained will ultimately lead to long-term erosional trends along our entire southern Atlantic shoreline (+/-1 5 miles). Given the realities above, County and Corp staff have worked diligently for over two (2) decades to routinely address this issue in hopes of reducing the inlet's impact on our downdrift beaches. Our objective has been to maintain a healthy level of storm protection for our adjacent residents and to maintain barrier island stability for all our stakeholders (including the FPL Nuclear Power Plant and the main hurricane evacuation route for South Hutchinson Island). As these maintenance efforts were underway and recognizing the eventual expiration of our initial 50-year partnership, the County and the USAGE (Jacksonville) set out in the early 2000's to reformulate the project to be more sustainable and to address an eventual extension of our relationship. The reformulation (including the prospect of coastal structures to abate aggressive erosion) eventually resulted in the County taking full control of the process in 2014 (due to the lack of Congressional funding). Our subsequent efforts advanced the developed the original plan envisioned while under Jacksonville direction. The project ultimately transitioned into a full-scale, non-federal feasibility report submitted by the County to the ASA's office (2018) under Section 1014 guidance provided in WRDA 2014.The hope was to have the project fully authorized by Congress and transitioned into the Planning, Engineering and Design (PED) phase of development before project expiration (originally 2020, now 2026). Due to limited access and funding for review, the ASA review process was cut short mid -stream by ASA management and the study was ultimately conditionally approved by Congress (WRDA 2020). Chris Doadovsky, District No. I — Sean MitcheH, Dlstrkt No. 2 - Linda Banz, Mstrict No. 3 — Frannp e HUWIMSM, Ustrkt No, 4 ­ Cathy Townsend, DistHct No, 5 County Adnifinistrator — Howard Tpton 2300 WrgWa Avenue Fort Nerce, FL 34982-5652 (772) 462-1451 FAX (772) 462-2131 — -rDD (772) 462-1428 RiLtchiniso�if@stnucieco.org Page 123 of 148 Most recently, County staff and your staff have been challenged to revive this effort and formally initiate a team approach to resolving the contingent nature of the feasibility study. You may have heard that resolution of this contingent authorization has been met with many challenges over the last few years; specifically, regarding the timely development of implementation guidance. The end goal being - to resolve the outstanding comments quickly and efficient) v without marginalizing or diminishing the substantial financial investments the County Previously made in lawfully preparinq and submitting this locally funded feasibility report (2018). Clearly, it is our hope that USACE management and staff seriously consider the nuances of this project (considering the history of the project and its critical function in addressing inlet impacts) while formulation a plan of action to resolve the contingent nature of this authorization, I suspect that specific due diligence will be needed to avoid a plethora of potential pitfalls that could permanently derail this effort and/or severely compromise or negate the major investments already put into this plan's formulation. The feasibility pathway and project authority may be unconventional and/or eccentric, but we hope that this is fully recognized by all Corps staff so that custom methodologies can be employed to meet this exceptional occasion. Again, there could be many dangers in addressing comments previously provided by unidentified ASA personnel. It is our hope that we can work collectively as a team to reasonably resolve these outstanding comments and streamline our future efforts, The County maintains that most of the comments as outlined in the St. Lucie County, Florida - Fort Pierce Shore Protection Project Section 203 Integrates feasibility Study and Environmental Assessment (June 2028) may have been easily resolved if proper dialog was established between County and ASA staff at the time of submission. At that time, no forum was provided to verbally discuss the rationale behind ASA comments and our responses. Given the oddity of this cooperation, it is easy to see why comments were not quickly resolved. It is my experience that face-to-face engagements are particularly needed, especially when engineering differences of option arise. To that end, we respectfully request each step in this process be thoroughly reviewed by USACE management staff and the County (to recognize unintended consequences) before any effort(s) are put into practice, Doing so may help us avoid roadblocks that could impact the substantial work product(s) already produced by the County, This letter is not intended to emphasize the lack of progress to resolve this issue over the last few years; to the contrary, this letter it is to reaffirm the County's partnership with the USACE moving forward, The County and the USACE have maintained a successful and complimentary relationship since 1971 and we look forward to the next phase in this relationship. In some ways this project is an extension of the preciously approved Shore Protection Project; in others, it is a conscious effort to make the project more resilient (so we better manage the overall cost of addressing this chronic issue). Thank you in advance for your willingness to address this critical issue for St. Lucie County. We look forward to the future of Fort Pierce Beach and are confident that our team approach will be successful in the end, Please contact me or our Coastal Engineer Joshua Revord at (772) 462-1269 if you have any questions or concerns. Sincerely, h C 4�, Frannie Hutchinson, Chair St. Lucie County Erosion District FH/JR c: St. Lucie County Erosion District Board U.S. Senator Marco Rubio Howard Tipton, County Administrator U.S. Senator Rick Scott Dan McIntyre, County Attorney U.S. Representative Brian Mast Mark Satterlee, Deputy County Administrator Greg Burns, Thorn Run Alphonso Jefferson, Deputy County Administrator Nick Mimms, City of Fort Pierce City Manager Patrick Dayan, Public Works Director Joshua Revord, Sr. Coastal Engineer Page 124 of 148 TO: Erosion District AGENDA REQUEST 2023-58611 DATE: 2/21/2023 PRESENTED BY: Joshua Revord, Senior Coastal Engineer SUBMITTED BY: Public Works SUBJECT: Work Authorization No. 08 (G.E.C., Inc.) - St. Lucie County, Florida, Coastal Storm Risk Management (CSRM) Project: Year 1 Post -Construction Physical and Biological Monitoring BACKGROUND: St. Lucie County pursued the federalization of its southern beaches in the early 2000's. The need to formally address erosion was championed by local interests in response to storm -induced erosion. The observed damage from the experienced storm events resulted in a formal federal request to the U.S. Army Corps of Engineers (USACE) for assistance in the protection of adjacent infrastructure. While pursuing future federal cooperation, a one-time (locally funded) beach project was completed (within the proposed federal beach project area) in 