December 31, 2018

Attention: Mrs. Jennifer MorganEnvironmental Compliance BranchRegional Planning and Environmental CenterGalveston DistrictU.S. Army Corps of EngineersP.O. Box 1229Galveston, Texas 77553-1229

Dear Mrs. Morgan,

Enclosed are the comments of the Houston Regional Group of the Sierra Club (Sierra Club) regarding the U.S. Army Corps of Engineers (Corps) and Texas General Land Office (GLO) Draft Coastal Texas Protection and Restoration Feasibility Study (CTPRFS), Draft Integrated Feasibility Report (IFR), and Draft Environmental Impact Statement (DEIS).

Introductory Comments

The Sierra Club understands the effort that the Corps has made to prepare the CTPRFS, or as the Corps states in Release No. 18-050, October 26, 2018, “a first-of-its-kind feasibility study”. These comments are provided to make the CTPRFS/IFR/EIS better as pre-decision documents. This should make for better decisions for the public interest by decision-makers.

For ease of reference in these Sierra Club comments, Alternative A, Coastal Barrier Alternative, Coastal Barrier CSRM System, Tentatively Selected Plan, and ER Measures, is called Ike Dike. The Sierra Club will also use the acronym DEIS to represent the CTPRFS/IFR/EIS in these comments.

The Sierra Club requests additional time for the public to provide comments. Since this Study covers all 367 miles of the Texas Coast, considers 10's of billions of dollars of expenditures, and proposes alternatives with enormous environmental impacts and social and economic costs it is reasonable to provide the public, and decision-makers with an additional 14 to 30 days of public comment time.

The Sierra Cub requests the Corps grant this additional time. This would mean that comments would be due either on January 23, 2019 or February

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8, 2019. This extension of the comment period would not appreciably slow the preparation of the final EIS since the Corps can begin analysis, assessment, and evaluation on public comments as they are submitted and the final EIS is not due until 2020.

The Sierra Club requests that the Corps implement an extensive public outreach/participation program for the DEIS. The reason that an extensive public outreach/participation program is needed is that this DEIS may result in the expenditure of 10's of billions of dollars, massive new infrastructure, significant environmental impacts, significant social and economic costs, and altered human environments for all coastal Texans (about 13 million), all Texans (28.77 million as of 2018), and all United States citizens (327 million as of 2018). All of these citizens are potentially interested in, concerned about, and are affected by the DEIS but not all know about its availability or will be able to participate in the public comment period if they are not informed via an extensive public outreach/participation program.

Since most of the money to pay for the DEIS is federal, since this is a federal project, since most of the money used to construct proposed alternatives is federal, since federal policy, like protection of wetlands via the Clean Water Act, is involved, it is reasonable that an extensive public outreach/participation program be implemented for this DEIS.

It is important for the Corps to understand that Ecosystem Restoration (ER) measures, while part of each alternative, do not serve as mitigation measures for the environmental impacts of alternatives. Mitigation measures for the environmental impacts of each alternative are separate, different, and must be addressed independently from ER measures which are a part of each alternative.

The DEIS does not address the human root causes (for example: desire to live in places dangerous to humans and harmful to the environment, arrogance, domination of Nature, and greed) of the storm surge problem. To some degree, the DEIS addresses the symptoms of our storm surge problem: population growth, development, habitat loss, erosion, wave, tide, current, storm/hurricane impacts on the Texas Coast. The DEIS should, but does not, fully address how human actions and activities will be restrained and altered to avoid, minimize, and mitigate their effects on the natural Texas Coast and how they increase human vulnerability to storm surge.

Attachment 1: Coastal Development

This attachment documents the actions and activities, like population and development increases, that have damaged the upper Texas coast but which the Corps Ike Dike project will not address or resolve but will encourage more damage from these same actions and activities.

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1. “Coastal development, sea rise sent Hurricane Irma storm surge to more homes, study shows”, Miami Herald, Alex Harris, November 2, 2018.

2. “Real estate industry blocks sea-level warnings that could crimp profits on coastal properties”, Stuart Leavenworth, McClatchy, September 13, 2017.

3. “We already knew how to reduce damage from floods. We just didn’t do it”, David Conrad and Larry Larson, The Washington Post, September 1, 2017.

4. “Texas Coastal Geological Dredging vs. Geotechnical Dredging: Can We anticipate the Future?”, J.C. Moya, M. Mahoney, T. Dellapena, C. Weber, and T. Dixon, Proceedings of Western Dredging Association and Texas A&M University Center for Dredging Studies, Dredging Summit and Expo 2015,

5. “Channel adjustments of the lower Trinity River, Texas, downstream of Livingston Dam”, Jonathan D. Phillips, Michael C. Slattery, and Zachary A. Musselman, Earth Surface processes and Landforms, Volume 30, Issue 11, Wiley Online Library, October 14, 2005.

6. “Dam-to--delta sediment inputs and storage in the lower trinity river, Texas” Jonathan D. Phillips, Michael C. Slattery, and Zachary A. Musselman, Geomorphology 62 (2004), pages 17-34, available online April 24, 2004.

7. “Anthropogenic effects along the Texas Gulf Coast – a case study of the Trinity River, Zachary A. Musselman, Millsaps College, no date, sometime within or after 2006.

Summary of Some Important Comments

The Sierra Club requests that all comments in this letter be given careful consideration. Some of the important points and requests that these comments make for the Corps to use include:

1. Extend the comment period on the current DEIS for two to four weeks.

2. Prepare and release for public review and comment a supplemental DEIS with all the impacts, mitigation, and other information that the Corps says it has not prepared in the current DEIS analyzed with at least a 90-day public comment period.

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3. Implement an extensive public outreach/participation program for the current DEIS and the supplemental DEIS. This extensive public outreach/participation program is needed due to the potential expenditure of 10's of billions of dollars, possible construction of massive new infrastructure, creation of significant environmental, social, and economic impacts and costs, and extensively altered human environments for all coastal Texans, all Texans, and all United States citizens. All citizens are potentially interested in, concerned about, and are affected by the DEIS but not all know about its availability or will be able to participate in the public comment period if they are not informed via an extensive public outreach/participation program.

4. Contact environmental justice communities, residents, advocates, and organizations that work on environmental justice issues and request their input into how environmental justice should be addressed in the DEIS.

5. Address the human root causes of the storm surge problem (for example: the desire to live in dangerous places, desire to participate in actions and activities that are harmful to the environment, arrogance, domination of Nature, and greed) and not just the symptoms of these actions and activities (population growth, development, habitat loss, etc.) which are based upon human desires that are incompatible with the natural coastal ecosystems and processes.

The DEIS should also address these human actions and activities (symptoms) including population growth, development, habitat loss, erosion, and sedimentation on the Texas Coast. The DEIS should fully address how human actions and activities can be restrained and altered to avoid, minimize, and mitigate their effects on the natural Texas Coast and how they increase human vulnerability to storm surge.

6. Prepare alternatives which have a better balance with more non-structural methods of storm surge protection, like the Sierra Club Double E Alternative and the Bayou City Waterkeeper “Sage” Alternative. Focus on elevated structures, better construction (FORTIFIED as an example), and strategic withdrawal.

7. Change the analysis period to at least 100 years to reflect the full impacts of climate change and sea level rise in the future.

8. Discuss in the current and supplemental DEIS the responsibility of the oil/gas industry, real estate development industry, and other businesses whose property will be protected and directly benefit from any storm surge project, to protect their own resources for stockholders (fiduciary responsibility) because they are public companies, how much they should pay, why federal, state, and local governments should subsidize the entire cost of any storm surge proposal that benefits them enormously, and the fact that these businesses are responsible for many of the risks that people and property incur from spills and or have been placed people in harm’s way when there are storms by these businesses.

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9. Create a No Action Alternative that accurately reflects the population growth and development and their impacts 50 years in the future.

General Comments

1) The Sierra Club was not notified of the release of the DEIS on October 26, 2018, when the Corps placed the proposal on its website and notified the public via press release, “Release No. 18-050” and the “Joint Notice of Availability for the Coastal Texas Protection and Restoration Study Draft Integrated Feasibility Report and Environmental Impact Statement”. This undermines the Corps assertion on Page 9-1, Section 9.0 Public Involvement, Review, and Consultation, 9.1 Public Involvement Program, that “A proactive approach was taken to engage the public”. The Sierra Club does not agree with the Corps that its public participation process was “proactive”.

The Sierra Club made every effort to ensure that it commented at appropriate times during and after the scoping comment period and that it kept the Corps updated on who and how to contact the Sierra Club. This is documented when the Corps states on Page 9-2, 9.1.1 Scoping, that “the vast majority of the comments submitted by NGOs, especially the Sierra Club … Additional comments were also received outside the scoping comment period from the Sierra Club …”.

In its May 2, 2016 scoping comments, the Sierra Club stated the following about being notified about the DEIS, “5) The Sierra Club requests that it be sent a copy of the Draft EIS/Feasibility Study when it is complete. The Sierra Club prefers a hard copy of this document. If a hard copy is not available then the Sierra Club requests a CD copy. The Sierra Club requests a 90-day public comment period for the Draft EIS/Feasibility Study due to the significant nature of the proposal (multiple locations and alternatives), its geographic extent (the entire 367 mile Texas Coast), and the significant environmental, social, and economic impacts and their intensity that this proposal will cause if implemented (both positive impacts like possible ecosystem restorations and negative impacts like large, hard structure alternatives with vast footprints and significant direct, indirect, connected, cumulative, and systemic environmental impacts).”

That the Corps would not honor the Sierra Club’s request to be notified does not speak well for its public participation program and the Corps.

The Corps states on Page 9-3, 9.1.2 Agency Coordination, “The DIFR-EIS is being provided to all known Federal, State, and local agencies. Interested organizations and individuals are also being sent notice of availability.” Page 9-4, 9.2 Distribution List (*NEPA REQUIRED), the Corps states “A list of all Federal and state legislative representatives, agencies, organizations, and persons to who the notice of availability will be sent is present at Appendix G-6.”

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There is no G-6 in Appendix G. The Sierra Club assumes that this quote refers to Appendix G-5, Distribution List. The Sierra Club is on this list under “Organizations”. The Sierra Club was never sent a “notice of availability”. This is unacceptable.

Apparently, the Corps has two groups that it refers to with respect to its public participation program. The first is the public. The second is stakeholders. The Corps does not tell the public the difference between these two groups and how it handled public participation for each. Page xxii, Public Involvement, Review, and Consultation, Executive Summary, the Sierra Club was not invited to “A series of stakeholder meetings” held in 2012 and 2014.

The Sierra Club was invited to and attended two Corps meetings along with other non-government organizations in January 2017 and 2018 for updates on the DEIS. The Sierra Club was not invited to “regular working meetings with potential stakeholders and resource agencies”. The Sierra Club was not considered a stakeholder. The Sierra Club should have been a stakeholder due to its public interest role in the protection of Galveston Bay and Gulf shorelines. Certainly, alternatives formulation and environmental mitigation are areas the Sierra Club has an interest and expertise in. The Sierra Club submitted to the Corps at least two alternatives and suggested that there were many environmental effects caused by an Ike Dike alternative and mitigation was needed for those effects.

For the Sierra Club, the Corps public participation program was not proactive or robust. It did not provide adequate public access and participation in purpose, goal, objectives, alternatives, effects, and mitigation discussions and decisions.

2) October 26, 2018, Release No. 18-050, the Corps quotes Texas Land Commissioner George P. Bush that “The Coastal Texas Study is about protecting our people, our economy and our national security.” It is sad that the protection of the “environment” is not listed as what the Coastal Texas Study is about.

The Corps further says that “The options selected are proven to be effective in mitigating the deadly effects of storm surge on our state.” The Corps forgets to say that storm surge is only “deadly” when people build in the dangerous and hazardous storm surge zone. This was said more eloquently by Steven P. Leatherman, in his “Barrier Island Handbook”, University of Maryland, 1982, when he stated:

“There is really no erosion “problem” until man builds on the shore … Structures located in hazardous areas necessitate protective measures, which often result in the alteration of barrier island topography and elimination or impairment of the

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natural migrational processes … Seawalls can also have a harmful effect on beaches … prevent the natural exchange of sand between the dune and beach during storms needed to build up the offshore profile … a significant portion of the wave energy is reflected off the seawall face and downward, increasing the strength of the longshore current and accelerating the rate of beach erosion … resulting in the complete loss of a beach … attempts to stabilize highly dynamic barrier islands will ultimately fail as sea level continues to rise … The strategy should be to avoid construction at vulnerable locations … These developments will eventually require protection with massive outlays of tax dollars for engineer-ing structures and disaster relief following future major storms.”

“A barrier Island is a dynamic geomorphic feature; it must be allowed to move and change shape in adjustment to the energy and sediment conditions. Any in-terference with these natural processes threatens the integrity and maintenance of the barrier island system.”

The Corps proposes to degrade or destroy processes that allow barrier islands and peninsulas to move or roll toward the mainland with the Ike Dike or other al-ternatives. These geomorphic processes help geological features, barrier is-lands/peninsulas, survive sea level rise. The Corps degrades and may destroy these geological features by constructing a 70 mile plus levee/modified seawall/floodwall which pins down and keeps the barrier island/peninsula from moving; by blocking storm surge movement of sediment via washover areas from the beaches and dunes to the backside of Galveston Island and Bolivar Peninsula which create salt marshes and tidal flats; by blocking aeolian (wind) movement of sediment toward tidal flats and other habitats; creating the loss of beaches and dunes via storm surge wave scouring on the Gulf of Mexico (GOM) side of the levee/seawall/floodwall; by creating erosion on the Bay side of the levee/seawall/floodwall via ebbtide and other flood flows; and by the failure to address loss of sediment in the longshore current due to jetties, deeper and wider navigation channels, rock groins, bulkheads, breakwaters, revetments, and other hard, structural, shoreline measures.

In his 2007 book, “The Formation and Future of the Upper Texas Coast: A Geologist Answers Questions about Sand, Storms and Living by the Sea”, Dr. John B. Anderson, perhaps the most knowledgeable coastal geologist on the Upper Texas Coast, as attested by his education, experience, research, and publications, states:

1. “The fact is, the beach is not the only part of the coast that is retreating land-ward. The shoreface is also retreating”, Page 14.

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2. “In east Texas the shoreline has retreated landward approximately 80 miles in the past 17,000 years”, Page 21.

3. “These former shorelines indicate rates of coastal retreat of 20 meters (60 feet) per year to 5 meters (15 feet) per year during this time interval between 7,700 BP (7.7 ka) and 2,800 BP (2.8 ka), compared to the current rate of 1 to 1.5 meters (3 to 5 feet) per year”, Page 22.

4. “Thus the east end of the island became wide enough to avoid breaching after that time. The narrower west end of the island is still susceptible to breaching during a major hurricane”, Page 27.

5. “The beach ridges that record the most recent phase of Galveston Island’s growth are now being overtaken by the advancing shoreline”, Page 27.

6. “… this change from growth to erosion took place around 1,200 years ago. Hence, the island stopped growing about 1,200 years ago and since then has been retreating landward”, Page 27.

7. “About 2,500 years ago, the shoreline shifted landward, reaching its present position only a few centuries later … Bolivar Peninsula formed in a different man-ner … The peninsula grew by what geologists refer to as spit accretion, the process by which coastal currents transport sand along the coast to form a spit”, Page 29.

8. “Relative sea level rise is the second leading cause of wetlands loss in Texas. Humans are the leading cause”, Page 66.

9. “Modern bayhead deltas are already stressed by the reduction in sediment in-put from dam construction, so they are already vulnerable to increased rates of sea level rise”, Page 66.

10. “Much of southern Chambers County is below five feet elevation and subject to flooding during the next few centuries, or possibly by the end of this century if the rate of sea level rise continues to increase”, Page 66.

11. “The combination of relatively rapid sea level rise, a gentle coastal profile, and a shortage of sand in the coastal system results in faster erosion in Texas … than elsewhere in the country … The shoreline is simply migrating landward”, Page 67.

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12. “Sand that is moved offshore during storms is, for the most part, not moving seaward of the shoreface. Hence, that sand remains within the longshore trans-port system and ultimately finds its way back onshore”, Page 69.

13. “If we remove sand from an area to nourish a beach, we need to be certain that we are not taking sand that will within decades be needed to maintain the coastal profile by natural forces”, Page 69.

14. “Where beaches have been allowed to migrate landward under the force of nature, they have remained fairly much the same in terms of their width and pro-file”, Page 69.

15. “Current rates of shoreline retreat along the upper Texas coast average be-tween 3 and 5 feet per year … The beach just west of the Galveston Seawall is moving landward at rates of nearly 6 feet per year because little sand is making its way past the seawall and the rock groins to the east. Follets Island has a low profile and limited sand supply, and in places the shoreline is retreating landward at a rate of nearly 10 feet per year”, Pages 69 and 71.

16. “Figure 5.4. This aerial view of the west end of the Galveston Seawall … The key pint here is that while the beach offshore of the wall was destroyed, there is still a beach west of the seawall. There the beach was not eroded; it simply moved landward.”, Page 76.

17. “Wetlands like those shown here are vanishing at an alarming rate, in part because humans have eliminated wetlands’ ability to migrate landward under the constant pressure of rising sea level”, Page 86.

18. “But in many areas, such as along the south shore of West Bay and East Bay and along virtually the entire western shoreline of Galveston Bay, humans have built on those areas where wetlands could migrate”, Pages 86 and 87.

19. “Any action that reduces the input of sediment to wetlands will reduce their ability to exist. Damming rivers has decreased sediment supply to wetlands, and construction of high-ways and the Intracoastal Waterway, for example, has re-duced natural sediment pathways to the wetlands”, Page 87.

20. “As far as wetlands are concerned, hurricanes are not necessarily a bad thing. A hurricane every now and then helps keep the supply of sand moving into the back barrier, and these wash-over deposits become wetlands. Coastal development is preventing this process form happening”, Page 87.

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21. “Like beach erosion, this process was occurring long before development on the island began, but people have built on those areas where the wetlands would have migrated.”, Page 87.

22. “The problem is that current laws only protect existing wetlands. They do not allow for the natural migration of these wetlands as relative sea level rises and forces them landward”, Page 90.

23. “New development on the west end of Galveston Island is allowing little room for wetlands to migrate landward as rising sea level slowly drowns them”, Page 90.

24. “The sand that washes across the barriers provides plants with a framework on which to grow and keep pace with the relative rise in sea level”, Page 113.

25. “As far as beaches are concerned, they will always retreat landward, and people who build too close to the vegetation line will always pay the ultimate price of seeing their homes destroyed. It is also a sure bet that some homeown-ers will try to figure out ways to have taxpayers pay for their mistakes. But the only effective way to combat beach erosion is beach nourishment, which will be expensive along most of the upper Texas coast because large sand resources are located too far offshore to be pumped directly onshore”, Page 154.

26. “We must stop nibbling away at the wetlands, and we must give them space to retreat form the rising sea”, Page 155.

27. “Adopting a reasonable setback law the prevents construction of houses so close to the beach that they will threaten beach access in a matter of years is just good common sense”, Page 155.

The Corps attempts to assert its control over Nature which has shrunk Galveston Island for 1,200 years. This is a losing proposition and Ike Dike will waste money, human efforts, and give false hopes that will be overcome eventually by the relentless sea. The Corps addresses the symptoms of the problem and not the real problem, “keep people out of harm’s way” and “work with Nature and not against Nature”.

Page iv, Authority, Executive Summary (*NEPA REQUIRED) and Page 1-11, 1.3.2 Need, the Corps has forgotten and or ignored its responsibility in Section 4091 of the Water Resources Development Act (WRDA) of 2007, Public Law (PL) 110-114 which states, “(b) Scope. The comprehensive plan shall provide for protection, conservation, and restoration of … barrier islands … from the impacts of coastal storms, hurricanes, erosion, and subsidence.”

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The Corps proposes a Tentatively Selected Plan (TSP, Alternative A, Ike Dike) that would degrade and could result in the destruction of the Galveston Island as a barrier island and Bolivar Peninsula as a barrier peninsula because it attempts to tie down, pin down, and hold in place a barrier island/peninsula complex that must move toward the mainland to survive relative sea level rise (RSLR).

The Corps proposes the degradation and perhaps destruction of this geologic feature and geomorphic process (a rolling barrier island/peninsula complex) that is the basis for the natural ecosystems (wetlands, beaches, dunes, tidal flats, coastal prairies, bays, coves, estuaries, etc.) that the Corps purports to protect via Ike Dike for human protection against storm surge. A more unscientific, short-sighted, and wrong-headed approach could not be conceived.

The Corps does not have authorization to construct Ike Dike because it does not protect, conserve, and restore barrier islands. 3) October 26, 2018, Release No. 18-050, further states, “This is the only study to fully identify the environmental impacts and required mitigation of the proposed plan.” This statement should be true but is not. The Corps admits in many places in the DEIS that further studies are needed to determine the full environmental impacts. As a result, the Sierra Club does not agree with the Corps that “The Coastal Texas Study complies with the National Environmental Policy Act …”.

4) Page 3, “Joint Notice of Availability for the Coastal Texas Protection and Restoration Study Draft Integrated Feasibility Report and Environmental Impact Statement”, refers to the proposal that was “formulated to address the habitat loss and degradation from coastal processes.” The Corps fails to state that many of the losses that it says will be mitigated are caused by human actions and activities or that these human actions and activities exacerbate natural ecological and geological process losses. This is particularly true for climate change, rising sea level, increased high intensity rainfalls, and increased intensities and numbers of hurricanes and other storms. Please see Attachment 1.

The Corps says in the “Joint Notice” and Page xi, Planning Objectives, Executive Summary, that “Where impacts could not be avoided, they were quantified, and a conceptual mitigation plan was formulated.” The Corps contradicts itself in the following sentence when it says, “Impacts would be fully compensated with the restoration of palustrine and estuarine emergent marsh in the amount determined during final feasibility planning”. This means the Corps does not know how much mitigation is needed for the destruction that Ike Dike will cause.

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A mitigation plan is required by Council on Environmental Quality (CEQ) regulations (Sections 1502.14(f), 1502.16(h), and 1505.2(c)). The quantification of impacts was not done in many cases. For instance, the Corps does not name and quantify the fragmentation of all public and private protected lands. The Corps does not have a fragmentation plan to reduce or minimize the fragmentation that will occur with over 70 miles of levee/seawall/floodwall.

The Corps further does not state how “These measures will also maintain a natural buffer for upland areas from coastal processes, relative sea level rise, and storm surge”. The Corps does not state long how mitigation will last and whether it will be sufficient. The Corps does not show where buffers will be, how large the buffers are, and how long they will last with RSLR. The Corps will have to conduct mitigation forever (in perpetuity) because coastal processes will never end, RSLR will occur, via best estimates, for 100’s or 1,000’s of years, and storm surge will never end because hurricanes will continue to form.

Page xxi, Potential Environmental Impacts, Executive Summary, the Corps introduces a new standard, “best extent practicable” which it does not define or compare to other standards like “best possible”, “best practicable”, and “best feasible”. Due to this, the public cannot judge whether this new standard that the Corps has introduced is what the public wants and is in fact “the best”.

5) Page 4, Joint Notice and Pages viii, ix, x, xiii, xiv, xv, Problems and Opportunities, Planning Objectives, Tentatively Selected Plan, Executive Summary (*NEPA REQUIRED), Page 4-1, 4.0 Formulation and Evaluation of Alternative Plans, Page 4-23, 4.2.3 Development of Conceptual Array of Alternative Plans, Page 4-26, 4.2.3 Development of Conceptual Array of Alternative Plans, the Corps mentions risk scores of times in the DEIS, says it will reduce risk, but never defines what the risk is that is the basis for proposed alternatives.

The Corps fails to establish the present-day risk, what the risk will be in the future, what it considers to be acceptable risk, and does not provide the public a probability of risk in each instance when it talks about risk. Therefore, the public does not know how to compare and deal with risk when it is mentioned. There should be short section in the DEIS which talks about the specific risk or risks that this proposal addresses, what the risks are now, how risks are defined and delineated, what these risks will be the future, and the probability of each risk discussed.

For example, many members of the public do not know what risk is associated with a Category 1 through 5 hurricane or a 100-year or 500-year floodplain. This basic, comprehendible, information is needed to discuss this complex and expensive proposal.

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The Corps must answer questions like: How much will the risk to human life be reduced from storm surge impacts with the proposal? What is the probability of losing each human life to storm surge? How much will the risk to critical infrastructure be reduced? What is that risk now? What is the probability of that risk?

The Corps does not give clear answers about the risk for Ecosystem Restoration (ER) alternatives, measures, and plans. How long will restored coastal wetlands, forested wetlands, bottomland forests, oyster reefs, beaches, and dunes last? What is their replacement cost? How long will reduced saltwater intrusion into estuarine systems last? How much reduced saltwater intrusion will an ER project provide? For how long will this level of benefit last? How long will reduced erosion for barrier islands last? What is the current erosion? What will be the erosion after implementation? What will be the erosion after 50 years? How will RSLR negate or alter the ER projects over 50 years, 100 years, 200 years?

The Corps should explain and define what a “risk reduction system” is and how each part of the system is analyzed to produce the percent risk reduction or probability that will be achieved. We need a percent risk reduction and probability reduction for all alternatives considered.

Pages xiv and xxv, Tentatively Selected Plan and Major Findings and Conclusions, Executive Summary, the Corps talks about risk reduction. However, the Corps cannot tell the public about “the scale of the level of risk reduction” because it has not done the proper analyses. The Corps says that “in the future planning and design phases” that this will be determined. The public needs this information now.

It is now, during the DEIS comment period, that the public gets time to review and comment on this proposal. When the final EIS comes out there will be less time for the public to read another several thousand-page document for a second time and provide comments. The CEQ regulations for NEPA require a shorter period of public input for the final EIS than the DEIS. In addition, there is no requirement that the Corps take the public comments for the final EIS, respond to them, and then provide the public with its response to their individual comments. The Corps ducks its responsibility to respond because CEQ regulations do not require further response to public comments after the DEIS comment period has expired.

Page xiv, the Corps refers to the Ike Dike (TSP, Alternative A) as “providing a natural buffer from coastal storms”. This is not true. The Ike Dike degrades the natural buffer, the barrier island and its habitats, and ensures that this geomorphic process is weaker and works less well after construction than before construction. Please see Attachment 1.

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Page xv, the Corps does not state whether it will require that private beach property owners pay for the re-nourishment they get for restoration of Gulf shorelines from High Island to the west end of Galveston Island. The public should not subsidize private property owners (who need to be responsible and pay their fair share) in hazardous and dangerous storm surge and flood zones.

Page xix, the Corps does not explain where nourishment and re-nourishment material of the right grain size (borrow areas) will come from for the rest of eternity (perpetuity) for all of Galveston Island, all of Bolivar Peninsula, and all ER projects. Massive amounts of the right grain size sands or other sediments will be required for application on beaches and dunes in perpetuity to combat RSLR and existing and increased beach erosion caused by the construction of Ike Dike.

Attachment 2: Beach Re-nourishment

This attachment spells out some of the downsides of beach re-nourishment, why it will not stop sea level rise, and why it must be done in perpetuity.

1. “Isle’s beach restoration criticized”, Harvey Rice, Houston Chronicle, page 1B, August 9, 2010.

2. “Beach rebuilding efforts won’t stave off climate change impacts forever”, Emily Holden, The Guardian, September 20, 2018.

3. “The End of Sand”, David Owen, The New Yorker, May 29, 2017.

Pages xix and xx, the cost figures are suspect. The Corps has done too little analysis to be able to reliably calculate costs. For barrow areas alone, the Corps admits that “the magnitude of the job and the need to transport borrow material for levee construction onto Bolivar Peninsula and Galveston Island … risk continency markups were included in the estimate to cover unknowns, uncertainties, and or unanticipated conditions at this time.” Therefore, the public will not get a good estimate of the total costs of the Ike Dike so that they can review and comment on whether they want to pay for Ike Dike.

6) Page xi, Formulation of Alternative Plans, Executive Summary, the Corps should explain to the public how it will “manage risks associated with coastal storms within the study counties”. It is not the risks that are managed. The risks remain. It is the probability of the risk occurring that is altered by construction of Ike Dike. The Corps should define what “unacceptable environmental impacts” are and what “environmentally acceptable impacts” are. The public has a right to know what the definition and target is for each.

