Texas Parks and Wildlife

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Dr. Lloyd H. Saunders
Page 6

barrier island and associated estuarine habitats. I he Padre Isles and Lake Padre
projects are located in the immediate project vicinity, yet they had not been
mentioned in the cumulative impact analysis. Therefore, TPWD recommends that
the cumulative impact section of the DEIS be rewritten to address and document
cumulative impacts within the project and study area. In addition. the proposed
private development mentioned in the Environmental Consequences Section of
the DEIS should he included in the Cumulative Impact Section.

The DEIS indicates that seagrasses will experience an area-wide increase and
approximately 935 acres of potential seagrass habitat will he created in the
beneficial use (BU) sites for the Corpus Christi Ship Channel-Channel
Improvement Project. Furthermore, the DEIS concludes that cumulative impacts
due to past, existing, and reasonably foreseeable future projects, along with the
proposed project, were found to produce a net positive cumulative impact in the
project urea." During the July 8, 2002 meeting, the resource agencies pointed out
the fact that the BU sites were to he designed to allow for a diversity of elevations
and habitat types and that the success of seagrass colonization is not assured. In
addition, the BU sites (and most of the other examples cited in the Cumulative
Impacts Section) arc not located within me study area (Upper Laguna Madre).
the USACE and City of Corpus Christi agreed to remove these inappropriate
references and revise the cumulative impact analysis to address activities in tile
Upper Laguna Madre area.

Project Purpose and Need

According to the DEIS. the purpose of the project is storm damage reduction and
environmental restoration. Environmental restoration would be accomplished by
constructing a water exchange pass (Packcry Channel) to periodically reduce
hypersaline conditions in the Laguna Madre. Although (lie Laguna Madre is one
of' the most productive and unique lagoonal ecosystems in the world, the DEIS
docs not include any information or scientific justification as to why salinities
need to he reduced in this naturally functioning ecosystem. Furthermore, (he
DETS indicates that "the proposed project will result in an insignificant change in
salinity of a few parts per thousand in the vicinity of the inlet and much smaller
changes well into Corpus Christi Ray and the Laguna Madre. These changes arc
expected to have little to no effect on the system." This information does not give
the reader a clear understanding of the goals and benefits of' the environmental
restoration component of the project. Therefore, it is recommended that the FIES
include a discussion which clearly identifies the ecological benefits and
justification of this aspect of the project.

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