2013 to address persistent erosion. Eventually, a feasibly study was completed for the project area (southern 3.4 miles of St. Lucie County's Atlantic shoreline) and Congress authorized the construction of the St. Lucie County, Florida, Coastal Storm Risk Management (CSRM) Project. Federal appropriations were subsequently approved by Congress for this CSRM project, and a Municipal Service Taxing Unit (MSTU) was created by the BOCC (adjacent to the project area) to help fund future construction. In 2020, St. Lucie County's BOCC entered into a SO -year Project Partnership Agreement (PPA) with the USACE for the newly authorized federal beach project. The design, permitting, and bidding of the federal beach project were all completed in 2021, and project construction was eventually completed in May of 2022. A vital component of this recently completed beach project is environmental protection. As such, both the County and the USACE (as co-permittee's, 2020-50865) are responsible for adhering to all environmental conditions found within our active state permit (Joint Coastal Permit 0154626-001-JC) from the Florida Department of Environmental Protection (FDEP). Permit compliance conditions include, but are not limited to, post -construction physical monitoring (surveys), post -construction biological monitoring (sea turtles, shore birds, hardbottom), and a variety of other project reporting elements needed to track impacts (if any) associated with the recently completed project. The tasks identified in Work Authorization No. 08 (G.E.C, Inc.) fulfill our permit obligations, and have been reviewed/approved by the FDEP for cost -sharing under FDEP Grant 20SL3 (194486). FDEP will fund 43.49% ($196,937.90) of the proposed monitoring effort. Local match funding ($255,897.00) was previously appropriated for this effort under FDEP Grant 20SL3. PREVIOUS ACTION: December 17, 2019 — Public hearing advertised and subsequent Board approval of Resolution 2019-286, establishing the definitions and physical boundaries for the South Hutchinson Island (SHI) Municipal Services Taxing Unit (MSTU). June 16, 2020 — FDEP Grant Agreement 20SL3 (194486) approved by the Erosion District Board (2020-49922). September 15, 2020 — Contract for Consulting/Professional Services executed with G.E.C., Inc./Coastal Technology Corporation (C20-09-811) for Coastal Engineering Services with Environmental Support Services, specifically for the St. Lucie County, Florida, CSRM Project (2020-50299). November 10, 2020—The Erosion District Board approves the Project Partnership Agreement (PPA) with the USACE (2020- Page 125 of 148 S0618). The project includes SO -years of federal participation. July 27, 2021— Capital Improvement Revenue Note (Loan) approved by the BOCC for the balance of the non-federal share required for both construction and post -construction permit required monitoring efforts ($4,560,000.00, RES-2021-317). August 3, 2021—The non-federal share of proposed construction wire transferred to the USACE ($9,273,000.00), including state funding from FDEP Grants 19SL4 ($3.096,946.00, 184234) and 20SL3 ($2,685,965.88, 194486). September 27, 2021— USACE bid award; Great Lakes Dredge and Dock Company, LLC. (total construction contract $11,340,600.00). November 2, 2021— USACE issues Notice to Proceed (NTP) to Great Lakes Dredge and Dock Company, LLC. December 14, 2021— Board approval of Work Authorization No. 3 (G.E.C., Inc.) for immediate post -construction physical and biological monitoring services required by permit (2021-52788). May 9, 2022 — Initial construction of the St. Lucie County, Florida, CSRM Project completed. February 01, 2023 — FDEP pre -approval of Work Authorization No. 08, (G.E.C., Inc.) for future cost sharing under FDEP Grant 20SL3 (194486). FINANCIAL IMPACT: The total cost of Work Authorization No. 08 (G.E.C., Inc.) is $452,834.90. Local funding ($255,897.00) was previously appropriated for this effort in FDEP Grant 20SL3 (194486). FDEP's contribution will be $196,937.90 towards the proposed monitoring effort. Funding in FDEP Grant 20SL3 requires a 43.49%(State)/56.51%(Local) grant match requirement. RECOMMENDATION: Staff recommends Board approval of Work Authorization No. 08 with G.E.C./Coastal Tech, Inc. ($452,834.90), and authorization for the Chair to sign documents as approved by the County Attorney. COMMISSION ACTION: RESULT: MOVER: SECONDER: None AYES: None NAYS: None EXCUSED: None Coordination/Signatures 11�U NuI��N�rllli�� �� � lii Date: February 07, 2023 Patrick Dayan, Public Works Director Date: February 07, 2023 Jennifer Hill, Office of Management & Budget Director Date: February 10, 2023 Daniel McIntyre, County Attorney Page 126 of 148 i Date: February 11, 2023 Mayte Santamaria, Planning & Development Services Director Page 127 of 148 WORK AUTHORIZATION NO.08 CONTRACT C20-09-811 COASTAL ENGINEERING SERVICES THIS WORK AUTHORIZATION is made as of the day of , 2023, by and between the ST. LUCIE COUNTY EROSION DISTRICT, a dependent taxing district of the State of Florida, hereinafter referred to as the "County" and G.E.C., INC./COASTAL TECHNOLOGY CORPORATION., hereinafter referred to as the "Consultant". WITNESSETH: WHEREAS, on September 15, 2020, the County entered into a Consulting Agreement (Contract No. C20-09-811) hereinafter referred to as "Contract" with the Consultant to provide continuing professional coastal engineering services; and, WHEREAS, pursuant to the Contract, the Consultant is to provide the professional services as outlined in this individual work authorization; and, NOW, THEREFORE, in consideration of their mutual promises made herein, and for other good and valuable consideration, receipt of which is hereby acknowledged by each party, the parties who are legally bound, hereby agree as follows: 1. PROJECT: The County has determined that it would like to complete a project described below: St. Lucie County South Hutchinson Island Coastal Storm Risk Management Project Year 1 — Post Construction Monitoring (hereinafter referred to as "the Project".) 2. SERVICES: The County has determined that it would like to utilize the services of the Consultant in the completion of the Project, to provide professional engineering services for the Project under the pricing, terms and conditions of the continuing contract (C20-09-811). The services to be provided by Consultant on the Project shall be for those as outlined in the Scope of Services attached hereto as Exhibit "A" and according to the schedule attached hereto as Exhibit "C" which are attached hereto and made a part of this work authorization and incorporated herein. 3. COMPENSATION: The cost to perform all services as described in the attached Scope of Services shall not exceed a total amount of $452,834.90 (four hundred fifty-two thousand eight hundred thirty-four and 90/100 dollars), as further detailed in Exhibit "B". No reimbursable expenses will be paid pursuant to this work authorization. Page 1 of 3 Page 128 of 148 Any sub -consultant fees associated with this work authorization will be paid as a direct pass through without any additional mark-up or administrative fee. This work authorization shall meet the definition of "Construction Services" as defined in F.S. §218.72. Payment to the Consultant shall be made within 20 business days of the County's receipt of the application. 