Beside the City of Cape Canaveral (#176, 12 parcels totaling 465 ft), only two Plaintiffs 

 (Pittman, #131, 350 ft and Eberwein, #8, 230 ft) own parcels in the first 10,500 ft of shore, and 

 their claims of loss total 172,663 cy. Recognizing that an indefinable portion of this volume loss 

 occurred after 1965, an estimate of Plaintiffs' volume losses after 1965 within the first 10,500 ft 

 south of Canaveral Harbor was made by subtracting 172,663 cy from 464,710 cy. This yields 

 292,047 cy of alleged volume losses after 1965, which is 2.3 times the amount of erosion 

 (125,900 cy) computed from 1965 to 1994 surveys above and landward of the 1951 MHW. 



F. 7.3. Other Issues Related to Plaintiffs ' Volume Claims 



Names of plaintiffs and associated frontage (in ft) were provided to the Defendant in 1995. 

 Summing this frontage for the first 10,500 ft south of Canaveral Harbor yields a total of 1 1,845 ft 

 of ocean frontage (for Plaintiffs north of R10+850), a physical impossibility. Defendant 

 estimates that Plaintiffs own 43 shorefront parcels totaling only 5,880 ft of ocean frontage in the 

 first 10,500 ft south of Canaveral Harbor. This appears in large part to be duplication by 

 Plaintiffs for condominium properties. As an example, Canaveral Sands Condominium 

 Association (Plaintiff No. 5) claims 700 ft of frontage and 149,380 cy of dune and bluff loss, yet 

 three additional Plaintiffs (Nos. 242, 108, and 130) appear to be claiming the same frontage and a 

 portion of the dune and bluff loss claimed by Plaintiff No. 5. Similar discrepancies exist in 

 Plaintiffs' Answer to Defendant's Interrogatory No. 10 and Request for Production dated 

 June 30, 1995, and Plaintiffs' second estimate of dune and bluff volume losses dated June 28, 

 1996. 



c_4Q Appendix F Brevard County Federal Projects and Surveys 