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7) Pages v, xv, xvi, xvii, xviii, and xix, Study Purpose and Tentatively Selected Plan, Executive Summary (*NEPA REQUIRED), the Corps refers to “breakwaters”. Throughout the DEIS this word is used scores of times, either in the singular or plural. Never once, does the Corps state for each project or location, where a “breakwater” is proposed for installation, where the sediment that currently flows past the “breakwater” proposed location goes, where it accumulates, and what impact construction of a “breakwater” will have on this sediment flow, erosion, or accumulation. The Corps should clearly state what the environmental impacts are of “breakwaters” in general, are at each location where they are proposed for installation, and how they affect erosion and accretion downstream of the “breakwater”, and how they affect sediment accumulation behind the “breakwater”. The same should be done for locations where “revetments” are proposed.

8) Pages v and vi, Study Purpose and Study Scope, Executive Summary (*NEPA REQUIRED), the Corps states, “The CSRM and ER structural and nonstructural features … would help protect the vital coastal ecosystem”. The Corps does the opposite of protection of Nature (barrier islands) from human actions and activities. The Corps actions say that Nature must be protected from Nature. This is patently untrue. Nature must be protected from human actions and activities, which exacerbate natural ecological, geological, and biological processes (changes and evolutionary alterations) that humans perceive are bad for them. Hurricanes are needed agents of ecological change in Galveston Bay and along the Gulf shoreline. Nature does not need to be protected from hurricanes because hurricanes are part of Nature and provide the ecological change that is needed on the coast.

Hurricanes are Nature's way of providing needed ecological change in our coastal and near-coastal ecosystems. Hurricanes drive natural geologic and ecologic processes like erosion, deposition, and vegetative succession so we have changed, but healthy, ecosystems. The benefits of hurricanes are not just local or regional, but global.

Hurricanes “break” droughts. This happens in Texas, Northern Mexico, and in other places in the United States. Hurricanes arrive in the summer and early fall when temperatures are often 90 to 100 degrees. Hurricane rains and winds cool temperatures and provide heat relief. Hurricanes draw up cooler waters from the deep Gulf of Mexico (GOM). This natural mechanism deters creation of more hurricanes. Cooler waters reduce heat stress in coral ecosystems. Hurricanes move warmer air from the tropics, near the equator, toward the poles so that tropical areas become cooler and poles warmer.

Hurricanes rearrange sediments (by erosion and deposition) which leads to colo-nization of new or changed land surfaces by the same, similar, or different plants. This results in the advancement or delay of natural changes in vegetation (eco-

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logical succession). When trees are blown down the forest canopy opens and more and different plants grow due to greater sunlight and increased biological production and diversity occurs.

Hurricanes erode barrier islands on the GOM side and build them up on the mainland side. This helps barrier islands move and survive RSLR. Hurricanes can create higher and wider barrier islands.

Hurricanes stir-up GOM waters which allows for up-welling of nutrients on the sea surface and increases marine life productivity. The overall productivity of ecosystems appears to increase with periodic hurricanes. After Hurricane Ike, the detritus and debris that was carried into Galveston Bay and the Gulf of Mex-ico by storm surge resulted in an increase in shrimp productivity.

Hurricane winds and waters spread seeds and other plant parts around. For ex-ample, Southern Florida tropical hardwood hammocks in Everglades National Park exist due to the movement of plant parts by birds, ocean currents, and hurri-canes.

In South Texas' Laguna Madre, hurricanes “flush” out and dilute salty waters by rain and runoff. Heavy hurricane rainfall, as it travels inland, increases water in streams, rivers, and floodplains. As these waters flow to bays, estuaries, and the GOM they bring a mixture of freshwater, organic matter, nutrients, and sedi-ments. Flushed out floodplains provide new places where plants and animals live. The “flush” of freshwater, organic matter, nutrients, and sediments fertilizes bays, estuaries, and the GOM so that, over time, biological productivity increases (more animals and plants).

Examples of how ecosystems have adapted to the effects of hurricanes are found in 1996 with Hurricane Fran and in 1999 with Hurricanes Dennis, Floyd, and Irene. These hurricanes hit the Neuse River and Estuary or Western Pam-lico Sound in Eastern North Carolina. Scientists studied the impacts of hurri -canes on these areas and found there were few negative, long-term, effects. Water quality, the number and health of most shellfish and finfish, and the overall health of water systems returned to normal. Estuaries are resilient to hurricane effects.

Today, natural ecosystems that are damaged by hurricanes, do not bounce back as quickly as they used to. Human development and impacts due to other hu-man actions and activities have degraded the health of natural ecosystems and they are no longer as resilient to hurricanes as they once were. Instead of at-tempting to protect or save barrier islands or wetlands from Nature, the Corps should work with local, state, and national governments and agencies to reduce

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the impacts of human actions and activities that cause the exacerbated coastal erosion, sedimentation, and storm surge that the Corps says it wants to mitigate. Mitigation should include the reduction or elimination of human develop-ment and population effects and not the control of natural geologic, bio-logic, and ecologic processes to “protect” them. Control of Nature is not needed. Control of humans is needed.

Attachment 3: Hurricanes and Ecology

This attachment documents that ecosystems and organisms are adapted to hurricanes and do not need to be protected from the “Nature” they are a part of.

1. “Beach Birds and Hurricanes, John C. Arvin, Gulf Crossings, Gulf Coast Bird Observatory, Fall 2009.

2. “Mother Nature is very resilient: A year after Hurricane Harvey, coastal ecosystems are thriving”, Natalia Alamdari, Texas Tribune, August 15, 2018.

3. “Texas Fisheries Begin Recovery from Harvey’s Wrath”, Cindie Powell, Texas Shores, Texas A&M University, Winter/Spring 2018.

9) Page v, Study Purpose, Executive Summary (*NEPA REQUIRED), the Corps does not address “keeping people out of harm’s way” and “working with, and not against Nature”. The Corps accepts and encourages the movement of population, industry, residential areas, etc. into hazardous and dangerous zones, the storm surge zone and floodplain zone, when it says “Population centers in and around the barrier islands and coastal area are essential to support the region’s industry. The same physical conditions that make the area vulnerable to coastal storms provide the setting for continued growth of industry and residential areas where the employees live.”

The Corps never faces the issue that people do not have to live in storm surge or floodplain zones in order to work at refineries and petrochemical plants. There are ways to keep people out of harm’s way and to keep structures safe. But the Corps makes excuses for the present philosophy which places people in “harm’s way” and then tries to justify this by spending public taxpayer dollars to subsidize a “fight” against Nature. Please see Attachment 1.

Most of the people of the United States, have wisely chosen not to live in these hazardous and dangerous zones and deserve to have their tax dollars protected and spent wisely and not used for projects which are supposed to protect people, but over the long-term but do not. We will not build our way out of RSLR.

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10) Page vi, Study Scope, Executive Summary (*NEPA REQUIRED), the 2019 Texas Coastal Resiliency Master Plan has been completed. The Corps must update this DEIS with the ER projects that will be implemented in the 2019 Plan. Some of the GLO projects appear to be the same, very similar, or overlap the projects that the Corps proposes. The DEIS must be updated and the relationship, overlap, and results of what the Corps proposes and the Texas General Land Office (GLO) proposes must be analyzed and presented to the public for its review and comment.

11) Page viii, Location, Executive Summary (*NEPA REQUIRED), the Corps refers to borrow sources. A complete environmental analysis of borrow sources today, their extent, how long they will last, and the environmental impacts when used has not be prepared for the DEIS. The Corps is required to do this under NEPA and CEQ regulations. This analysis and documentation are needed now for public review and comment.

12) Pages viii through x, Problems and Opportunities, Executive Summary (*NEPA REQUIRED), the Corps talks about RSLR “… which is a combination of land subsidence and sea level rise, is expected to increase the potential for coastal flooding, shoreline erosion, saltwater intrusion, and loss of wetland and barrier island habitats in the future.” The Corps fails to state that human actions and activities have created most of the RSLR now and in the future (water, oil, gas withdrawals, jetties, dams, groins, revetments, breakwaters, population and development growth, carbon dioxide (CO2) and methane releases from fossil fuels, etc.). The Corps does not propose a reduction in human actions and activities that currently make the “Ike Dike” and other structural projects ineffective in the short and long-term. Please see Attachment 1.

The Corps attacks the symptoms and not the causes of land subsidence, sea level rise, coastal flooding, shoreline erosion, saltwater intrusion, loss of wetland and barrier island habitats, increased rainfalls and intensity, and increased intensity of storms. The Corps does not offer a permanent or long-term solution to the problem. The Corps offers a short-term solution that wastes taxpayer dollars.

This is further exacerbated by the “specific problems” and “specific opportunities” that the Corps identified for the DEIS. These include the vulnerability of residential areas, petrochemical industry, and infrastructure to coastal storm events because people live in the wrong place; the failure of public lands with wildlife habitats to acquire buffers so that these lands can migrate as sea level rises; overuse of water supplies; reduction of risks to real estate, infrastructure, public, commercial, and residential property and structures; reliability of energy supplies; restoration of habitats; etc. The Corps proposes the opposite of restoration for barrier islands because Ike Dike degrades or possibly destroys, over the short and long-terms, the movement of barrier islands/peninsulas as a

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geologic landform which expresses a geomorphic process that protects itself from RSLR. Please see Attachment 1.

13) Page x, Planning Objectives, Executive Summary (NEPA REQUIRED), the Corps uses a planning period for its analysis of only 50 years. Since RSLR is predicted to last 100’s of years, at least a 100 to 200-year planning period analysis is needed. When sea level rises to its ultimate height in the long and short-terms, Ike Dike will either be underwater or severely compromised and most of its 50% reduction in storm surge wave protection will be gone. But the Corps ignores this and fails to state who is going to pay for this lost infrastructure and the continuous and perpetual improvement of this infrastructure for the time that sea level rise occurs. A minimum of 100 years is needed as a project life and analysis period. The Sierra Club requests that the Corps change its analysis period to at least 100 years.

The Corps also does not state who should pay how much for any proposal. Although the Corps refers to certain percentages that the federal government and GLO will pay, the Corps does not analyze why the refinery, petrochemical, and oil/gas industry is not responsible for paying some or most of the cost to protect their property. The Corps ignores the responsibility of this industry as a public company to protect its resources for its stockholders (fiduciary responsibility) and why the federal, state, and local governments should subsidize the entire cost of any proposal that benefits them enormously.

Attachment 4: Oil/Gas Coastal Protection Subsidies

This attachment documents that the oil/gas industry may be protected by Ike Dike but has not asked or offered to pay a single penny for this protection which is an all-public subsidy of billions of dollars.

1. “Big oil asks government to protect it from climate change”, Will Weissert, Associated Press, August 22, 2018.

2. “Houston’s Ike Dike: Crucial storm Barrier or Fossil-Fueled Boondoggle?”, Seamus McGraw, date unknown, probably late 2017.

3. “Texas fast-tracks seawalls for oil and gas infrastructure”, Jonathan Hilburg, August 23, 2018.

4. “Big Oil Wants Taxpayer-Funded Protection from Climate Change Crisis of its Own Making”, Gabby Brown, Sierra Club, August 23, 2018.

14) Page xii, Formulation of Alternative Plans, Executive Summary, the Corps states that “The evaluation included a comparison of the future without-project conditions and the future with-project conditions.” This is a false comparison and makes no sense. The Corps understands that in the next 50

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years, if Ike Dike is not constructed, that local, state, and federal governments will react to storm surge, sea level rise, increased rainfall intensity, increased storm intensity, etc. due to climate change and other factors. The Corps could conduct a survey of governments and ask them what their plans are without Ike Dike. The Corps can make the assumption that if enough money cannot be found to build huge structures that nonstructural methods, including large buyout programs, will be implemented. This is common sense and should be part of the No Action Alternative.

15) Page xiii, Performance, Executive Summary, the Corps should provide to the public, for all models used, a percent error and range of outcomes that could occur due to the output of each model. Models are used to show, in general, a direction of what may happen if an alternative is implemented based upon the assumptions made. The assumptions can be wrong, there may be important assumptions missed, etc. The public has a right to know how accurate and how precise models are and how close they are to reality and or the target they are supposed to achieve. This makes all the difference in the world when determining which alternative may or may not be appropriate.

16) Page xx, Environmental Compliance, Executive Summary, the Corps bias shows when it begins this section’s discussion with the phrase “The TSP is likely to have environmental impacts”. The entire DEIS documents there will be environmental impacts and proposes mitigation for some of them. Remove the word “likely” so the Corps does not look biased.

The Corps does not analyze the total environmental impacts that Ike Dike will have on Houston Audubon Society, The Nature Conservancy, Galveston Bay Foundation, Artist Boat, Texas Parks and Wildlife Department, U.S. Fish and Wildlife Service, and other public and private property owners with sensitive environmental resources and lands. The Corps should, right now, be able to state how many acres of which property will be destroyed, how many acres will be degraded by the constriction of Ike Dike, and what the environmental effects are to the parts of existing protected lands that remain after the construction of Ike Dike.

17) Page xxi, Potential Environmental Impacts, Executive Summary, the Corps states that “The project must mitigate for impacts that cannot be avoided.” The Corps must do more than this. Mitigation for environmental impacts must also be successful. Ike Dike does not just absorb energy from ocean currents and vessel wakes. It also reflects (deflects) this energy via water directed waves which causes additional erosion or sedimentation. The Corps must recognize this fact, explain the consequences, and provide mitigation for this negative environment effect.

18) Page xxii, San Luis Pass Closure, Executive Summary, the Corps does not address where the energy of deflected waves will go when they crash into Ike

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Dike at the San Luis Pass Toll Bridge. The reflection/deflection/ricochet of these waves, water, energy will go somewhere and there will be environmental impacts (probably erosion and sedimentation). The Corps must state what these environmental impacts are, where they will occur, and how large they will be.

19) Page xxiii, Nonstructural Formulation, Executive Summary, the Corps appears loath to admit that “wind-driven bay surges” are storm surge. The Corps should state that storm surge in the bay is no different than storm surge in the GOM. They both are created by hurricane winds.

20) Page xxiii, Managed Retreat, Executive Summary, the Corps assertion that managed retreat is not cost effective as a stand-alone alternative does not make sense. First, if the Corps accurately analyzed for 100 years or more the cost of Ike Dike, which would not be able to withstand RSLR for that length of time, the loss of money due to construction, operation, maintenance, repair and replacement of Ike Dike would mean that managed retreat and buyouts would make more eminent economic sense.

Secondly, no one that the Sierra Club has talked to in the 9 years that Ike Dike has been touted as the solution for storm surge, including the Sierra Club, has ever said that managed retreat should be used as a “stand-alone” alternative. This is a “red herring” the Corps uses to make managed retreat look unviable. The fact is that eventually, probably within 100 years or perhaps a bit longer, all structures within the storm surge zone today will either be lost or be bought via managed retreat. The Corps fails to address “residual risk increases over time”. The bias of the Corps is showing in its attempt to diminish the promise of managed retreat.

Attachment 5: Strategic Withdrawal (Managed Retreat) and Ike Dike Impacts

This attachment documents the value of strategic withdrawal (like protection of intact natural vegetation) and some of the environmental impacts that Ike Dike has.

1. “Should we build a wall or choose life along our Gulf Coast?”, Cameron Smith, July 1, 2016.

2. “Protecting the bay, Analysis: Ike Dike won’t stop bay flooding”, John Wayne Ferguson, Galveston Daily News, October 24, 2014.

3. “As sea levels rise in a changing climate, how best to protect coasts?”, Jan Ellen Spiegel, Texas Climate News, July 14, 2016.

4. “Groups say maps show corps’ true plans for coastal barrier”, John Wayne Ferguson, Galveston Daily News, December 4, 2018.

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5. “Mapping vulnerability and conservation adaptation strategies under climate change”, James E.M. Watson, Takuya Iwamura, and Nathalie Butt, Nature Climate Change, Volume 3, Macmillan Publishers Limited, published online September 15, 2013, November 2013.

6. “When is it Time to Retreat from Climate Change?”, Michelle Nijhuis, The New Yorker, March 27, 2017.

7. “Panelists: Dangerous Inaction on Rising Seas”, Ashita Gona, Coastal Review Online, October 9, 2017.

8. Email from Brandt Mannchen, Houston Regional Group of the Sierra Club, September 26, 2016, to Orrin H. Pilkey, James B. Duke Professor Emeritus of Earth sciences, Nicholas School of the Environment, Duke University, with email response from Dr. Pilkey, September 26, 2016.

9. “Interview of Orrin Pilkey: Coastal Warning: An Unwelcome Messenger on the Risks of Rising Seas”, Gilbert M. Gaul, Yale Environment 360, December 6, 2018.

21) Page xxiv, Barrier Improvement Act of 1990, Appendix D Engineering Design, Cost Estimates, and Cost Risk Analysis, and Appendix E Economic, the Corps cynically manipulates the Coastal Barrier Resources Act by saying federal dollars will not be spent on Ike Dike on a portion of Bolivar Peninsula. The Crops says that the GLO will build that portion of the structure. This makes no sense because this means the State of Texas, via the GLO, must come up with about $10 billion, probably more, for its share of the total construction costs. The Corps should tell the public where this money comes from.

Economically, the Corps. GLO, and other supporters of Ike Dike has been wrong consistently. Initially the Ike Dike was estimated to cost $1-2 billion, then it was $3-4 billion, then $6 billion, then it was $10 billion, then $12 billion, and now it ranges from $20 to over 30 billion. The figures in Appendices D and E cannot be trusted because so much of the Ike Dike has not been finalized or is conceptual or environmental impacts have been underestimated or ignored or ecosystem services and land prices have been given little thought or calculation.

22) Page xxvi, What’s Next, Executive Summary, the Corps states that “The project will be maintained after construction by a “local sponsor.” The Corps should state who the local sponsors are. The Corps should discuss how it will audit and provide oversight to ensure that the local sponsor conducts operation, maintenance, repair, and replacement as required by the agreement signed with the Corps. The Corps should tell the public what the process will be to ensure

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compliance, what happens if non-compliance occurs, who will enforce the agreement, what are the penalties for not meeting the agreement, and what will be the Corps involvement with this process, compliance, and enforcement. The public must know what will be done to keep it safe.

23) Page 1-1, 1.1 Introduction, the Corps states that “The DIFR-EIS presents the investigation of comprehensive water resources management for the Texas coast”. This statement is false. The proposal does nothing about water quality, water supplies, inflows into bays and estuaries, rainfall flooding, etc. This is not an investigation of comprehensive water resources management for the Texas Coast.

Attachment 6: Rainfall Flooding

This attachment reveals the problem of rainfall flooding, which Ike Dike does not address. Ike Dike will create further impacts via its interaction with rainfall flooding and will be affected by rainfall flooding.

1. “Rainfall severity getting worse”, Mihir Zaveri, Houston Chronicle, Page 1A, November 28, 2017.

24) Page 1-1, 1.1 Introduction, the Corps states “in order to maintain existing coastal storm risk levels and or reduce coastal storm risk along the Texas coast.” The Corps has not told the public what “existing coastal storm risk levels” are. The public must have this information as a foundation for comparison and analysis of this proposal. The Corps should provide the public this information in a supplemental draft proposal.

25) Page 1-2, 1.1.2 Economic Diversity, the Corps states that “These vast economic benefits highlight that the shutdown of even a single Texas port can deliver a devasting blow to State and national economies”. The Corps makes this statement about all Texas ports and presents no documentation to support it. Port Mansfield’s closure would not be a devastating blow to state and national economies. The Corps provides no data to support that if any of the Texas ports closed that this would be devastating to state and national economies. This assertion is overblown at best and false at worst. The Corps should not bias this proposal with statements that are patently meant to convey a particular outcome. Remove this biased statement.

26) Page 1.6, 1.1.4 Human Environment, the Corps makes the statement “Although the Texas Gulf coast is ecologically diverse and industrial sectors play a key role in our national economy, the people living and working in the coastal region are, by far, the most valuable and vulnerable assets.” This statement is false. It is another case of overblown rhetoric that conveys a particular outcome (bias). The people of the coast are important, but no more so than

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other people in Texas, the Nation, ecosystems, and living organisms. Remove this biased statement.

If we talk about importance, we should talk about, for example, plants, who give us the oxygen we breathe, store carbon to stabilize our climate, protect soil so we do not have erosion and sedimentation, fertilize the soil so we can grow vegetation, and provide habitat, food, and shelter for wildlife so we have recreation, food, and spiritual satisfaction. Ecosystems shelter us and provide us with everything we have but we have abused them. Without ecosystems and their life forms and non-living elements humans would not survive. Yet we have abused, degraded, and destroyed these ecosystems which makes them far more vulnerable than people on the Texas Coast who have participated in this degradation of these ecosystems.

27) Page 1.6, 1.1.5 Risk, the Corps states “A 4-foot increase in sea level could affect a quarter of interstates and arterials and nearly 75 percent of port facilities on the Gulf coast.” The Sierra Club agrees with the Corps about sea level rise. Ike Dike will not stop sea level rise or keep it from rising on the Texas coast. The best scientific estimates are sea level rise will be greater than 4 feet at the end of this century. This proposal does not prevent sea level rise from occurring.

The proposal, while purporting to protect natural features like “barrier islands, marshes, and ridges” instead degrades these features by preventing their movement toward the mainland where they may be able to stay ahead of, above, and survive sea level rise. Large, unyielding, hard, concrete, structures do not lend themselves to the wind and water movement of sands and sediments across barrier islands/peninsulas. The movement of sediments by water and wind allow barrier islands/peninsulas to move and geo-morphically, biologically, and ecologically function.

Attachment 7: Climate Change and Sea Level Rise Impacts

This attachment documents some of the effects of sea level rise, that sea level rise has increased, and future sea level rise predictions have continued to increase for the past 5 years.

1. “Arctic warming stokes fears of region’s rapid unraveling”, John Schwartz and Henry Fountain, New York Times, December 12, 2018.

2. “Patterns and Projections of High Tide Flooding Along the U.S. Coastline Using a Common Impact Threshold”, National Oceanic and Atmospheric administration, U.S. Department of Commerce, February 2018.

3. “Climate Science Special Report: Fourth National Climate Assessment, Volume 1”, D.J. Wuebbles, D.W. Fahey, K.A. Hibbard, D.J. Dokken, B.C.

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Stewart, and T.K. Maycock, editors, U.S. Global Change Research Program, Washington, D.C. 470 pages, 2017.

4. “Study: Rising seas may routinely flood more than 10,000 Texas homes by 2045”, Ryan Faircloth, undated, probably 2018.

5. “Earth’s Most Famous Climate Scientist Issues Bombshell Sea Level Warning”, Eric Holthaus, Slatest, July 20, 2015.

6. “Melting of Antarctic ice rises at alarming rate”, Seth Borenstein, Associated Press, June 14, 2018.

7. “These Worst-Case Projections Keep Getting Upgraded”, Extra!, FAIR, Volume 31, Number 5, June 2018.

8. “Flooding from high tides has doubled in the US in just 30 years”, The Guardian, June 6, 2018.

9. “U.S. High-Tide Flooding Has Doubled in 30 Years, NOAA Report Says”, The Guardian, undated, probably 2018.

10. “Flooding from sea level rise threatens over 300,000 US coastal homes – study”, The Guardian, June 18, 2018.

11. “Satellite snafu masked true sea-level rise for decades”, Jeff Tollefson, July 17, 2017.

12. “Houston: A Global Warning”, Jeff Goodell, Rolling Stone, September 21, 2017.

13. “Bolivar road set for 2-foot raise”, Dug Begley, Houston Chronicle, July 21, 2018.

14. “Taking the Long View: The Forever Legacy of Climate Change”, Rob Wilder and Dan Kammen, Yale Environment 360, September 12, 2017.

15. “The Doomsday Glacier”, Jeff Goodell, Rolling Stone, May 18, 2017.

16. “New study confirms the oceans are warning rapidly”, John Abraham, The Guardian, June 26, 2017.

17. “Greenland’s ice sheet is melting at the fastest rate in centuries”, Allison Hufford, The Dartmouth, April 10, 2018.

18. “Gulf Stream current at its weakest in 1,600 years, studies show”, Damian Carrington, The Guardian, April 11, 2018.

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19. “Avoid Gulf stream disruption at all costs, scientists warn”, Damian Carrington, The Guardian, April 13, 2018.

20. “Earth’s oceans are warming 13% faster than thought, and accelerating”, John Abraham, The Guardian, March 10, 2017.

21. “Experts say the IPCC underestimated future sea level rise”, John Abraham, The Guardian, December 4, 2013.

22. “Rising Waters: How Fast and How Far Will Sea Levels Rise?”, Nicola Jones, Environmental 360, October 21, 2013.

23. “Sea-level rise could nearly double over earlier estimates in next 100 years”, Science Daily, March 30, 2016. 24. “Climate Disruption in Overdrive: Submerged Cities and Melting that Feeds on Itself”, Dahr Jamail, Truthout, March 28, 2016.

25. “Ocean Study Has Horrific Implications for Climate Change Fight”, Rob Quinn, Newser, November 1, 2018.

26. “Quantification of ocean heat uptake from changes in atmospheric O2 and CO2 compositions”, L. Resplandy, R.F. Keeling, Y. Eddebbar, M.K. Brooks, R. Wang, L. Bopp, M.C. Long, J.P. Dunne, W. Koeve, and Oschlies, Nature, Volume 563, pages 105-108, 2018.

27. “New research shows the world’s ice is doing something not seen before”, John Abraham, The Guardian, September 26, 2018.

28. “Underwater melting of Antarctic ice far greater than thought, study finds”, Jonathan Watts, The Guardian, April 2, 2018.

29. “New month in Galveston begins with more floods, lost business”, Nick Powell, Houston Chronicle, October 2, 2018. 28) Page 1-6, 1.2 Study and Project Area, the Corps is right that “A key feature of the study is the GIWW”. It is key not because of any economic benefits it provides but because it has fragmented the entire Texas Coast and wherever it goes, has destroyed marshes, prairies, and geological processes. If the GIWW stays in place, it will destroy more ecosystems and will be destroyed by sea level rise. The Corps must decide whether a GIWW makes sense anymore. If so, how can a GIWW be operated so that it is not at war with ecosystems needed to tie the fabric together and support the Texas Coast. The Ike Dike proposal does not do this and makes the GIWW and Texas Coast more vulnerable to RSLR and other factors in the future.

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29) Page 1.7, 1.3.1 Problems and Opportunities, the “Problem Statement” does not acknowledge that people have put themselves and their economy into “harm’s way” and that most of this risk (which is not clearly defined via probability or percentage) is self-induced and can be resolved not by moving more people and structures into hazardous and dangerous storm surge and floodplain zones. The Corps does not acknowledge that most of the “regions’ loss of biodiversity” and much of the “Land subsidence … rising sea level … coastal flooding, shoreline erosion, saltwater intrusion, and loss of wetland and barrier island habitats” in the past, present, and future has been or will be caused by human actions and activities. The Corps fails to propose limiting or altering most of these human actions and activities.

30) Page 1-9, Table 1-1, the Corps fails to list important “Federal Laws and Programs” like the Endangered Species Act, Coastal Barrier Resources Act, Clean Water Act, Clean Air Act, Fish and Wildlife Coordination Act, etc. The Corps needs to be complete for this table.

31) Page 1-10, 1.3.1 Problems and Opportunities, the Corps states that “Shores are retreating an average of 4 feet per year”. Is this bad? The Corps should state what normal erosion is along different parts of the Texas shoreline. The Corps should also state what is causing this erosion.

The Sierra Club understands there is natural erosion and accretion but that much of the erosion on the Texas Coast is due to a loss of sediment because of ship channels, dams, jetties, and other human actions and activities that remove sediment from rivers and streams and the longshore current system. Ike Dike does nothing to return sediment to the longshore current system. Ike Dike may dredge more sediment from the coast in an effort to perpetually re-nourish beaches for recreational/economic reasons.

The Corps should state what is the “increased risk” due to coastal erosion from coastal storm surges, what is normal risk, how much coastal erosion risk should be allowed, what are the “economic risks due to coastal storm events”, what is normal risk, how much economic risk should be allowed.

The Corps should state how much “more at risk of damage” are critical infrastructure, what is normal risk, and how much risk to critical infrastructure should be allowed.

The Corps should state what does it mean when it says that existing hurricane structures “will be increasingly at risk” from storm damages due to sea level rise and climate change”, what is normal risk, how much risk to existing hurricane structures should be allowed.

