Packery.Com - Information source for the proposed Packery Channel Project...
PROJECT IMPACTS
In addition to properly identifying and analyzing the direct and secondary project
purposes, the direct and secondary project impacts need to be thoroughly analyzed. For instance,
we understand that a proposed disposal area designated as MMPA (Maintenance Material
Placement Area), west of Packery Channel, has been withdrawn since the DEIS was written.
Therefore, a new disposal area needs to be designated. Also. about five acres of seagrasses may
be impacted, as well as eleven acres of salt marsh. Although compensation is proposed,
seagrass creation is problematic and unpredictable. Also, we could not find any compensatory mitigation
for salt marsh impacts. Impacted marsh should be replaced at a 2:1 ratio with conditions similar
to those proposed for the seagrass planting.
Similarly, the secondary impacts from this project need to be more fully addressed. The DEIS (section 4.11, p.454) states that secondary development will occur and in fact is necessary for the project sponsor to meet the funding match requirement, yet no environmental impacts associated with that development are discussed. Additional marinas, canal communities, and waterfront commercial development may, in the foreseeable future, impact wetlands, seagrasses, and intertidal flats. The cumulative impact of such activities could be significant. Therefore, an analysis should be provided regarding the potential impacts from induced development on Padre Island as a result of this project. Please discuss fully in the FE1S.
ECONOMIC ANALYSIS
The DEIS should include a cost-benefit analysis, since this project will involve expensive maintenance (maintenance dredging of the channel, pumping sand across the jetties, and monitoring). It is difficult to make an informed analysis weighing the national environmental and economic costs to the national and local environmental benefits in the absence of projected construction and maintenance outlays required. As Ac document stated (page ES-1), "the environmental benefits of all alternatives were essentially negligible." Since this is proposed as an environmental restoration project with a number of ecological unknowns, yet few predicted ecological benefits, a full cost accounting is necessary in order to properly weigh the environmental risks. Please discuss this concern fully in the FEIS.
RECOMMENDATIONS
The DEIS offers little evidence that the project purposes
would be achieved. We
therefore ask that the Final EIS provide more information in the areas
address above to support the project purpose and need. In view of the
current analysis, we find and recommend that the
no action be considered the least damaging practical
alterative and therefore recommend its Selection as the preferred
alternative.
Back
To Packery.Com
Copyright 2001 ©
Packery.Com all rights reserved
No tax dollars or political funds have been used to create or maintain
this web site. webmaster