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Our Comments to the Corps

The US Army Corps of Engineers restarted the coastal vulnerability risk assessment for Collier County in April. They are accepting input from the public and other local stakeholders through June 8th.  Growing Climate Solutions, in concert with the Conservancy of Southwest Florida, Sanibel Captiva Conservation Foundation, and the  Environmental Defense Fund, submitted a letter with the following comments.


RE: Collier County Coastal Storm Risk Management Feasibility Study NEPA scoping comments


Dear Ms. Perdue,

Growing Climate Solutions was pleased to be included in the Collier County Storm Risk Management Study Charrette last week. Since 2019, Naples-based Growing Climate Solutions, a joint initiative of the Collier Community Foundation, Florida Gulf Coast University, Collaboratory and the Conservancy of Southwest Florida has worked to elevate the public dialogue around climate vulnerabilities and solutions and spur community engagement on sustainability.   We have thus gained a deep and nuanced understanding of community sentiments on environmental and climate issues.  We ask that the following comments be considered as the USACE assesses the scope of the NEPA review and begins developing alternatives to mitigate coastal storm risk in the region.


Flooding can result from multiple sources and mitigating vulnerability requires addressing all of them in an integrated fashion.  Collier County’s natural beauty and unique ecosystem stem from its varied habitats and coastal interfaces – gulf, estuary, mangrove forest, riparian wetlands, and rivers. The hydrology is interconnected and the function and quality of each component are codependent.  While the USACE’s mandate has traditionally focused on mitigating storm surge, we now know that any intervention approach must be considered and evaluated from a holistic perspective. We urge that Collier County, the non-Federal sponsor, request the Corps to address alternatives that address comprehensive flood issues using Section 8106 of the Water Resources Development Act (WRDA) of 2022.  A comprehensive look would include compounding impacts of intense precipitation, periodic flooding (both nuisance & tidal), long-term inundation due to rising sea levels, and issues of groundwater levels, and adequacy of engineered systems of canals and retention ponds – all contributing factors to coastal storm vulnerability. At the charrette, the USACE team suggested the application of WRDA 8106 to the County representatives, but the Corps may need to coach the County on follow-though with this request and then, most importantly, cast a wide net around the water resource issues to examine during the environmental review and alternative formulations.


Collier County residents have a strong preference for nature-based, green infrastructure, or “sage “ (combined green/grey) infrastructure approaches to storm and climate vulnerability. Growing Climate Solutions is partnered with nearly 40 local partners groups; and in multiple forums, most recently the SWFL Climate & Community Summit held in January 2023, residents and local community leaders voiced support for addressing the vulnerability of the coastline and issues of water management through nature-based approaches. These include mangrove protection and planting, land acquisition, wetland restoration and conservation, native landscaping, and beach nourishment etc.  The Summit Outcomes report documents support for this approach and can provide insight into environmental concerns voiced by residents.  While these measures may not maximize risk reduction compared to structural engineered projects, investing in green infrastructures provides critical ecosystem benefits that support our tourism, recreation, and water-dependent economy. We ask that the USACE team generously account for these environmental and economic benefits and creatively incorporate green/sage approaches to the maximum degree possible. We are strongly supportive of the Corps team’s efforts to involve the Engineering with Nature team and hope this group will collaborate with local environmental scientists to identify the best solutions.