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The Corps should state what role “water supply shortages due to increasing conflicts between municipal and industrial water supply and the ecological needs of coastal estuaries and ecosystems” play in coastal erosion due to storm surge, the relevance and relatedness of this, and why the Corps does not mention risk here.

The Corps should state how much it wants to “reduce the risk to public, commercial and residential property, real estate, infrastructure, and human life” and how much risk should be allowed.

The Corps should state how much it wants to “reduce the susceptibility of residential, commercial, and public structures and infrastructure” from hurricane-induced storm damage, how much storm damage should be allowed, and how much wind damage risk will be reduced.

The Corps should state how much it wants to “lessen damages to refinery infrastructure and increase the reliability of the Nation’s energy supply” due to coastal storm events, how much risk will be reduced, how much will be left, how much of a role should alternative energy sources play that are not as exposed to coastal storm events, and who should pay for Ike Dike.

The Corps should state how much it wants to “restore the long-term sustainability of coast and forested wetlands”, what is normal, and how much mitigation will address past impacts.

The Corps should state how much restoration of barrier island environments to “promote long-term sustainability of fish and wildlife” it wants to do, how much is needed, and how does the Corps expect to do this when its proposal will degrade Galveston Island and Bolivar Peninsula geologically so that they cannot function as important geo-morphic processes.

The Corps should state how much “long-term erosion reduction” it will support and what is normal erosion due to everyday geological processes and storm events.

32) Page 1.11, 1.3.2 Need, the Corps states that “vital resources critical to the economic and environmental welfare of the Nation are at risk from coastal storm damage”. The Corps should state what is the risk, what is normal, and how much of the risk it want to reduce.

The Corps has forgotten and or ignored its responsibility in Section 4091 of the Water Resources Development Act (WRDA) of 2007, Public Law (PL) 110-114 which states, “(b) Scope. The comprehensive plan shall provide for protection, conservation, and restoration of … barrier islands … from the impacts of coastal storms, hurricanes, erosion, and subsidence.”

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The Corps proposes a Tentatively Selected Plan (TSP, Alternative A, Ike Dike) that degrades and could result in the destruction of the Galveston Island barrier island and the Bolivar Peninsula barrier peninsula because it attempts to tie down, pin down, and hold in place a barrier island/peninsula complex that must move toward the mainland to survive relative sea level rise.

The Corps proposes the degradation and perhaps destruction this geologic land-form and geo-morphic process (a rolling barrier island/peninsula complex) that is the basis for the natural ecosystems (wetlands, beaches, dunes, tidal flats, coastal prairies, bays, coves, estuaries, etc.) that it purports to protect with Ike Dike and for human protection against storm surge. Levees, floodwalls, seawall extensions, gates, etc., do not provide “protection, conservation, and restoration of … barrier islands” and other ecosystems on Galveston Island, Bolivar Penin-sula, and Galveston Bay. This is a wrong-headed and illegal approach to storm surge protection.

Attachment 8: Levee Problems

This attachment documents that levees have problems that make them vulnerable. These problems the Corps fails to discuss in the DEIS.

1. “National Flood Policy Challenges, Levees: The Double-edged Sword”, Association of State Floodplain Mangers, February 13, 2007.

2. “Broken Levees: Why they Failed”, Donald T. Hornstein, Douglas A. Kyser, Thomas O. McGarity, and Sidney A. Shapiro, Center for Progressive Reform, updated, probably from 2005 or 2006.

33) Page 1.12, 1.3.2 Purpose, the Corps purposes refer to “risk reduction” but do not state how much risk is normal, how much risk is due to human actions and activities, and how many of the human actions and activities the Corps will address to reduce risk. The Corps does not state what increase in “net quantity and quality” it aims to achieve in which parts of the Texas Coast and how this will be done. The Corps ignores that actions and activities of humans have led to reduced ecosystem existence and function and that only by a reduction of these actions and activities will the loss of ecosystems and their functions stop.

The Corps does not define what “risk mechanisms” are. The Sierra Club believes the Corps has erred in not formulating any proposals that deal with flood risk management for rainfall events especially since these rainfall events are a key factor that causes impacts due to hurricanes.

34) Pages 1.12 and 1.13, 1.3.4 Planning Goals and Objectives and Table 1-2, the Corps fails to state what a “sustainable economy” is. Without a definition for “sustainable economy” and criteria that measure whether the proposal moves

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society closer to this definition the Corps cannot state whether its “planning goals” actually “promote a sustainable economy”. The Corps does not say whether we have a “sustainable economy” now and if so how the present economy is sustainable and if not what needs to change to make it that way.

The Corps encourages growth of population and development by protection of poorly planned areas. These areas will now be considered “protected with risk reduced” via Ike Dike which will attract more people and development to hazardous and dangerous storm surge and floodplain zones. Ike Dike does not “Enhance and restore coastal geomorphic landforms”. Ike Dike will degrade these landforms by not allowing movement of the Galveston Island barrier island/Bolivar Peninsula barrier peninsula complex. This occurs because Ike Dike, via a 70 plus mile levee/seawall/floodwall with giant gates, interferes with water and wind generated sediment movement and pins these geologic landforms down so they will not move.

The present economy is not “environmentally sustainable” and does not provide for a “sustainable coastal ecosystem”. The Ike Dike provides more of the same development that currently is not environmentally sustainable. The Corps must focus on long-term (several hundred years) as well as short-term (50 years) problems. The Corps must use at least a 100-year, better a 200-year, planning horizon or money will be spent for proposals that cannot withstand long-term environmental change like RSLR. Please see Attachment 1.

35) Page 1-14, 1.3.5 Planning Constraints, the Corps fails to discuss all environmental impacts that occur to ecosystems due to Ike Dike and existing and future federal projects. The Corps is more concerned about “induce no impact to authorized navigation projects” rather than protection of coastal shoreline sediments, sediment movement, and erosion and accretion processes like the longshore current and the sediment that is trapped behind jetties, dams, and in navigation channels.

Although the Corps says that “Careful consideration should also be given to actions that could induce flooding inside and outside of systems” the Corps provides insufficient information about storm surge in Galveston Bay, ebbtide flooding, and rainfall flooding due to storms and the effects of human actions and activities including Ike Dike.

The DEIS should analyze the impact on overland flow of Ike Dike. Many local areas flood during rains even though they are in an area that has existing storm surge protection. The disruption of overland flow patterns and volumes by Ike Dike must be analyzed and shown in the DEIS. The day-to-day rains that occur in our area, some very heavy and some very light, create overland flow patterns and regimes that will be altered by Ike Dike.

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The Corps lists “Avoid induced development, to the maximum extent practicable” but does not commit to any mitigation measures in the DEIS which do this. The public is not just concerned about “potential enclosed wetland areas would be opened in the future to urban development.” The public is also concerned about more population growth and development behind Ike Dike and the environmental impacts, injuries, and deaths that will occur if the levee, etc., is breached. Please see Attachment 1.

36) Page 1.14, 1.4 USACE Civil Works Guidance and Initiatives, the Corps says that it “seeks to balance economic development and environmental needs” but does not acknowledge that environmental needs (ecosystems) have already been compromised over the 100 years that the Corps uses to look at cumulative impacts. The seagrass and marsh losses in Galveston Bay, loss of most coastal prairie habitat, loss of large numbers of oyster beds and hash areas, degraded water quality, huge impervious pavement effects, and other environmental impacts have already made Galveston Bay, Galveston Island, and Bolivar Peninsula more sensitive to further degradation and destruction. Compromising what already exists is like cutting the baby in half. It does not ensure ecological life in the coastal zone.

The Sierra Club does not agree with the Corps that it has undertaken “a proactive public involvement campaign” or that has “facilitated the consensus-building process” with the Sierra Club and other members of the environmental community. Oftentimes the Sierra Club has been on the outside looking in and has not been invited to “target stakeholder meetings”. The Sierra Club did not receive notification about this DEIS even though it commented during the scoping period.

37) Page 1-15, 1.5 National Environmental Policy Act Compliance and Report Structure, the Corps names cooperating agencies for the DEIS but does not include the U.S. Fish and Wildlife Service (FWS). The Corps should state why the FWS is not a cooperating agency.

38) Page 1-17, 1.6 Non-Federal Sponsor and Congressional Representation, the Corps does not state how GLO will be able to provide the 10-15 billion dollars that is its share of construction funds for this proposal. The public must know this now to determine if it agrees the State should fund Ike Dike and whether the method to fund this proposal is acceptable.

39) Page 2-1, 2.2 Climate Change and Page 3-1, 3.1 Climate Change, there is a need for a longer period of analysis than 50 years. The Corps admits that “Climate change … creates stressors such as SLR, temperature changes, salinity changes, and wind and water circulation changes that would continue to influence coastal climates in Texas over the 50-year period of analysis and longer.” Because RSLR will continue in the future and Ike Dike does not prevent

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sea level rise from happening, the level of storm surge protection by Ike Dike will degrade over time. A 100 to 200-year period of analysis is needed.

For instance, if by 2100, 15 years beyond the 50-year planning and analysis horizon, sea level rises 8 feet or more, and if it is assumed that Ike Dike will be 18 feet tall, then 44.44% of the storm surge protective capacity of Ike Dike (reduction of 50% of the storm surge in Galveston Bay) will be nullified by sea level rise. In 65 years, and it may be less, and sea level rise may be more by 2100, Ike Dike’s storm surge protection will be degraded by 44.44% and sea level rise will occur since it is not inhibited by Ike Dike. The Corps must discuss this situation and the chances to get funding repeatedly to upgrade Ike Dike’s storm surge protection so it stays the same for 50 years and beyond.

40) Page 2-3, 2.3.1.1 Geology, the Corps refers to sea level rise slowing down in the “last 2,000 to 9,000 years”. In the last 100 years or so sea level rise has increased and this increase is the current trend.

The Corps refers to “sandy low lands that are subject to severe shoreline retreat and limited sediment supply” but does not state that the “limited sediment supply” is caused by human actions and activities like jetties, dams, navigation channels, etc. and that these impediments to the introduction and transport of sediment into the longshore current are what exacerbate the “severe shoreline retreat”. The Corps’ proposal does nothing to reduce interception and loss of sediments of the longshore current on the Texas Coast by these human actions and activities. Please see Attachment 1.

41) Page 2.5, Table 2-1, shoreline change has not been excessive for most of Texas. For instance, for Sabine Pass to Rollover Pass, a minus 9.7 feet a year is used. However, Rollover Pass will be filled by GLO and this rate should go down. Bolivar Peninsula’s rate is 1.4 feet surplus, although the Corps states that rates up to minus 6.4 feet occur, the Corps does not say where these rates occur and what they are.

Galveston Island has a minus 0.9 feet/year, Matagorda Peninsula has a minus 3.3 feet/year, Matagorda Island minus 2. feet/year, San Jose Island minus 2.4 feet/year, Mustang Island minus1.1 feet/year, and North Padre Island a minus 2.7 feet/year. Galveston County has a minus 0.8 feet/year, Calhoun County minus 2.4 feet/year, Brazoria County minus 1.4 feet/year, Aransas County minus 2.5 feet/year, Nueces County minus 1.2 feet/year, and Kleberg County minus 1.71 feet/year.

Much of the erosion that occurs along the Gulf and Bay shorelines is due to interception of sediments by dams, jetties, navigation channels, etc., which the Corps ignores and does nothing about. There are no plans, other than beneficial use of some dredge material, to install sediment by-pass mechanisms at dams,

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jetties, navigation channels, etc., to get the natural sediment back into the longshore current system.

The Corps focuses instead on unnamed and unknown barrow areas which will temporarily provide some sediment. But this is temporary, since erosion and human actions and activities that cause erosion, continue and the Corps must provide sediment for 50 plus miles of beaches in perpetuity. Meanwhile sea level continues to rise which causes erosion that the Corps cannot prevent on a region-wide basis while bulkheads, revetments, and breakwaters are installed and exacerbate the erosion along the Gulf and Bay shorelines. This has a storyline that never ends, that the Corps cannot fix, and cannot catch-up to and address in a region-wide manner. Fighting Nature instead of working with it does not work over the long-term. Please see Attachment 1.

42) Page 2-7, 2.3.3.1 Relative Sea Level Change, localized subsidence may increase due to the compression of sediment deposits along the Texas Coast. The increased melting of the Greenland ice sheet, glaciers, and underwater ice in Antarctica points toward more sea level rise rather than less for the Gulf Coast. The Corps should use worst-case scenarios for sea level rise because all indications are that melting of Arctic and Antarctic ice is occurring quicker than scientists thought it would occur. Please see Attachment 8.

43) Page 2-7, Table 2-2, this table is misleading. The cost of damage for hurricanes has not been adjusted for inflation. Therefore, the public cannot compare hurricanes on the same basis (apples to apples). This table misleads people to believe that hurricanes that occurred recently are more expensive than those that occurred in the past. In part, this may be true because population and development is greater today, because human actions and activities have increased in shoreline areas that are hazardous and dangerous zones, and due to climate change.

However, Hurricane Carla, was estimated to cost $300 million in 1961 dollars. If you use the inflation adjustment, which is 8.27, and multiply this number times $300 million you get $2.481 billion in 2018 dollars. This would move the cost of Carla from ninth, or last on the table, to 5 th. If you look at Hurricane Celia the inflation adjusted cost would go from $930 million in 1970 to $6.52 billion in 2018. The Corps must portray costs on the same basis so that cost information can be compared and does not mislead the public.

44) Page 2-14, 2.3.7 Soils (Prime and Other Important Unique Farmland), the sources the Corps refers to about what crops, pasture, and hay fields exist are very old. These sources are from 1976, 42 years, 1977, 41 years, and 1979, 39 years. More recent information is needed to document what crops, pasture, or hayfields are planted in the project area along the Texas Coast.

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45) Pages 2-14 and 2-15, 2.3.9 Hazardous, Toxic, and Radioactive Waste Concerns, the Corps does not talk about contaminated shallow water aquifers or water tables that exist under many refineries or chemical plants along the Houston Ship Channel or exist at other heavy industrial areas on the Texas Coast. The Corps should discuss these toxic waters and how hurricanes, floods, and industrial activities affect their release to Gulf and Bay shorelines and waters. Please see Attachment 1.

46) Pages 2-24 through 2-32, 2.4.5 Protected Resources, 2.4.5.1 Protected Lands, Figure 2-9, Table 2-8, and Appendix F Real Estate, the Corps has an incomplete list of protected lands in the project area along the Texas Coast. There are thousands of acres of Artist Boat, Galveston Bay Foundation, Houston Audubon Society, and other protected lands on Galveston Island, Bolivar Peninsula, and other parts of the Texas Coast. The Sierra Club provided the Corps with a list of 273 sensitive areas and lands in our May 2, 2016 scoping comments. The Corps should use that list and other information to make a complete list for Table 2-8 of protected lands so that none that exist in the project area are left out. All protected lands that may be affected by hurricanes, sea level rise, erosion, accretion, other climate change impacts, and Ike Dike and should be included on Table 2-8.

Appendix F Real Estate figures and information are not accurate and cannot be counted upon. For instance, the Corps. GLO, and other supporters of Ike Dike has been wrong consistently about price and have estimated the cost of Ike Dike to be $1-2 billion, $3-4 billion, $6 billion, $10 billion, $12 billion, and $20 to over 30 billion. The figures in Appendix F cannot be trusted because so much of Ike Dike has not been finalized, is conceptual, environmental impacts have been underestimated or ignored, ecosystem services and land prices have been undervalued for protected lands because not all protected lands are included in the costs or acknowledged in the DEIS.

47) Page 2-48, 2.5 Cultural Resources and Page 3-5, Cultural Resources, the Corps should document which cultural resources are “at highest risk” and show the public how many of these exist and in general where they are located. The public needs this information so that it can understand the environmental impacts of Ike Dike and alternatives.

48) Pages 2-48 and 2-49, 2.6 Socioeconomic Considerations and Page 2-53, Table 2-18, the Corps provides many figures for structures, critical infrastructure, electricity, gas distribution, water supply, transportation, education, community services, medical care facilities, police stations/sheriff’s offices, fire stations, poverty populations, etc. The Corps does not tell the public which of these facilities and populations are in storm surge zones and floodplains. The public cannot distinguish the risk or greatest risk with the information that the Corps has provided. The Corps should provide a table with a total for different types of facilities and populations and then divide these facilities and populations into

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those that are not or are within storm surge zones and floodplains. Please see Attachment 1.

49) Page 2-49, 2.7 Navigation and 2.7.1 Commercial Waterborne Commerce, the Corps states that there are “270 miles of deep-draft channels (greater than 15 feet deep)” and then says there are “11 major deep-draft channels (25 feet or deeper)”. Which statement is accurate. The Corps must correct this contradictory information.

50) Page 2.7.2 Recreational, the Corps uses two sets of figures which seem to contradict each other. First the Corps says that “combined economic impacts of these recreational activities totaled over $5 billion in annual spending” and then says that the same activities “accounted for over $43.5 billion in annual economic value”. The Corps should explain the difference in these two figures and the information they provide.

51) Page 3-1, No Action/Future Without-Project Conditions (*NEPA Required), the Corps biases the No Action Alternative by assuming that nothing will be done to improve existing hurricane flood risk reduction projects, no intervention to reduce the impacts of storm surge on vulnerable populations and infrastructure in the study area will occur, and no large-scale ER projects that improve the sustainability of fragile coastal systems will be implemented. These are not reasonable or realistic assumptions and make no sense. It would be very easy for the Corps to estimate a future No Action Alternative by surveying coastal cities, counties, and other entities and simply ask them about their future plans and what they would be without an Ike Dike.

The Corps argues for a future that is not legal. The Corps knows that existing hurricane flood risk reduction projects must be maintained and improved by law to maintain their current protection. The Corps knows that the GLO is going to implement projects for ER, as will the NRDA and the Deepwater Horizon Spill programs for 10 years. The Corps knows the predictions of population and development growth and the planning and protection that will be done via the National Flood Insurance Program and local programs. The Sierra Club recommends a No Action Alternative that is realistic and not biased to make other alternatives or cost/benefit ratios look better.

52) Page 3-2, 3.2.2 Coastal Processes, the Corps states “There would be no direct impacts to coastal processes by implementing the No-Action Alternative”. This statement is false. As development and population growth increases on Galveston Island and Bolivar Peninsula additional wetlands will be filled, more impervious surface will be installed, hurricane wash-over areas will be ignored, etc. and the integrity of barrier islands will be reduced. Dams, jetties, navigation channels will continue to catch sediment. Deeper navigation channels will catch more sediment. Beaches will be re-nourished but borrow areas will be more expensive and harder to find. The Corps must state that the No Action

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Alternative will result in habitats and barrier island processes that are degraded or decrease. The Corps acknowledges this on Page 3-6 when it says, “The overall population is projected to increase coastwide; however in the upper coast, the population is expected to increase under the No-Action Alternative due to the robust economics of the area.”

53) Page 3-2, 3.2.3 Water and Sediment Quality, the Corps states that “Water and sediment quality trends would not change with the No-Action Alternative”. This statement is false. As development and population growth increases on Galveston Island, Bolivar Peninsula, West Galveston Bay, Baytown, Houston Ship Channel, etc., additional wetlands will be filled, more impervious surface will be constructed, hurricane wash-over areas will be ignored, the integrity of barrier islands will be reduced. The Corps must state that the No Action Alternative will result in water quality and sediment trends that degrade water quality.

The Corps ignores the ER projects that GLO, NRDA, and Deepwater Horizon Spill will construct and any positive impacts that will occur. The Corps contradicts itself in this paragraph because it acknowledges that “increased human population growth and coastal development may increase nutrient loading, cause algal blooms, and decrease transparency in estuaries etc.”. The Corps must state that the No Action Alternative will result water quality and sediment trends that are probably negative. The Corps acknowledges this on Page 3-6 when it says, “The overall population is projected to increase coastwide; however in the upper coast, the population is expected to increase under the No-Action Alternative due to the robust economics of the area.” Please see Attachment 1.

54) Page 3.2, 3.2.4 Hydrology, the Corps states that “Under the No-Action Alternative, there would be no direct impacts to watershed and river basin hydrology.” This statement is false. The increase in coastal population and development alone will cause changes in hydrology including many flood control projects which widen and deepen stream and river channels. This increase in population and development is a part of the No Action Alternative and must be acknowledged and shown in this section. Otherwise the Corps biases the description of the No Action Alternative and misleads the public about what will occur in the next 50 years. The Corps must state that the No Action Alternative will result in changes to hydrology. The Corps acknowledges this on Page 3-6 when it says, “The overall population is projected to increase coastwide; however in the upper coast, the population is expected to increase under the No-Action Alternative due to the robust economics of the area.”

55) Page 3-2, 3.2.5 Soils (Prime and Other Important Unique Farmland”, the Corps states that “Under the No-Action Alternative, there would be no direct impacts to soil prime farmlands.” This statement is false. Increased population and development will destroy or degrade more prime or unique farmlands. This is the essence of development today and if unchanged in the next 50 years. The

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Corps must state that the No Action Alternative will result in further prime and unique farmland losses. These soil losses should be estimated and revealed to the public in this DEIS. The Corps acknowledges this on Page 3-6 when it says, “The overall population is projected to increase coastwide; however in the upper coast, the population is expected to increase under the No-Action Alternative due to the robust economics of the area.”

56) Page 3-3, 3.2.6 Energy and Mineral Resources, the Corps states that “The No-Action Alternative would result in no direct impacts on energy and mineral resources. This statement is false. The No Action Alternative will result in a 3- to 4 million Houston Area population increase along with development that supports or comes from this population increase. This will result in the use or more energy (fossil fuels) and mineral resources and cause more release of climate change gases that will cause more sea level rise, more intense rainfalls, more intense storms, and other climate change impacts. The Corps must state that the No Action Alternative will result in further energy and mineral use. The Corps acknowledges this on Page 3-6 when it says, “The overall population is projected to increase coastwide; however in the upper coast, the population is expected to increase under the No-Action Alternative due to the robust economics of the area.”

57) Page 3-3, 3.2.7 Hazardous, Toxic, and Radioactive Waste Concerns, the Corps states that “The No-Action Alternative would result in no direct impact on hazardous materials associated with regulated facilities and shipping traffic.” This statement false. The projected increase in population, 3 to 4 million people, and the development that comes with this increased population will result in the use of more hazardous, toxic, and radioactive materials and the waste generated from the use of these materials. The Corps must state that the No Action Alternative will result in more hazardous, toxic, and radioactive materials and the waste. The Corps acknowledges this on Page 3-6 when it says, “The overall population is projected to increase coastwide; however in the upper coast, the population is expected to increase under the No-Action Alternative due to the robust economics of the area.”

58) Page 3-3, 3.2.8 Air Quality, the Corps states that “The No-Action Alternative would have no direct impacts on air quality.” This statement is false. The No Action Alternative calls for a 3 to 4 million population increase along with development that supports or comes with this increase. This will result in the use of more fossil fuels and use of more plastics which results in more air pollution including volatile organic compounds, nitrogen oxides, particulate matter, ozone, carbon dioxide, methane, hazardous air pollutants, and other air pollutants. The Corps must state that the No Action Alternative will result in more air pollution due to the built-in population and development growth assumed in the next 50 years. The Corps acknowledges this on Page 3-6 when it says, “The overall population is projected to increase coastwide; however in the upper coast, the

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population is expected to increase under the No-Action Alternative due to the robust economics of the area.”

59) Page 3-3, 3.2.9, Noise, the Corps states that “existing noise conditions would continue”. This statement is false. It is likely that in the next 50 years noise levels will get worse because there is no national or state legislation to address this problem and there will be at least 3 to 4 million additional people and development for this number of people in the future. The Corps must state that the No Action Alternative will result in more noise pollution due to the built-in population and development growth assumed in the next 50 years. The Corps acknowledges this on Page 3-6 when it says, “The overall population is projected to increase coastwide; however in the upper coast, the population is expected to increase under the No-Action Alternative due to the robust economics of the area.”

60) Pages 3-3, 3-4, and 3.5, 3.3.1 Wetlands, 3.3.2 Aquatic Resources, 3.3.3 Wildlife Resources, 3.3.4.1 Protected Lands, 3.3.4.2 Threatened and Endangered Species, 3.3.4.3 Essential Fish Habitat, and 3.3.4.4 Migratory Birds, the Corps states for these natural resources that there will be “no direct impacts”. These statements are false. There will be at least 3 to 4 million additional people and development for this number of people in the future. This population and development growth will directly impact, in a negative way, wetlands, aquatic resources, wildlife resources, protected lands, threatened and endangered species, essential fish habitat, and migratory birds. The Corps must state that the No Action Alternative will result in negative impacts to wetlands, aquatic resources, wildlife resources, protected lands, threatened and endangered species, essential fish habitat, and migratory birds due to the population and development increase for 3 to 4 million people in the next 50 years. The Corps acknowledges this on Page 3-6 when it says, “The overall population is projected to increase coastwide; however in the upper coast, the population is expected to increase under the No-Action Alternative due to the robust economics of the area.”

61) Page 3-6, 3.5 Socioeconomic Conditions, the Sierra Club agrees “The area’s social vulnerability is expected to increase over time” but this is because humans move into hazardous and dangerous areas. The Corps should “keep people out of harm’s way” and “work with Nature, and not against Nature”. Please see Attachment 1.

62) Page 3-6, 3.6 Navigation, the reason that the “GIWW’s barge traffic “has problems from storms and shoaling” is because the Corps and local sponsors have not operated and maintained the so GIWW so it does not wide and destroy marshes.

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The Corps must include environmental impacts of the increased use of larger ships (Panama Canal complex) for DEIS and show how it will affect Galveston Bay salinity and sediment.

63) Pages 3-6 and 3-7, 3.7 Flood Risk Reduction, the Corps states “risk is considered low”, “reducing flood risk”, “risk is considered moderate”, but never stays what this risk is and the probability of the risk. The Sierra Club agrees that population growth, sea level rise, and storm intensity is rising and that local communities in the No Action Alternative can “make improvements to the system to offset these impacts.” This statement is true for all other natural resources that the Corps says will not have direct impacts. The Corps must be consistent about the negative environmental impacts that the No Action Alternative will have due to population and development growth that is forecast to occur in the next 50 years. The No Action Alternative is not a no negative impact alternative.

64) Page 4-1, 4.0 Formulation and Evaluation of Alternative Plans, the Corps should define what “sound decisions” are and explain what goes into determining if something is a “sound decision”.

65) Page 4-3, 4.1.1 Expanded Problems and Opportunities with Linked Specific Objectives, the Corps refers to “basic problems the Texas coast is facing.” The basic problems are human actions and activities placed in hazardous and dangerous coastal areas. We express surprise when people are killed, injured, and property damaged. CSRM and ER are not issues, they are strategies and or alternatives the Corps has prepared to address the problem of people living in hazardous and dangerous places. Please see Attachment 1.

66) Page 4-4, Table 4-1, Expanded Problems and Opportunities for the Upper Texas Coast, the Corps does not provide data about risk and probability for CSRM. The Corps gives no probability values and ignores the need for “strategic withdrawal” now and in the future. The City of Houston, for the most part, does not flood due to storm surge. Most of Houston’s flooding problem is rainfall flooding which the Corps says that Ike Dike will not address. Most problems in the City of Houston with flooding are caused by people living in the 100-year floodplains/floodways. People are repeatedly flooded but rebuild in the same dangerous places.

For oil refineries and petrochemical companies, people who own and manage these facilities, are responsible for their safety and the safety of people and the environment that are near them or could be harmed by them. Only a portion of these refineries and petrochemical facilities are at risk due to storm surge. The Corps uses all of them to make a case for huge levees and gates. This biases the numbers, costs, and outcomes of the DEIS.

Many of the companies have levees to protect their facilities and they are responsible for their operation and maintenance. The Corps and others must

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make sure that these companies are responsible. These companies have storage tanks and units that may be at risk. But this risk can be reduced by moving tanks, tying tanks down, emptying tanks, elevating tanks, putting different products in tanks to reduce risk when a spill occurs, etc. The Corps, GLO, and others have done nothing to require that companies be responsible for their vulnerable tanks and units in this DEIS. These mitigation measures should be implemented before the Corps asks the taxpayer to spend 20, 30, 40, or more billion dollars for huge levees and gates. If current hurricane risk reduction systems, for companies and governments, do not meet safety and risk standards, then it is the Corps, GLO, and other sponsors’ responsibility to ensure that they do. Please see Attachment 4.

