March 31, 2016

Gulf Coast Community Protection and Recovery Districtc/o Christopher SalleseDannenbaum Engineering3100 West Alabama StreetHouston, Texas 77098

Dear Chris,

Enclosed are the comments of the Houston Regional Group of the Sierra Club (Sierra Club) regarding the Gulf Coast Community Protection and Recovery District’s (GCCPRD) Storm Surge Suppression (SSS) Study (SSSS) Phase II Report (report).

The Sierra Club is extremely disappointed with the report that the GCCRPD has published about SSS. Not only is this report biased but it leaves out a tremendous number of important issues, many that are environmental issues, which are critical to get right before we decide upon any potential solution(s). The report fails to consider “all reasonable alternatives” and thus leaves the public and decision-makers bereft of important information that may affect their views, opinions, and decisions about what should be done on SSS in the Houston-Galveston Area.

The Sierra Club presents these comments with the hope that they will help fill the holes that the report currently has and affects what potential solutions will be seriously considered.

Executive Summary

1) Page 1, Executive Summary, one concern that the Sierra Club has is how the report deals with climate change in an insufficient manner. Since the GCCPRD suggests that the proposed hard structure alternatives may last 100 years (Page 29, 3.4.4. Galveston and the Coastal Spine, Page E-23, Operation & Maintenance (O&M)) it is critical that any potential alternative or solution be analyzed, assessed, and evaluated within that 100 time-frame. Instead the report uses a 2035 to 2085 time-frame, which is 50 years (Page 1, Executive Summary, Page 54, 7.3.1.1. Analysis Years, Page G-8, Levee Sections). If the alternatives truly do have a lifetime of 50 years then the projected cost of replacement should be clearly stated so the public and

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decision-makers know what long-term costs may be. The sea level rise that will occur in 100 years due mostly to climate change is obviously going to be much greater than sea level rise that occurs in 50 years.

2) Recent research into sea level change has shown that sea level rise is increasing at a faster rate than predicted 10 years ago. According to some experts the Intergovernmental Panel on Climate Change (IPCC) has underestimated future sea level rise. The likelihood of the higher emission scenario has become more likely in recent hears and therefore the results for this scenario means by the end of 2100 almost a 4 foot rise will occur and 6.5 to 9.8 feet by 2300. (Appendix 1, “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, environment360) Some studies refer to sea level rise by 2100 at 1 to 4 feet with an uncertainly range of 0.66 feet to 6.6 feet. This means that a much greater sea level rise could occur than used for this report. (Appendix 2, “Future Climate Change,” U.S. Environmental Protection Agency, last updated February 23, 2016, http://www3.epa.gov/climatechange/sceience/future.html)

In addition, climate change means, for the Houston-Galveston Area in all probability, greater numbers of large precipitation events and potentially more and or more intense storms or hurricanes. These predicted changes should be considered with regard to any impacts they will have on any potential alternatives.

For instance, although a hard structure (levee, T-wall, etc.), will be built to a certain specification, if sea level rises and other climate change impacts occur over the 50 to 100 years the supposed benefits of that hard structure will degrade or diminish. The report does not explore this concern and therefore the public and decision-makers do not know what the efficacy is of potential alternatives proposed as they age over their 50 to 100-year lifetime. In other words, the public and decision-makers do not know what they get for their money in 50 to 100 years.

This is particularly important since the GCCPRD and others have emphasized the danger and potential losses without one of these alternatives in an effort to move the public and decision-makers toward accepting potential alternatives and their costs. (Appendix 3, “Houston-area Residents Protest Hurricane Plan”, March 22, 2016, The Texas Tribune) The video shown by GCCPRD at the March 22, 2016 public meeting emphasized frightening scenarios instead of “scientific-based study. When costs upward of 6 to 10 billion dollars are considered it is even more important that the public and decision-makers be informed without fear-based presentations. The public and decision-makers must have all the information about adequacy of operation and promised ability to withstand environmental impacts when hurricanes hit the coast every 20 years

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or so (probably 5 storms in 100 years) in addition to storms that are not hurricane but are significant in their shoreline impacts.

3) There is an important since the assumption is that by 2035 the potential alternatives proposed are supposed to be built. The assurance of this occurring on time is not analyzed in the report and there is no analysis of what happens if the structure is not built on time in the report.

The report does not address how construction of potential alternatives will be affected during the 15 to 20 years of construction time when storms and or hurricanes hit the Houston-Galveston Area and the construction site.

