Comment from Coastal Conservation Association Virginia

Many areas of the Continental Shelf seafloor off of the Delmarva Peninsula have been degraded by fishing industry draggers which tore up the bottom with their harvesting gear, destroying the natural conditions which supported the fish they harvest. Natural recovery of these areas takes decades yet remains possible because the sedimentary character of the bottom is unchanged. Excavation of bottom sediments for extraction of minerals cannot be accomplished without destruction of valuable marine biological resources because of the massive industrial scale removal of material over large acreages that would be necessary to make such activity profitable. This removal would change the sedimentary and marine biological characteristics of the bottom to the detriment of marine fisheries. A thorough assessment of fisheries impacts, and mitigation thereof should be part of the official consideration of the sediment mining and minerals extraction proposal. The proposal by Odyssey Marine Exploration doesn’t effectively address protection of wrecks, all of which provide valuable three-dimensional structural marine habitat, including low profile and broken-up wreckage. This is a serious defect because the full extent of wrecks with historical and archaeological value is undetermined. The Continental Shelf off the Delmarva Peninsula holds hundreds to thousands of charted and uncharted wrecks. Many recorded wrecks have yet to be found. Many obstructions and “hangs” are wrecks. Hydrographic surveys with Bathymetric Attributed Grid (BAG) coverage is limited to a band along the coast and there are large areas which are uncovered by high-technology comprehensive hydrographic surveys. Industrial excavation of sediments without a comprehensive hydrographic survey of proposed dredging sites and correlation of survey data with wreck documentation would thus have a high risk of destroying marine historical and archaeological resources which are also marine habitat resources. Assessment of wreck resources in the proposed sediment mining areas should include, but not be limited to, correlation with the following sources which document wrecks and obstructions: * NOAA Coast Survey’s former Automated Wreck and Obstruction Information System (AWOIS) which is extensively referenced in National Ocean Service (and predecessor agency) Hydrographic Survey Descriptive Reports. Although these data are incomplete and vary in position accuracy and extent of detail, they are nevertheless an invaluable compilation of wrecks and wreck details. Electronic copies of the AWOIS wreck, obstruction, and ENC wreck data are available at the Library of Congress. KML extracts of AWOIS data are submitted with these comments. Electronic files of the extracts and the full AWOIS dataset wreck, obstruction, and ENC Wreck files available on request. *Gary Gentile’s Popular Dive Guide Series which documents many wrecks off the Delmarva Peninsula. *Eastern Search and Survey’s high-technology surveys of wrecks off Delmarva Peninsula. *Wrecksite.eu, a subscription service with extensive wreck data including the proposed minerals leasing area. *“Fishing Reef” books by Wayne Young which document wrecks and obstructions in the coastal waters off the Delmarva Peninsula with geographical coordinates. A wreck coordinates PDF file and KML prepared for CCA Virginia of the wreck sites, obstructions, and obstructions with wreck signatures in these books are included with this electronic submission. Wrecks, large and small, intact, distributed, or broken up, interact with surrounding bottom and nearby features and bathymetry and current flow in relation to these. If a lease is granted, it should include a required buffer around all wreckage to minimize any changes in environmental conditions as they pertain to each specific wreck site. A 1,000 yard minimum buffer is suggested. Site-specific conditions may necessitate a wider buffer zone. Enormous quantities of a publicly-owned resource would be removed if the proposal were approved and became operational. Transportation, storage, processing, and disposition of processed sediments would have their own suite of impacts, all of which should be assessed. Processing sediments would necessarily change their structural and chemical composition. These changes should be assessed as part of the offshore leasing process to determine the structure and chemical composition of prospective processed materials, whether or not the changed character of the processed material poses a hazard, and whether or not the processed material can be used beneficially, and if not, the disposal needs and requirements. Minerals in whatever form mined from the public bottom shouldn’t be given away without compensation. A royalty should be established for mined materials. Royalties should be earmarked for use in marine environmental conservation and restoration insofar as may be allowable under Federal rules and regulations.