John C. Ogden
Florida Institute of Oceanography
830 First Street South
St. Petersburg, FL 33701
727-553-1100
Email: jogden@marine.usf.edu
I fully support the proposal by DEP to create corridors, or fiber optic safety zones, for fiber optic cables installed in coastal waters in southeast Florida. Unlike the industry, whose planning only encompasses a 10-year horizon, the Trustees are responsible for the long-term management and use of Florida's delicate sub-tropical marine environments. The health of these environments is the key to Florida's economic future. Our nationally famous lifestyle is absolutely dependent upon healthy beaches, clean coastal waters, and robust marine resources.
The corridor concept fits within the zoning techniques being applied by coastal states all over the U.S. to separate potentially conflicting human activities in the coastal ocean. By locating corridors where past cables have already been placed and acknowledging the trade-offs necessary to allow both fiber optic industry development and conservation, the DEP has established an appropriate and, indeed, favorable mechanism for the industry. The corridors support and encourage the growth of information technology in Florida while avoiding the "spaghetti effect" of cables coming chaotically to landings anywhere.
In order to make the corridors more appealing to the industry, the DEP has come up with an incentive plan which rewards companies siting cables within corridors with dramatically eased permitting conditions and fees. Given that the industry reckons that a broken cable costs about $5000 per minute, the fees, consisting of a one-time fee of $15K and an annual fee of $100/year are very favorable indeed.
Potential Impacts
The DEP has summarized most of the direct impacts, which arise from the
installation and operation of fiber optic cables. The Trustees must appreciate
that a coral for example can live for over a century, well beyond the 10-year
maximum planning horizon of the industry. How can we compensate for the loss of
these organisms with concrete mitigation measures? The answer is that we can't.
But we are willing to make trade-offs by limiting the industry to corridors in
order to control the damage.
We must also recognize that there are subtle potential impacts about which we now know nothing. For example, are the cables potential avenues for the transmittal of diseases through the coastal zone? In the Keys, coral diseases are rampant and we must be concerned about future threats for which we currently lack information. The un-buried sections of the cables will act as barriers to dispersal and movement for many organisms. How will this affect the long-term health of these delicate bottom communities of organisms? Finally, are there any electro-magnetic concerns arising from the operation of the cables? The point is that we don't know the answers to these questions. Acting on behalf of the industry in the face of this uncertainty, the DEP has compromised in a measured, logical way, defining the trade-offs that the Trustees might take to enhance the industry and limit the potential future damage.
Mitigation with Modules and/or Boulders
The draft permit establishes strict procedures for installing the cables order
to minimize immediate environmental damage. Where damage does occur, the rules
specify the use of concrete reef modules and/or limerock boulders to be
installed to mitigate damage. It should be noted that in no way do concrete
modules or boulders actually substitute for the destruction of long-lived corals
and hard bottom communities with complexes or organisms built up over hundreds
of years. Let's not fool ourselves, this is the best we can do, but there is no
"engineering" solution for this type of damage. This is all the more
reason to acknowledge the trade-offs required and to support the localization of
environmental damage in corridors.
Conclusion
The bottom of state waters under the jurisdiction of the Trustees is land,
just as beaches, dunes, roadways, developments, and natural areas are. This land
contributes to our industry, our recreation, and our quality of life no less
than any other land. It makes sense to apply land-use-planning techniques in
this common property in which we all have a stake. The use of zones and
corridors to limit environmental damage, co-locate similar activities, and
define the trade-offs necessary for economic development and land conservation
have guided us for centuries. I commend DEP for recognizing that these
principles also apply in the coastal ocean and for taking bold, yet sensitive
steps on behalf the people of Florida and of the fiber optic industry.
Florida leads the nation in creating an ocean policy. The Florida Governor's Ocean Committee, which met in the last year of the Chiles Administration and reported to Governor Bush in June 1999, identified broad areas of future concern for Florida's oceans (see Florida's Ocean Strategies 1999). The Committee, composed of a broad cross section of Florida citizens, also presented preliminary calculations of over $100 billion in direct economic activity generated annually by Florida's oceans in fishing, ports, tourism, and industry. While this is a preliminary result the Florida Ocean Alliance, established in 1999 by former members of the Ocean Committee, has determined to work to implement Florida's Ocean Strategies and to carry the simple message that a healthy ocean is Florida's economic future, to the state government.
A key part of Florida's ocean policy is the recognition that the principles of ecosystem management and land-use planning apply in the coastal ocean (see Looking Seaward: Development of a State Ocean Policy for Florida). For example, the zoning action plan of the management plan Florida Keys National Marine Sanctuary managed under a cooperative state-federal agreement establishes a number of zones, including corridors for boats, marine reserves, and special use areas. The Key Sanctuary management plan is the first of its kind in the U.S. and has received wide endorsement by other coastal states which are using it as a model for ocean use planning.
The use of corridors for fiber optics cables is simple common sense and good business. It establishes the state's vital concern for the long-term in ocean-use planning and helps to sustain a critical part of our environment for the economic and spiritual benefit of generations of future Floridians. Finally, it provides a critical hedge against the present uncertainties of the long-term impacts of fiber optic cables in the coastal ocean.
References
Christie, Donna R. 1997. Looking Seaward: Development of a State Ocean Policy for Florida. Department of Community Affairs, Florida Coastal Management Program.
Florida Governor's Ocean Committee. 1999. Florida's Ocean Strategies. Florida
Department of Community Affairs, 49p.