4. CONTRACT DOCUMENT: Except as amended hereby, all of the original terms and conditions in the Continuing Contract shall remain in full force and effect. TIME OF COMPLETION: a. It is hereby understood and mutually agreed by and between parties hereto that the time of completion is an essential condition of this Contract, time being of the essence. b. Consultant shall commence work per the written Notice to Proceed, and shall complete all work as further described in the Exhibit "C". C. The period herein above specified for project completion may be extended by such time as shall be approved by the County Administrator or designee, or the Contract may be cancelled by the County Administrator with the County invoking all rights and remedies thereof. d. Where any deductions from or forfeitures of payment in connection with the work of this Contract are duly and properly imposed against the Consultant, in accordance with the terms of the Contract, State Laws, governing ordinances or regulations, the total amount thereof may be withheld from any monies due or to become due the Consultant under the Contract; and when deducted, shall be deemed and taken as payment in such amount. e. SCRUTINIZED COMPANIES TERMINATION: The County may immediately terminate the Contract without cause at any time upon ascertaining that pursuant to § 287.135, Florida Statutes, a company is ineligible to, and may not, bid on, submit a proposal for, or enter into or renew a contract with an agency or local government entity for goods or services if at the time of bidding or submitting a proposal for a new contract or renewal of an existing contract, or at any time thereafter, the company: (1) is on the Scrutinized Companies that Boycott Israel List, created pursuant to § 215.4725, Florida Statutes, or is engaged in a boycott of Israel; (2) is on the Scrutinized Companies with Activities in Sudan List or the Scrutinized Companies with Activities in the Iran Petroleum Energy Sector List, created pursuant to § 215.473, Florida Statutes; or (3) is engaged in business operations in Cuba or Syria. Furthermore, the County may immediately terminate the Contract if it is determined that the company submitted a false certification stating that it was not (1) on the Scrutinized Companies that Boycott Israel List or engaged in a boycott of Israel; (2) was not on the Scrutinized Companies with Activities in Sudan List or the Scrutinized Companies with Activities in the Iran Petroleum Energy Sector List; (3) or was not engaged in business operations in Cuba or Syria when in fact the company was engaged in such activities at the time of the bid or proposal, or at the time of entering into or renewing the Contract. E-VERIFY/ VERIFICATION OF EMPLOYMENT STATUS Effective as of January 1, 2021, as required by Section 448.095(2)(a), the Consultant and sub - consultant shall register with and use the E-Verify System to verify the work authorization status of all newly hired employees. The County, Consultant, or sub -consultant may not enter into a Contract unless each party Page 2 of 3 Page 129 of 148 to the Contract registers with and uses the E-Verify System. The Consultant shall provide documentation of their compliance of this requirement to the County upon request. If the Consultant enters into a contract with a sub -consultant, the sub -consultant must provide the Consultant with an affidavit stating that the sub -consultant does not employ, contract with, or subcontract with an unauthorized alien. The Consultant shall maintain a copy of such affidavit for the duration of this Contract. The County will not intentionally award contracts to any Consultant who knowingly employs unauthorized alien workers, constituting a violation of the employment provisions of the Immigration and Nationality Act ("INA"). The County shall consider the employment by the Consultant of unauthorized aliens a violation of 8 U.S.C. Section 1324a(e) [Section 274A(e) of the INA]. The Consultant agrees that such violation by the Consultant shall be grounds for the unilateral cancellation of this Contract by the County. IN WITNESS WHEREOF, the parties hereto have executed this Work Authorization effective the date first written above. ATTEST: BY: ST. LUCIE COUNTY EROSION DISTRICT ST. LUCIE COUNTY, FLORIDA BY: DEPUTY CLERK CHAIR APPROVED AS TO FORM AND CORRECTNESS: COUNTY ATTORNEY G.E.C., INC./COASTAL TECHNOLOGY CORPORATION BY: PRINT NAME: Page 3 of 3 Page 130 of 148 St. Lucie County Work Authorization 8 Year 1 - Post Construction Monitoring Scope of Services EXHIBIT "A" SCOPE OF SERVICES Work Authorization 8 Introduction: In May 2022, construction of the South Hutchinson Island Coastal Storm Risk Management Project was completed by the Great Lakes Dredge & Dock Corporation under a construction contract administered by the U.S. Army Corps of Engineers (USACE). The Project was authorized by the Florida Department of Environmental Protection (FDEP) Permit Number: 0154626-001-JC —issued to the USACE and the St. Lucie County Erosion District (District). The FDEP Permit: identifies 43 Specific Conditions including those describing monitoring requirements, and cites: o The USACE "shall be responsible for Specific Conditions 3-7, 9, 11-16, 18, 19, 21- 29, 34-37, 40, and 43". o "St. Lucie County will be responsible for Specific Conditions 8, 10, 17, 20, 30-33, 38-43." This Scope of Services address the monitoring requirements for which the County and District are responsible during Year 1 Post Construction to be primarily performed in the summer of 2023. Note that: • Specific Condition 8 is relative to the "artificial reef" for which construction was completed in 2015 and monitoring was completed in 2018. • Specific Condition 10 addresses dune planting, which required "80 percent survival ...at the end of the first year post -planting" with a requirement that "replanting and monitoring shall continue until 80 percent survivorship is achieved for 1 full year." • Specific Condition 17 addresses notifications regarding shorebird nesting in the fill area during construction, which has been completed. • Specific Conditions 20, and 30 to 33 address Marine Turtle Nest Surveys per FDEP's Post -construction Monitoring and Reporting Marine Turtle Protection Conditions including Nesting Success, Hatching success, Emergence Success, Disorientations, Escarpment surveys, and Lighting Surveys completed in 2022. • Specific Conditions 38-42 address Nearshore Hardbottom Monitoring. • Specific Condition 43 addresses Physical Monitoring. The work is proposed to be performed by G.E.C., Inc. (GEC) with support by Morgan & Eklund, Inc. (M&E), CSA Ocean Sciences Inc. (CSA), and Ecological Associates, Inc. (EAI). This Scope of Services includes the following tasks: Task 1 — Physical Monitoring: GEC will provide physical monitoring services for