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Boa 94 PTE 70 <br />Beth Mitchel�l,�ndsDon Donaldson <br />March 24 ; - A 5 <br />Page 4 <br />incomplete. <br />7.1 Segmenting and offsetting - The report states that <br />segmenting and offsetting aploars to orov de sgM rel s O the <br />longshore curs-entf created by the pumping sochani+�,�. There has <br />been no demonstration with the numerical model that the ponding <br />will not exist,.and act similarly to the Midtown project and cause <br />a significant adverse impact to the shoreline of Vero Beach. <br />7.2 The discussion of relative freeboard in the completeness <br />response is incorrect. In the third paragraph there is a <br />statement that the University study recommends that the project <br />should provide a relative freeboard value of equal to or less <br />than -1.3 after conetidering unit settlement.. -.In fact, the report <br />recommends that the relative freeboard after unit settlement be <br />greater than or equal to -1.3. The report goes on to state that, <br />"if the relative freeboard is less than -1.3, the effectiveness <br />of the Reef will be reduced significantly". It appears that the <br />proposed project is contrary to this recommendation. <br />7.3 Consideration of short segments - Even with the segmented <br />offset design, due to the "bridging" effect cited in #6 of the <br />Summary and Recommendations section contained on page 26 of the <br />report, the structure may perform as though it is*a continuous <br />line of units, contributing to the pumping mechanism causing <br />ponding and the potential for increased erosion. <br />7.4 Irregular planform of the shoreline - There has been no <br />demonstration through the use of the numerical model that the <br />proposed design will eliminate this possibility or what the <br />shoreline response will be in the area between the north and <br />south segments of the proposed project. <br />7.5 Swimmer safety - Rip currents - In the February 23, 1995, <br />completeness response, the applicant relies on the predictions of <br />the numerical model to dismiss any currents as a significant <br />threat to swimmers and states that the model shows there is a <br />decrease in currents landward of the structure. These statements <br />again point to the fundamental flaws contained in the numerical <br />modelling where the constriction of flow caused by the units and <br />the resulting pondinq is not considered. This is also a result <br />Of assuming a negative wave set-up on the landward side of the <br />structure. As mentioned previously, this is contrary to the <br />physical modelling which was supposed to be used in the numerical <br />modelling, and the existing installation at Midtown,'Palm Beach. <br />Swig safety remains a serious concern of the Department. <br />7.6 Placement of sand fill to mitigate <br />County has adamantly opposed placement <br />�Tl <br />MARCH 28, 1995 <br />adverse impacts - The <br />of sand fill to mitigate <br />