For ER proposals, the Corps and sponsors do nothing about sediment that is prevented from being transported in the longshore current via dams, jetties, deep channels, etc. RSLR cannot be stopped so the Corps and sponsors have a responsibility to do something about getting people “out of harm’s way” and not allowing them to stay in hazardous and dangerous areas.

Long-term sustainability means planning several hundred years ahead (like the Dutch) and not investing taxpayer money in structures that will be degraded or worthless in less than 100 years. Breaches in barrier islands on Galveston Bay are not the problem. It is the reduction of sediment and the Corps determination to block hurricane washover areas that is the problem. Long-term sustainability requires that barrier islands move toward the mainland. They cannot if the Corps ties-down the island and does not allow washover areas and aeolian (wind) movement processes to work. Please see Attachment 1.

67) Page 4-5, Table 4-2, Example: Upper Texas Coast Specific Objectives Through 2085 and Appendix C-1 Environmental Supporting Documentation, the objectives are intended to allow more people to move into hazardous and dangerous storm surge and floodplain/floodway areas. Why does the Corps want to protect a highway, Bluewater Highway, that no longer can withstand sea level rise? Follet’s Island is so low that it cannot be saved over the next 50 to 100 years from RSLR and erosion. The Corps should buy all properties on Follet’s Island so no one is in harm’s way and so it can function as a barrier island without human degradation and intervention.

The Corps does not “Enhance and restore coastal landforms along Galveston Island and Bolivar Peninsula” because it pins down these two landforms and doesn’t allow them to move geo-morphically as a process, via water and wind sediment transfer, toward the mainland. This results in degradation of these barrier islands not their protection. The Corps does not acknowledge these irreparable problems and irreversible environmental impacts that Ike Dike will cause in Appendix C-1 and does not provide any mitigation for them. Re-nourishment will not save beaches and dunes from erosion. Please see Attachments 1 and 2.

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68) Page 3-13, 4.2.1 Measure Development and Initial Phase, the Corps shows its bias when it says “CSRM measures were to reduce flood damages to property and infrastructure”. Instead the Corps should get people out of harm’s way and keep people from moving into hazardous and dangerous storm surge, sea level rise, and floodplains/floodways. Please see Attachment 1.

69) Page 4-23, Step 3, 4.2.2 Screening of Measures, since there is a new GLO 2019 Coastal Resiliency Master Plan out, the Corps must review those measures to ensure that they are included in the DEIS or if there are duplicate or near duplicate projects, that they are removed or modified so they do not duplicate benefits.

70) Page 4-23, 4.2.3 Development of Conceptual Array of Alternative Plans, the Corps states that “to adapt to impacts that increase risks”. The Corps should state what these impacts are, how much is risk increased, and what adaptation is possible to reduce risks.

71) Page 4-26, Table 4-7, General Overview Formulation Strategies, the Corps put the emphasis on the wrong points. It is not that the “Texas coast must be protected from hurricane surge” but that the Texas coast must be protected from human actions and activities that threaten ecosystems, geo-morphic processes, and geological landforms, like barrier islands. Levees and large gates threaten all of these elements. These structural measures do not protect these elements because they interfere with the natural erosion, accretion, storm, wind, wave, and other processes that shape the coast and that native estuarian and marine organisms and ecosystems are adapted to.

The Corps fails to address how coastal erosion occurs due to dam, jetty, navigation channel, and other human actions that interfere with the sediment load in river systems and longshore currents. The Corps addresses the symptoms and not the actual reasons for these environmental impacts, which are human actions and activities based upon human desires that are incompatible with the natural coastal ecosystems and processes.

To “repair or prevent future damages” the Corps would have to begin strategic (planned) withdrawal and restore ecosystems and reduce human population and residential, commercial, institutional, and industrial development in areas that are currently hazardous and dangerous, like storm surge zones and 100-year floodplains/floodways. The Corps fights against Nature, does not work with it, and continues to put people in harm’s way. This is a failed system and will continue to fail as climate change, sea level rise, more intense rainfalls, more intense hurricanes and storms, and other natural phenomena interact with the Texas Coast over several hundred years.

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If the Corps wants to prevent or slow “coastline degradation” it is going about it the wrong way. Its solution will further degrade the coast and ecosystems dependent upon storm and other natural processes on the coast.

The Corps states that “Measures that conflicted with other measures were not combined (e.g., coastal barrier versus inland barrier systems).” This is not true. The massive levee and gate system, that the Corps proposes, conflicts with and degrades the continued existence and natural condition of barrier island and peninsula ecosystems and geological landforms that it rests upon. The high inputs needed to maintain such a system drain economic and financial resources and degrade ecological resources while supplying 50% protection against storm surge, but zero protection and perhaps even negative protection from ebbtide and other storm surge impacts in Galveston Bay. Please see Attachments 1 and 5.

72) Page 4-28, 4.2.3 Development of Conceptual Array of Alternative Plans, the Corps suggests that Alternative A “preventing storm surge from entering Galveston Bay”. This statement is misleading and only partially true. Galveston Bay will still have significant storm surge, what is often called residual storm surge, because of its large size, 31 miles long by 17 miles wide. At most, Ike Dike prevents 50% of the storm surge (personal communication with UT modeler Clint Dawson) that would normally develop in Galveston Bay. Ike Dike does not eliminate storm surge in Galveston Bay and it does nothing to protect against ebbtide flow and other erosion, accretion, and flooding impacts that will occur in Galveston Bay behind Ike Dike.

Alternative A conflicts with the protection of Galveston Island and Bolivar Peninsula because it interferes with and degrades the natural water and wind erosion/accretion processes that allow these geological landforms to move toward the mainland and stay above sea level rise. Ike Dike will starve backbay marshes of sediment that is needed for this rolling movement.

The Corps attempts to pin down these geological landforms when they want to move and have moved for thousands of years in a natural process. Alternative A requires massive “forever” or “in perpetuity” re-nourishment of 55 or more miles of beaches and dunes for Galveston Island and Bolivar Peninsula. The Corps has no idea where sediments of the right grain size will come from for “eternity” and how and who will be able to afford this cost for several hundred years.

Attachment 9: Alternatives to CTPRFS Proposals

1. “Response to Coastal Barrier Alternative”, thirteen environmental organizations, December 11, 2018.

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2. “Double EE (Economically and Environmentally Sound Storm Surge Alternative for Galveston Bay”, Evelyn Merz and Brandt Mannchen, Houston Regional Group of the Sierra Club, November 1, 2017.

3. “Working with Nature: An Economically and Environmentally Sound Storm Surge Alternative for Houston-Galveston Area”, thirteen environmental organizations, undated, probably 2017 or 2018.

4. “Guiding Principles for a Sage Alternative: Protection of People and Property from Flooding and Storm Surge”, thirteen environmental organizations, undated, probably 2017 or 2018.

5. “Alternative for Ecosystem Protect and Restoration, Storm Surge, Shoreline Erosion, and Climate Change for Galveston Bay”, Brandt Mannchen, Houston Regional Group of the Sierra Club, December 17, 2016.

73) Page 4-28, 4.2.3 Development of Conceptual Array of Alternative Plans, the Corps states that “The plan also addressed flooding on Galveston Island with a levee system, which rings the island.” There is no levee system which rings the island. The levee system rings the East part of the City of Galveston.

74) Pages 4-34 through 4-36, Development and Evaluation of the Lower Texas Coast Alternative Plans – South Padre Island CSRM and Table 4-12, the Corps refers to “elevated development”. The Corps should look at the “FORTIFIED” system that is being implemented in Alabama. At the October 31, 2018, 2019 GLO Coastal Resiliency Master Plan meeting in Galveston, Texas, a person from FORTIFIED gave a talk and showed how structures with minimum additional cost, about $3,000/building, were able to withstand 130, 140, 150 mph winds. The Corps should focus on elevation, better construction, and strategic withdrawal.

If the Corps is going to talk about “life-cycle costs” it must include in costs “forever or perpetual” re-nourishment of beaches and dunes on Galveston Island and Bolivar Peninsula. At the very least the Corps should estimate the cost of re-nourishment for 100 or 200 years since sea level rise will continue at least this long and probably much longer. The public can then get a true picture of what it will cost for South Padre Island. Table 4-12 documents that costs keep going up and up for beach re-nourishment, starting at almost $6 million and in year 40 costs are over $25 million.

75) Page 4-38, Measure G-5, - Bolivar Peninsula/Galveston Island Gulf Beach and Dune Restoration, the Corps never states why developments like Vista Del Mar, Jamaica Beach, etc. do not pay for the benefits of “perpetual re-nourishment”. The Corps ignores the impacts of Ike Dike on existing beaches and dunes due to the erosion caused by storm surge waves slamming into the levee and scouring out beach and dune sediments. Ike Dike degrades and

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destroys the ability of barrier island/peninsula moving toward the mainland so that they stay above sea level.

There are also erosion and accretion impacts from Ike Dike due to ebbtide flow as the bay storm surge empties into the GOM. Ike Dike will cause scouring of beaches, dunes, and residential homes due to storm waves that hit the levee and whose energy removes sediment from the beach front. The Corps ignores the erosion of backside marshes on Galveston Island and Bolivar Peninsula caused by sediment starvation because hurricane washover areas will be blocked by Ike Dike. Appendix 15, “The Formation and Future of the Upper Texas Coast”, John B. Anderson, Texas A&M Press, 2007; Appendix 16, “Atlas of Sustainable Strategies for Galveston Island”, Christopher Hight, John Anderson, Michael Robinson, Davin Wallace, and the students of the Rice School of Architecture, Rice University, 2009; Appendix 18, “Geohazards Map of Galveston Island, Texas”, James C. Gibeaut, Thomas A. Tremblay, Rachel Waldinger, Edward W. Collins, Rebecca C. Smyth, Williams A. White, Tiffany L. Hepner, John R. Andrews, and Roberto Gutierrez, Bureau of Economic Geology, April 2007; Appendix 20, “Living with Geohazards on Galveston Island: A Preliminary Report with Recommendations”, James C. Gibeaut, John B. Anderson, Timothy M. Dellapenna, July 2, 2004; Appendix 21, “Beach replenishment may have 'far reaching' impacts on ecosystems”, Science Daily, March 29, 2016; 25. Appendix 25, “Living by the Rules of the Sea”, David M. Bush, Orrin H. Pilkey Jr., and William J. Neal, Duke University Press, 1996; and Appendix 26, “Living with the Texas shore,” Robert A. Morton, Orrin H. Pilkey, Jr., Orrin H. Pilkey, Sr., and William J. Neal, Duke University Press, 1983, from the Sierra Club’s May 2, 2016 scoping comments document the barrier island processes, how they operate, and how humans can disrupt them like the Corps proposes to do for Ike Dike.

The 5,000 acres of land that will be lost in 50 years, is going to happen due to the erosion of existing beaches and dunes in front of Ike Dike and due to sea level rise, which Ike Dike does not stop. Please see Attachment 2.

76) Page 4-38, Measure G-28 – Bolivar Peninsula and West Bay GIWW Shoreline, Island Protection, the Corps ignores that the problem is the GIWW. The Corps has known about this problem for 30 to 40 years but has done little. Now the Corps wants to harden parts of the GIWW. The Corps should state how the parts of the GIWW that are hardened will affect the non-hardened parts when wave energy is reflected off the hardened parts. The GIWW has de-stabilized Bolivar Peninsula and West Galveston Bay and should be removed. The Corps ignores this option. The GIWW will be destroyed by sea level rise. Now is the time to come-up with another solution and not pour money into an option that will fail. The Corps uses short-term, 50-year, thinking when long-term thinking of several hundred years is needed.

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The Corps ignores that breakwaters and revetments create sediment traps which take sediment from currents. This means that shorelines where the current used to go with sediment will no longer have that sediment. This is a trade-off. One eroding area gets more sediment but another area gets more erosion because it does not get the sediment it has in the past. The Corps does not identify these effected areas that will lose their sediment, does not state what will happen in these areas, and how much it will cost ecosystems and humans for these new, Corps implemented, erosion impacts.

The 18,000 acres of existing intertidal high marsh along the GIWW will be lost due to sea level rise regardless of what is done about installation of revetments and or breakwaters in the GIWW. This proposal does not stop sea level rise. If the Corps wants to restore the GIWW it will have to bring in enough dredge material to restore the original authorized GIWW dimensions and restore all marshes and coastal prairie that has been lost as the GIWW eroded. The Corps ignores existing shoreline loss and only focuses on saving the GIWW as it now exists, not as it was authorized. The Corps, due to poor design, engineering, operation, and maintenance is responsible for the widening of the GIWW and should propose restoration that takes care of this environmental impact. The Ike Dike is not a navigation improvements project and the Corps cannot legally shoehorn a navigation project into this DEIS because it does not meet the requires of Section 4091 of the WRDA of 2007.

77) Pages 4-39 through 4-40, Measure B-2 – Follets Island Gulf Beach and Dune Restoration and Measure B-12 – West Bay and Brazoria GIWW Shoreline Protection, if any place is positioned to benefit immediately from strategic withdrawal it is Follets lsland. Not only are there few people on the Island, this barrier island is small, low, and sea level rise is going to engulf it no matter what is done for the Bluewater Highway. Whether sea level rise comes from the Gulf side or West Bay side will not matter. It is not clear whether the Corps administratively has the wherewithal to make promises that must be kept 45 or more years in the future. The Corps should explain what mechanism it will use that guarantees it will be able to conduct a one-time marsh nourishment of 19,794 acres in 2065 and that this will work.

78) Pages 4-40 through 4-45, Measure CA-5 – Keller Bay Restoration, Measure CA-6 – Powderhorn Shoreline Protection and Wetland Restoration, Measure M-8 – East Matagorda Bay Shoreline Protection, Measure SP-1 – Redfish Bay Protection and Enhancement, Measure W-3 – Port Mansfield Channel, Island Rookery, and Hydrologic Restoration, 4.3.3.2 Construction Cost Estimates of ER Measures, Table 4-14 Sediment Sources and Volumes by Measure, and Table 4-15, Construction Cost Estimates of ER Measures, FY 18, the Corps ignores the environmental impacts and financial costs of the construction of miles of breakwaters which will alter in large areas the current sediment erosion and sedimentation (accretion) balance and risks destabilization of areas where the shoreline is relatively stable.

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The borrow areas that will be used have no life-time use estimates and the volumes are simply guesses. The Corps wants to dredge Big Reef Area, which is important habitat for diving birds, wading birds, gulls/terns, shorebirds, pelagic birds, crabs, shrimp, sea turtles, dolphins, and fish. The Corps wants to dredge the Sabine and Trinity River Paleo channels, the San Bernard River, Chocolate Bayou, Colorado and Brazos River Deltas. This dredging could alter important in-floodplain Trinity River ecological and geo-morphic processes and ecosystems and affect Galveston Bay with more freshwater or less freshwater and higher salinity. Please see Attachment 1.

The Corps proposes to “steal from Peter to pay Paul” and will destroy important existing habitats for beaches, dunes, and tourism. This is not an even trade-off and natural balance and ecosystems will suffer more as humans modify natural processes and ecosystems to prevent sea level rise and erosion that is due to human actions and activities that the Corps and others will not prevent. This is a “house of cards” that is destined to fall and make matters worse, not better.

The Corps bases this all on “assumed year in the future under an intermediate rate of RSLC” when the most recent science documents that sea level rise is getting worse as additional scientific research projects are completed. The Corps underestimates the costs and the environmental impacts by not using the highest sea level rise scenario. The high sea level rise estimate should be used. Please see Attachment 7.

79) Page 4-45, 4.3.3.3.1 Identify Lines of Defense Strategy for Ecosystem Restoration, the Corps states that “The series of barriers … can reduce the physical impacts of storm surges and winds that enter the bays.” This is a false statement. Barrier islands and other natural features and structural features like Ike Dike do nothing to stop winds from entering bays and do nothing to stop the creation of storm surge due to wind after it has entered the Bay. Winds are not blocked by barrier islands or Ike Dike.

80) Page 4-46, 1st Line of Defense and Ecosystem Restoration – Barrier Systems and 2nd Line of Defense and Ecosystem Restoration – Estuarine Bay System, the Corps has proposed the degradation of Galveston Island and Bolivar Peninsula by tying them down with a 55 mile plus long levee/seawall/floodwall system. This system will not permit barrier landforms to move toward the mainland and will degrade their ability to stay about sea level rise. This system starves backside marshes of sediment because storm washover areas will be blocked, ebbtide will erode behind the system, and beaches and dunes in front of the levee will erode due to wave energy scouring them in front of the levee system.

The Corps implementation of miles of breakwaters, interrupts sediment currents and will destabilize where sediment is deposited and eroded. The Corps Ike

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Dike will be worse for Gulf and Bay shorelines than currently exists and human actions and activities that currently disrupt shorelines will be allowed to continue as 3 to 4 million more people move into the area. Please see Attachment 1.

81) 3rd Line of Defense and Ecosystem Restoration – Bayhead Deltas, the Corps proposes to dredge these deltas of the Colorado and Brazos Rivers and ancient channels of the Trinity and Sabine Rivers which will degrade them as a line of defense. The six ER measures are stop gap measures. The Corps must tell the public about the impacts of shoreline loss as sea level rises for the next several hundred years. The Corps must adjust its thinking and use a longer timeframe to determine how we can, over time, withdraw, reduce expenditures, and adapt to these new, inevitable conditions. Please see Attachment 1.

82) Page 4-55, 4.3.3.4 ER Benefit Quantification, the Corps states that there may be “one or more out-year nourishment after initial construction and within the 50-year period of analysis”. The Corps should consider a worst-case scenario and tell the public how many re-nourishments could occur in 50 years and beyond 50-years for at least 100 to 200 years, so the public knows what the long-term monetary commitment is. Please see Attachment 2.

83) Pages 4-57 through 4-59, 4.3.3.8 Comparison of Final Array of Coastwide ER Alternative Plans and Selection of TSP, the problem with proposals to benefit sea turtles, Piping Plover, Rufa Red Knot, and other birds is that the right sand grain size is required for nesting and feeding. The Corps does not document that enough sediment of the right grain size will be available now and in perpetuity for these species. The Corps does not guarantee that the appropriate oversight will be required to ensure that this occurs. The Corps and GLO failed at the Quintana/Surfside area in 2017/2018 when it allowed a contractor to place sediment on the beach that was of the wrong (too small) grain size. This wrong grain size interferes with or prevents Kemp’s Ridley Sea Turtle nesting. The Corps and GLO must tell the public how it will ensure that beach re-nourishment is done with the right grain size and what it will do if this does not happen. Please see Attachment 2.

84) Pages 4-60 through 4-64, 4.3.4.1 Nonstructural Plans, the Corps states that “Nonstructural measures reduce flood damages without considerably altering the nature or extent of flooding”. This means that the natural ecological and geo-morphic processes are left more intact. It also means that with “buyouts” there is land available if flood control projects are necessary. The Corps ignores “FORTIFIED” flood construction and proofing that keeps buildings together during high winds. Nonstructural programs could be used 100% in certain areas, but the Corps hardly uses them at all and with Ike Dike, which has little in the way of buyouts. This documents the Corps bias against nonstructural solutions.

The Corps states that “relocating residents away from the coastal surge doesn’t necessarily remove all flooding risk from residents”. The same is true for Ike

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Dike. Flooding will still occur on the backside of Bolivar Peninsula and Galveston Island via ebbtide and Bay storm surge.

The Corps does not include the cost of rainfall flooding in its benefit-cost analysis. This is a big part of what will occur in La Porte, Santa Fe, La Marque, City of Galveston, Shoreacres, and other vulnerable communities. Ike Dike does not stop rainfall flooding and residents will still be in jeopardy.

The Corps estimates under FWOP and FWP conditions, “which require residents to rebuild above the base flood elevation after a structure receives greater than 50 percent damage to the structural components” are inaccurate since it has been found, via newspaper and other investigations, that many entities, including the City of Galveston, underestimate damage so people can rebuild in places where they should meet the new building code, elevate, or be bought out. This is a systemic statewide problem that the Corps must acknowledge and analyze for alternatives. Please see Attachment 5.

85) Page 4-66, 4.3.4.2.1 Navigation Concerns, the Corps states that “with additional traffic and larger vessels transiting every year”. The Corps is biased for and overemphasizes larger vessels. The Corps knows that the Houston Ship Channel in Galveston Bay cannot be enlarged forever. If this continued enlargement occurs the Galveston Bay Ecosystem will face further, permanent, damage.

86) Page 4-69, 4.3.4.3.1 Navigation Concerns, the Corps states “including multiple yacht clubs along the east side of the bay”. The yacht clubs are on the “west” side of Galveston Bay not the “east” side.

87) Page 4-73, 4.3.4.3.3 Direct and Indirect Environmental Impacts, the Corps violates NEPA and CEQ regulations (Sections 1502.2, 1502.5, 1502.9, and 1502.14), by comparing only two alternatives, other than No Action, which the Corps must consider under NEPA. There are many other alternatives, like the Sierra Club and Bayou City Waterkeeper alternatives that could have been compared. But the Corps refused to do this. The second alternative, Alternative B, the Corps critiques more harshly than Ike Dike so it is obvious the Corps is biased in favor of Ike Dike (Alternative A). Please see Attachment 7.

88) Pages 4-73 and 4-74, 4.3.4.4 Coastal Barrier with Complementary System of Nonstructural Measures (Alternative A), the Corps claims Ike Dike will maintain “existing geomorphic features along Bolivar Peninsula and Galveston Island … preventing storm surge from entering Galveston Bay”. As mentioned before in this comment letter, the Corps actions will degrade and attempt to pin down the movement of Galveston Island and Bolivar Peninsula, starve bayside marshes, and erode existing and re-nourished beaches and dunes. The Corps Alternative A, Ike Dike, does not protect Galveston Island and

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Bolivar Peninsula and degrades their ability to move and stay above sea level rise.

The Corps states “nonstructural measures, such as ring levees and closures on key waterways”. Ring levees are not non-structural measures. They are structural measures. The Corps fails to state that a levee system will result in the erosion of beaches, dunes, and houses in front of the system due to scouring by flood waves during storms. Please see Attachment 1.

89) Page 4-74, 4.3.4.5 Upper Bay Barrier (Alternative D), the correct state highway designation is SH 146, not SH 145.

90) Page 4-78, 4.3.4.5.1 SH 146 Alignment ((Alternative D1), the Corps refers to “Much of the existing rights-of-way or corridors necessary to build a levee system would be unavailable because of the expanded highway”. The Corps should tell the public which is more important, a highway that makes people more vulnerable to storm surge or a storm surge levee that protects the highway and people. Please see Attachment 8.

91) Page 4-78, 4.3.4.5.2 Upper Bay Barrier-Bay Rim (Alternative D2), the Corps does not explain why Hitchcock and Santa Fe residents cannot elevate their buildings. A levee system alternative which rings Galveston Island does not exist. This is a proposal that no one has made. Please see Attachment 8.

92) Page 4-81, Table 4-21 Comparison of Alternative A and D2, the Corps ignores the alternatives that the Sierra Club and Bayou City Waterkeeper provided to it. This biases the alternatives selection process. The Corps refers to risk – mitigation risk, high acquisition risk, localized direct and indirect risk, risk to navigation, high indirect environmental risk, lower acquisition risk, etc. The Corps never explains what each risk is and the probability of each risk. Please see Attachment 7.

The Corps ignores the effects on San Luis Pass, washover areas, ebbtides, residual storm surge in Galveston Bay, all protected lands, etc. in its risk statement. This is not acceptable.

93) Pages 4-82 through 4-84, 4.3.4.7 Comparison of Design Details, Galveston Ring Levee, the Corps states that, “The Galveston ring levee with Alternative A only has to address wind-driven surges from the Galveston Bay system”. The Corps does not mention that this levee must also withstand ebbtides after the hurricane passes. Water deflection will play a role in Alternative A for structures and landforms that are next to the levee and at both ends of the levee. Water deflection will also occur due to the existing Texas City Dike and storm levee system. All of these water deflections must be modeled together, and mitigation provided.

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The Corps states that “Alternative D2 would require a large number of drainage features along the westside of Galveston Bay”. Alternative A has 80 total drainage structures compared to 38 drainage structures for Alternative D2. Alternative A will have the greatest number of drainage structures and impacts due to them. The Corps is incorrect when it says that “With Alternative A, the only drainage structures needed are associated with closures at Clear Lake and Dickinson Bayou.” Many more drainage structures than these two locations, in total, will be needed including the High Island GIWW closure. This is an example how the Corps biases an alternative by providing an incomplete and misleading description of the alternative. Please see Attachments 2 and 8.

94) Page 4-84, 4.3.4.8 Construction Schedule and Benefit Assumptions, the Corps fails to discuss how the construction site will be protected from storms because it will take 10-15 years to construct Ike Dike. The Corps fails to state how much protection of the construction site will cost.

95) Page 4-86 through 4-90, 4.3.4.9 Environmental Impacts, the Corps does not present a worst-case scenario for sea level rise because it uses the intermediate scenario. The Corps underestimates environmental impacts that will occur due to the proposal and overestimates its protective features. The major direct environmental impact will be interference with barrier island process functioning and circulation of water and sediments in and out of Galveston Bay and not “loss of wetlands within the project right-of-way”. The Corps ignores the environmental impacts of ebbtide, water deflections, loss of backside marshes, loss of washover areas, loss of land, impacts due to Ike Dike for all protected lands that are affected, loss of existing and re-nourished beaches and dunes due to scouring, etc. The Corps has not provided a complete list, detailed explanation. and discussion of environmental impacts.

On Table 4-24 the Corps ignores the loss of coastal prairie, beaches, dunes, and tidal flats. Please see Attachments 5 and 8.

96) Page 4-90 and 4-91, 4.3.4.10 Potential Induced Flooding, the Corps states that “With Alternative A the potential for induced flooding is limited to the structures on Bolivar Peninsula and Galveston Island.” This assumes that ebbtides only damage structures and landforms on these two barrier landforms. This may not be accurate since water deflection and re-deflection can occur. But no study has been conducted to determine these impacts. Please see Attachments 1, 5, and 6.

97) Page 4-91, 4.3.4.11 Navigation Impacts, the Corps fails to state what the environmental impacts will be if a 60-foot sill is used for Alternative A which allows for a deepened and widened Houston Ship Channel. There are indirect, cumulative, and connected impacts that should be discussed and quantified in this proposal.

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The Corps assertion that Alternative D2 leaves much of the navigation infrastructure at risk does not take into account the responsibility of those who own or operate ports and channels to protect themselves from storm surge. This has occurred in the past and why this responsibility should now be passed to the U.S. government is not explained.

Large storm surge will occur within Galveston Bay regardless of Ike Dike, so this occurs with or without its presence. Storm surge can move large amounts of sediment out of channels and not just into channels. The Corps has no documentation to show what will occur. Since Rollover Pass will be closed its shoaling should not be counted as a cost but as a benefit of hurricanes.

The Corps assertion that “Alternative A … would help to maintain existing geomorphic features along Bolivar Peninsula” is false. The Ike Dike will degrade barrier island and peninsula geo-morphology by attempting to pin these landforms down when they naturally want to move to keep above sea level rise. The Corps Alternative A proposal will block washover areas, which feed sediment to backside marshes and allows barrier landforms to move toward the mainland. The levee will result in erosion of beaches and dunes as well as structures on the Gulf side due to scouring by waves which hit the hardened structure and are deflected. Please see Attachments 1 and 5.

98) Page 4.3.4.12 Critical Infrastructure, the suggestion that I-10 inundation increases as sea level rises is not new. Sea level rise will eventually, if climate change effects are as large and pervasive as they seem, move toward and may inundate I-10. Roads can be moved or abandoned. Sea level rise cannot be stopped. SH 124 is not a critical roadway because Bolivar Peninsula is not a critical place for people to live. The Corps should propose strategic withdrawal for Bolivar Peninsula and people should be bought out or people should elevate their structures. Why built a 20 to 30-billion-dollar levee to save a road that is not needed? This makes no sense. The Corps ignores that SH 124 has already been raised at the High Island end by the Texas Department of Transportation. Please see Attachment 5.

If the Corps insists on guarding roads it will eventually be surrounded by sea level rise and will have to give in to the power of Nature which we have unleased with human-caused climate change, sea level rise, increased intensity rainfalls, and increased intensity hurricanes and storms. Please see Attachment 7.

