EPA DEIS Comments

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[ NOAA DESI Comments ] [ US Fish and Wildlife DEIS Comments ] [ Texas Parks and Wildlife DEIS Comments ] [ Texas GLO - DEIS Comments ] [ EPA DEIS Comments ]
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constniction, which is expected to block longshore sediment drift. This concern should be fully
discussed in the FEIS.

In regards to jetty construction, the effect of the jetties is not thoroughly discussed. The
DEIS states that monitoring should be scheduled to determine the extent of erosion or accretion^>in the vicinity of the jetty". The effect of jetties on longshore currents and sediment transport
might be felt several miles from the jetties. Thus, the monitoring area should be extended to
cover the entire area that may be affected. Please discuss this concern fully in the FEIS.

The DEIS states that new work material from the proposed channel would be used for
beach nourishment and to provide storm damage protection. But how this new material will
reduce existing erosion or storm damage is not discussed. The benefits from new work material
could be temporary. If this project is supposed to have long term benefits, storm damage
scenarios (with and without project) using just maintenance material should be conducted.
Furthermore, this should be presented as a beneficial use of dredged material and should not be
construed as a major project purpose. Please discuss this concern fully in the FEIS.

The second proposed project purpose stated in the DEIS is to reduce the hypcrsalinc
conditions of the Laguna Madre. The document concludes that opening the Packcry Channel to
the Gulf could result in small, localized effects, which could increase bay salinity by increasing
tidal exchange with the Gulf. The Habitat Evaluation Procedure (HEP) analysis found that gains
in habitat occur under high salinity conditions, once every five years, but slight habitat losses are
predicted under average annual conditions. Thus, a major project purpose appears to be unmet
by the proposed alternative. Please clarify this concern in the FEIS.

UNSTATED PROJECT PURPOSES

There appears to be two unstated project purposes. The first relates to providing
unproved recreational boat access to the Gulf. Since the existing bridge across the channel is not
proposed to be raised to allow sailboat access, it would appear that the reason for the channel
extension is to provide recreational powerboat access from Laguna Madre to the Gulf. For
example, on page 1-7 it states, "[t]he design of the channel width and depth was based on
previous study, results and boat registration statistics for the area, which determined that a
40-foot Bertram Yacht encompassed the majority of registered boats in the area. Therefore, a
Bertram 390 Yacht was used as the maximum size vessel for the Packery Channel design." If
this is the project purpose, recreational demands for such access should be presented in the FEIS.

The second unstated and unanalyzed project purpose appears to be to increase economic
development on North Padre Island. That the local sponsor is counting on economic benefits is
demonstrated by the fact that the local share of the project would be paid from increased tax
revenues generated on private lands adjacent to the new Packery Channel cut. The DEIS states,
"[t]he theory is that construction of the proposed Project and proposed recreational development
would generate higher tax revenues due to secondary private development, and that without the
proposed Project as stimulus, the increased tax revenues would not occur" [page 4-57].
Therefore, the FEIS should include an analysis regarding the potential for induced development on Padre Island as a direct result of this project. Please include these project purposes in the
FEIS.