Consideration of sea level rise during the 50-year life cycle of the project must be incorporated into the Cost-Benefit analysis of alternatives.  Sea level rise (SLR) is inevitable and likely to depreciate some coastal assets in the next 30 to 50 years, a period within the life cycle of the proposed risk-reduction projects.  Locally-calibrated models of sea-level rise, such as ACUNE and ACUNE+ developed by the University of Florida and Florida Gulf Coast University for this region, use SLR estimates that concur with the Intermediate-High curve issued by NOAA, a standard that Florida’s Department of Environmental Protection requires for local community vulnerability assessments.  Assuming SLR of 6 to 8 millimeters annually, which has been observed in the past 20 years, the asset value of hundreds of low-lying homes in the USACE study areas might fall due to the increasing frequency of sunny-day flooding, during the lifecycle of the project, and perhaps before the projects even break ground. Accounting for the anticipated depreciation of SLR may impact cost-benefit ratios of alternative intervention. Less intense interventions might have a better CB ratio if one is not committed to protecting all buildings, but accepting more residual risk on properties that will not have a high future value.  It is wasteful to spend large amounts of public dollars to protect assets that may not hold their value during the life of the project. Perhaps, non-structural approaches, in particular land acquisition or lower cost wet and dry floodproofing, should be considered for the protection of properties that will ultimately experience chronic low levels of inundation.  In considering the sea level rise analysis it is critically important to use locally specific and current data, as the USACE’s SLR curve is woefully optimistic of low rates of SLR compared to currently scientifically accepted projections for the region from NOAA.


USACE’s risk reduction plan should be part of comprehensive planning efforts. Land-use planning can be one of the most powerful risk mitigation tools and thus the Corps’ tentative selected plan must work in concert with planning efforts organized at the local and state level. Florida has a rich history of comprehensive land planning; yet to date, the USACE Risk Mitigation Feasibility Study does not appear to reference or be coordinated with Collier County’s, Naples’, and Marco Island’s Comprehensive Plans, all of which have Coastal Elements focused coastal hazards risk. Additionally, Florida’s Department of Environmental Protection recently awarded Collier County $46,700 for a Vulnerability Assessment and an additional $78,000 for city-wide assessments and Peril-of-Flood Comprehensive Plan Amendments. Everglades City is slated to receive $125,000 for its Climate Vulnerability Assessment.  It is recommended that the USACE ask the local sponsor, and the encompassed jurisdictions to coordinate updates to the Comprehensive Plan and other relevant strategic plans in conjunction with the preparation of CRMS. Planning together with localities might make land acquisition and other tools used in managed retreat more feasible and ultimately reduce asset accumulation in the future.


Inclusive public participation and clear, up-to-date communication should be incorporated throughout the planning process. The large scale and complexity of the proposed risk reduction measures make transparency and active public engagement a necessity. The USACE should incorporate regular outreach and citizen engagement into the work scope. Detailed timelines should be publicly available, public comment periods included at all key milestones, and meeting dates and times established well in advance and with regularity, allowing stakeholders to plan for consistent engagement. Additionally, the new website should have more robust content and a user-friendly interface. Creating an environment that fosters communication and collaboration with the public, especially with under-represented communities, will go a long way toward achieving desired outcomes.


Lastly, I want to express my appreciation for the fluid and constructive dialogue that emerged post-charrette with key members of the USACE’s project team, especially the opportunity to ask questions and provide comments informally during the planning process. While Growing Climate Solutions is independently submitting these comments, we and the Conservancy of Southwest Florida, Environmental Defense Fund and Sanibel-Captiva Conservation Foundation are working in partnership on the Collier County CSRM Feasibility Study, and we are supportive of each other’s contributions to both the NEPA scoping process and the CSRM Feasibility Study planning process. Growing Climate Solutions looks forward to seeing this study advance with creative alternatives: Alternatives that are supported locally, consider environmental and social benefits, incorporate a range of longer-term hazards associated with a warmer climate, and leverage the land-use and development policies and regulations framed by state, regional and local governmental entities.  Collier County is home to some of the state’s most unique ecosystems and thrives from a robust tourism, recreation, and water-based economy. We are hopeful that by developing a USACE CRMS study that comprehensively examines coastal hazard vulnerabilities and develops innovative approaches to balance multiple interests, this initiative will help protect and preserve the county’s unique landscape for future generations.


With Warm Regards,

Ana Puszkin-Chevlin, Ph.D.

Regional Director, Growing Climate Solutions


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