99) Pages 4-96 and 4-97, 4.3.4.16 Residual Risk, the Corps states that “Alternative D2 comes with residual flood and life safety risk”. Ike Dike (Alternative A) also has residual flood and life safety risk due to ebbtide and storm surge within the Bay risk and could cause structures on Galveston Island and Bolivar Peninsula behind the levee to flood and areas on either end of the levee, particularly San Luis Pass Area.

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The Corps does not combine with Alternative D2 and Alternate A an extensive buyout program so that places that are next to the levee are not in danger of flooding due to the levee, ebbtide, and water deflections.

The Corps states that for Alternative D2 “Rainfall would stack up behind the levee system until it was pumped or drained out.” This same risk occurs with Ike Dike, which blocks ebbtide and rainfall flooding. Please see Attachment 6.

100) Page 4-97, 4.3.5 Summary of CSRM Alternatives Comparison, the Corps does not tell the public what the probability of lower residual risk is for “extreme overtopping events”. The Corps is wrong that Ike Dike “is set farther away from the developed areas of the study area.” Certainly, all the people who live on Galveston Island and Bolivar Peninsula would disagree that they are far away and would not be affected by “extreme overtopping events”. What is the probability of these overtopping events? For what category of storm are we talking about? Sine the Corps admitted in a 2018 meeting with the Sierra Club and others that the levee system would be for a Category 3 storm these “extreme overtopping events” are less likely than with Category 4 and 5 storm which Ike Dike does not protect against. The Corps should provide probability figures since it has conducted 100’s or 1,000’s of model runs with dozens of different storms. Please see Attachment 8.

101) Page 4-98, 4.4 Overview Coastwide Array, the Corps states that “the main difference between the No-Action Alternative and the two action alternatives was the location for a Coastal Barrier CSRM in the upper Texas coast.” This statement clearly exposes the Corps bias. Some of the major differences include spending of multiple billions of taxpayer dollars, massive environmental impacts due to levees, and all the analyses, evaluations, assessments, studies, research, etc. that have not been conducted so the public knows the real costs environmentally, socially, and economically of Ike Dike.

102) Pages 4-100 through 4-102, 4.4.2 Coastal Barrier Alternative, ER Measures, the Corps never addresses how many of the ER locations will be affected by a high sea level rise scenario, more intense rainfalls, and more intense storms over the next 50 years and 100 to 200 years after this, since sea level rise may increase for centuries to come. The Corps ignores the impacts of borrow areas and whether there are enough of these areas to provide sediment of the right grain size for 50 years and more (100 or 200 years). The Corps also does not address the ricochet effect on ER projects near the levee or breakwaters and revetments that are proposed for implementation. Please see Attachment 7.

103) Pages 4-102 through 4-104, Coastal Barrier CSRM Measure, the Corps says it will “attempt to avoid impacts to the Anahuac NWR”. The Corps must explain what this means; what impacts the Corps is talking about; what methods will be used to avoid impacts; and what avoidance, minimization, and mitigation

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will be used. The Corps does not tell the public what the impacts are and how it will reduce them. The Sierra Club does not support any impacts to Anahuac NWR.

The Corps states that the “Galveston seawall “would have to be raised to maintain the same level of risk reduction”. The same is true for Ike Dike as sea level rise affects its storm surge protection capabilities.

The Corps states that “From that point the system turns southwest and would include use of a system of levees and floods to reach the vicinity of Port Bolivar”. The Sierra Club assumes the Corps is not going to flood people purposefully. The Corps should make it clear what it means here.

The Corps refers to 38, 100-foot gates. The Corps should clearly state where gates will go in the Ike Dike proposal, what type of gate each will be, and how many gates total there will be at Bolivar Roads and for the proposal as a whole.

The 60-foot sill will allow a deepened and widened Houston Ship Channel. The Corps must state what the environmental impacts of this deepening and widening are in Galveston Bay. The Corps never says how the “temporary bypass for navigation” channel will be dredged, what the environmental impacts are, and how this temporary channel will be filled after it is no longer needed.

104) Page 4-107, 4.4.3 Bay Rim Alternative, the Corps states that this alternative “would leave the city of Galveston at risk of damages from storm surge and could induce storm surges in the area.” This statement is also true for Ike Dike because it blocks ebbtide flows out of Galveston Bay and deflects water onto structures behind the levee and structures in front of the levee are not protected.

105) Page 4-107 through 4-110, 4.5 Selected TSP, the Corps emasculates NEPA and CEQ regulations by not applying the same analyses for all alternatives. NEPA and CEQ regulations do not allow only one alternative to be analyzed. Section 1502.14, requires comparison of all alternatives so it is very clear about their differences (“sharply defining the issues and providing a clear basis for choice among options by the decisionmaker and the public”). The Sierra Club is opposed to the DEIS because it violates NEPA and CEQ regulations.

106) Page 4-108, 4.5 Selected TSP, the Corps should make it clear that since most years there are no hurricanes and there is no storm damage that the estimated annual reduction in storm damages of $970 million to $1.288 billion would not occur in most years. The Corps ignores the ebbtide and storm surge in the Bay threats, risk, and probabilities and their environmental impacts when talking about Ike Dike.

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107) Pages 5-1 through 5-4, 5.1 Introduction, the Corps refers to open water or unconsolidated shoreline and marsh restoration and “out-year marsh nourishment” that is needed due to sea level rise. The Corps provides no information or data to show what is planned, the magnitude of what is planned, the borrow areas needed, and the likelihood of success. The Corps must provide the public with more than vague assertions that what is planned will succeed.

The Corps should discuss what it means when it says that the “Lower Laguna Madre would be hydrologically restored”. The Corps should discuss the historical conditions of hydrology, what the conditions are now, why the conditions have changed, how the proposal will result in permanent or partial changes, and how long these changes will last.

The Corps refers to borrow source locations and upland commercial sources and a combination of routine dredging, offshore sources, and excavation from coastal barrier construction. The Corps does not state where these borrow sources are, how much material will be taken from each borrow source, and the environmental impacts of this action. NEPA requires that environmental impacts be covered in a DEIS. The Corps must reveal these impacts now so the public can review and comment on them.

108) Page 5-4 and 5-5, 5.2 Estuarine Modeling Summary, a two-year simulation of water level, velocity, and salinity is insufficient. Since the proposal is for a minimum of 50 years the Corps should model for 50 years and document the changes that may occur during that time. If the proposal lasts 50 years, then the Corps should discuss what will replace this proposal at 50 years and 1 day and what the potential replacement costs are.

109) Page 5-6, 5.3.1.1.1 Coastal Barrier Alternative, the Corps should discuss how organic matter and nutrients are affected by the dynamics of the Bolivar Road gate and flow into and out of Galveston Bay.

The Corps admits there will be erosion at San Luis Pass and changes in overwash sediments that are delivered to marshes but it does not state how much erosion will occur, discuss these environmental impacts, and state how they can be mitigated.

110) Pages 5-6 and 5-7, South Padre Island CSRM Measure, the Corps does not discuss the shoaling rate, sediment transported by aeolian processes, and the environmental impacts that beach-fill will have on South Padre Island.

111) Pages 5-7 and 5-8, ER Measures, the Corps fails to state how much habitat will be replaced with hardened structures, how much the rate of sedimentation into bays and waterways will decrease, and how much habitat would be reduced or restored due to erosion caused by breakwaters and revetments.

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The Corps refers to shoaling increases at Bolivar Roads and San Luis Pass but does state how much will occur, does not talk about proposals to dredge these areas, and the environmental impacts that this may have on natural inlets. The Corps never states if the out-year marsh nourishment in 2065 will be adequate to address erosion losses. The Corps does not state what environmental impacts will occur when shoaling increases, how much shoaling will increase, and what occurs within the entrance channel at Port Freeport when this is dredged.

112) Page 5-9, 5.3.1.2.1 Coastal Barrier Alternative and ER Measures, the Corps fails to state what the increase for “Gulf-side erosion rates and shoreline retreat rates” will be, the environmental impacts Ike Dike will have (including at the Galveston Seawall, increased erosion rates), and how much sediment from Galveston Bay to the longshore current will be reduced.

113) Page 5-9, ER Measures, the Corps should mitigate any temporary increase in suspended sediments in the water column by using silt curtains or other mitigation measures.

114) Page 5-10, 5.3.1.2.3 Bay Rim Alternative, the Corps should state what it means (quantify) when it says that “erosional patterns at the shorelines of Bolivar Peninsula would only slightly increase … could result in an increase in shoreline retreat within the non-protected bay rim areas as well as a slight increase in storm-induced shoreline retreat at Bolivar Peninsula and Galveston Island”.

115) Page 5-11, South Padre Island CSRM Measure and ER Measures, the Corps should state how much shoaling of the Port Mansfield Channel will occur over a certain time period and how much it will cost to dredge the channel. The Corps should also state how much out-year marsh nourishment costs are (how many times is this estimated to occur) and how long it will take to “stabilize existing and restored island shorelines and marsh fringes.”

The Corps should state what “localized current and circulation changes” may occur, give a quantification for these changes, and state clearly what “hydrologic restoration” of the Lower Laguna Madre is. The Corps should quantify what “Measurable beneficial impacts to tides, currents and circulation … are expected to be induced by dredging of the Port Mansfield Channel.” Since tides are affected by the moon, how will what the Corps does affect tides?

116) Page 5-11, Bay Rim Alternative, the Corps uses phrases like “for the most part”, “remain relatively unchanged”, “would be nominally impacted”, “impacts are considerably less”, “velocities increase minimally”, “may be slight increases”, “partially constricting tidal flows”, and “velocity magnitude changes are expected to be negligible”. The Corps must state what these phrases mean. Quantification is needed so the public understands the magnitude of what may occur.

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117) Page 5-12, 5.3.2.2.1 Coastal Barrier Alternative, Table 5-5, the Corps must compare the actual salinities at places named with those predicted by its computer model and then discuss the differences.

118) Page 5-14, 5.3.3.1.1 Costal Barrier Alternative, the Corps fails to provide data for a Category 5 hurricane and its storm surge impacts. The Corps ignores ebbtide flows, their size, and impacts.

The Corps uses a 100-year return interval for Ike Dike storm surge protection which the Sierra Club understands is a Category 3 storm. The Corps fails to provide quantification of its modeling for storm surge reductions (not color codes which are hard to read, deduce, and identify by feet) and “slight increases” at specific points or locations in Galveston Bay. If reduction is one-half foot to 10 feet, what are the damages at each point between these two extremes?

119) Page 5-17, South Padre Island CSRM Measure and ER Measures, the Corps says that “beach/dune features would still be overtopped … but at a reduced level.” The Corps should state what that reduced level is in feet or inches, so the public knows how much protection is provided.

The Corps does not state how much the improved “tidal circulation” will be from dredging of the Port Mansfield Channel and what standards or criteria are used to define successful hydrologic restoration of the Lower Laguna Madre.

The Corps does not state what the grain size is of dredged material that will be used to widen 10 miles of Padre Island National Seashore and whether this grain size is compatible with sea turtle nesting. The Corps should state how much the nourishment features “would contribute to absorb storm surges”.

120) Pages 5-20 and 5-21, 5.3.4.1 Coastal Barrier Alternative, the Corps should state how much Ike Dike will “affect water and sediment quality” and “reduce flushing and mixing of point and nonpoint source pollutants”. If retention times increase then greater sedimentation will occur upstream of Ike Dike and at barriers at Clear Lake, Dickinson Bay, Offatts Bayou, and the High Island GIWW. How much additional sedimentation will occur and how much will salinity and dissolved oxygen levels change? The Corps should state what plankton and zooplankton communities will change to if nitrogen and phosphorus ratios change. The Corps should state how many times “widely and frequently” will harmful algal blooms occur with increased retention times.

121) Page 5-21, South Padre Island CSRM Measure and ER Measures, the Corps should state how long it will take to construct the project. The Corps should define what “localized and temporary increases in turbidity” are and how long these and low dissolved oxygen levels will last.

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122) Page 5-23, 5.3.5.1 Coastal Barrier Alternative, the Corps should explain ecologically what reduced tidal amplitude will mean for ecosystems on the shoreline of Galveston Bay. The Corps should explain what the impacts on water quality are of stormwater which in pumped out of Ike Dike and other surge gates and levees/floodwalls/seawall.

123) Page 5-23, ER Measures, the Corps should state how much erosion downstream and sediment catchment at the location of the revetment and or breakwater will occur.

124) Page 5-24, 5.3.5.2 Bay Rim Alternative, the Corps should state how much localized flooding upstream and downstream will increase and where rainfall runoff and sheet flow will be forced into areas not typically inundated. The Corps should state what the water quality impacts are of localized flooding. Please see Attachment 6.

125) Page 5-25, 5.3.6 Soils (Prime and Other Important Unique Farmland), the Corps should state how operation of farmland next to Ike Dike will be affected. The Corps should estimate how much induced development will occur on important farmlands due to the presence of Ike Dike.

The Corps states that the “Coastal barrier is expected to benefit prime farmlands by providing a buffer and protective barrier against rising sea level and erosive wind/wave action that could potentially wash out prime farmland soils.” Ike Dike does not stop rising sea level. The sea level will rise and will seep, move, and follow whatever path it must to inundate land that is at an elevation lower than sea level. Ike Dike will deflect storm surge and cause internal flooding that will affect farmland in front and behind the barrier. Ebbtide will affect farmland more with Ike Dike in place. Finally, by providing what appears to be protection, farmland will become subject to more development pressure since developers and real estate interests will sell property and tell people that they are protected from flooding by Ike Dike.

126) Pages 5-25 through 5-27, 5.3.7 Energy and Mineral Resources and 5.3.8 Hazardous, Toxic, and Radioactive Waste (HTRW), the Corps states “Steps would be taken to avoid, minimize, and reduce any potential impacts to oil and gas activity and HTRW to the best extent practicable.” The Corps fails to state what these “steps” are and what “best extent practicable” means for mitigation.

The Corps ignores how it can mitigate against storm surge impacts on oil refineries and petrochemical plants via moving storage tanks and units, tying them down, raising their elevation, removing more hazardous chemicals, etc.

127) Pages 5-27 through 5-29, 5.3.9 Air Quality, 5.3.9.1 Coastal Barrier Alternative, and 5.3.9.2 Bay Rim Alternative, the Corps fails to estimate

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indirect air pollution that will be released due to increased population growth and development that occurs behind Ike Dike due to perceived protection from storm surge. The Corps should place diesel-fueled generator information under 5.3.9.1 Coastal Barrier Alternative. The air pollution estimates should be reported now and not delayed so the public can see how much air pollution will occur due to Ike Dike.

128) Pages 5-29 and 5-30, 5.3.9.3 Conformity of General Federal Actions – General Conformity Determination, conformity should be done now and not put off to a later date when the public is not aware of data and analysis and cannot review and comment on the results.

129) Pages 5-30 and 5-31, 5.3.9.4 Potential Air Quality Mitigation Measures, the Corps should state what the “expected life of the project” is. The Corps should be more specific about mitigation. The Corps should state what “energy efficient equipment” it is talking about, its availability, what “cleaner diesel engines” there are, their availability, what air pollution control equipment there is, its availability, the availability of electric dredges, etc. The Corps must talk about leaks of methane (additional climate change gases) that occur with the use of compressed natural gas or liquified petroleum gas, what cleaner, more fuel-efficient diesel engines there are, what newer vehicles with more fuel-efficient engines there are, and what non-road ultra-low sulfur diesel fuel exists, and its availability. The entire issue of realistically requiring mitigation measures must be discussed so the public knows how likely mitigation measures are to be used and the costs of their use.

130) Pages 5-31 to 5-33, 5.3.10 Noise, Coastal Barrier CSRM System, South Padre Island CSRM Measure, ER Measures, 5.3.10.2 Bay Rim Alternative, Bay Rim CSRM System, and South Padre Island CSRM Measure and ER Measures, the Corps does not have site-specific information about noise at various locations along the levee or gates (including Clear Lake, Dickinson Bayou, Offatts Bayou, and High Island GIWW).

There will be emergency generators that create noise and there will be an increase in ambient noise levels as population growth and development occur behind the levee on Galveston Island, Bolivar Peninsula, and throughout the shoreline of Galveston Bay.

The Corps ignores that all protected lands are also “noise-sensitive receivers”, along with residential areas. Shorebirds (nesting, feeding, loafing, hunting, etc.), sea turtles, and many other wildlife are affected by human noise. The Corps statement that “The long-term reduction in noise would be from the expected decrease in infrastructure damage and subsequent decrease in infrastructure damage and subsequent construction/rehabilitation activities” ignores this development and the ambient noise that will be generated and increase on the bayside of levees.

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Noise will increase on the beaches and dunes on Galveston Island and Bolivar Peninsula as beach re-nourishment occurs and makes these areas more attractive for more tourism than occurs now.

The pump stations along the Bay Rim will create noise along Ike Dike. There is one noise that currently occurs, that people like, that will be diminished by Ike Dike. That noise is the sound of waves rolling onto beaches. The surf noise is important for the atmosphere it provides but will be muffled or eliminated by Ike Dike. The vista of the GOM will be removed or damaged by Ike Dike for many residents of Galveston Island and Bolivar Peninsula and tourists. It is assured that noise-sensitive areas, protected from storm surge, will not benefit form a minor long-term reduction in noise due to population growth and development.

131) Pages 5-34 through 5-37, 5.4.1 Wetlands, the Corps does not reveal that Ike Dike, 18 feet or higher, will interfere with the aeolian process of wind moved sediment that provides sand to marshes and other wetlands on Galveston Island and Bolivar Peninsula. Ike Dike causes more marsh erosion on the backbay side because it will interfere with the washover process that storm surge provides for the movement of barrier islands and which feeds marshes on the bayside. Ike Dike will cause more freshwater marsh erosion on the Gulf side because of the scouring energy of storm surge waves on dunes and coastal prairies where freshwater wetlands occur.

The mitigation plan does not account for an increase in dredge/fill permits behind Ike Dike due to an increase in population growth and development. Revetments and breakwaters will not protect freshwater marshes in dunes and coastal prairies from loss due to sea level rise and the construction and operation of Ike Dike. A 10-year timeframe to create marshes will result in marsh loss as sea level rises during the marsh creation process. The Corps fails to state how long restored wetland and marsh habitat will last before sea level rise and erosion from Ike Dike overwhelms these habitats.

The Corps fails to state how it will oversee marsh creation when it has little in money, resources, and personnel to do enforcement for Section 10/404 permits. The Corps must guarantee that it can provide oversight and state how this will be done, how often it will be done, what happens if marsh mitigation does not work or disappears due to sea level rise, Ike Dike, and other factors. The Corps should require silt curtains during dredging so that marshes and seagrass beds are not buried in turbidity and suspended sediments.

The Corps is incorrect when it says the “Direct impacts resulting from construction activities would likely not affect the wetland and marsh habitats where dune and beach restoration features are proposed.” The Corps ignores that there are freshwater and brackish water wetlands in current dunes and any efforts to increase their size, height, and extent would probably affect these

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wetlands. The Corps does not discuss loss of wetlands on protected lands that are covered and fragmented by Ike Dike. The impacts on remaining wetlands due to operation, maintenance, repair, and replacement activities must be discussed and quantified.

The Corps must place under the Coastal Barrier Alternative of this section the same language that it puts under the Bay Rim alternative that, “tidal wetlands … could be negatively impacted by the construction of levee/floodwall by disconnecting the tidal exchange on the portion of those wetlands on the interior of the system. The wetlands outside of the system may also be negatively impacted by the changes in hydrology and sediment exchange that could occur as a result of construction.” Impacts would occur for both alternatives and the Corps must state how many wetlands it estimates will be destroyed or degraded by these impacts. Please see Attachment 5.

132) Pages 5-37 through 5-39, 5.4.2 Aquatic Communities, the Corps should state how often and how long lower and higher salinities would occur due to Ike Dike, what the salinity levels would be, and how large an area (areal extent) would have low and high salinities due to Ike Dike.

133) Pages 5-39 through 5-43, 5.4.2.2 Estuarine Habitats and Fauna, the Corps should use silt curtains to reduce turbidity and impacts on phytoplankton, zooplankton, algae, marshes, and seagrasses. The Corps says that community structure, composition, and function may occur but would be temporary in “some dredging areas”. The Corps should state which dredging areas will impacts occur, how many and the size of dredging areas are estimated to have these impacts, and why the impacts occur at these dredging areas. The Corps should commit to mitigation measures that reduce or eliminate these impacts and state what those mitigation measures are. The Corps should state where sediment build-up and erosion will occur.

The Corps assertion that “no adverse effects on fauna are expected due to changes in salinity that may result from the construction of the Coastal Barrier” is false. Since it will take at least 10 years to construct levees/add to the sea wall/floodwalls and gates and since weather and climate changes each year the Corps cannot make this blanket assertion. In a particularly dry time, Ike Dike may be the factor that increases salinity to a tipping point in Galveston Bay. The Corps should state how much aquatic organism impacts (“some of the potential impacts”) will there be due to the gate at Bolivar Roads. The gate itself will cause far more impacts than any it may reduce. Suggesting that the mammoth gate should help reduce impacts to aquatic organisms that use shallow edge habitats, if true, does not justify the gate. We know sediment and erosion will be increased which will alter present estuarine habitats and fauna.

The Corps states that the Causeway Bridge, Texas City Dike, Galveston Jetties, and dredge material placement areas “my have had adverse effects on fisheries”.

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The fact is, as the Corps knows, these actions and others have negative impacts as marshes and shallow water habitats were destroyed or degraded. For instance, Galveston Bay has lost almost all seagrasses, many of its marshes, and a sea turtle population so large that it provided for a fishery at one time. These are documented losses and not “may have happened” losses.

There are many other examples of Galveston Bay losses and these losses do not document resilience but do document a less healthy Bay. The Corps should speak the truth and not try to “sugar coat” environmental damage. As the Corps knows, oyster reefs and hash areas exist that are not known so just because current maps don’t show losses does not mean oyster habitat losses will not occur. The Corps admits this on Page 5-44 when it states, “The interagency team has noted that oysters do occur in locations that are not included in the GLO dataset”.

The Sierra Club does not call construction that will take 10 years or more “temporary and local” and does not call turbidity increases from that construction “temporary and local”.

134) Page 5-41 and 5-42, South Padre Island CSRM Measure, the Corps should state and define what “short-term water column turbidity and impacts to benthos during placement activities” means.

135) Pages 5-42 and 5-43, ER Measures, the Corps should provide documentation that “constructed revetment/breakwaters would … provide a greater ecological service than without the structure in place”. The Corps should state that if it wants to “protect valuable marsh, SAV, and oyster reef habitat from eroding” it must address the widening of the GIWW so that it is restored to its original width.

The Corps assumes that it can keep 28,000 acres of marsh from being inundated by sea level rise by an application of sediment. The Corps provides no information on how long this will take and what this assumption is based upon. The Corps assumes that it has the ability, the money, and the sediment to re-nourish 55 miles or more of beach and dunes every 5 to 10 years. This is up to 5 years sooner than the once every 10 years the Corps says will occur on Page 5-42. Which figure is correct? The Corps must be consistent with its assertions. Please see Attachment 2.

136) Pages 5-44 through 5-47, 5.4.3 Wildlife Resources, Coastal Barrier CSRM System, South Padre Island CSRM Measure, ER Measures, Bay Rim CSRM System the Corps does not talk about protected lands and the wildlife on them that will be killed or affected by Ike Dike. The Corps states that “Wildlife can avoid the area and potentially relocate away from the project area to adjacent habitat.” This statement is misleading and false. First, wildlife can only relocate away from Ike Dike if there is habitat to go to which is under its carrying

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capacity for that species. Overall natural habitat like coastal prairie, wetlands, dunes, etc. will decrease with the construction of Ike Dike so there will be will less habitat available for wildlife.

Second, if there is habitat that is populated by the same species, then either the relocated species will die or the relocated species will push out the same species that currently lives in that habitat. Either way, wildlife will lose. Third, there are a lot of wildlife species (usually smaller and less mobile) that either cannot or have a very difficult time relocating to other habitats. Species that are struggling, like Diamond-back Terrapins and Gulf Salt Marsh Snakes will do worse with Ike Dike when it is constructed and operational.

Most of these species are small and less mobile and include fungi, bacteria, annelid worms, crustaceans, insects, snakes, frogs, toads, turtles, small mammals like rats, mice, shrews, etc. These species form the base of the animal food chain and are important prey species for other animals. Many plants will not be able to relocate because their seeds are not airborne or easily move. Plants form the base of the entire food chain which means there will be less of them for wildlife to eat. Levees, floodwalls, and seawalls are not friendly places for wildlife to recolonize and are poor quality wildlife habitat. These places are open with few areas of shelter and have a monoculture of non-native grasses with little wildlife benefit. You call such areas “wildlife deserts”.

This means predators, like hawks, owls, other birds, coyotes, bobcats, and other predators, will attack and kill many wildlife species more easily thus causing higher mortality. Even meso-predators, like raccoons, opossums, and skunks, will have a difficult time crossing levees without being attacked by larger predators. Regular mowing will make levees depauperate of vegetative structure and places for wildlife to live.

Storm surge waves and other waves will erode beaches and dunes in front of levees and destroy natural wildlife habitat. The sediment that is used to re-nourish these areas may or may not be the appropriate grain size and will be compacted so it will not have the pore space and permeability that natural sand systems have on the Texas Coast. The Corps ignores the impacts that wildlife face with re-nourishment. Some of the effected wildlife includes shorebirds, sea turtles, ghost crabs, and other coastal wildlife. To say that “No long-term impacts to wildlife resources are anticipated form the construction of the Coastal Barrier” is false and not based upon current science, wildlife biology, and ecology. Please see Attachment 5.

The Corps should use silt curtains or other mitigation measures to reduce turbidity and other impacts from construction and dredging. The Corps does not talk about wildlife species found on coastal prairies and how they will be affected by huge, fragmenting, levees. Levees will be placed near roads (Page 5-44, “Most of the levee barrier would be placed adjacent to roadways and developed

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areas”) which will increase roadkill, fragmentation, isolation, and other negative impacts that roads have on wildlife.

137) Pages 5-47 through 5-49, 5.4.4 Protected Resources, Coastal Barrier CSRM System, South Padre Island CSRM Measure, ER Measures, Bay Rim CSRM System, the Corps ignores many protected lands like those owned by Artist Boat, Galveston Bay Foundation, and other private and public lands. The Corps states that “indirectly benefit from the coastal levee protection measures by gaining risk reduction from storm surges and RSLR”; “would provide resiliency against coastal storms and RSLR”; “mitigating RSLR impacts to coastal infrastructure and ecosystems from storm events”; and “provide resiliency against coastal storms and RSLR.” These are false statements. Ike Dike does nothing to stop sea level rise which will continue to increase and affect Texas Parks and Wildlife Department (TPWD), U.S. Fish and Wildlife Service (FWS), and other protected lands. Ike Dike will degrade and reduce geological and ecological processes on protected lands like the movement of barrier islands, washover sediment transfer to backbay marshes, scouring of beaches and dunes, etc. Ike Dike impacts and does not help these landforms, habitats, and ecosystem processes. Please see Attachment 7.

138) Pages 5-50 through 5-56, 5.4.4.2 Threatened and Endangered Species, Coastal Barrier CSRM System, South Padre Island CSRM Measure, ER Measures, Bay Rim CSRM System, the Corps refers to species not affected by Ike Dike as “lack suitable habitat within the project areas. They are found … or freshwater riverine habitat”. Some of the species, like whales, are found offshore and are not freshwater dependent.

Increased artificial lighting can cause disorientation in shorebirds and migratory birds. The Corps mentions shielding lights to protect sea turtles. However, the Corps does not commit to shielding lights. Will the Corps shield lights or not? Tell the public. What does “shield a small amount of light from the bay side” mean?

The Corps states that “Once completed the levee barrier feature would provide storm protection and shoreline stabilization for piping plover critical habitat.” This is not true. Ike Dike will cause scouring of beaches and dunes in front of the levee and eliminate natural Piping Plover habitat.