post - construction monitoring of the Project - consistent with the Physical Monitoring Plan (PMP) dated June 12, 2012 as required by Specific Condition 43 of the FDEP Permit. Consistent with the PMP, GEC will: (1) sub -contract with M&E to provide: (i) a topographic and bathymetric profile survey of the beach and offshore — one year from completion of construction expected to be surveyed during 2023 late spring or summer months — including along FDEP reference monuments R-93 to R-115 in St. Lucie County and R-1 through R-5 in Martin County (if not supplied by Martin County); (ii) a digital (PDF) signed and sealed survey drawing; (iii) an AutoCAD copy of the surveys; and Page 1 of 5 January 23, 2023 Page 131 of 148 St. Lucie County Work Authorization 8 Year 1 - Post Construction Monitoring Scope of Services (iv) data in FDEP monitoring format. (2) prepare 81/2" by 11" plots of the new surveyed profiles with (a) the pre -construction profiles surveyed under Task 1a, and (b) the 2021 USACE construction template; (3) compute and assess volumes and shoreline changes based upon the new profile surveys; and (4) provide a letter report summarizing results of the above with digital (PDF) format. Task 2 — Biological Monitoring - Hardbottom: GEC, via sub -contract with CSA Ocean Sciences Inc. (CSA), will provide biological services for post -construction monitoring of the Project. In general, CSA will perform a Year 1 Post -Construction Survey expected to be conducted in Spring/Summer 2023 - consistent with the existing Biological Monitoring Plan (BMP) approved by FDEP on July 30, 2021 and Specific Conditions 38 through 42 of the FDEP permit. CSA will monitor and note field conditions in the Project area daily beginning in May 2023, when local sea conditions usually begin to improve, until completion of field work. Field conditions of note will include wind direction and speed, wave height, wave period, and visibility, as applicable, along with any significant weather conditions. Wave heights greater than 0.6 m typically result in increased turbidity and reduced underwater visibility, which prevents surveys from being reliably conducted. Consistent with the BMP update, GEC/CSA will perform the following sub -tasks: Task 2a — Nearshore Hardbottom Monitoring: Twenty-six cross -shore permanent hardbottom monitoring transects beginning at the nearshore hardbottom edge and located directly offshore of FDEP Monuments R-78.7, R-80.4, R-82.8, R-85, R86.3, R-88.7, R- 90.4, R-92, R-100, R-101, R-101.1, R-101.9, R-102, R-102.8, R-103, R-103.1, R-108.8, R-109.2, R-109.7, R-110, R-111, R-112, R-112.3, R-113, R-2 (Martin County), and R-3 (Martin County) will be established and monitored by CSA during the 2023 survey. As part of the nearshore hardbottom monitoring, a marine biologist will collect qualitative video documentation of the seafloor and associated biota along each of the 26 biological transect lines. A species inventory of major taxonomic groups and a species list of fishes and sea turtles observed during the survey will also be produced from each of the 26 biological monitoring transects. Sand depth measurements will be collected at 1-m intervals along all 26 transects using a marked steel ruler, and the physical transitions between sand and hardbottom along all transects will be recorded as line intercepts. Quantitative video will be collected at 40 cm above the bottom of each transect for archival purposes. American Academy of Underwater Scientists (AAUS)-certified nearshore hardbottom specialists will determine percent cover of major benthic groups, average sediment depth, and substrate type from 0.5 m2 quadrats along each biological transect for a total area of 10 m per 150 m transect. The number of quadrats per transect will vary based upon the length of the transect but will be distributed along each transect so that at least 2.5 m2 of area is sampled in each of the following zones: 0 to 30 m; 30 to 60 m; 60 to 100 m; and 100 to 150 m. Digital photographs of each quadrat will be taken for reference at the time of monitoring. Quadrats will meet prescribed FDEP BEAMR data collection criteria from the 2016 FDEP Standard Operation Procedures for Nearshore Hardbottom Monitoring of Beach Nourishment Projects. Page 2 of 5 January 23, 2023 Page 132 of 148 St. Lucie County Work Authorization 8 Year 1 - Post Construction Monitoring Scope of Services Task 2b — Nearshore Hardbottom Edge Mapping: Delineation of the nearshore hardbottom edge will provide information on hardbottom exposure within the Project area and allow for determination of direct impacts, when occurring, due to hardbottom burial by Project fill. Hardbottom formations have been documented to run parallel to the St. Lucie County South Beach Project shoreline. Therefore, the entire length of the nearshore hardbottom edge between FDEP reference monuments R-96 in St. Lucie County and R-4 in Martin County will be mapped during the survey. Two divers will swim the entire length of the hardbottom edge. Divers will tow a Differential Global Positioning System (DGPS) buoy to record their track and will also record qualitative digital video to document the nearshore hardbottom edge for a descriptive analysis (e.g., dominant benthic communities, vertical relief, sand cover). The camera will be positioned at an oblique angle to the seafloor. Locations of breaks in the hardbottom edge or sand gaps greater than 5 m in length will be noted during the survey. Task 2c — Side Scan Sonar Survey: CSA will subcontract Morgan & Eklund, Inc. (M&E) to perform a side -scan survey to verify the locations of hardbottom within the Project area. The side -scan survey will be performed between 1,000 m updrift of the Project boundary and 3,000 m downdrift of the project boundary and offshore a distance of approximately 350 m. Hardbottom mapping data collected during the side -scan survey will be (a) recorded and provided digitally, (b) interpreted with other field data to prepare a summary map of nearshore hardbottom extent and character. Task 2d — Data Analysis & Reporting: Data from Tasks 2a to 2c will be analyzed by CSA and summarized in a draft report to document and characterize the conditions in the Project area one year after construction. The draft report will be submitted to GEC and the County for review. Upon acceptance of the draft report, the draft report will be submitted to FDEP. Qualitative descriptions based on video and diver observations will be provided for substrate types, sediment movement, and benthic assemblages. Percent cover of benthic groups and substrate within quadrats and average sediment depth will also be determined. Results of this survey will provide a basis for comparison future subsequent post -construction monitoring data to determine changes among transects and between years — potentially attributable to the Project. Task 3 — Biological Monitoring — Sea Turtles: GEC, via sub -contract with EAI, will provide biological services for post -construction sea turtle monitoring for the Project — consistent with Specific Conditions 20, and 30 to 