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E71 <br />Beth Mitchell and,.Don Donaldson <br />March <br />Page 7 ' <br />shall be considered to be causing an adverse impact. <br />Shorelines are considered as the Mean High Water (MHW) <br />contours and the computations shall weight the changes by <br />one-half the distance to the adjacent profiles. The average <br />mean high water changes shall be assessed on an annual basis <br />and will be considered net cumulative shoreline change for <br />the purposes of the determination of increase in beach <br />width. <br />Scour - Additional detail for this parameter is required such as <br />what will be the frequency of performance assessment, i.e., <br />average annual scour or scour from a specific storm event? now <br />will the underlying rock effect this performance parameter? In <br />other words, what good will an upper limit of greater that 3.5 <br />feet be if the depth of sediment is only 2 feet? <br />Settling of Units - This performance criteria is somewhat soot <br />since most of the units are expected to settle to underlying <br />rock. <br />Alignment of Units - it is not clear how and when this criteria <br />will be measured. <br />Increase in currents - Same comment as above. <br />Marine Turtle Impacts - Please refer to the enclosed meso from <br />Mike Sole concerning the assessment of this performance criteria. <br />Biological Impacts - Please refer to the enclosed memo from Mike <br />Sole concerning.the assessment of this performance criteria. <br />Sediment Accumulation on Hardbottom - Additional detail is <br />necessary, i.e., how and when will this be measured? <br />These performance criteria need to be more explicitly expressed <br />in the test plan matrix and explained in detail in the text of <br />the test plan. <br />Exhibit 6, PEP Reef Test Plan <br />General Comments: , <br />J <br />The test plan does not incorporate the test plan matrix nor <br />explains the matrix performance parameters. <br />The test plan outlines performance criteria as claimed <br />he <br />proprietary owner. As mentioned in previous correspond*nce, this <br />Is inappropriate. <br />There is no provision or section involving contingency plans that <br />would be triggered by the limitations set out in the test plan <br />matrix. <br />The test objectives are vague, lacking clarity and definition <br />The various components of the monitoring program and data <br />analysis involving three different organizations make the plan <br />confusing with unnecessary coordination required and high costs <br />associated with travel and overhead. <br />The total cost of the test plan is prohibitively high when <br />compared to other test plans for equivalent projects. <br />29 boos 94 pAin 711 <br />MARCH 28, 1995 <br />i <br />