The Corps should explain what “turtle deflecting devices” are and how they will be used in construction on South Padre Island. The Corps does not commit to using the right grain size for sea turtle nesting because it says “beach-quality sand would likely be used for the nourishment”. In Quintana in 2017/2018 the contractor put the wrong sand grain size on the beach. Turtle Island Restoration Network complained and documented this problem, but little was done to stop the contractor, remove the wrong sediment, and place the right sediment on the beach so sea turtles could nest. The Corps must say that beach-quality sand will

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be used to ensure that endangered and threatened sea turtles can lay eggs on Bolivar Peninsula and Galveston Island. All nourishment and re-nourishment must be done with the right grain size. No exceptions! Please see Attachment 2.

The Corps must explain what it means when it says that “movement of construction vehicles and barges with riprap or revetment material along the GIWW could potentially increase the risk of a collision with an animal.” What animal is the Corps talking about?

The Corps talks about accretion of sediments “behind the breakwater structure” but says nothing about the loss of sediment that natural was deposited in the locations where currents used to go before the breakwater or revetment was installed. The Corps must identify these locations and conduct modeling and analyses which document if these areas will erode and if so, how much over 50 years. This is a negative environmental impact for these shoreline locations that the Corps must reveal and quantify.

The Corps states that “providing coastal shoreline protection from erosive wave action from barge traffic or rising sea levels”; “restored marsh and wetlands would provide improve habitat for plants and wildlife and a coastal buffer from RSLR and storms”; and “Restored dunes and beaches … by protecting coastal habitat and providing a barrier to erosive wave action and RSLR”. The impacts due to rising sea level will continue and cause retreating shorelines. Nothing the Corps can do will stop RSLR and its impacts over 50, 100, 200, or more years. Please see Attachment 7.

The Corps should tell the public why “migrating sea turtles … traverse upstream to the San Jacinto River”. The San Jacinto River is not prime sea turtle habitat and the likelihood of Bay Rim Alternative gates impeding or harming sea turtles is low.

139) Pages 5-56 through 5-58, 5.4.4.3 Migratory Birds, Coastal Barrier CSRM System, South Padre Island CSRM Measure, ER Measures, Bay Rim CSRM System, the Corps does not state that backbay marshes will erode because the geological process of sediment transfer via washover areas and storm surge waves will be stopped. The Corps talks about maintaining historical coastal dune habitat characteristics for plovers and sandpipers but fails to state that Ike Dike will cause scouring of beaches and dunes which destroys their habitats.

The Corps states that there are no long-term impacts to migratory birds from revetments and breakwaters but does not say that these hard structures will cause erosion at other locations that may be migratory bird habitat. The Corps does not state how many of these locations there are, how much they will erode,

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and which of these locations are important for migratory birds. The Corps does not reveal all environmental impacts that Ike Dike causes to migratory birds.

The Corps states that “Sand dunes are also natural barriers for wave and wind action” but does not say that Ike Dike will cause erosion of these sand dunes. Due to its height, Ike Dike will interfere with aeolian sediment transfer and wave sediment transfer via washover areas so that backbay marshes and tidal flats will not have sediment to create habitat for migratory birds. The Corps has not committed to using the appropriate grain size of sand so that migratory birds and sea turtles have beaches they can use. The Corps must make this mitigation commitment. Please see Attachment 2.

140) Pages 5-58 through 5-60, 5.4.4.4 Essential Fish Habitat, Coastal Barrier CSRM System, South Padre Island CSRM Measure, ER Measures, Bay Rim CSRM System, the Corps must tell the public how long it will take after construction for benthic organisms to recover. It is not clear why the Corps states that “No long-term impacts to oyster reefs in the Galveston Bay system are expected” since Ike Dike can either increase or decrease salinities depending on rainfall that comes with storms. Oysters can either have too many predators in higher salinity water or water that is too fresh and they will not grow well. The Corps should commit to using silt curtains to reduce the increased water column turbidity it says will take place when Ike Dike is constructed. This is particularly important since construction will take 10 or more years to complete.

141) Pages 5-69 through 6-63, 5.4.4.5 Marine Mammals, Coastal Barrier CSRM System, South Padre Island CSRM Measure, ER Measures, Bay Rim CSRM System, the Corps does not commit, but should, to mitigation measures like bubble curtains, double-walled piles, hydro sound dampers, noise mitigation screens, cofferdams, soft-start operational procedures, and dolphin exclusion zones to reduce impacts on marine mammals.

The Corps ignores the growth in vessel traffic that it has projected for the Houston Ship Channel in this DEIS. The Corps attempts to increase vessel traffic by building into the Ike Dike DEIS a 60-foot sill which allows for expansion of the Houston Ship Channel. Navigation improvement is not a purpose that Section 4091, Water Resources Development Act (WRDA) of 2007, allows for under (b) Scope) “protection, conservation, and restoration of wetlands, barrier islands, shorelines, and related lands and features that protect critical resources, habitat, and infrastructure from the impacts of coastal storms, hurricanes, erosion, and subsidence”. Navigation improvements do not protect Galveston Bay, Galveston Island, and Bolivar Peninsula. The same is true of the GIWW where the Corps wants to deepen the GIWW from 12 feet to 16 feet. This is a navigation improvement project that is not covered by Section 4091.

The Corps is trying to shoehorn through two navigation improvement projects under the cover of the Coastal Texas Protection and Restoration

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Feasibility Study and DEIS. This is not legal or supported by Section 4091, WRDA of 2007. This will increase the risk of ship and marine mammal collisions. The Corps should state what the risk is of vessel collisions and increased noise due to more industrial and recreational vessels. The Corps should state what it means when it talks about “extended construction time”. The Corps should state how this will affect marine mammals and how the Corps will mitigate this additional noise.

The Corps makes the assertion that Ike Dike may reduce the risk of dolphins “being stranded out of habitat during a storm”. The Corps must provide documentation that supports this assertion. The reverse could be true, that Ike Dike prevents dolphins from leaving Galveston Bay and increases their risk of being exposed to poor quality habitat.

142) Pages 5-63 through 5-65, Table 5-9, Potential Impacts and Mitigation Summary for the Coastal Barrier and Bay Rim Alternatives, the Corps summary is deficient. The Sierra Club has pointed this out in this comment letter about Chapter 5 of this DEIS. The mitigation measures that the Corps will use are vague or the Corps does not commit to their use. The impacts and mitigation information must be provided now so the public can review and comment on its adequacy. The Corps is aware that the DEIS public comment period is the only time that the public can comment and have its comments responded to by the Corps in the final EIS.

The Corps should pull together all the impacts, mitigation, and other information that it says it has not prepared and then release a supplemental DEIS with at least a 90-day public comment period. The public will have to pay for Ike Dike, if it is approved, so the public has a right to see all the information (analysis, assessments, lists, etc.) that the Corps has not included in this DEIS and have enough time to read, review, and comment on it.

143) Pages 5-66 and 5-67, 5.5 Cultural Resources, Coastal Barrier CSRM System, South Padre Island CSRM Measure, ER Measures, Bay Rim CSRM System and Page 6-4, 6.1.1 Ecosystem Restoration Measures, the Corps does not provide the public with an analysis of how many staging and borrow areas there will be, their locations, their size, their impacts, and how the Corps was able to determine volume of adequate grain-sized material at each location. The Corps, without revealing the exact locations of cultural resources, should show the public their general area location. The Corps says that levee material will be dredged from offshore but does not say where and how many of these sites there are. The Corps does not discuss how the levee can result in deflection or ricochet of water onto the Fort Travis Historic Site. The Corps should tell the public about the environmental impacts of this water deflection and what mitigation measures will be used to protect Fort Travis. Please see Attachment 2.

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144) Pages 5-67 through 5-69, Socioeconomics, Coastal Barrier and Bay Rim Alternatives, the Corps says Ike Dike “would reduce risks”. The Corps should tell the public how much Ike Dike will reduce risks and what these risks are. The Corps says that Ike Dike will “enhance the sustainability of the communities”. The Corps does not state how this will be done and what communities it is talking about.

Since there will be a larger population and more development growth the Corps should tell the public how this will be more sustainable in a hazardous and dangerous area where development is not required to be done sustainably. The Corps should tell the public what happens if “local building codes” do not protect the public sustainably or are not implemented. The Corps should not assume that “local building codes” will be approved and implemented.

For instance, in 2007, the City of Galveston rejected required use of a geohazards map which would have reduced risk to people. Currently, the City of Galveston and other communities underestimate the flood damage in 100-year floodplains so that people can rebuild more cheaply with old floodplain standards instead of new ones. The Corps should not assume that the right thing will be done. Please see Attachment 1.

The Corps should begin calling storm surge in Galveston Bay, storm surge, and not “wind-driven bay surges”. Storm surge is made up of wind-driven waves that are caused by hurricane winds that occur on the coast. Hurricanes create storm surge in Galveston Bay, with or without Ike Dike.

The Corps is not correct when it says, “It is not expected that the CSRM measures directly impact public facilities or services”. The Ike Dike will destroy part of Galveston Island State Park, Anahuac National Wildlife Refuge, City of Galveston and Galveston County beaches and dunes. These are and have public facilities which provide public services which will be affected by Ike Dike.

Both Ike Dike and Bay Rim Alternatives will induce flooding via deflection of storm surge and ebbtide flow. Both alternatives leave critical roadways at risk because Ike Dike (Coastal Barrier) does not stop flooding behind the levee on the bayside along most of Galveston Island and all of Bolivar Peninsula. The Coastal Barrier will “increase vehicular congestion along roads, highways, and streets during construction”. This is not an impact that is unique only to the Bay Rim Alternative but will also occur with Ike Dike.

145) Pages 5-69 through 5-71, 5.7 Navigation and 5.7.2 Recreational, Coastal Barrier CSRM System, South Padre Island CSRM Measure, ER Measures, Bay Rim CSRM System, the Corps should conduct ship simulations of the bypass channel alignment and present these in this DEIS so the public can review and comment on this information. The Corps states that “Risks to

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navigation safety are expected to increase”. The Corps should tell the public how much the risk will increase.

The flow of sediment into the Port Mansfield Channel is an impact on navigation, whether due to recreation or otherwise. The Corps should tell the public the cost of the “increase in maintenance dredging requirements of the GIWW”. The GIWW interferes with the proper functioning of Bolivar Peninsula, which attempts to move toward the mainland to stay above sea level rise. The Corps should restore the overwash areas sediment transfer geomorphic process so that Bolivar Peninsula can move. This may require the removal or relocation of the GIWW.

146) Pages 5-71 and 5-72, 5.8 Flood Risk Reduction, the Corps should tell the public how much Ike Dike will reduce “coastal storm risk in the area”.

147) Pages 5-72 through 5-87, 5.9 Environmental Consequences Summary, Table 5-11, Alternatives Comparison Table – Potential Impacts to Evaluation Criteria, the Corps does not assess all the environmental impacts and fails to provide all data needed to assess them. See the Sierra Club’s comments of Chapters 4 and 5 for this DEIS.

148) Pages 5-72 and 5-87 through 5-95, 5.10 Cumulative Impacts, 5.10.1 Past or Present Actions, the cumulative impacts analysis the Corps has provided is inadequate. First, there is no cumulative impacts analysis for any alternative except the Ike Dike (TSP). If there is to be a comparison between alternatives a cumulative impacts analysis must show how each alternative interacts with its environmental impacts, direct, indirect, connected, and cumulative, both in the past, present, and future. This has not been done.

The Corps states that the cumulative impacts analysis period is from 1918 to 2018. Page 5-87 the Corps states, “This cumulative impacts analysis was scoped with a temporal boundary of approximately 100 years in the past (1918), from the beginning of the study, and approximately 50 years into the future (2085), from construction completion.”

The Corps never conducts the cumulative impacts analysis it is supposed to do. Instead the Corps lists projects, not all projects, that affect the Upper, Mid, and Lower Coasts and Galveston Bay, Galveston Island, and Bolivar Peninsula. The actual environmental impacts and how they add to those impacts 50 years in the future are not tabulated or presented in any understandable way. The Corps does not list the projects, impacts, and mitigation for all Section 10/404 permit applications that were approved, all after-the-fact permits, all illegal dredge/fill actions, etc. from the Section 404 permit program, which has existed since the Clean Water Act was approved in 1972. The Section 10, 1899 Rivers and Harbors Act permit program has existed since 1899 and for the purposes of this DEIS cumulative impacts analysis, has existed since 1918.

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The Corps could have conducted a cumulative impacts analysis by choosing some surrogate factors and then it could have shown geographically or scientifically how the Galveston Bay Area and Texas Coast has been affected. For instance, the Corps could have taken aerial photos that go back as far as the 1930s and shown the type of land use over time and how it changed. The Corps could have done the same for impervious surface. The Corps could have used the Texas Commission on Environmental Quality and U.S. Environmental Protection Agency’s databases on water quality permits and discharges and shown how these have increased and what the pollutant loads are today. The Corps could have looked at water quality sampling data historically and discussed changes. The Corps, via the Galveston Bay Estuary Program, U.S. Fish and Wildlife Service, National Marine Fisheries Service, Texas Parks and Wildlife Department, Texas General Land Office, Railroad Commission, and other sources, could have tabulated seagrass, salt marsh, oyster, and other habitat losses, number of oil/gas wells drilled, changes in habitat status, and areas that have been protected and presented these in a cumulative impacts analysis.

The Corps could have tabulated all navigation channels (including the GIWW, its original dimensions, and its enlarged status today), jetties, groins, bulkheads, piers, revetments, breakwaters, etc. that have been constructed on the coast and reported their impacts. The Corps could tabulate all dams, ditches, and flood channels that have been built or widened or deepened and reported the environmental impacts of these. The Corps could have included all roads and calculated fragmentation impacts. The Corps could have included the projects that have been predicted but not constructed and tabulated those for its cumulative analysis and then stated what this means for the Galveston Bay Area and Texas Coast.

The Corps could take present predictions, projections, forecasts, and estimates of future population growth and development to 2085 and beyond and used today’s best information to calculate the water use, sewage, impervious surface, air pollution, roads, etc. that may be generated or constructed if no change occurs from how we do things today. The Corps could even put in factors that account for past energy and environmental improvements for the future based on what we have done in the past and present. Please see Attachment 1.

The Corps could have summed what the erosion and accretion has been on Texas Coasts for the past 100 years and what is projected to occur 50 years in the future. The Corps could have taken air pollution records and calculated what is released today, in the past, and using certain assumptions what will occur 50 years in the future. The CEQ regulations under Section 1502.16, call “Environmental consequences” (which include cumulative impacts) “the scientific and analytic basis for the comparisons under Section 1502.14” (Alternatives including the proposed action).

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Instead, the Corps did none of this. A simple list of projects with a few statements about what the project is does not provide analytic information and a comparison or baseline of impacts. The basis for comparison of alternatives is how does the Galveston Bay Area’s and Texas Coast’s ecosystems now fare, how did past, present, and will future foreseeable actions add to or detract from its health. The Corps must state how an 18-foot-high, with 600 feet or greater width, 55 mile or longer levee, with floodwalls, that attaches to an enlarged existing seawall, with a ring levee around the east part of the City of Galveston, with huge gates, and gates at four other locations, affect Galveston Bay and add to its current environmental impacts. The Corps is silent about this and its cumulative impacts analysis is deficient for the Galveston Bay Area and for the Texas Coast.

149) Pages 5-95 through 5-108, 5.10.2 Reasonably Foreseeable Actions and 5.10.3 Cumulative Impacts from TSP Implementation, and 5.10.3.2 Synergy with the TSP and Potential Cumulative Impacts, there now is a GLO 2019 Texas Coastal Resiliency Master Plan. The Corps should review this 2019 plan and make appropriate changes to this section of the DEIS. There may be ER projects that are similar or the same as the GLO 2019 plan. The Corps fails to list and discuss the environmental impacts of City of Houston, Harris County Flood Control District ($2.5 billion in flood projects passed in August 2018), and other entities as reasonably foreseeable actions. These actions, along with Ike Dike, have the potential to degrade Galveston Bay and are cumulative impacts.

The same can be said for private projects. Large developers, oil/gas, and other industries have projects they foresee will be built in the future. Some of this can be learned from business publications and some form the companies themselves. The Corps apparently did none of this. The Texas Department of Transportation, counties, cities, and Metro entities all have plans for future roads and transportation projects that can be determined.

The Houston-Galveston Area Council has a plethora of data and information sources that can assist the Corps with these future foreseeable actions. The Corps has ignored listing and discussing all the refinery and petrochemical expansions that have occurred in the past five years. Billions of dollars have been spent on additions to these facilities. The same is true for pipelines. Pipelines are increasing as more oil/gas from fracked shale areas are sent to refineries and petrochemical plants or to LNG facilities for export. LNG export facilities have increased greatly in the past few years and there are many projects that are on the Federal Energy Regulatory Commission (FERC) calendar that the Corps can document and reveal their cumulative impacts (three in the Valley alone).

The Corps ignores future population growth, which the Texas Water Development Board, Houston-Galveston Area Council, and Region H Water

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Planning Group all have information about. The Corps should state what population growth and residential, commercial, institutional, and industrial development forecasts are for Galveston Island, Bolivar Peninsula, West Galveston Bay, Houston Ship Channel Area, City of Baytown, City of Pasadena, City of Deer Park, City of Galena Park, Jacinto City, Channelview Area, City of Houston, western and northern Chambers County, etc. The Corps should state how many people and structures are in each of these areas and what are the 50-year predictions of future population and development growth. Please see Attachment 1.

The Corps refers on Page 5-112, to the GLO Coastal Resiliency Master Plan “is intended to be synergistic and contribute beneficial cumulative effects to Texas coastal resources”. First, what are those beneficial cumulative effects? Second, the GLO plan does not have a mechanism to resolve project conflicts. The GLO told its Technical Advisory Committee, which the Sierra Club participates with, that it will plug into the GLO Master Plan what the Corps decides in the DEIS. There will be no analysis to make sure the DEIS is complimentary and does not conflict with other GLO projects or programs. This DEIS is assumed by the GLO to be part of its Master Plan.

The Corps states that for the “Sabine Pass to Galveston Bay Coastal Storm Risk Management and Ecosystem Restoration” project that “This project recommends several levees, which support risk reduction along a broader extent of the Texas coast, and they complement the TSP’s objectives. Direct compatibility of risk reduction efforts with the TSP would expand resiliency of the Texas coast”.

The Corps has not revealed to the public whether it has modeled the interactions and interface of the Sabine Pass projects with Galveston Bay projects. This is important since there is an area between the two projects that is vulnerable to deflection of water from both projects that may cause storm surge and flooding impacts. This may affect erosion and accretion in an area that is between the two projects. The Corps has not provided any analysis that shows what will happen in this area. The Corps statement that projects will “expand resiliency of the Texas coast” certainly does not apply to stopping the effects of climate change, more intense rainfalls, more intense storms, and sea level rise and their environmental impacts. Please see Attachment 8.

Page 5-112, the Corps refers to flood control projects in the Houston Area. Corps projects and Harris County Flood Control District (HCFCD) flood projects have not worked because people continue to flood in areas where these projects have been built. The policy of keeping the 100-year flood between the banks of streams and rivers has not worked. If the Corps is going to say that “The hydrologic changes from flood risk management features could be greater than salinity changes from the TSP features” it must document that this is true. Since “could” is a word that means it “could be” or it “could not be” the Corps should give a probability of “could” coming true or not coming true. After all, “could” also

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means it “could fail”. What are the consequences of failure and the probability of the risk of failure? The Corps does not tell the public about its “certainty” about “could” and what would occur if failure happens. Please see Attachment 1.

Page 5-122, the Corps cannot make the statement that “cumulative impacts that may result from the TSP are likely to be positive or beneficial” because it has provided no data to document this statement, has provided an incomplete summary and analysis of the direct, indirect, cumulative, and connected impacts of Ike Dike, and has not provided a suitable or complete analysis of cumulative impacts for past, present, and future foreseeable actions and activities.

150) Page 5-122, 5.11 Any Adverse Environmental Impacts That Cannot Be Avoided Should the TSP Be Implemented, the impacts to benthic and plankton organisms will be permanent. The Corps cannot say impacts are minor because it has provided no data that supports this statement. The Corps has not analyzed all impacts or even named them. Please see previous Sierra Club comments which bear out this statement. The Corps has not demonstrated that any mitigation it proposes, much has not been proposed, for environmental impacts will be adequate over the short-term, 50 years, and over the long-term of 100 to 200 years.

151) Pages 5-122 and 5-123, 5.12 Any Irreversible or Irretrievable Commitments of Resources Involved in the Implementation of the TSP, the loss and fragmentation of habitat will be permanent. The loss of nutrient, organic matter, and sediment via circulation constriction is permanent, the loss of protected land is permanent, the increased damage due to deflection of water behind the levee and in front of the levee for beaches, dunes, prairies, and marshes is permanent, the loss of movement of barrier island/peninsula is permanent, the loss of sediment for backbay marshes is permanent. Many of the environmental impacts that Ike Dike causes will be permanent, but the Corps does not list these impacts in this section of the DEIS.

152) Page 4-123, 5.13 Relationship Between Local Short-Term Uses of Man’s Environment and the Maintenance and Enhancement of Long-Term Productivity, the Corps does not document that ecosystem restoration and mitigation will account for all losses and environmental impacts that occur due to Ike Dike. There will be long-term impacts, losses of wetlands, and productivity because of continued deflection of water by Ike Dike, loss of washover sediments for backbay marshes, etc. These will be permanent losses and not “short-term” as the Corps states. Corps actions will lead, not to temporary losses of productivity, but to permanent losses because wetlands and other habitats will be destroyed. The Corps cannot protect Gulf shorelines because sea level rise continues to occur, will not stop, and will create erosion and accretion different from what the Corps intends.

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The Corps does not calculate “long-term benefits” but takes credit for them. The Corps severs and fragments geologic, ecologic, and biologic processes on a barrier island/peninsula complex which leads to poor quality habitat and health of these moving geologic landforms. The movement of barrier island/peninsula will be stopped. These landforms will not be able to move toward the mainland to stay above sea level rise. Backbay marshes will starve to death for sediment and die submerged by sea level rise because Ike Dike keeps sediment movement by storm waves from occurring. The Corps says that “short-term uses will be impacted … those impacts are expected to last months to a few years”. This is not true. Since construction will take 10 years or longer this is not short-term for ecosystems. The delay and changes in ecosystem conditions in 10 years or longer could result in permanent changes.

The Corps states that “The reduced height and inland extent of storm surge will decrease long-term”. This statement is misleading. Storm surge will still occur within Galveston Bay and it will be significant. The changes that occur when storm surge is reduced 50% have not been enumerated and the environmental impacts by interrupting a geomorphic and ecosystem process like this have not been studied and revealed by the Corps in the DEIS.

The Corps attempts to protect Nature from Nature but does not protect Nature from Ike Dike and other human actions and activities that have affected Galveston Bay, Galveston Island, and Bolivar Peninsula and will continue to do so after Ike Dike (and in some cases Ike Dike will accelerate these impacts) is constructed. The ecosystems of Galveston Bay, Galveston Island, and Bolivar Peninsula are adapted to hurricane impacts and do not need protection from them. What Galveston Bay, Galveston Island, and Bolivar Peninsula need to be protected from are human actions and activities and their impacts which the Corps ignores and allows to continue (building in hazardous and dangerous places where sea level rise and other climate change impacts like more intense rainfalls and storms will occur).

Page 5-124, the Corps states “Some of these impacts will be offset by implementation of the TSP’s ER measures and required mitigation”. The deficits need to be listed and mitigation applied to them or the Corps must state that certain impacts, which it lists, are not mitigatable.

The Corps has not adhered to Section 1502.24, Methodology and scientific accuracy, of CEQ NEPA regulations which requires that it “shall identify any methodologies used and shall make explicit reference by footnote to the scientific and other sources relied upon for conclusions in the statement.”

The Corps has also not adhered to Section 1502.22 Incomplete or unavailable information, which requires it to either acquire the reasonably foreseeable significant adverse impacts information or if it cannot prepare a statement that the information is complete or unavailable, tell the relevance of the incomplete or

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unavailable information, summarize existing credible scientific evidence, and evaluate the impacts based upon methods generally accepted in the scientific community.

The Corps states that “The Coastal Barrier Alternative is expected to reduce the long-term and wide ecological footprint associated with response to and reconstruction following major storms striking the area in the future”. This is an untrue statement. The ecological footprint of storms is made worse by human actions and activities like Ike Dike and other human actions and activities the Corps will not change and will probably encourage when developers use Ike Dike as a selling tool for more development on Galveston Bay, Galveston Island, and Bolivar Peninsula. The response to reconstruction following major storms is an ecological footprint that humans cause, not storms. People build in places that are hazardous and dangerous instead of keeping out of harm’s way. The Corps advocates “control of Nature” instead of working with Nature. Nature plays a long game and bats last. The Corps will not win against Nature in the long-term.

The Corps states that Ike Dike will “reduce the risk of serious disruptions in the Nation’s energy and petrochemical supplies”. This is not true. The risk will remain, and the Corps has not stated what the probability is. The Corps ignores that levees eventually fail, the Corps does not have money, and neither do the sponsors, to ensure that operation and maintenance will address all needs long-term. Please see Attachment 5.

153) Page 6-1, 6.0 Tentatively Selected Plan, the Corps states that Ike Dike (TSP) addresses the “protection, conservation, and restoration of … barrier islands”. Ike Dike does not protect, conserve, or restore Galveston Island and Bolivar Peninsula. Ike Dike dismantles their geomorphic and ecologic processes by tying down these geological landforms and cutting off their movement and re-nourishment via storm waves and wind. 155) Pages 6-4 through 6-6, 6.1.1 Ecosystem Restoration Measures, the Corps refers to “an out-year nourishment or continuing construction component”. What this means is a “forever” re-nourishment component for its operation and maintenance functions. This function will last in perpetuity. The cost and difficulty of such a plan is not discussed. The Corps does not discuss whether it will have enough of the right grain-sized sand to conduct all nourishment, re-nourishment, and out-year re-nourishment for 50 years to perpetuity and whether it will have the money to do this. The Corps should tell the public where the money will come from and the reliability of its funding sources. Please see Attachment 2.

Page 6-5, the Corps talks about placing in Matagorda Bay and Keller Bay sediment “directly behind the breakwaters”. Since breakwaters collect sediment (accretion) at the site of the breakwater and cause erosion elsewhere, this statement indicates that sediment collected may not be enough to prevent

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erosion. Long-term over 100 to 200 years, the Corps should state how it will effectively and reliably be able to provide sediment to prevent erosion that occurs during sea level rise and for other reasons and the cost of this. Please see Attachment 7.

Page 6-6, the Corps provides no explanation why seagrasses will grow behind 7,392 linear feet of oyster reef and what happens if this does not occur. The Corps provides no analysis that documents that seagrasses will grow behind these reefs and does not require that if this does not occur that additional mitigation occur.

Page 6-6, the Corps provides no documentation that dredging 6.9 miles of the Port Mansfield Channel will make available the right grain-size material to deposit on Padre Island. The Corps should provide the analysis that documents this can in fact be done and will be successful.

156) Pages 6-6 through 6-10, 6.1.2 Coastal Barrier CSRM System, the Corps states that “It includes a complementary system of nonstructural measures that consists mainly of a barrier system across Bolivar Peninsula, a closure at the pass at Bolivar Roads, improvements to the Galveston seawall, and a barrier along the west end of Galveston Island.” None of these measures are “nonstructural”. These measures are “structural” (54 miles of levee, 20 miles of floodwall, 93 highway gates, 4 railroad gates, 80 drainage closure structures, and 5 pump stations). The Corps should state explicitly what the “nonstructural” measures are, where they will be located, how they will work, what they will cost, how they will be implemented, how many structures will have them, etc. The Corps has not done its job and leaves the public in the dark!

On Page 6-7, the Corps reports that it will dredge the GIWW to 125-feet wide and 16 feet deep. The original depth was 12 feet deep. The Corps should state what the actual width and depth is now and whether this is greater than the authorized depth and width. If it is, how will the Corps restore the GIWW to its original dimensions. This deepening of the GIWW is a separate project that should not be in this DEIS. It is a navigation project, not a storm surge project and not an ER project. The Corps is attempting to shoehorn a project into this DEIS that does not meet the criteria of the project. This is illegal.

The Corps should state whether SH 124/FM 3005 will be behind the levee for its entire length or if part of this road is in front of the levee. The Corps must state what will happen to people and structures that are in front of the levee on Bolivar Peninsula and Galveston Island and structures that are subject to storm surge on Galveston Bay side.