33 of the FDEP permit. All sea turtle monitoring and related activities will be performed under FWC Marine Turtle Permit #010 issued by FWC to EAI Director of Operations, Niki Desjardin. All persons engaged in monitoring performed by EAI for St. Lucie County will be listed on the permit. All data will be subject to rigorous QA/QC protocols and stored in EAI's Project specific database. Daily nesting surveys will be charged at a per survey rate. EAI will perform the following sub -tasks: Task 3a — Post -construction Nesting Surveys: Per SPBO Condition A11, Table 18, EAI will conduct daily morning sea turtle nesting surveys of the Project Area from February 25 2023 to November 11, 2023 or until fifteen (15) days without a nest in the Project Area, whichever is earlier. If there is a fifteen -day period where no nests are laid in the Project Area, EAI will request a waiver from the USFWS and FWC to discontinue daily monitoring. Page 3 of 5 January 23, 2023 Page 133 of 148 St. Lucie County Work Authorization 8 Year 1 - Post Construction Monitoring Scope of Services If permission is granted, EAI will then perform surveys three days per week to monitor marked nests until a fate can be determined. Surveys will commence within 30 minutes of sunrise. Monitoring will be performed by EAI staff using All Terrain Vehicles (ATVs). All emergences (turtle crawls) apparent from the previous night will be interpreted to determine which species of turtle came ashore and whether or not it nested. Crawls will be denoted as being above or below the previous high tide line. The approximate geographic location of each crawl will be determined by GPS (sub -meter accuracy). In addition to segregating crawls into nesting and non -nesting emergences (false crawls), each false crawl will be assigned to one of the following categories denoting the stage at which the nesting attempt was abandoned: no digging, abandoned body pit, or abandoned egg cavity. Any obstacles encountered by turtles during their crawls will be documented. During the course of daily monitoring, any evidence of hatchling misorientation or disorientation from either marked or unmarked nests will be documented using FWC's electronic Marine Turtle Hatchling Disorientation Incident Report Form. Based on track evaluations, an estimate of the number of hatchlings disoriented will be recorded and light sources potentially responsible for the disorientation identified. Information concerning each incident will be forwarded by email to St. Lucie County so appropriate remedial action may be taken. Information from disorientation events is also expected to be used by COUNTY Code Enforcement and the Sea Turtle Working Group to improve lighting conditions on the beach. A requirement of FWC sea turtle permit holders conducting nesting surveys is to respond to the stranding of sick, injured, and dead sea turtles within their survey area. These animals are examined, and if alive, transported to state approved care facilities. A standard Sea Turtle Stranding and Salvage data form will be completed and submitted for each stranded animal encountered by EAI. This information will be transmitted to FWC in accordance with established guidelines. Task 3b — Nest Marking and Monitoring: Per FDEP Specific Condition 31, once the construction -phase nest protection program has been completed, a representative sample of sea turtle nests in the Project Area will be left in place and marked for the purpose of determining nest fate and reproductive success. Nests will be marked using a series of stakes and surveyor's tape. These nests will be monitored throughout their incubation period to determine nest fate (e.g., hatched, washed out, depredated, vandalized, etc.). After an appropriate incubation period, and in accordance with FWC guidelines, nests will be excavated to determine reproductive success. Two measures of reproductive success will be calculated: hatching success (the percentage of eggs in the nest that hatch) and emerging success (the percentage of eggs in the nest that produce hatchlings which successfully escape from the nest). Nest marking will be charged at a per nest rate. Task 3c — Weekly Escarpment Monitoring: Per FDEP Specific Condition 30, EAI will perform escarpment (scarp) monitoring on a weekly basis commencing March 1, 2023 through October 31, 2023. In accordance with FWC protocol, scarps will be functionally defined as an abrupt change in beach slope (greater than 45) that is at least 18 inches in height and persists for a distance of 100 feet or more. The location of both the northern and southern terminus of each scarp will be recorded by GPS and average scarp height assigned to one of three categories (0 to 2 feet, 2 to 4 feet, and 4 feet or higher). Page 4 of 5 January 23, 2023 Page 134 of 148 St. Lucie County Work Authorization 8 Year 1 - Post Construction Monitoring Scope of Services Additionally, the maximum height of each scarp will be measured. The location, approximate length, height category, and maximum height will be presented in tabular and/or graphic format for reporting purposes. EAI will notify GEC and the COUNTY of any persistent scarps that may interfere with sea turtle nesting. GEC shall notify FDEP of the presence of those scarps and for coordinating any mechanical knockdowns by the COUNTY if required. Scarp monitoring will be charged at a per survey rate. Task 3d — Reporting: Per FDEP Specific Conditions 20, and 30 to 33, EAI will prepare and submit to the COUNTY, USACE, FDEP, and GEC the following reports in support of regulatory permitting requirements. ■ Monthly summary reports will tabulate the dates and times of monitoring, names of monitoring personnel, numbers of sea turtle emergences by species, and numbers of nests marked and evaluated for reproductive success, as applicable. Monthly reports will be submitted no later than the last day of the month following delivery of services (e.g., March report due no later than April 30). ■ A year-end report will summarize in tabular format the numbers of sea turtle emergences by species, nest fates of all marked nests, and reproductive success of evaluated nests, including graphic representations, as applicable. The annual summary report will be submitted to no later than 90 days following completion of monitoring activities. ■ Permit -related reports will be prepared following the completion of monitoring and activities. The Statewide Nesting Beach Survey and Nest Productivity Assessment reports required of all marine turtle permit holders by FWC will be submitted by November 30 of the year activities were conducted. All nesting activity and reproductive success for the Project area will be submitted on standard nourishment Excel spreadsheets, as required by the FDEP permit, by December 31 of the year activities were conducted. Task 4 — Dune Plants - Survival: Per FDEP Permit Specific Condition 10, GEC will visit the Project Area to assess and document the survival rate of dune plants. GEC will provide a letter report summarizing findings. Page 5 of 5 January 23, 2023 Page 135 of 