To the Editor: Turtle Windows

Re: East Coast Dredging Issues Widely Covered at Charleston Meeting IDR November/December 2008 page 6.

The report presented by Dena Dickerson at the ICHDMG meeting regarding the “environmental window” imposed on ocean dredging for beach restoration is indicative of restrictions mandated by the regulatory agencies without prior adequate scientific investigation to determine the necessity and applicability of the regulation to the specific site involved.

The findings reported indicated that in the 2007 study period only 27 turtles were impacted by dredging while during the same period the fishing industry impacted 10000 turtles.

Dredging “windows” have resulted in greatly increased costs due to the limitation of available equipment and the inefficiencies of cold weather operations.
These same type of “generic” restrictions for “winter flounder spawning” and “hibernating Indiana bats” also severely curtail the time that dredging can be performed resulting in increased costs.

Environmental windows should only be imposed based on project site specific investigations during the permitting process.

During the 32 years that we have operated hydraulic dredges in the performance of more than 250 projects we have observed the proliferation of restrictions imposed by federal state and local governments without scientific evidence of the necessity or benefits of the “windows”.

Charles E. Pound
President
Aqua Dredge Inc.
Armonk New York