Page 6-7, the Corps should address whether the construction of a levee and gate at Bolivar Roads will allow the construction of a bridge from Galveston Island to Bolivar Peninsula. How will the Bolivar Ferry be affected by the levee

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and gate at Bolivar Roads? Dredging the sill of the gate to 60 feet ensures that the Houston Ship Channel will be deepened and widened. The environmental impacts of the widening and deepening of the Houston Ship Channel should be part of any discussion of how Ike Dike will affect the environment.

Page 6-8, “Gulf and bay surges” are the same. They are both storm surge. The Corps should state whether the ring levee around the east part of the City of Galveston includes Pelican Island. The Corps should state how much money does “4 feet of additional risk reduction” cost and how affordable this is for local, industrial, state, and federal sponsors. The Corps should discuss how much industry should pay, both oil/gas and real estate development, for Ike Dike or any other alternative since these businesses directly benefit and they are responsible for many risks to people from spills and place people in harm’s way. Please see Attachment 4.

Page 6-8, the Corps should state how much “overtopping protection” Ike Dike provides. The Corps should provide an analysis of the ricochet or deflection impacts that waves have on the Clear Creek Channel, Dickinson Bayou, and High Island GIWW gates and areas due to storm surge in the Bay.

Page 6-8, the Corps should state how much elevation will be needed for structures at different locations. The Corps should state what nonstructural measures other than elevation, will be used. The Corps refers to “elevation” as a nonstructural measure but is vague about this because it does not say what is needed, where, and how much it will cost.

Page 6-9, the Corps should state what its definition of “extent practicable” is for hydrologic connectivity at the Galveston Harbor Entrance Channel crossing, in the Galveston Ring Levee/Floodwall Reach, and in closures at Clear Creek Channel and Dickson Bayou via water control structures to minimize changes in tidal flows and tidal amplitude.

Page 6-9, the Corps says that “The risk reduction system is only authorized to address storm surge caused by hurricane and tropical storm events. It is not authorized to mitigate for or reduce impacts caused by higher day-to-day water levels brought about by increases in RSLR.” The Corps must state how it will address the deterioration of Ike Dike protection over the years as these other factors have affects and what that is likely to cost. It is not clear how the Corps can address sea level rise, increased rainfall intensity, increased storm intensity, and other effects of climate change via closure frequency, when closures are not constant and they directly interfere with Houston Ship Channel operation and economic activities.

Page 6-9, the Corps talks about “project features such as pump stations would not be impacted by developments in the areas behind the risk reduction system”. The Corps should explain what this means. The Corps is not a land use

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agency and will have no authority to control increased population and development growth behind Ike Dike.

The DEIS requires mitigation measures for the damage that climate change will have on the Texas Coast. The DEIS should have a climate change Resilient Habitats Plan (RHP). The RHP would be based on:

1. Protection of existing functioning ecosystems in the Study area.

2. Reduction of stressors on the ecosystems in the Study area.

3. Restoration of natural functioning ecological processes in the Study area.

4. Use of natural recovery in the Study area.

5. Acquisition of buffers, corridors, and core reserves to expand and ensure connectivity of ecosystems in the Study area.

6. Intervention to manipulate (manage) ecosystems in the Study area.

7. Reduction of climate change gases in the Study area.

The DEIS must acknowledge sea level rise and look at scenarios that are best and worst-case. At the very least a 100-year timeframe should be used in the DEIS. Probably a 500-year timeframe is better due to temperature, rainfall, drought, and sea level rise changes that will occur. Recent research has shown that sea level rise is increasing at a faster rate than predicted 10 years ago.

Climate change means, for the Houston-Galveston Area, greater numbers of large precipitation events and potentially more and or more intense storms/hurricanes. Please see Attachment 7.

The proposed Ike Dike will be built to a certain specification, if sea level rises and other climate change impacts occur over a 100-year timeframe, the Ike Dike’s effectiveness will degrade and diminish. The DEIS has failed to explore this concern and state plainly how much degradation of Ike Dike effectiveness will occur. The public and decision-makers do not know what the efficacy is of potential alternatives as they age over their 100-year lifetime. The public and decision-makers do not know what they get for their money in 100 years.

With costs of $30 or even more billions of dollars it is important that the public and decision-makers be informed without fear-based presentations. The public and decision-makers must have all information about adequacy of operation and promised ability to withstand environmental impacts when hurricanes hit the coast every 20 years or so (5 hurricanes in 100 years) in addition to storms that are not hurricanes but are significant due to their shoreline impacts.

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157) Pages 6-10 and 6-11, 6.2 Hazardous, Toxic, and Radioactive Waste and Appendix C-7, Hazardous, Toxic, and Radioactive Waste Assessment, the Corps states “If a recognized environmental condition is identified”. The Corps should state what a “recognized environmental condition” is so the public knows. The Corps should state what it means when it says, “that the probability of encountering or disturbing HTRW would continue to be low”. The Corps should state what probability is low and what probability is acceptable.

The story of why there is a risk with HTRW is not told by the Corps in the DEIS. The remarkable thing about the HTRW assessment is how it fails to discuss how oil/gas companies have put people and Galveston Bay at risk from oil and chemical spills because they have poorly designed (not tied down or made of stronger material), located (in the most vulnerable places due to low topography), and managed (lack of levees, levees in poor condition, stored dangerous chemicals in most vulnerable sites) their storage tanks and units in their oil/gas facilities so they are subject to damage or destruction by hurricanes and storm surge.

These facilities are vulnerable because the companies have not protected their assets as required of public companies so their stockholders’ investments (fiduciary trust) are safe from known risk that is an act of humans and not an act of God (could be avoided or minimized). The Corps does not choose to tell the story about how many of these companies have levees, how many can withstand a Category 3, 4, and 5 hurricane storm surge, and their current condition and ability to weather such phenomena.

158) Page 6-11 and 6-12, 6.3 Monitoring and Adaptive Management, the Corps refers to “restoration success”. If projects are implemented for mitigation and restoration, they must have monitoring and adaptive management in perpetuity. The Corps should tell the public what process it will use if it finds that restoration and mitigation projects are not successful or if over time they degrade. The Corps should state who will monitor, who will conduct oversight of monitoring, what criteria will be used for success, and what happens when oversight finds problems. Page 6-12, the Corps should add “revetments” as ER measures that must have monitoring and adaptive management plans. Monitoring should occur in perpetuity, so the public’s ER measures and money invested in them are protected and it is documented that they continue to function correctly.

159) Page 6-13, 6.4 Real Estate Requirements Associated With the Tentatively Selected Plan, a “perpetual flood protection levee easement” requires perpetual monitoring and operation and maintenance expenses for levees, floodwalls, seawall, gates, (structural measures) etc. The Corps should state where the money will come from and what the history is of getting all money needed to provide these functions in a timely and complete way. The Corps

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should document where the location of “temporary work area easements” will be for staging areas, how many there will be, how large they will be, environmental impacts they will cause, and the mitigation measures that will be required for these easements, etc.

160) Page 6-14, 6.6 Operation, Maintenance, Repair, Rehabilitation, and Replacement (OMRR&R) Associated With the Tentatively Selected Plan, the Corps should not limit OMRR&R to adaptive management and monitoring activities for ER measures. It is quite likely that erosion, accretion, rising sea level, more intense rainfalls, more intense storms, human actions and activities, and failure of ER measure construction will require that ER measures and mitigation projects have, at some point, major OMRR&R which should be estimated and included by the Corps in this DEIS.

161) Page 6-19 and 6-20, 6.7.2 Net Benefits and Benefit-Cost Ratios, Tables 6-3, 6-4, and 6-5, the Corps fails to compare costs of alternatives as required by NEPA. The Corps should tell the public, for similar projects, what the DEIS costs were, final EIS costs were, and actual final costs of the project were. The public will then know the range of estimated and actual costs that occur in large, complicated, and expensive projects. The public will know what to expect and can comment on whether the costs are appropriate or too high.

162) Page 6-20 and 6-21, 6.8 Risk and Uncertainty Analysis Associated With the Tentatively Selected Plan, 6.8.1 Residual Damages and Residual Risks, the Corps should provide the public with a list of all uncertainties and why they cannot be determined now in the DEIS. Section 1502.22 Incomplete or unavailable information, in CEQ regulations requires this. Currently, what the Corps lists on Pages 6-20 to 6-24, is not a list of all uncertainties for this proposal. This is because all environmental impacts have not been revealed and thus not all ER measures and mitigation projects have been proposed for Ike Dike. This leaves the cost and ability to mitigate for environmental impacts uncertain.

The Corps here should state clearly what the design storm is and what level of protection it provides for what storm surge wave height. The Corps should state what category of hurricane the proposal will provide protection for and how much protection this is. The Corps should state what storm surge wave height in Galveston Bay (residual storm surge) will still occur. The Corps should state, in plain English, what “storm exceeding the system’s 1 percent probability storm level of risk reduction” means.

163) Page 6-24, 6.9 Views of the Non-Federal Sponsor, the Corps states that it has “worked with an interagency team and local stakeholders to develop a feasible comprehensive plan … for the entire area.” This is an untrue statement. The Corps did not work with the Sierra Club to prepare a proposal it would

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support even though the Sierra Club provided the Corps with alternatives in early and late 2017. Please see Attachment 9.

164) Page 7-1, 7.1 National Environmental Policy Act, the Corps states that “This DIFR-EIS has been prepared in accordance with the NEPA process.” The DEIS does not meet NEPA CEQ regulations. As mentioned before, the failure to have “all reasonable alternatives” available for public review and for comparison means the Corps does not meet Section 1502.14. The Corps also does not meet Section 1502.16 because it does not discuss all environmental consequences. These Sierra Club comments contain information which document some of the parts of the CEQ regulations that this DEIS does not meet and provides information that the Corps can use to make changes to meet NEPA requirements.

165) Page 7.2, 7.2 Clean Water Act, the Corps refers to Ike Dike and says “if the features are constructed by the NFS are in or affect the course, condition, location, or capacity of navigable waters or the discharge of dredge or fill material into waters of the U.S., the NFS would require a USACE Regulatory Permit to comply with the requirements set forth in the Rivers and Harbors Act of 1899 and the CWA.” Since the gates at Bolivar Roads, Dickinson Bayou, Clear Lake, and GIWW near High Island and any GIWW breakwaters/revetments on Bolivar Peninsula are in navigable waters the GLO and Corps should obtain a Section 10/404 permit.

166) Pages 7-2 and 7-3, 7.3 Clean Air Act of 1970, the Corps refers to Ike Dike and states “It is anticipated that air contaminant emissions from operation of the surge barrier gates would result in relatively minor increase”. The Corps ignores the major increase in air pollution that construction of the gates with a 60-foot deep sill will have since this will enable the construction of a wider and deeper Houston Ship Channel which means more and larger ships that generate more air pollution will use the Ship Channel and expansion of industrial development. The induced population and development growth that this proposal will have on Galveston Island, Bolivar Peninsula, West Galveston Bay, Baytown, Texas City, Clear Lake/NASA, and Houston Ship Channel areas will generate a great deal of indirect air pollution environmental impacts. The Corps must prepare an analysis which documents these increases and any mitigation measures that will be used to reduce these negative environmental impacts.

167) Pages 7-5 and 7-6, 7.8 Marine Mammal Protection Act of 1972 and 7.9 Magnuson-Stevens Fishery Conservation and Management Act, the Corps must provide to the public now, in this DEIS or a supplemental DEIS, with a scientific plan to address marine mammal population impacts and the National Marine Fisheries Service consultation about Ike Dike. The public must be able to understand the impacts and review and comment on the mitigation for those impacts.

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168) Pages 7-7 and 7-8, 7.12 Coastal Barrier Resources Act, Coastal Barrier Improvement Act of 1990, and Appendix C-2 Clean Water Act 404(b)(1) Evluation, the Corps states that it does not have to comply with the Coastal Barrier Resources Act and Coastal Barrier Improvement Act of 1990 because the GLO will construct and pay for the part of the levee/floodwall that is on Bolivar Peninsula. This is a false legal concept that is unlawful.

First, the Corps must apply for a Section 10/404 permit under the Rivers and Harbors Act of 1899 and Clean Water Act which includes the so-called GLO portion of the proposal. This is because the Corps has not provided “information on the effects of such discharge in an EIS pursuant to NEPA.” The Corps has not totally revealed all environmental impacts due to dredge and fill in this DEIS. The Corps cannot provide mitigation for dredge/fill impacts because it does not know the final dimensions of the proposal. The loss of backbay marshes due to the interference of geomorphic processes like washover and wind carried sediments are not reflected in this DEIS. The Corps fails to acknowledge that a barrier island is a mosaic of habitats that all fit together and function as one via geomorphic processes and for the one geological landform. If one part of the barrier island is damaged this will lead to damage to other parts including wetlands under Section 404(b)(1). Loss of sediment via washover channels and aeolian processes being blocked by Ike Dike will affect the ability of backbay wetlands to survive and stay above sea level rise with the rest of the barrier island as it attempts to move toward the mainland. The indirect impacts of dredge/fill activities behind the levee due to increased population growth and development are not presented. This lack of a legal and complete NEPA DEIS makes the Corps responsible for Ike Dike and its impacts on the Coastal Barrier Resources System.

Second, the Corps has prepared and paid for the public participation, planning, and DEIS preparation including the GLO supposed part of the Ike Dike. Third, the Corps has GIWW responsibilities via ER projects that are a part of Ike Dike which it manages. Fourth, under NEPA, the Corps must evaluate Ike Dike as a “single course of action” “in a single impact statement” (Section 1502.4 Major Federal Actions requiring the preparation of environmental impact statements, CEQ NEPA regulations) and not piece-meal the project. There is one project and not two projects. The GLO portion of the Ike Dike cannot work or function, or be effective, or be efficient, without there being a Corps Ike Dike and therefore its impacts are dependent on the Corps and its interaction and compliance with the Coastal Barrier Resources Act

The Corps has not shown how the GLO will pay for its 35% share. Where the money will come from, when it will come, and whether the GLO can pay its share is not known at this time and makes any suggestion that the Coastal Barrier Resources Act does not apply mute.

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The Corps cannot separate out the ER features of Ike Dike, then separate out certain Ike Dike portions, and then say that only these Ike Dike portions are exempt from the Coastal Barrier Resources Act. There is one project and one project only. Not two separate projects, one Federal and one State. Ike Dike measures are all part of one project and not two projects and ER measures are part of one project with all Ike Dike portions of the project and make one proposal and alternative. This indelibly links the Corps to the entire proposal and not just part of it, because only one proposal exists, not two.

The Corps will have to coordinate, link-up with, and seal the Ike Dike on Bolivar Peninsula with the GLO funded and constructed part (12.4 miles of levees/floodwalls). This makes the GLO project impossible without the Corps assistance, money, and cooperation. The Corps and GLO work on one project, not two, and the Corps cannot escape this fact and its responsibility for the entire proposal and compliance with the Coastal Barrier Resource Act.

Finally, the Corps with this Ike Dike alternative has not and does not minimize loss of human life, discourage development in high-risk areas, reduce wasteful expenditures of Federal resources, and preserve the ecological integrity of areas of the Coastal Barrier Resources System, which are the very purposes of the Coastal Barrier Resources Act and Coastal Barrier Improvement Act. The Corps is subject to the Coastal Barrier Resources Act and Coastal Barrier Improvement Act.

Page 7.7, Ike Dike features of the proposal do not “form a comprehensive barrier for the upper Texas coast.”. The Upper Texas Coast extends from Sabine Pass to approximately Matagorda County. Ike Dike does not extend along the entire Upper Texas Coast and does not protect the entire Upper Texas Coast

169) Pages 7-9 through 7.11, 7.14 Executive Orders Concerning Floodplain Management, the Corps states that “the project is designed to reduce damages to existing infrastructure located landward of the proposed project.” This may occur, but what also will occur is damage to developments behind Ike Dike due to ebbtide and slosh effects and the loss of development in front of Ike Dike due to its exposure to storm surge waves, deflected waves, and scouring from these waves. Please see Attachment 2.

Page 7-10, the Corps states that “local building codes would require large amounts of fill material for new developments”. This fill will displace water on the floodplain. The entire levee/floodwall system, greater than 55 miles long, will displace water in the floodplain and make it more difficult to drain areas because it interferes with water movement.

Page 7-11, the Corps says “The project would not induce development in the floodplain” but provides no data to document this statement. The Corps statement contradicts what happens when levees are placed in floodplains.

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People feel safe behind the levees because they are told by local governments and developers that they are safe. Developers build and tell people they are safe but fail to tell people that ebbtide and other slosh effects can flood them behind Ike Dike on West Galveston Island and Bolivar Peninsula. Please see Attachment 1.

170) Page 8-1, 8.1 Division of Plan Responsibilities and Cost-Sharing Requirements, the Corps fails to tell the public how this “massive in scale” proposal will protect construction sites and reduce environmental impacts while construction occurs over 10 or more years. The Corps fails to provide mitigation measures for the phased construction operation process. The implementation plan is a mitigation measure and the public must be able to review and comment on its completeness and appropriateness.

171) Appendix C-6, Coastal Zone Management Act Coordination – Consistency Determination (CD), Appendix C-4 Essential Fish Habitat Assessment (EFHA), and Appendix C-2 Clean Water Act 404(b)(1) Evaluation, the Sierra Club opposes the CD, EFHA, and 404(b)(1). How can the GLO and Corps agree to a CD and EFHS, via the consultant Freese and Nichols, when they do not know what the environmental impacts of the Ike Dike will be? The GLO and Corps have admitted in public that the barrier alignment for Ike Dike is not chosen and is only conceptual. GLO and the Corps have an inherent conflict of interest in approval of the CD, EFHA, and 404(b)(1) when they are applicants and sponsors of the largest, most costly, and potentially most environmentally devastating project for Galveston Bay, Island, and Bolivar Peninsula.

In a Houston Chronicle article, by Nick Powell, December 15, 2018, “Bolivar residents worry about ‘Ike Dike’ impact”, the Corps (and therefore the GLO) admits in the article “Kelly Burks-Copes, the Army Corps’ project manager for the coastal barrier study, also insisted in a separate interview that the records showing mapping shapefiles with a red line showing the barrier alignment were conceptual. The alignment could change based on feedback during the public comment period, and could even be considered as green infrastructure through a series of dunes rather than an actual barrier or levee … What was not clear, I guess, when we (responded to the open-records request) was that that line was first of all, conceptual, and second of all, was just a line,” Burkes-Copes said. Levees are bigger, they’re actually wider. You have to have right entry easements and that kind of thing. It would be a wall, and then it would be smaller.”

The Corps and the GLO apparently does not know that the Ike Dike will not protect people form sea level rise. In a Houston Chronicle article “Barrier project derided at forum”, by Nick Powell, December 16, 2018, it states “Azure Bevington, an ecologist who lives on High Island, called the proposed alignment of the barrier along Texas 87 unconscionable, and a beach placement of a

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barrier unacceptable because it would exacerbate sea level rise and accelerate beach erosion… Col. Zetterstrom expressed to a number of people at the meetings in Winnie that this will protect us from sea level rise. That is extremely false, Bevington said, We will lose our beach if we build it there. There is not enough sand to cover a wall – it is no such thing as an engineered dune. There are dunes and there are walls covered in sand. That is it”.

With the confusion about what is factually correct about science and the Ike Dike it boggles the mind that GLO and Corps prepared a CD, ESHA, and 404(b)(1) about this proposal without doing the required research. Instead, the GLO and the Corps relied upon a consulting firm that writes documents that agree with its client’s desires. It is frightening that the CD, ESHA, and 404(b)(1) do not make the connection that barrier islands and their habitats (wetlands, beaches, dunes, tidal flats, coastal prairies, etc.) are all tied together. This is basic science.

This CD does not justify or document that Ike Dike is “a comprehensive plant to protect, restore, and maintain a robust coastal ecosystem” (Page 1-1) and that it does not meet the requirements of Section 4091 Water Resources Development Act, Coastal Texas Ecosystem Protection and Restoration, Texas, Scope, because it does not “provide for the protection, conservation, and restoration of wetlands, barrier islands, shorelines, and related lands and features that protect critical resources, habitat, and infrastructure from the impacts of coastal storms, hurricanes, erosion, an subsidence.”

The GLO and Corps Ike Dike does the exact opposite which is not presented in the CD, EFHA, and 404(b)(1). The Ike Dike results in the loss of backbay marshes due to interference with geomorphic processes like washover channels and wind carried sediments and thus degrades Galveston Island and Bolivar Peninsula. Ike Dike interferes with these landforms and their movement toward the mainland and to stay above sea level rise. Ike Dike causes the loss of beaches, dunes, and other habitats in front of it, via wave energy scouring of these areas. Ike Dike also results in indirect impacts of dredge/fill activities behind the levee due to increased population growth and development. These impacts are not presented in the CD, EFHA, and 404(b)(1). Therefore the “protection, conservation, and restoration” that is required by law does not occur with Ike Dike. Ike Dike also destroys protected lands and alters their ability, their remaining portions, to function ecologically, biologically, and geomorphically after it has been constructed.

The GLO and Corps, in the CD, has not performed “estuarine modeling on other measures (Page 2-1), “… no modeling was performed on the other measures”; does not define what “Relative minor amounts of vertical salinity stratification” are (Page 2-1), alters “hydrosalinity gradients, tidal amplitude, and tidal prism” (Page 2-1), does not acknowledge there are unmapped oyster reefs (Page 2-2) that can be destroyed or degraded by the Ike Dike, does not protect and actively impacts

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Fort Travis as a historic area (Page 2-3), and causes further erosion and future land loss (Page 2-3).

The GLO and Corps state repeatedly that the Ike Dike will reduce “coastal storm risks” (Page 2-4). This is not true. Ike Dike does nothing to reduce coastal storm risks. What Ike Dike does do is potentially reduce coastal storm damage. The risk of coastal storms remains the same because Ike Dike does not stop coastal storms from happening and does not reduce the number of coastal storms that hit the Mid and Upper Texas Coast.

The GLO and Corps CD further errs when it says that it “considered numerous alternative CSRM and ER alternatives” (Page 2-5). This is untrue since the Corps looked at two alternatives other than the No Action Alternative. The Corps refused to look at and analyze the Sierra Club’s “Double E Alternative” and Bayou City Waterkeeper and other environmental group’s “Sage Alternative”. The Corps has done almost nothing in its analysis, assessment, and evaluation of “non-structural” alternatives, including a very large buyout program and strategic withdrawal.

The GLO and Corps can hardly say the “The CSRM measures are intended to reduce coastal storm risk, which is a benefit to human health and welfare” since Ike Dike will attract more people to live behind it which will set-up more damage, loss of life, and injuries when the levee fails, when ebb-tide occurs, and during residual storm surge (storm surge within Galveston Bay) occurs.

172) Pages 10-1 and 10-2, 10.0 Recommendations (Current TSP) and 10.1 Tentatively Selected Plan, the Corps has provided the public and decision-makers with an incomplete and unfished DEIS. The Corps admits that it must optimize the Ike Dike (TSP), refine relocation and real estate requirements, conduct additional hydraulic modeling, determine the scale of the level of risk reduction for the Ike Dike (levee heights, flood heights, pump station sizes, nonstructural features, and alignments), determine the cost, and detailed implementation guidance for non-Federal interests.

There are other analyses, information, environmental impacts, data, and studies mentioned by the Corps that must be presented to the public now so that it can review and comment effectively and with the required level of knowledge about their accuracy in a complete DEIS. This lack of information ensures that all environmental impacts are not revealed and discussed and are available for public review and comment in the DEIS.

The Corps has not adhered to Section 1502.22 Incomplete or unavailable information, which requires it to either acquire the reasonably foreseeable significant adverse impacts information or if it cannot prepare a statement that the information is complete or unavailable, tell the relevance of the incomplete or unavailable information, summarize existing credible scientific evidence, and

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evaluate the impacts based upon methods generally accepted in the scientific community.

The Corps should revise the DEIS and put it back out for public comment as a supplemental DEIS when the documents listed below, that have not been prepared, are completed. The public cannot comment in a vacuum and these documents must be worded so they are easy for the public to understand and comprehend. Failure to do this ensures that the public does not have the economic, environmental, social, financial, and other information, data, and analysis that is needed in a format that it can understand so that it can compare alternatives and determine if the risks, environmental impacts, and economic costs are worth what is proposed.

The public must have this information to determine whether the proposal should be supported or opposed. Some of the analyses, information, environmental impacts, data, and studies mentioned by the Corps that are needed now in the DEIS include:

1. Detailed implementation plan, Page xxiii.

2. Scale of the level of risk reduction for the TSP, Page xxv.

3. How the GLO will pay for the State of Texas’ share of the proposal, Page 1-17.

4. Studies and modeling to determine specific marsh restoration or preservation measures, Page 2-8.

5. Essential Fish Habitat consultation documents, Page 2-34.

6. Further development under future planning and design phases, Page 4-1

7. Nonstructural measures, Page 4-28.

8. More detailed qualitative and quantitative comparisons of individual plan components, Page 4-29.

9. Future relative sea level rise impacts on alternatives via risk reduction greater than a 100-year exceedance event, Page 4-31.

10. More conservative plan with higher impacts (worst-case scenario), Page 4-37.

11. Adaptive Management Plan, Page 4-37.

12. Individual features such as levee heights, flood heights, pump stations sizes, and nonstructural features, Page 4-60.

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13. Different scales of plans and level or risk reduction, Page 4-60.

14. Optimize the design and alignment of levee/floodwall systems and engineered dune systems that may replace levees/floodwalls, Page 4-73.

15. Additional structure inventory investigations, Page 4-74.

16. The size and impacts of “any surges induced into the area by the levee system”, Page 4-74.

17. The induced stages and damages outside the levee system in Alternatives D1 and A, Page 4-74.

18. Storm surge modeling to estimate water levels and waves for the proposed levee alignment to optimize the level or risk reduction, Page 4-82.

19. Modeling of water deflections from levees in Alternatives A and D2, Page 4-82.

20. Multiple vehicle and railroad access gate locations, Page 4-84.

21. A systemwide model that looks at all environmental impacts, Page 4-89.

22. Additional investigations in densely populated communities of Baytown and Santa Fe to determine if the levee system induces stages, Page 4-91.

23. Reevaluation of relative sea level rise for additional extensions of levees or flood walls, Page 4-94.

24. Scale of the level of risk reduction for individual features such as optimization of levee heights, flood heights, pump station sizes, and nonstructural features, Page 103.

25. Interior drainage analysis for pump station requirements and locations for Offatts Bayou and Harborside Drive, Page 4-104.

26. For the Bay Rim Alternative, additional structure inventory investigations on 10,000 structures between SH 146, Page 4-104.

27. Individual features such as levee heights, flood heights, and pump station sizes would be optimized, Page 4-105.

28. Buffalo Bayou pumping discharge area requires further detailed hydrology and a joint-probability analysis, Page 4-106.

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29. For the Bay Rim Alternative, additional watershed analysis would be performed to refine the pump station and drainage requirements, Page 4-106.

30. For Alternative A, individual features, such as levee heights, flood heights, pump station sizes, and nonstructural features would be optimized, Page 4-108.

31. Gate design to reduce potential impacts, improve performance, and confirm cost effectiveness, Page 5-1.

32. Footprints for march restoration and out-year marsh nourishments, Page 5-1.

33. A detailed inventory and analyses of borrow source materials, Page 5-4.

34. Environmental impacts of a 60-foot sill for Houston Ship Channel widening and deepening, Page 5-4.

35. Conduct modeling with a permanent and not tentative gate configuration across Bolivar Roads, Page 5-5.

36. Determine and discuss what a 6.6 feet per second velocity difference means for the gate at Bolivar Roads, Page 5-5.

37. Provide the data about influx of sediments into Galveston Bay and how much settles into adjacent marshes after storm surge and how this would affect overwash and other storm-related sediment deposition, sediment budgets, and health of adjacent natural features like marsh and wetland complexes, Page 5-6.

38. Provide data and discussion about how much and where erosion at San Luis Pass is expected to increase due to increase flow velocities from the Ike Dike, Page 5-6.

39. Provide data and discussion about how much localized scouring would increase near inlets during non-storm conditions, Page 5-6.

40. Provide data and discussion about how much the Ike Dike reduces sloshing and storm0induced bay-shoreline erosion, Page 5-6.