148 V N .O a E N f� y +0+LL E O o Cu v% E N O M I.LI O m O N O (ir- Cu C o Cu N UE N fn LL N a- a T (a 7 } Co O U u J N L C W N C C C W ----- L----- 0 0: o: a) C; C � W: (D `o a) 'C C' o n C: W O aco a) U C C d W: 0, o coi . --- : Lo I� C --- -- ----*--- ----t-- t--- N i- i ---+---T--- N o f O M ; V ------ ---- N i O i V ---- ---- ---- i N i N i ---+----�---4---- i O i O i ---i h i---- --- i ---- h i---- i 0 i 0 i --- -- --- ---------------------- --------- co coO!to N ----------------------f--------- N ---------------------f--------- 7 --- --- --- ---- --- ----F-- N i ---- F------- p N co fn -- --- Cl a)o m a0 � -- --- Lo r- a0 0 o N l0 O D N rt» o o 2 U m C m m o o � H H U Q O � VI O C i i E C .O N O i i `C . N Z ++ M mIU QI a5 ' I C N o Lo V I i as N N o ZIZ ; c Im'o rO+ o vl 3 ° Q y i to i S Mou m > i N� 4) i (6i �i i vl Y (n 01 IC N U 7i <4 QI o I (DI _ 'EI a) Cl) So c1 1 O1 i� LU Ti L C N ... L E' i i O 01 01 a L N '.' Q �I o. U) i a1 1 2 cc' O O as I O c N I o.od I o 1 0 1 ' S S;� ° Q L N N mi y V V WccCL i Cn N � i( od d C G o Q m =ON- � co 00 o IL o m1 m �I�Is m1N m -Q o o; N N; N; N; N m M M M `' � a; a5 ; a5 N ; N ; a5 a5 ; a7 ; a7 ; N A l l F m >I I- I- I- I- j o O N N N N W O N ci' V O h- i Ct i N O Q 67 N N co a ev dev N o --- -- ------- ------------ M ---- --- ---- --- ---- coM M -- ------------------------------- M i co@Y i --- ------- t co N O O O N O O N co N d 04 N NO N O NNNN O O N N N N F lL p N Cl co _ N M N M N aB O O O O r r O M r- O Z L- w N N N N N N M N N O N w O N N O O O N N N N N O N N N O N fn r O M r r r r N - N N 4') � li7 Lmo ll7 O N M I� 2 E 2 \45 � F Fl / / g / / \ \ \ \ \ 76 \\ E j \} ;; { E y \\ \ \/) B B \ \ ) - rq ] ] ) Lu - t _ � \ \ `rq k;� 2 - - - k.j \ \ \ _ - - \ - -A§/f/R!] ;2 � \\ o\\/� 0 o20 ./ \\ ,( \\\\{){\DEo E // } \{ _ § - - - --2S 2 )( \ J2 3 3762omloo < = o = a z 2± )\ . )� \ r _= b� &2 f) \ \ _ - » R / - 2} ] /\ \ ) /vi ® ®\G \ 2 /§a ; / LO E� }\ ). ) ) ) E E / 0 . \ ! f / { \ { { Q ƒ \ \ " \ 2 = % < s { » 2; 2 { \ ) 5 ° \) ƒ \ \ 7 \ { / \ \. ~ 0/ f ]) ) / M ) . 2 y � , , ,) \ Q -. k \ \ \ « \ \ \ \ « \ ® en: z e e e J(( J]/ / �. 2023-58538 DATE: 2/21/2023 TO: Erosion District AGENDA REQUEST PRESENTED BY: Joshua Revord, Senior Coastal Engineer SUBMITTED BY: Public Works SUBJECT: FDEP Grant Agreement 18SL1 - Amendment No. 04 BACKGROUND: In the mid 2000's, St. Lucie County coordinated with the Florida Department of Environmental Protection (FDEP) to evaluate inlet sand bypassing and the potential for an inlet sand trap within the Fort Pierce Inlet. Sand bypassing is a necessary component of any Inlet Management Plan (IMP) and Florida State Statute (161.143) requires local governing bodies to pursue (to the best of their ability) regional sediment management at inlets to mitigate the downdrift impacts they have on natural coastal processes. After an extensive design process, there was eventually a consensus to move forward with the final design and permitting of a sediment impoundment basin (sand trap). The goal being, to establish a "sand trap" within the inlet that would effectively catch and retain sands that migrate into this dynamic environment. Sands caught in the trap could then be used for future maintenance of St. Lucie County's downdrift beaches, specifically Fort Pierce Beach. The Fort Pierce Inlet Sand Trap (Phase 1) project was designed and permitted, featuring a 60,000 cubic yard capacity sand trap located within the throat of the Fort Pierce Inlet (between the federal navigation channel and the north jetty structure). Construction commenced in November of 2021 and was completed in July of 2022. FDEP administers the Beach Management Funding Assistance (BMFA) Program, which provides funding opportunities to assist eligible local governments with their beach erosion control and inlet management projects. The Florida Legislature partially funded the Fort Pierce Inlet Sand Trap (Phase 1) project with FDEP Grant 18SL1 (184231) during the FY 2017/18 application period. Subsequent BMFA applications and grant amendments included additional funding for the recently completed project. Amendment No. 4 to this agreement includes an additional $1,107,500.00 from the FDEP, requiring a $387,500.00 local match share from the Erosion District. Amendment No. 04 will complete our state funding request(s) for this recently completed project and will result in 75% of the project cost being funded by the state of Florida (FDEP). To date, $4,280,315.00 has been allocated by the FDEP for this project and subsequent monitoring events. PREVIOUS ACTION: July 15, 2008 — Board approval of FDEP Project Agreement No. 07SL3 — Funding secured to evaluate inlet sand bypassing alternatives, including an inlet sand trap. February 17, 2015 — Board approval of FDEP Project Agreement No. 15SL2 — Funding secured to assist/initiate permitting of the Fort Pierce Inlet Sand Trap (Phase 1) project. Page 138 of 148 July 26, 2016 — Board approval to submit a FDEP inlet funding request for sand trap construction during the FY-2017/18 Beach Management Funding Assistance (BMFA) program application period. March 20, 2018 — Board approval of the FDEP Project Grant Agreement 18SL1 (184231, RES-2018-32) — State funding received $1,818,315.00, Local match required $606,105.00. July 10, 2018 — Board approval of Amendment No. 01 to FDEP Grant 18SL1 (184231, Res-2018-107) - State funding increased by $679,500.00 to $2,497,815.00, Local match requirement increased by $226,500.00 to $832,605.00. October 20, 2020 - Board approval to submit a BMFA application for additional construction funding during the FY-2021/22 application period (2020-50463, RES-2020-243). March 31, 2021 — Administrative approval of Amendment No. 02 to FDEP Grant 18SL1 (184231) — Project Time Extension. August 17, 2021— Board approval/bid award of the Ft. Pierce Inlet Sand Trap (Phase 1) project (Bid No. 21- 063, 2021-52221) — Ahtna Marine and Construction Company, LLC. (up to $4,802,283.20). October 20, 2021- Board approval to submit a BMFA application for additional construction funding during the FY-2022/23 application period (2021-52048, RES-2021-316). November 16, 2021 - Board approval of Amendment No. 03 to FDEP Grant 18SL1 (184231, Res-2018-107) - State funding increased by $675,000.00 to $3,172,815.00, Local match requirement increased by $225,000.00 to $1,057,605.00. July 31, 2022 - Fort Pierce Inlet Sand Trap (Phase 1) construction completed —Total construction cost $4,365,712.00. January 4, 2023 — FDEP provides St. Lucie County Erosion District with Amendment No. 04 - State funding increased by $1,107,500.00 to $4,280,315.00, Local match requirement increased by $387,500.00 to $1,445,105.00. FINANCIAL IMPACT: Amendment No. 04 includes an additional $1,107,500.00 from the Florida Department of Environmental Protection (FDEP) for the recently completed Fort Pierce Inlet Sand Trap (Phase 1) project, and subsequent monitoring efforts, requiring a local match share of $387,500.00. A breakdown of the new grant funding in Amendment 04 is provided below: Task 1 (Construction) $1,440,000.00 (Total Grant Value) State Appropriation (75%) = $1,080,000.00 Required Local Match (25%) = $360,000.00 Task 2 (Monitoring) $55,000.00 (Total Grant Value) State Appropriation (50%) = $27,500.00 Required Local Match (50%) = $27,500.00 Required local matching funds ($387,500.00) are proposed from the Erosion District Reserves (184-9910- 599300-800). RECOMMENDATION: Board approval of: (1) Amendment No. 04 to FDEP Project Agreement 18SL1 (Fund # 184231), accepting an additional $1,107,500.00 from the state of Florida, requiring a $387,500.00 local match share; (2) A supporting budget resolution, provided separately by OMB; and authorization for the Erosion District Chair to sign documents as approved by the county attorney. Page 139 of 148 COMMISSION ACTION: RESULT: MOVER: SECONDER: None AYES: None NAYS: None EXCUSED: None Coordination/Signatures Date: January 25, 2023 Patrick Dayan, Public Works Director a� 'kYN-Y tA Lu"" Date: January 26, 2023 Jennifer Hill, Office of Management & Budget Director Date: January 27, 2023 Daniel McIntyre, County Attorney �.