Here is a copy of my email correspondence with the COE on this issue:
Good morning Mr. Blyth,
Thank you for taking the time to submit this inquiry. I will forward these questions to our project manager and ask that she provide you with a detailed response.
Please let me know if you have any questions or additional concerns.
Sandra Arnold, APR+M
Chief, Public Affairs
U.S. Army Corps of Engineers Galveston District
Office: (409) 766-3005
Blackberry: (409) 502-9150
From: Matt Blyth [mailto:firstname.lastname@example.org]
Sent: Wednesday, December 21, 2011 11:17 PM
To: Public Affairs, Galveston District Corps of Engineers
Subject: Current Dredging Operations in West Galveston Bay
I am writing to you on behalf of Texas Flyfishers of Houston, a Houston based non-profit organization associated with the Federation of Fly Fishers (www.texasflyfishers.org
) and also as a concerned individual and Houston area resident. I have been following the progress of the dredging operations currently ongoing in the ICWW on the north side of West Galveston Bay with great concern. I am sure you have been bombarded with emails over the last few days asking for information on why the dredging material is being dumped where and how it is, however hopefully you will have time to reply to my questions and concerns.
I have been reading the publicly available Environmental Assessment done for the proposed new Beneficial Use of Dredged Material zones on the north side of the ICWW published by the COE in February 2007. In this document you propose developing a new material dumping zone (PA-62A) on the north side of the ICWW with the purpose of restoring and maintaining the marshland. In this report you state: "The no action alternative is continued use of the existing emergent unconfined PA No. 62 (Figure 2). This alternative remains an available option; however, use of this alternative would result in continued discharge of dredged material into West Bay. Submerged aquatic vegetation (SAV) is colonizing the bay margin along this PA; however, continued use of PA 62 will occasionally be necessary to prevent the land from disappearing due to erosion. If all of the dredged material from the adjacent reach of channel was to be discharged into this area, as is the historical and current practice, adverse impacts to the SAV would not be minimized. More importantly, beneficial uses of the dredged material described in this EA would not be realized. The intrusion of saline water into the marshes would continue unabated unless action is taken to impede it. Implementation of other suitable measures would not be as cost-effective as the preferred alternative." My first question therefore is why, when you have publicly stated that using the new proposed dumping zone would be better on all counts, has the COE made the decision to continue using the existing dumping zones (PA-62 and PA-63) as stated in your December 21st News Release (No 121103) rather than the new beneficial use zone PA-62A? According to the report the COE has been aware of the newly developing seagrass beds on the existing PA-62 and PA-63 locations since the EA was conducted and is also aware that the use of these locations does not minimize the impact to the grasses, as is a stated aim of the Corps' activities.
From what I can gather the use of the PA-62 and PA-63 locations has been approved since the Final Environmental Statement (EIS) for Maintenance Dredging, Gulf Intracoastal Waterway, Texas Section -- Main Channel and Tributary Channels (USACE, 1975). I would like to know how often you are obligated to repeat the EIS for these areas to allow for changing conditions and when the last one was performed? Please can you point me towards the documents for any EIS conducted on these areas?
Lastly I would also like to know where I can find the COE's studies of the effects of dredged material type and thickness on seagrass beds and what thickness of dredged material the COE considers the absolute safe maximum to ensure survival of the seagrass, even during the dormant period? I am sure that you are currently aware that the thickness of dredged material placed on the current PA-63 location is so deep that it is causing considerable doubt amongst local residents that any of the seagrass and oyster beds will survive at all. Therefore I would also like to know if a COE inspector has personally been out to the current dredge dumping location, has measured the sediment level over the complete zone and has pronounced it to be within the COE's benchmarked limits for seagrass survival? If not, when will this occur and if these limits are exceed then what plans does the COE have in place to restore the seagrass beds to acceptable conditions?
I look forward to your reply
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