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Galveston Baykeeper
P.O. Box 71
Seabrook, Texas  77586
info@galvestonbaykeeper.org

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Letter to US Army Corps of Engineers

USACE

(This letter used by permission from www.ourgalvestonbay.com)

 

June 15, 2012

 

Via U. S. Mail and Facsimile: 409-766-6301

Ms. Denise Sloan

Regulatory Branch, CESWG-PE-RB

U.S. Army Corps of Engineers

P.O. Box 1229

Galveston, Texas 77553-1229

 

Re:  Permit Application No: SWG-2011-01183

       Applicant:  Port of Houston Authority

       Project: Proposed Bayport Ship Channel Dredge Island

 

Dear Corps of Engineers and Ms. Sloan;

 

[Please insert personal description of who you are and how you are affected by the project. Following text is from the first form letter.]

 

I am a Texas citizen and a person very interested in the above referenced Permit Application and proposed project.   I live on the shores of and am frequently out in a boat on Upper Galveston Bay.  I believe that the creation and installation of the so-called “Beneficial Use Marsh” option in the Application (the “Marsh”), would adversely affect the water quality of the Bay and would have very detrimental environmental, economic, esthetic, fishery, and recreational boating impacts on Upper Galveston Bay. 

 

 

The alternative disposal site east of the Houston Ship Channel is already permitted, would have no new environmental or human impacts, and is the most cost-effective alternative.  In contrast, the current public notice provides very little information or analysis of the potential impacts of the proposed Marsh alternative. No supporting materials are provided that demonstrate the feasibility or effectiveness of the open bay marsh concept. The proposal is so vague and the cost assumptions are so speculative, that the Marsh cannot be considered a practicable alternative at this time. Therefore, it would be arbitrary and capricious for the Corps to grant a permit including the option for the Marsh.  If the Corps decides that the Marsh is worthy of further study, I request that a Public Hearing be held, and that the Corps prepare a full Environmental Impact Statement on this project to address the full range of environmental impacts that this open bay disposal of materials with the intention of creating a marsh would have. 

 

Some of the issues that require further examination include:

  • Water quality impacts of dumping silt into a placement area that is below the water line
  • Stability of the island/marsh during regular weather as well as storms
  • Effect on storm surge conditions in the local area
  • Impacts on fish and oysters in the area due to short- and long-term turbidity
  • Economic impacts in the region from the impacts to recreational boating, including fishing
  • Property value impacts from the aesthetic impacts of the dredge spoil disposal, the diminished usability of the adjacent waters, and the depression of the local economy from reduced recreational boating tourism
  • Siltation of adjacent shorelines from the dredge spoil disposal, including the beaches at Sylvan Beach Park and Miramar Park
  • Impact on Little Cedar Bayou, Pine Gully, and other area bayous from silt inflows, and the impact on wastewater treatment facilities that discharge into those bodies of water
  • Safety hazard created by the submerged marsh in a heavily used portion of the Bay
  • Safety hazard created by funneling recreational boating traffic into the Houston and Bayport Ship Channels
  • Whether the cost assumptions for the Marsh are anywhere near accurate given the failure of two previous open bay marshes in Galveston Bay and the likelihood of the need to armor the dredge disposal in the future

 

[Please add or subtract from this list and elaborate on some of these topics to personalize your letter.]

 

In summary, I request that the Corps of Engineers NOT include the so-called Beneficial Use Marsh as a permitted option for dredge spoil disposal for this project. If the Corps will not reject this damaging alternative at this point in the review process, I request that a full EIS of the impacts of all aspects of the project, particularly the open bay disposal of dredge spoil material under the guise of marsh creation. The EIS process would provide opportunities for the public to review the analysis done on these and other topics and provide meaningful opportunities for public input, including Public Hearings.   

 

                                                                        Sincerely yours,

 

 

 

                                                                       

 

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