��,,�,�', Date: January 27, 2023 Mayte Santamaria, Planning & Development Services Director Page 140 of 148 AMENDMENT NO. 4 TO AGREEMENT NO. 18SL1 BETWEEN FLORIDA DEPARTMENT OF ENVIRONMENTAL PROTECTION AND ST. LUCIE COUNTY EROSION DISTRICT This Amendment to Agreement No. 18SL1, as previously amended, (Agreement) is made by and between the Department of Environmental Protection (Department), an agency of the State of Florida, and St. Lucie County Erosion District, 3701 Oleander Avenue, Ft. Pierce, Florida 34982 (Grantee), on the date last signed below. WHEREAS, the Department entered into the Agreement with the Grantee for the Ft. Pierce IMP Implementation Project effective March 27, 2018; WHEREAS, the parties wish to amend the Agreement as set forth herein. NOW THEREFORE, the parties agree as follows: 1) The total amount of funding of the Agreement is increased by S1,107,500.00 to $4,280,315.00. 2) The Agreement is extended for a 12-month period to begin January 1, 2025, and remain in effect until December 31, 2025. The Department and the Grantee shall continue to perform their respective duties during this extension period pursuant to the same terms and conditions provided in the Agreement. 3) Attachment A-3, Third Revised Grant Work Plan, is hereby deleted in its entirety and replaced with Attachment A-4, Fourth Revised Grant Work Plan, as attached to this Amendment and hereby incorporated into the Agreement. All references in the Agreement to Attachment A-3, Third Revised Grant Work Plan, shall hereinafter refer to Attachment A-4, Fourth Revised Grant Work Plan. 4) Attachment 5, Special Audit Requirements, Exhibit 1-13, is hereby deleted in its entirety and replaced with Exhibit 1- C, attached and hereby incorporated into the Agreement. All references in the Agreement to Attachment 5, Special Audit Requirements, Exhibit 1-13, shall hereinafter refer to Exhibit 1-C. 5) All other terms and conditions of the Agreement remain in effect. If and to the extent that any inconsistencies may appear between the Agreement and this Amendment, the provisions of this Amendment shall control. The parties agree to the terms and conditions of this Amendment and have duly authorized their respective representatives to sign it on the dates indicated below. St. Lucie County Erosion District Title: Date Agreement No.: 18SL1 Florida Department of Environmental Protection Secretary or Designee Date: Amendment No.: 4 Rev. 3/1/2022 1 of 2 Page 141 of 148 LIST OF ATTACHMENTS/EXHIBITS INCLUDED AS PART OF THIS AMENDMENT: Specifv Twe Letter/Number Description Attachment A-4 Fourth Revised Grant Work Plan (3 pages) Attachment 5, Exhibit 1-C Revised Special Audit Requirements (3 pages) - REMAINDER OF PAGE INTENTIONALLY LEFT BLANK - Agreement No.: 18SL1 Amendment No.: 4 2 of 2 Rev. 3/1/2022 Page 142 of 148 ATTACHMENT A-4 FOURTH REVISED GRANT WORK PLAN PROJECT TITLE: Ft. Pierce IMP Implementation PROJECT LOCATION: The Project is located between Department of Environmental Protection (DEP) reference monuments R33 and R34 along the Atlantic Ocean in St. Lucie County, Florida. PROJECT BACKGROUND: The Ft. Pierce IMP was adopted in 1997. A draft feasibility study to evaluate sand bypassing alternatives was completed in 2003. A design study completed in 2009 recommended construction of a sand trap inside the inlet. An updated sediment budget report was completed and submitted to the Department in 2018. The design and permitting of the sand trap were completed in 2019. The construction bidding process was completed in 2021 for phase I of the sand trap construction, and the construction of the sand trap will continue in phases, as allowed in the permit. Post - construction monitoring will begin once the construction is completed. PROJECT DESCRIPTION: The Project consists of construction and monitoring. PROJECT ELIGIBILITY: The Department has determined that 100 percent of the non-federal Project cost is eligible for state cost sharing. Therefore, the Department's financial obligation shall not exceed the sum of $4,252,815.00 or up to 75 percent of the non-federal Project cost for the Construction Task, and the sum of $27,500.00 or up to 50 percent of the non-federal Project cost for the Monitoring Task, if applicable, for the specific eligible Project items listed, whichever is less. Any indicated federal cost sharing percentage is an estimate and shall not affect the cost sharing percentages of the non-federal share. The parties agree that eligibility for cost sharing purposes will be maintained pursuant to 6213-36, F.A.C. The Grantee will be responsible for auditing all travel reimbursement expenses based on the travel limits established in Section 112.061, Florida Statutes (F.S.) Pursuant to Sections 161.091 - 161.161, F.S., The Department provides financial assistance to eligible governmental entities for beach erosion control and inlet management activities under the Florida Beach Management Funding Assistance Program; and Pursuant to 62B-36.005(2)(d), Florida Administrative Code (F.A.C.), the Grantee has resolved to support and serve as local sponsor, has demonstrated a financial commitment, and has demonstrated the ability to perform the tasks associated with the beach erosion control project as described herein. The Project shall be conducted in accordance with the terms and conditions set forth under this Agreement, all applicable Department permits and the eligible Project task items established below. All data collection and processing, and the resulting product deliverables, shall comply with the standards and technical specifications contained in the Department's Monitoring Standards for Beach Erosion Control Projects (2014) and all associated state and federal permits, unless otherwise specified in the approved Scope of Work for an eligible Project item. The monitoring standards may be found at: h1tpL//www.d state 1 us/bea h s/ rublications/ d1/1'h sicaMoriitorinuStandards. df. One (1) electronic copy of all written reports developed under this Agreement shall be forwarded to the