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Packery.Com - Information
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contractual commitment should be obtained from the local sponsor to ensure that the
maritime enforcement office will be operated and staffed as indicated.
4.4.2 Submerged Aquatic Vegetation
(SAV)
The DEIS mentions that the channel is designed to create approximately 5.4 acres of
shallow shelves between the channel and bulkheads that may be suitable for SAV
recruitment. The description of the proposed shelves in section 4.4.2 of the DEIS as well
as Section 4.5.1.3, Essential Fish Habitat, implies that the constructed area would help
mitigate for the 5.2 acres of impacts to existing SAV. We are not convinced that the
constructed shelves will be occupied by SAV as the sediment characteristics, boat wakes,
and reflected wave energy from the bulkheads will make the establishment of SAV
difficult. It should be clarified in the FEIS that the 5.4 acres of potential SAV habitat on
the constructed shelves will not be considered as mitigation for impacted SAV.
In Appendix A of the DEIS - Texas Coastal Management Program
(CMP)
Compliance with Goals and Policies - the 5.4 acres of shelves are actually described as
on-site, in-kind mitigation for SAV. This issue needs to be clarified or corrected in the
FEIS and Appendix A to state that the constructed shelves are not considered as
compensatory mitigation for impacted SAV.
4.4.4 Coastal Shore Areas/Beaches/Sand Dunes
It is our understanding that the dune protection permit issued by
Nueces County for
Phase I of the North Padre Island Storm Damage Reduction and Environmental
Restoration Project obligates the City of Corpus Christi to fully mitigate for any damages
to the dunes and dune vegetation within the geographic scope of the Dune Protection Act
jurisdiction. Furthermore, the City of Corpus Christi is required to carry out mitigation
for all dune and dune vegetation impacts in consultation with the GLO.
The beach nourishment through the beneficial use of sand dredged from the proposed
channel is described as having a positive impact by countering the current erosional trend
of the shoreline. It should be stressed in the FEIS that this is most likely a one-time
positive impact, as the presence of the jetties will possibly result in greater long-term
negative erosional impacts than currently exist. Without an aggressive sand bypassing
program and renourishment from maintenance dredging, the areas currently affected by
erosion could experience accelerated beach loss with erosion rates in excess of current
trends.
4.11.2 Tax Increment Finance District
(TIF)
The DEIS provides a good description of the intent and operation of the
TIF. It is
unclear if the purchase of the bonds by private developers will occur prior to
construction. Purchase of the bonds prior to the start of construction would help to
ensure the local sponsor's financial viability and commitment towards the project.
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