August 9, 2002

Dr. Lioyd H. Saunders
Chief, Planning, Environmental and Regulatory Divisions
U.S. Army Corps of Engineers
P.O.Box 1229
Galveston. Texas 88553-1229

Dear Dr. Saunders:

This letter is in response to your June 6, 2002 request (or comments concerning the Draft Environmental Impact Statement (DEIS) for the North Padre Island Storm Damage Reduction and Environmental Restoration Project (PL 1U6-53). The proposed project involves the construction of a channel between the Lagnna Madre and the Gulf of Mexico across North Padre Island, Nueces County, Texas, and is referred to as the Packery Channel project

As mentioned in our July 26, 2002 letter to you, members of your staff and the consulting firm of PBS&J contacted Texas Parks and Wildlife Department (TPWD) and the other resource agencies in an effort to coordinate a meeting to discuss potential environmental concerns associated with the proposed project. Department staff participated in (he subsequent July 8, 2002, July 1 1. 2002, and July 19, 2002 interagency meetings and site visits. A number of issues were discussed and clarified. The USACE. PBS&J. and the City of Corpus Christ! attended the meetings and provided additional information to the various resource agencies in attendance. TPWD has reviewed the DR1S and the newly acquired information and offers the following comments.

Direct Habitat Impacts and Mitigation

Based on information contained in the DF.IS. 5.2 acres seagrass beds. 0.2 acres of smooth cordgrass marsh, 10.9 acres of high salt marsh, and 1.5 acres of tidal flats will he impacted as a result of the dredging and disposal activities associated with this project. The DEIS does not include mitigation for any of the aforementioned habitats except for seagrass beds. During (he July 8, 2002 meeting, the USACE and local sponsor agreed to provide compensation for these habitat types at the following ratios- seagrass beds 3:1, smooth cordgrass marsh 2:1, high salt marsh 1:1 and tidal flats 1:1 This would result in the creation of 28.4 acres of estuarine habitat. the resource agencies suggested several sites