Department, unless otherwise specified. DEP Agreement No. 18SL1, Amendment 4, Attachment A-4, Page 1 of 3 Page 143 of 148 Acronyms: DEP — Florida Department of Environmental Protection F.A.C. — Florida Administrative Code F.S. — Florida Statutes FWC — Florida Fish and Wildlife Conservation Commission IMP — Inlet Management Plan TASKS and DELIVERABLES: The Local Sponsor will provide detailed scopes of work or a letter requesting advance payment if authorized by Attachment 2, for all tasks identified below, which shall include a narrative description of work to be completed, a corresponding cost estimate and a proposed schedule of completion for the proposed work and associated deliverables. Each scope of work shall be approved in writing by the DEP Project Manager to be included into this work plan for reimbursement. Task 1: Construction Task Description: This task includes work performed and costs incurred associated with the placement of fill material and/or the construction of erosion control structures within the Project area. Project costs associated with eligible beach and inlet construction activities include work approved through construction bids and/or construction -phase engineering and monitoring services contracts. Eligible costs may include mobilization, demobilization, construction observation or inspection services, physical and environmental surveys, beach fill, tilling and scarp removal, erosion control structures, mitigation reefs, dune stabilization measures and native beach -dune vegetation. Construction shall be conducted in accordance with any and all State or Federal permits. The Local Sponsor will submit work products to the appropriate State or Federal regulatory agencies as requested by the DEP Project Manager in order to be eligible for reimbursement under this task. Deliverable: Certification of Completion by a Florida -registered Professional Engineer with documentation of submittal to the Department of a final construction observation report affirming the construction task was completed in accordance with construction contract documents. For interim payment requests, a Task Summary Report must be submitted detailing activities completed during the payment request period. The Task Summary Report must include the dates and descriptions of all activities, surveys and reports completed or in progress during the time period of the interim payment request. Performance Standard: The DEP Project Manager will review the task deliverable and any associated work products as necessary to verify they meet the specifications in the Grant Work Plan and this task description. Payment Request Schedule: Payment requests may be submitted after the deliverable is received and accepted and may be submitted no more frequently than quarterly. Task 2: Monitoring State and federal monitoring required by permit is eligible for reimbursement pursuant to program statute and rule. In order to comply with Florida Auditor General report 2014-064 regarding conflicts of interest and to be consistent with Section 287.057(17)(a)(1), F.S., all monitoring data and statistical analysis must be provided directly and concurrently from the monitoring contractor to the Department/Local Sponsor permittee/engineering consultant. The Local Sponsor's engineering consultant must provide an adequate mitigation plan, consistent with Section 287.057(17)(a)(1), F.S., including a description of organizational, physical, and electronic barriers to be used by the Local Sponsor's engineering consultant, that addresses conflicts of interest when contracting multi -disciplinary firms for Project engineering and post -construction DEP Agreement No. 18SL1, Amendment 4, Attachment A-4, Page 2 of 3 Page 144 of 148 environmental monitoring services, or when the Project engineering consultant firm subcontracts for post - construction environmental monitoring. Environmental monitoring includes hardbottom, seagrass, and mangrove resources. Department approval of the consultant's mitigation plan will be required prior to execution of this Agreement. If at any time the Local Sponsor and/or its engineering consultant fails to comply with this provision, the Local Sponsor agrees to reimburse the Department all funds provided by the Department associated with environmental monitoring for the Project listed. Task Description: This task includes activities associated with pen -nit -required monitoring conducted in accordance with the conditions specified by state or federal regulatory agencies. All monitoring tasks must be located within or adjacent to the Project area and follow the Department's Regional Coastal Monitoring Program and FWC's marine turtle and shorebird monitoring programs. Guidance for monitoring of nearshore resources is available in the Department's Standard Operation Procedures For Nearshore Hardbottom Monitoring Of Beach Nourishment Projects. The Local Sponsor must submit work products directly to the appropriate state or federal regulatory agencies in accordance with pen -nit conditions to be eligible for reimbursement under this task, unless otherwise directed. Deliverable: For each interim or final payment, the Local Sponsor will provide a Task Summary Report signed by Local Sponsor containing; 1) An itemized listing of all monitoring activities completed or in progress during the payment request period and, 2) Documentation of submittal to state and federal regulatory agencies of completed monitoring data, surveys and final reports for permit -required work under this task description. Estimated Eligible Project Cost State Task # Eligible Project Tasks Cost DEP Local Total Share 1 Construction 75.00% $4,252,815.00 $1,417,605.00 $5,670,420.00 2 Monitoring 50.00% $27,500.00 $27,500.00 $55,000.00 TOTAL PROJECT COSTS $4,280,315.00 $1,445,105.00 $5,725,420.00 PROJECT TIMELINE & BUDGET DETAIL: The tasks must be completed by, and all deliverables received by, the corresponding deliverable due date. Task No. Task Title Budget Category Budget Amount Task Start Date Deliverable Due Date 1 Construction Contractual Services $4,252,815.00 01/15/2018 06/30/2025 2 Monitoring Contractual Services $27,500.00 07/01/2022 06/30/2025 Total: j $4,280,315.00 Note that, per paragraph 81. of the agreement, authorization for continuation and completion of work and any associated payments may be rescinded, with proper notice, at the discretion of the Department if the Legislature reduces or eliminates appropriations. Extending the contract end date carries the risk that funds for this project may become unavailable in the future. This should be a consideration for the Local Sponsor with this and future requests for extension. DEP Agreement No. 18SL1, Amendment 4, Attachment A-4, Page 3 of 3 Page 145 of 148 sz O O .y O O f w w � N O ;.To H ^' H � � Q Q Q Q O U U H O F." Q> 40 i. O �U y � � d d a� 3 w w d' t4 U i. O O m v a� ar w a> w S O y :r N O � O � � O N N Q N lu a0. a� , O a.. + y cr ID N ~ rl Q% N CI 3 � 3 � � y C Q.) ci U 7= U �y o yLL o et w ;To 00 r O co r Dl co LL O .y O d d R s. 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