Comment from Connie Gasque

Connie Gasque August 21, 2009 167 Root Trail Palm Beach, Fl. 33480 National Marine Fisheries Service Southeast Regional Office Protected Resources Division 263 13th Avenue South Saint Petersburg, FL, 33701 Re: RIN 0648–XP68, Public Comment Petition to Revise Designated Critical Habitat for Elkhorn & Staghorn Corals Dear Ms. Moore, I am a resident of the Town of Palm Beach, a member of the Palm Beach County (PBC) Reef Research Team, a Board of Director for the Palm Beach chapter of the Surfrider Foundation and a volunteer diver for PBC Reef Rescue. I have been diving the reefs of Palm Beach County, Caribbean and Indo-Pacific for 30 years. I have participated in research diving projects with the Smithsonian Tropical Research Institute, Harbor Branch Oceanographic Institute and have been a contributor on peer reviewed published scientific papers with Dr. Brian Lapointe and D.S. and M.M. Littler. I have logged many thousands of hours diving the PBC coral reef tract and I am intimately familiar with its characteristics. I recently appeared as an expert witness on behalf of the Surfrider’s successful challenge of the Town of Palm Beach’s Reach 8 beach renourishment permit. I am writing this letter to provide my public comment pursuant to the NOAA/NMFS, 90–day Finding for a Petition to Revise Designated Critical Habitat for Elkhorn and Staghorn Corals. First, I would like to share with you my observations based on my 30 years of diving experience on the PBC reefs system both north and south of the Boynton Beach Inlet. One barrier reef with occasional breaks spans the entirety of the county approximately one mile off-shore. The topography of the reef does not change until north of the Palm Beach Inlet. Over the years I have observed staghorn coral present throughout this reef system. In years past the staghorn was more abundant than it is today and no one paid much attention to it. There are even anecdotal reports of elkhorn on the inshore patch reefs in the area from the Mar-a-lago estate north to the Palm Beach Inlet. Generally, the staghorn was and still is found on the outer, seaward reef face in about 50 to 60 feet of water. Today only a faction of the former number of colonies exist., but an abundance of staghorn skeletons still present throughout the PBC reef tract testify to the once common occurrence of this coral on these reefs. I was shocked to learn, knowing staghorn is still present on most of the PBC reef tract, that the proposed critical habitat border at the north PBC line was moved south to the Boynton Beach Inlet. I immediately performed a dive on Bath and Tennis Reef to obtain the needed documentation of staghorn colonies which was submitted in the PBC Reef Rescue petition to revise the staghorn habitat boundary. I urge you to consider the evidence that staghorn coral was present throughout the PBC reef tract at the time of ESA listing and include all PBC staghorn colonies and suitable habitat within a revised designation and move the north boundary back to where it was originally proposed. Sincerely, Connie Gasque