F. 7.1. Plaintiffs ' First Claim of Volume Loss 



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In 1995, plaintiffs claimed total volumetric losses of 4.8 Mcy (claimed dune loss of 1.8 Mcy 



37 



and other volumetric loss of 3.0 Mcy ) for the first 10,500 ft south of the south jetty at Canaveral 

 Harbor for the period 1951 to 1995. These claims of volume loss, presumably above and 

 landward of the 1951 MHWL, are 16 times higher than those estimated from beach-profile 

 surveys for the period 1951-1994. It is important to note that within the first 10,500 ft south of 

 Canaveral Harbor, the Defendant estimates that 43 shorefront parcels owned by Plaintiffs sums 

 to 5,880 ft. Because Plaintiffs shorefront parcels are 5,880 ft of the first 10,500 ft, it could be 

 expected that erosion losses would be similarly reduced from a computed total. 



Alleged volume losses from the Applegate property, which is located within the 10,500 ft 



36 



south of Canaveral Harbor, totaled 42,550 cy (21,340 cy of dune and bluff erosion, 21,210 cy 



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of other volumetric loss. Applegate's claim of volume losses in 1995 amounts to 13.9 % of 

 actual loss (305,200 cy), yet Applegate's property width of 100 ft is only 0.9 % of 10,500 ft. 



F. 7.2. Plaintiffs ' Second Claim of Volume Loss 



Plaintiffs provided the Defendant a second estimate of dune and bluff volume losses from the 

 time of purchase to 1995 on or about June 28, 1996. Summing the information provided by 

 Plaintiffs second submission for claims within 10,500 ft south of Canaveral Harbor yields 

 464,710 cy of alleged losses from time of purchase to 1995. This is 1.5 times the amount of 

 erosion from 1951 to 1994 (305,200 cy) above and landward of the 1951 MHW for the 10,500 ft 

 of shoreline south of Canaveral Harbor. It is important to note the following: (1) Defendant 

 estimates that Plaintiffs own 43 shorefront parcels totaling 5,880 ft within the first 10,500 ft 

 south of Canaveral Harbor. Since Plaintiffs' shorefront parcels are 5,880 ft of the first 10,500 ft, 

 it could be expected that erosion losses would be similarly reduced from a computed total; and 

 (2) Plaintiffs' claims are alleged to have been made from time of purchase, and yet they exceed 

 the estimate of loss based on survey data for the period 1951 to 1994. 



The volumes losses from 1965 to 1995 have been estimated to be 125,900 cy above the 1951 

 MHW line for the area 10,500 ft south of Canaveral Harbor (see Table F-13). These 

 comparisons were made based on the US ACE October 1951 Canaveral Harbor pre-construction 

 survey, the USACE 1965 survey (D.O. File 24-29, 128; thirty-five sheets, a copy of which is in 

 Plaintiffs' possession) and the USACE January 1994 survey. 



Based on information in Exhibit "A," November 16, 1995, Plaintiffs' Response to Defendant's Request for Information in 

 Accordance with Court Order Dated August 1 8, 1 995. Volume is summed for the first 62 Plaintiffs (to R1 0+850). 



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Based on information in table enclosed to 30 June 1995 Plaintiffs' Answer to Defendant's Interrogatory No. 10 and 

 Request for Production. Volume is summed for the first 62 Plaintiffs (to R1 0+850). 



Appendix F Brevard County Federal Projects and Surveys F-39 