41. Provide data and discussion about how much beaches and marshes will be affected by storm surge piling up at Ike Dike, Page 5-6.

42. Provide data and discussion about the transport of re-nourished sediment to the Port Mansfield Channel and South Jetty and what the shoaling rates are, Page 5-7.

43. Provide data and discussion on how much erosion will occur due to the construction of breakwaters or revetments, how much habitat would be replaced

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with hardened structures, and how much habitat would be reduced or restored by breakwaters or revetments due to erosion, Page 5-7.

44. Provide data and discussion about increase in Gulf-side erosion rates and shoreline retreat rates due to Ike Dike, shoreline erosion rates at the Galveston Seawall, reduced exchange of flow and sediments through tidal channels, reduced sediment from Galveston Bay to the longshore current, Page 5-9.

45. Provide refinements for project to minimize differences between with and without project velocities, Page 5-11.

46. Provide data and discussion about salinity impacts due to surge barrier gates at Clear Creek, Dickinson Bayou, and Offatts Bayou, Page 5-14.

47. The level that Ike Dike is “expected to affect water and sediment quality throughout the Galveston Bay system, Page 5-20.

48. Analyses that shows how the direction and rate of rainfall runoff will affect Galveston Bay or Gulf water levels where the Ike Dike meets the land and where and how much surge gates at Offatts Bayou, Dickinson Bayou, Clear Lake, and the GIWW near High Island increase localize flooding upstream and downstream of these barriers, Page 5-23.

49. Provide how oil and gas activity and hazardous, toxic and radioactive waste impacts caused by Ike Dike will be avoided, minimized, and reduce to the best extent practicable, Pages 5-26 and 5-27.

50. Estimates of air contaminant emissions rates for alternatives including non-road construction equipment, dredging, and other equipment Pages 5-27 through 5-29.

51. Lists of dredging energy efficient equipment, repowered/refitted cleaner diesel engines, newer dredges with more efficient engines, dredges with air pollution control equipment, compressed natural gas or liquified petroleum gas vehicles, refitted/repowered cleaner more fuel efficient-diesel engines for vehicles, newer vehicles with more fuel-efficient engines, and non-road ultra-low sulfur diesel fuel, Pages 5-30 and 5-31.

52. The design and positioning of the Ike Dike and surge gates at Dickinson Bayou, Clear Lake, Offatts Bayou, and GIWW at High Island, Page 5-38.

53. The predicted tidal amplitude reduction and how much marsh would be flooded, Page 5-41.

54. Oyster information that will be used for mitigation, Page 5-41.

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55. Modeling of the Bay Rim Alternative for the effects on salinity and velocity, Page 5-43.

56. Oyster assessment for Offatts Bayou and other areas and the impacts that the TSP will have on oysters, Page 5-44.

57. Analyses for San Jacinto Battleground and Battleship Texas State Historic Site and other protected lands about how much inundation and what the drainage issues are that will occur when the gates are close during storm surge events, Page 5-49.

58. Modeling of the Bay Rim Alternative for salinity and velocity changes, Page 5-59.

59. Construction and operational measures to minimize impacts for the physical barrier and other actions, Page 5-64.

60. The location, number, and size of offshore dredge material placement areas, Pages 5-66 and 5-67.

61. Cultural resource investigations of historic properties within proposed areas of direct and indirect impacts, Page 5-67.

62. The Programmatic Agreement for cultural resources investigations, Page 5-67.

63. Additional considerations related to community cohesion and environmental justice concerns along the west side of Galveston Bay, Page 5-68.

64. Ship simulations of bypass channel alignment, Page 5-69.

65. Model and provide a hydrodynamic analysis of the Bay Rim Alternative, Page 5-70.

66. Refine the TSP optimizing the design for level of risk reduction, design details, construction sequence details, and proposed construction methods, Page 6-1.

67. An Adaptive Management Plan for re-nourishment, Page 6-4.

68. A study of the restoration plan to determine which areas can qualify as part of the ER plan based upon individual cost and benefits for separable features in the TSP, Page 6-6.

69. Optimization of design and alignment to minimize impacts to existing structures and the environment on the peninsula and island, Page 6-6.

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70. An interior drainage analysis of pump station requirements and locations, Page 6-8.

71. Additional structure inventory investigations to determine structure risks and their need for nonstructural measures, Page 6-8.

72. Closure criteria for gates in the Ike Dike alternative, Page 6-9.

73. A Monitoring and Adaptive Management Plan (MAMP) for the ER plan, uncertainties investigations, cost breakdowns for the MAMPs, decision criteria or adaptive management triggers, and performance standards for ER measures, Pages 6-11 and 6-12.

74. Location of mitigation lands, Page 6-13.

75. Nonstructural features, Page 6-13.

76. Residual storm surge damages in Galveston Bay and how to prevent these, Page 6-13.

77. Relocations due to the TSP and determinations of compensation for utility/common carriers and others, Pages 6-13 and 6-14.

78. ER and mitigation project operation, maintenance, repair, rehabilitation, and replacement for the TSP, Page 6-14.

79. Operation and maintenance of gates, Page 6-14.

80. Final design heights of levees, Page 6-14.

81. Cost of the loss of risk reduction due to RSLR, Page 6-14.

82. Refined changes to optimize the design including level of risk of reduction, design details, construction sequence details, and proposed construction methods, Page 6-14.

83. Refined project costs, Page 6-15.

84. Investigation into borrow sites for detailed quantities or suitability, Page 6-15.

85. Closure system design, Page 6-19.

86. Barrier most effective design, Page 6-19.

87. Beach and dune barrier (versus floodwalls) designs, locations, and costs, Page 6-19.

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88. Additional ADCIRC modeling to determine the level of induced flooding, Pages 6-21 and 6-22.

89. Analysis about whether the levee will be shifted toward the beach, Page 6-22.

90. More detailed evaluation of the combined impacts of storm surge and precipitation to determine pumping station capacity, Page 6-23.

91. Scientific plan to address impacts on marine mammal population via evaluation of data gaps, pre-project data collection, mitigation options, and construction and long-term operational adaptive monitoring plans, Page 7-6.

92. Consultation with the NMFS and its input on the proposal, Page 7-6.

93. Implementation plan for efficiencies in dredging, sponsor readiness, most productive gate or measure W-3, air quality impacts, prioritized implementation, costs, priority goals and objectives, mobilization cost savings, complement to existing features, and preliminary phasing of constructed elements, Page 8-1

94. Optimization of the TSP, refinement of relocation and real estate requirements, additional hydraulic modeling, and scale of the level of risk reduction for the TSP (levee heights, flood heights, pump station sizes, nonstructural features, and alignments, Pages 10-1 and 10-2

Information is needed now to determine if the alternative is viable and what its environmental impacts are. This DEIS should have a supplement DEIS which is put out for public review and comment of at least 90 days.

173) Pages 2-48 and 49, 2.6 Socioeconomic Considerations, Page 7-12, 7.17 Executive Order 12898, Environmental Justice, the Corps presents environmental justice as an issue in three paragraphs at these two places in the DEIS. One of the paragraphs explains what environmental justice is. The Corps then dismisses this issue with no further comments in the DEIS. This is not acceptable for the poor, working poor, working class, lower middle class, and minority residents of the Texas Coast who deal with environmental justice issues every day.

The Corps refers to its analysis in Appendix C-1, Environmental Supporting Documentation, Pages 2-129 through 2-148, 2.6 Socioeconomic Considerations, Pages 3-19 through 3-22, 3.5 Socioeconomic Conditions, and Pages 5-121 through 5-123, Socioeconomics. Only on two pages, 2-147 and 2-148, 2.6.6 Environmental Justice, in two paragraphs, is environmental justice specifically dealt with. The Corps, on these pages, appears more interested in what happens to “waterfront communities” on the west side of Galveston Bay (like Kemah and Tilman Fertitta’s “Boardwalk”, Page 2-133) and

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the social vulnerability index for communities of “La Porte, Santa Fe, and La Marque” than actual fence-line and environmental justice communities located along the entire Texas Coast.

The Corps ignores environmental justice communities in several ways. First, the Corps uses scales, the entire Texas Coast, different geographical parts of the Texas Coast, entire counties, and entire cities or areas, that are so large that they dilute where environmental justice communities are and the very real issues that exist in each of these communities.

The Corps fails to provide a list of environmental justice communities along the Texas Coast. These communities can be determined by use of socioeconomic information and data at the zip code, sub-zip code, census tract or block, and sub-census tract or block levels. The Corps does not conduct this analysis. The Corps could have contacted environmental justice communities, residents, advocates, and organizations that work on environmental justice issues and requested their input about a list of environmental justice communities. The Corps apparently did not do this basic outreach, research, and analysis.

The Corps delays any decisions about how environmental justice will be addressed or considered when it says “Environmental justice concerns at this time are limited to the upper coast related to the structural recommendations, however, as discussed in the DIFR-EIS, the future evaluations of nonstructural measures to address wind-driven surges in the bay should be carefully planned … There are also community cohesion and environmental justice concerns in minority populations and low-income populations in some of the communities along the west side of Galveston Bay that will have to be taken into consideration when investigating the details of nonstructural recommendations.”

The Corps ignores the requirement in NEPA and CEQ regulations to provide a rigorous analysis and comparison between alternatives for environmental justice. Five paragraphs on environmental justice in 2,457 pages is not acceptable and shows that the Corps has not seriously considered and analyzed this issue. The Corps provides some statistical information about socioeconomic measures but does not integrate this into a discussion and analysis of specific environmental justice communities and issues.

Pages 5-121 through 5-123, the Corps says that there are environmental justice impacts due to the Bay Rim Alternative but not the Coastal Barrier Alternative. This is false. The “induced flooding” issue is one that affects both alternatives, and not just the Bay Rim Alternative. The Corps ignores this and does not give a fair, rigorous, comparison of the two alternatives and thus biases any environmental impact analysis, environmental justice analysis, and fails to discuss potential impacts that would occur on specific environmental justice communities. This lack of analysis misleads the public about the problems the

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environmental justice issue presents. The Corps dismisses this issue without adequate NEPA analysis. This is not appropriate and hides any possible discussion and implementation of mitigation measures. The Corps must conduct an adequate NEPA analysis on environmental justice.

Each environmental justice community is different. Each environmental justice community should be looked in a site-specific manner when determining what mitigation measures are appropriate. Environmental justice is not something that is done to a community. It is something that a community is, claims, and makes decisions about. Mitigation measures for environmental justice communities and residents should include:

1. Buyouts to remove environmental justice communities and residents from harm.

2. Payment of moving costs.

3. Strategies to keep environmental justice communities together when they must move.

4. Assistance in finding and moving into better, low-cost, replacement, housing.

5. Follow-up monitoring on people who move to ensure they get restarted.

6. Provide jobs for environmental justice community residents via ecosystem restoration work.

7. Elevation of buildings in environmental justice communities where the risk of danger is lower.

8. Use of “FORTIFIED Home” residential and commercial structures that have been created by the Insurance Institute for Business and Home Safety or similar hurricane resistant homes like those made by Deltec Homes.

Attachment 10: Hurricane Resistant Structures

This attachment has information about how houses and commercial structures on the Texas Coast can be constructed so they are more hurricane resistant.

1. “Which Home Would You Rather Live In?, FORTIFIED Home”, FORTIFIEDHOME.ORG.

2. “What is FORTIFIED Home?”, FORTIFIED Home, IBHS Headquarters, 4775 East Fowler Avenue, Tampa, Florida 33617, 813-286-3400.

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3. “Hurricane Resistance”, Deltec Homes, https://www.deltechomes.com, 2018.

9. Use strategic withdrawal when possible to get frontline communities out of the floodplains/ways and storm surge zones.

10. Create green buffers between environmental justice communities and moving shorelines.

11. Involve environmental justice communities in decision-making and give them ample time to determine what it best for them. A variety of ways and times to provide input must be built into all decision-making processes.

12. Environmental justice communities should be involved in designing a program and process for deciding which mitigation measures are chosen and the criteria used to make these decisions. A variety of ways and times to provide input must be built into all decision-making processes.

13. Require that a process about climate change be implemented which has environmental justice community and resident participation, education, and input procedures.

14. Make available to environmental justice communities and residents web access, reports, and maps about the Texas Coast, storm surge, and flooding issues.

15. Provide transportation assistance to environmental justice communities and residents.

16. Provide health care and education assistance to environmental justice communities and residents.

17. Prepare and implement an “adaptive management plan” for mitigation measures in environmental justice communities and for residents.

174) The DEIS must ensure that all environmental impacts are covered including direct, indirect, connected, cumulative, and systemic. Some of the environmental impacts that have not been adequately analyzed, assessed, and evaluated include:

1. The loss of the beach in front of Ike Dike. This occurs as storm/hurricane waves slam up against the “dike” and soil is eroded and taken down the coast. A perfect example of how this occurs is found at the Galveston Seawall which has no beach unless it is re-nourished. The cost of perpetual beach re-nourishment was not estimated and was ignored in the DEIS.

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2. The loss of beach will require perpetual beach sand re-nourishment. This will cause environmental impacts wherever the replacement sand is dredged, will cost a lot of money and energy forever by sending ships out to dredge sand, bring sand back, deposit sand on the shoreline, use heavy equipment to move sand around, and causes compaction of sand which interferes with animal and plant use and regeneration of the beach zone. This environmental impact was not adequately analyzed.

3. The loss of dunes in front of Ike Dike. This occurs for the same reason as beach loss. This environmental impact was not adequately analyzed.

4. The loss of the dunes, if they are to be replaced and rebuilt, will require a similar large-scale mechanical removal, retrieval, deposition, and recreation process as occurs for sand on beaches. This will also be required in perpetuity. This environmental impact was not adequately analyzed.

5. The loss of native coastal prairie in front of Ike Dike. This occurs for the same reason as beach loss. This environmental impact was not adequately analyzed.

6. The loss of native coastal prairie, if it is to be replaced and rebuilt, will require a similar large-scale mechanical recreation process as for sand on beaches plus a significant replanting effort of native grasses and herbaceous vegetation (wildflowers). This environmental impact was not adequately analyzed.

7. Loss of freshwater wetlands in front of Ike Dike. This occurs for the same reason as beach loss. This environmental impact was not adequately analyzed.

8. The loss of freshwater wetlands, if these freshwater wetlands are to be replaced and rebuilt, will require a similar large-scale mechanical recreation process as for sand on beaches plus significant wetlands replanting efforts. This environmental impact was not adequately analyzed.

9. The loss of residences in front of Ike Dike. This occurs for the same reason as beach loss. This environmental impact was not adequately analyzed.

10. The loss or degradation of salt marshes on the backbay (Galveston Bay) part of Galveston Island, behind Ike Dike. This occurs due to the elimination of the wash-over (sand, sediments, soil) part of the sediment budget and movement process, which provides sediments from the beaches and other areas to the back bay. The loss of sediment will diminish ecosystems that are dependent on this sediment. This environmental impact was not adequately analyzed.

11. The loss of backbay salt marshes, if these wetlands are to be replaced and rebuilt (maintained in perpetuity), will require a similar large-scale, mechanical, recreation process as for the beaches plus a significant wetland creation and planting effort. This environmental impact was not adequately analyzed.

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12. The loss or reduction of wind generated sediments in front of Ike Dike. Ike Dike will interrupt and interfere with the sediment budget and movement process and diminish ecosystems that are dependent on this sediment. This environmental impact was not adequately analyzed.

13. The loss or reduction of animal/plant species due to fragmentation caused by Ike Dike. Animals will have difficulty crossing the “dike” to get to the northern side of Galveston Island. Some of these animals include small sized mammals (rabbits, rats, mice, shrews, etc.), medium sized mammals (raccoons, opossums, coyotes, etc.), snakes, turtles, frogs, toads, lizards, insects, and other invertebrates.

This fragmentation of habitat (600 or more feet wide) not only provides a formidable barrier (in addition to any existing development barriers) to movement but also exposes these animals to predation, desiccation, and can result in their inability to move from south to north of Ike Dike.

Plant propagation and dispersal of seeds and plant parts will be interrupted by Ike Dike. SH 87/FM 3005 could be located directly behind Ike Dike and this will provide an additional (cumulative) formidable fragmentation and isolation barrier for animals/plants to cross. This can result in genetic isolation and loss of habitat adaptability. This environmental impact was not adequately analyzed.

14. The loss of nesting beach for the federally endangered Kemp's Ridley Sea Turtles in front of Ike Dike. This occurs for the same reason as beach loss. This environmental impact was not adequately analyzed.

15. The loss of wintering/foraging habitat for Piping Plovers in front of Ike Dike. This occurs for the same reason as beach loss. This environmental impact was not adequately analyzed.

16. The degradation and interruption of the ecological processes and their functions that San Luis Pass provides as the most natural coastal pass left on the Upper Texas Coast (Appendix 15, “The Formation and Future of the Upper Texas Coast”, John B. Anderson, Texas A&M Press, 2007). According to Rice University scientist and coastal geologist Dr. John B. Anderson, in “The Formation and Future of the Upper Texas Coast, A Geologist Answers Questions about Sand, Storms and Living by the Sea”, “San Luis Pass is one of the few remaining natural tidal inlets on the Texas Coast.” (Page 12, Chapter 1) Dr. Anderson further states on Pages 131 through 134, Chapter 7, “The San Luis tidal delta is the largest natural tidal delta in Texas. It is what engineers refer to as an “unimproved” tidal inlet, a term that has never ceased to amuse me. The delta contains most of the sand that has been eroded from Galveston Island by natural processes. Most of this sand

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occurs in the flood tidal delta, but part of the tidal delta is a protected wetlands and bird sanctuary. Removal of just the sand from bars within the flood tidal delta would potentially alter the flow of water into and out of West Bay and could have adverse impact on the bay. It would certainly influence future wetlands development. The flood tidal delta should be considered off-limits for sand exploitation.”

“The sizable ebb tidal delta at San Luis Pass is considered by some a viable sand resource for beach nourishment. However, removal of sand from the ebb tidal delta could also alter the natural tidal circulation between the Gulf and West Bay. The impact could be quite significant. Furthermore, the sand within the ebb tidal delta will ultimately make its way west, where it is needed to maintain Follets Island.”

Currently, the Ike Dike does not have a tie-in to the mainland on its western end, West Galveston Island. A tie-in may be needed or excessive erosion of this end of Ike Dike could cause damage to the structure and the environments to its west and south. Currently, the Ike Dike, on its west end, is left hanging with nothing to hold onto.

If a tie-in is made at or near San Luis Pass, then the most natural pass left on the Upper Texas Coast will have its ecological functions interrupted and degraded. The circulation of water, the flow of water (amount), the flow of organic matter, sediments, and nutrients, salinity levels, the location and effects on oyster reefs/hash areas, shorebird or other bird feeding areas, seagrass beds in Christmas Bay, salt marshes on the back bay of Galveston Island (the elevation of Galveston Island varies from 5 feet to 20 feet with an average of about 5 to 10 feet), Drum Bay, Cold Pass, Mud Island, West Galveston Bay, and the mainland, will all be affected by the location and tie-in of the western end of Ike Dike.

There will be soil erosion and re-sedimentation when waves, storm surge, tides, and rising sea level, over time, create a ricochet off the west end of Ike Dike, with or without a tie-in to the mainland. This will result in significant changes in water circulation and habitat conditions in this area. This environmental impact was not adequately analyzed.

17. The loss or degradation of movement of Galveston Island, a barrier island and Bolivar Peninsula, a barrier peninsula, in an attempt to stabilize these dynamic and unstable geomorphic systems with the embedded Ike Dike. This environmental impact was not adequately analyzed.

18. The significant reduction/loss of vistas on the GOM (blocked or altered) by construction of Ike Dike. This means that existing recreational and inspirational activities will be significantly altered. This environmental impact was not adequately analyzed.

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19. The significant reduction/loss of existing recreational and inspirational activities at San Luis Pass, along the GOM shoreline of Galveston Island, and the backbay (Galveston Bay) of Galveston Island due to the construction of Ike Dike. This environmental impact was not adequately analyzed. Please see Attachments 1, 2, 5, and 6.

175) As a part of the Sierra Club’s May 2, 2016 scoping comments, it included 26 Appendices (Attachments). These Appendices provide important baseline information for these Sierra Club DEIS comments. The Sierra Club assumes, since its May 2, 2016 scoping comments and appendices are on the record, that it does not have to submit these 26 Appendices again. If this is not the case the Sierra Club requests that the Corps notify it and we will again submit these 26 Appendices. The Appendices the Sierra Club has submitted with its May 2, 2016 scoping comment letter are:

1. Appendix 1, August 27, 2015 Comments on the Coastal Texas Protection and Restoration Reconnaissance Study and for the Identification of Coastal Storm Risk Management and Ecosystem Restoration Problems and Opportunities in Coastal Texas.

2. Appendix 2, December 1, 2014 Comments on Gulf Coast Community Protection and Recovery District Storm Surge Suppression Study and Environmental Impact Statement.

3. Appendix 3, April 10, 2015 Comments on Gulf Coast Community Protection and Recovery District Storm Surge Suppression Study Phase I Report.

4. Appendix 4, March 31, 2016 Comments on Gulf Coast Community Protection and Recovery District Storm Surge Suppression Study Phase II Report.

5. Appendix 5, February 28, 2012 Comments on Identification of Storm Damage Reduction Ecosystem Restoration, and Flood Risk Management Opportunities in Orange, Jefferson, Chambers, Harris, Galveston, and Brazoria Counties Study, “Sabine Pass to Galveston Bay, Texas Study”.

6. Appendix 6, October 23, 2015 Comments on Draft Integrated Feasibility Report and Environmental Impact Statement for the Tentatively Selected Plan of the Sabine Pass to Galveston Bay Coastal Storm Risk Management and Ecosystem Restoration Project

7. Appendix 7, November 18, 2002 Comments on Notice of Studies and Initial Public Scoping Meetings for Sabine Pass to Galveston Bay, Texas Shoreline Erosion Project.

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8. Appendix 8, July 18, 2009 Lone Star Chapter of the Sierra Club “Resolution on Upper Texas Coast Protection”.

9. Appendix 9, September 16, 2015 Comments on Severe Storm Prediction, Education, and Evacuation for Disasters Center (SSPEED Center) 2015 Annual Report, Houston-Galveston Area Protection System (H-GAPS).

10. Appendix 10, “Experts say the IPCC underestimated future sea level rise”, John Abraham, The Guardian, December 4, 2013 and “Rising Waters: How Fast and How Far Will Sea Levels Rise?”, Nicola Jones, October 21, 2013, environment 360.

11. Appendix 11, “Future Climate Change,” U.S. Environmental Protection Agency, last updated February 23, 2016, http://www3.epa.gov/climatechange/sceience/future.html) and “Sea-level rise could nearly double over earlier estimates in next 100 years”, March 30, 2016, Science Daily.

12. Appendix 12, “Climate Disruption in Overdrive: Submerged Cities and Melting That “Feeds on Itself”, Dahr Jamail, Truthout Report, March 29, 2016.

13. Appendix 13, “Galveston Bay”, Wikipedia, January 7, 2016.

14. Appendix 14, “DOTD announces closure of I-10 at Sabine River”, Eddie Scott, Tri-County Sun Times, March 24, 2016; “Texas governor visits communities engulfed by floods”, David Warren, Associated Press, March 16, 2016; “Rising Rivers, Bayous Force Texas Evacuations”, Insurance Journal, 2016.

15. Appendix 15, “The Formation and Future of the Upper Texas Coast”, John B. Anderson, Texas A&M Press, 2007.

16. Appendix 16, “Atlas of Sustainable Strategies for Galveston Island”, Christopher Hight, John Anderson, Michael Robinson, Davin Wallace, and the students of the Rice School of Architecture, Rice University, 2009.

17. Appendix 17, “The Impact of Global Warming on Texas”, Second Edition, Editors Jurgen Schmandt, Gerald R. North, and Judith Clarkson, 2011.

18. Appendix 18, “Geohazards Map of Galveston Island, Texas”, James C. Gibeaut, Thomas A. Tremblay, Rachel Waldinger, Edward W. Collins, Rebecca C. Smyth, Williams A. White, Tiffany L. Hepner, John R. Andrews, and Roberto Gutierrez, Bureau of Economic Geology, April 2007.

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19. Appendix 19, “Oil Spill Planning and Response Atlas Upper Coast of Texas”, Texas General Land Office and U.S. Department of Commerce, National Oceanic and Atmospheric Administration, 1996.

20. Appendix 20, “Living with Geohazards on Galveston Island: A Preliminary Report with Recommendations”, James C. Gibeaut, John B. Anderson, Timothy M. Dellapenna, July 2, 2004.

21. Appendix 21, “Beach replenishment may have 'far reaching' impacts on ecosystems”, Science Daily, March 29, 2016.

22. Appendix 22, “Blue Carbon: A Management Tool for Conservation and Restoration of Coastal Wetlands,” April 6, 2016 Workshop, Restore America's Estuaries.

23. Appendix 23, “Systemic Risks: The New Kid on the Block”, Ortwin Renn, Environment Magazine, Volume 58, Number 2, March/April 2016.

24. Appendix 24, “The effects of the “Ike Dike barriers on Galveston Bay”, M. Ruijs, Master of Science Thesis, Delft University of Technology and Royal Haskoning, June 2011.

25. Appendix 25, “Living by the Rules of the Sea”, David M. Bush, Orrin H. Pilkey Jr., and William J. Neal, Duke University Press, 1996.

26. Appendix 26, “Living with the Texas shore,” Robert A. Morton, Orrin H. Pilkey, Jr., Orrin H. Pilkey, Sr., and William J. Neal, Duke University Press, 1983.

Conclusion and Summary of Some Comments

The Sierra Club again emphasizes its “Summary of Some Important Comments”:

1. Extend the comment period on the current DEIS for two to four weeks.

2. Prepare and release for public review and comment a supplemental DEIS with all the impacts, mitigation, and other information that the Corps says it has not prepared in the current DEIS analyzed with at least a 90-day public comment period.

3. Implement an extensive public outreach/participation program for the current DEIS and the supplemental DEIS. This extensive public outreach/participation program is needed due to the potential expenditure of 10's of billions of dollars, possible construction of massive new infrastructure, creation of significant environmental, social, and economic impacts and costs, and extensively altered human environments for all coastal Texans, all Texans, and all United States

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citizens. All citizens are potentially interested in, concerned about, and are affected by the DEIS but not all know about its availability or will be able to participate in the public comment period if they are not informed via an extensive public outreach/participation program.

4. Contact environmental justice communities, residents, advocates, and organizations that work on environmental justice issues and request their input into how environmental justice should be addressed in the DEIS.

5. Address the human root causes of the storm surge problem (for example: the desire to live in dangerous places, desire to participate in actions and activities that are harmful to the environment, arrogance, domination of Nature, and greed) and not just the symptoms of these actions and activities (population growth, development, habitat loss, etc.) which are based upon human desires that are incompatible with the natural coastal ecosystems and processes.

The DEIS should also address these human actions and activities (symptoms) including population growth, development, habitat loss, erosion, and sedimentation on the Texas Coast. The DEIS should fully address how human actions and activities can be restrained and altered to avoid, minimize, and mitigate their effects on the natural Texas Coast and how they increase human vulnerability to storm surge.

6. Prepare alternatives which have a better balance with more non-structural methods of storm surge protection, like the Sierra Club Double E Alternative and the Bayou City Waterkeeper “Sage” Alternative. Focus on elevated structures, better construction (FORTIFIED as an example), and strategic withdrawal.

7. Change the analysis period to at least 100 years to reflect the full impacts of climate change and sea level rise in the future.

8. Discuss in the current and supplemental DEIS the responsibility of the oil/gas industry, real estate development industry, and other businesses whose property will be protected and directly benefit from any storm surge project, to protect their own resources for stockholders (fiduciary responsibility) because they are public companies, how much they should pay, why federal, state, and local governments should subsidize the entire cost of any storm surge proposal that benefits them enormously, and the fact that these businesses are responsible for many of the risks that people and property incur from spills and or have been placed people in harm’s way when there are storms by these businesses.

9. Create a No Action Alternative that accurately reflects the population growth and development and their impacts 50 years in the future.

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The Sierra Club appreciates this opportunity to comment. Thank you.

Sincerely,

Brandt MannchenConservation CommitteeHouston Regional Group of the Sierra Club20923 Kings Clover CourtHumble, Texas 77346832-907-3615brandtshnfbt@juno.com

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