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Texas General Land Office Comments on the Draft
Environmental Impact Statement for the North
Padre Island Storm Damage Reduction and Environmental
Restoration Project (Packery Channel)
1.1 Purpose and Need
The purpose and need statement mentions that a water exchange pass will be created to periodically reduce hypersaline conditions in the Laguna Madre for ecosystem restoration. Given that the Laguna Madre is considered one of three unique hypersaline lagoon systems on Earth, it is not clear why decreased salinity levels are needed or desired. A better justification of the need for reducing salinity levels and the anticipated benefits should be provided in the Final Environmental Impact Statement (FEIS).
1.2.2 Placement Areas (PAs)
The effect of windblown sand on channel shoaling rates is considered to be
insignificant in the DEIS based on the observation that the adjacent area is predominantly vegetated. Although there is vegetation in the area, there is also evidence of unvegetated dune blowouts in close proximity to the proposed channel. Additionally, aeolian transport of sand is a major component of the beach environment that may significantly affect channel-shoaling rates. The effects of windblown sand on channel shoaling rates and subsequent maintenance dredging requirements should be examined in greater detail in the FEIS, or contrary evidence should be presented to show reasons windblown sand shoaling rates are insignificant.Initial construction of the proposed channel will be a federal action, but maintenance dredging will be the responsibility of the local sponsor. The local sponsors have expressed a desire to have Packery Channel designated as a federal navigation project in order to have the U.S. Army Corps of Engineers (USACE) be the responsible party for maintenance dredging. Although the preference of the local sponsor to federalize the maintenance dredging is understandable, it raises concerns as to the financial commitment of the local entities for properly maintaining the channel. The FEIS should provide details of local funding mechanisms to properly conduct maintenance dredging over the 50-year life of the project.
Decant water from proposed PA I and PA2 is to be drained from the PAs and directed across the beach towards the surf zone. Dredged material decant water is usually returned to the channel being dredged. The drainage ditches across the public beach could unnecessarily raise turbidity levels in the project area and create hazardous conditions for vehicles and pedestrians on the beach, impairing access to and use of this public beach.
The quality of dredged material suitable for beach placement is described in the DEIS as material with a fines content of 5 percent or less, but up to 30 percent if the fines fraction does not contain a significant amount of cohesive clay. The desired quality of the dredged material for beach placement should contain no more than 5 percent cohesive clay. Material with more that 5 percent cohesive clay may lead to poor drainage during
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