January 28, 2005
Ms. Virginia Lane, Environmental Specialist
Federal Aviation Administration
Orlando Airports District Office
5950 Hazeltine National Dr. STE 400
Orlando, Florida 32822-5024

RE: Draft Environmental Impact Statement (DEIS) for Proposed Relocation of the Panama City-Bay County International Airport (PFN), Panama City, FL

Dear Ms. Lane,

The Florida Wildlife Federation appreciates the opportunity to review the subject Draft Environmental Impact Statement for Proposed Relocation of the Panama City/Bay County International Airport (PFN), Panama City, FL.

Since the preferred alternative for the proposed airport is a site located between the headwaters of Crooked and Burnt Mill Creeks in northwest Bay County, we are especially concerned about impacts of the development on Burnt Mill and Crooked Creeks that flow into West Bay. The quality, quantity, and seasonal discharge of freshwater from the two creeks provide almost, if not all, of the annual freshwater inflow to West Bay. Flow from these creeks is essential to the maintenance of the water quality and species diversity of West Bay and the creeks. Therefore, impacts of the proposed airport development on the surrounding water bodies and fisheries are of utmost concern. These impacts cannot be adequately assessed without basic information on these resources.

Unfortunately, your administration, the FAA did not require the necessary field work that would properly document the aquatic species that would be impacted, and it did not conduct studies on water flows in the creeks and tributaries that are essential, even critical, to determining impacts as requested during FAA/EIS scoping meetings.

Furthermore, on page 3 of the Appendix to the DEIS, the U.S. Fish and Wildlife Service Representatives told the consultants that there were few, and possibly no studies that characterized the streams or drainage patterns associated with the site. As I am sure you can understand, without adequate ecological characterization of these steams and drainages, it is impossible to assure proper upland management which will protect delicate species, critical water quality, and assure vital water flow.

A Florida Wildlife Federation member, James Barkuloo [a retired fishery biologist with well over 30 years of field experience in Bay County] could find no fishery inventories or hydrological

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studies on Crooked and Burnt Mill creeks, after an extensive search for such materials. Jim helped conduct fishery surveys on the only streams in the area where inventories were conducted. These were the Econfina, Bear, Cedar and Bayou George creeks which flow into North Bay. He collected Gulf sturgeon and alligator gar in those surveys. The sturgeon is listed as a threatened species and the alligator gar is very rare in Florida.

FAA consultant interviews with Florida Fish and Wildlife Conservation Commission biologists resulted in no additional information on fish populations in these streams. Mr. Terry Gilbert (FWFC Biologist) stated in the meeting that rare species should also be included in your surveys. Since there have been no fishery or hydrological studies on these streams, there is no way to determine impacts of the airport development on fisheries because there is no way to know the type and degree of management needed. An inventory of fishes is a basic need to address impacts of airport development on freshwater and estuarine species diversity and your EIS will be incomplete without it.

The description of your contractor’s field surveys for fish and the resulting list of fish species indicate a total lack of experience and training necessary to inventory fishes in these streams. The sampling design, number of samples, techniques used to collect samples, and length of study, are all, unfortunately, woefully inadequate and scientifically flawed. More importantly, dependence upon such inadequate data to guide management strategies is a dangerous strategy to protect coastal resources and species of Florida. The ecological risk of using this inadequate information is very high. To take such a risk, when proper studies can and should be completed is, as I am sure you will agree, really unnecessary.

Methodologies described on pages 4-64 and 4-65 are ineffective in acquiring fishery information needed. Aquatic biologists experienced in a variety of collection techniques would be necessary to do an adequate survey. It appears from the description of the surveys that only streams directly in the area of construction were surveyed. There was no attempt to survey the downstream portions of the streams which would be directly and indirectly affected by the proposed development. Also, only Burnt Mill Creek, not Crooked Creek was mentioned in this survey description. Was a fishery survey attempted on Crooked Creek?

Page 4-64 states that specialized surveys were made for certain species. How were surveys for the Gulf Sturgeon, shoal bass, and bluenose shiner conducted? Were there aquatic biologists experienced in fish collecting techniques conducting the surveys and who were they? What are the qualifications of those identifying the fish and what species were actually collected? The list of preparers and consultants on pages 7-1, 7-2, and 7-3 does not include fishery specialists.

Fishery and hydrology information in and downstream of the proposed construction area is absolutely necessary in order for this DEIS to be a valid decision document.

How would Crooked and Burnt Mill Creeks be impacted by being located in or next to a mitigation site discussed on page 4-27?

The DEIS, page 4-29 states that secondary and tertiary tributaries to Burnt Mill and Crooked creeks are located within the proposed relocation site and would be impacted by the Proposed

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Project. Please explain how these tributaries will be impacted and to what extent. Also explain what can be done to mitigate these impacts. Why are Crooked and Burnt Mill creeks not considered under the category of ""black water"" streams?

Page 5-111 of the DEIS includes a statement that FDEP monitors water quality in the two basins (Crooked and Burnt Mill creeks), and therefore the effectiveness of the BMP’’s in protecting biotic and human health from surface water degradation would be assessed frequently through this monitoring program. FDEP has an infrequent (about every two years) biological index monitoring program on these two basins and there is a volunteer program (St. Andrew Bay Resource Management Association’’s Baywatch Program) that monitors water quality in the lower portion of these basins. These are good programs, but are totally inadequate to assess the effectiveness of the BMP’’s. This statement is misleading and should be modified accordingly.

 

In view of the above, we now realize that the project should not go forward without the proper ecological information. St. Andrew Bay is an estuary of National significance. Other independent

efforts, costing millions of dollars, are currently underway to preserve and restore habitats and the extensive biodiversity which exists only in West Bay. Knowing this, we are confident you will partner with us to ensure adequate hydrology and fishery investigations are conducted before management initiatives aimed at protecting Burnt Mill and Crooked creeks are designed. Federal and State law requires that you have adequate hydrological and biological information on the area to be impacted prior to making a final decision. 

Sincerely,

Manley Fuller, Executive Director

FLORIDA WILDLIFE FEDERATION

RR/pp