4) It is very important that the public and decision-makers know who will fund potential alternatives and how much the actual costs are. Although estimated costs are given, with 20-40% overage costs, the GCCPRD does not provide the public with any information about how accurate these cost estimates are particularly since they are for construction done over several decades in the future, involve extremely large structures, and involve highly complex engineered potential alternatives.

5) The report fails to provide potential modular or partial alternatives that can be implemented over time if all the money is not available from federal or other sources or the money takes a long time to be approved and then appropriated. The source of funds and how those funds will be provided alerts the public and decision-makers about what realistic financing costs are. The failure to provide any replacement/repair costs in or over 50 years (Page 5, Executive Summary, Table 2) is not acceptable. The public and decision-makers must know all costs associated with the potential alternatives so that they are not pushed to support “A pig in a poke”. Complete transparency is crucial during this analysis process.

6) Pages 5 and 6, Executive Summary, Central Region: Chambers, Harris, and Galveston Counties, the environmental impacts are inadequately or not addressed. See the Sierra Club's concerns below and throughout this letter.

7) Page 2, Executive Summary, construction of a gate 60 feet deep at Bolivar Roads, ensures that there is an emphasis and motivation to deepen the Houston Ship Channel to 60 feet. That should be a separate public policy issue and decision. The additional salt water intrusion, increase in oyster predators, disruption of the Galveston Bay ecosystem, and other issues must be addressed now if the 60 foot deep gate will be built. Otherwise the existing 45 foot plus a several foot maintenance dredging overage (call it 48 feet) should be the depth of the gate for a potential alternative. Page E-2, Bolivar Roads Gate, states that the current “main channel depth” is 45 feet. Page C-3, C.1.1 Bolivar Roads Crossing, GCCPRD states that there is “a 1,500-foot wide navigation channel (50 feet deep)”. The GCCPRD must correctly state what the dimensions are of the present Houston Ship Channel (HSC) so that the public and decision-makers

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understand the true estimate of the changes that are proposed and thus the environmental impacts.

1. Introduction

8) Page 10, Consolidated GCCPRD Cost Estimate, Appendix G.2 and Data Library of Costs, Appendix G.3, for the report were difficult to open using the computer and software that the Sierra Club used. The Sierra Club was never able to print out the material from these two Appendices so that it could more easily read and analyze their contents. The Sierra Club requests that in the future that all GCCPRD documents be created in such a way that their contents can be easily printed out.

9) Page 11, 1.2. Storm Surge Suppression Study Purpose, the so-called Coastal Spine, Central Spine, or Ike Dike alternative is certainly not comprised of natural or nature-based features. It is difficult to envision how a 17 foot tall levee, that extends for over 50 miles, with a giant multi-billion dollar gate, with additional hard structures and engineered features, is natural or nature-based. An accurate description of what is included for each alternative should be printed so the public is not mislead about what will be done and how it will be done.

10) Page 11, 1.3. Phase 2- Scope of Work, the “Environmental analysis” is not only perfunctory at best but fatally flawed. Please see the Sierra Club's concerns about the “Environmental analysis” as stated below in this letter.

2. Phase 2 – Planning Methodology

11) Page 12, 2.1. Alternative Scoping, the GCCPRD states “The study area has been thoroughly examined by the US Army Corps of Engineers and other researchers over the past 50 years and the majority of the technical alternatives were already identified through these efforts.” The Sierra Club very much disagrees with this statement and complained about the bias in alternatives in our comments on the Phase I report.

The report fails to consider “all reasonable alternatives” (Page 9, Executive Summary, The Way Ahead-Phase 3: Final Report Development (Feb 2016-June 2016)). Although the report suggests that the Corps of Engineers has sufficiently looked at the majority of possible alternatives for the past 50 years this is not the case. A series of potential modular or partial alternatives, that can be implemented over time, as money is available, which are less environmentally destructive, that address the SSS problem comprehensively, and are brought together and considered as one or more potential alternatives that can be implemented to reduce storm surge damage over time acceptably are ignored.

For example, one potential partial alternative addresses the protection of the HSC. The report does not address why with government assistance and

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regulatory backing the large industrial companies with petrochemical plants and oil refineries along the HSC cannot totally or partially finance individual levees to protect their plants or in an association (like a levee district) cannot fund a levee to protect the entire HSC district (the East Harris County Manufacturers Association could assist with such an alternative).

The report also fails to analyze a potential partial alternative that implements “strategic withdrawal” from certain parts of the coast that are particularly vulnerable, expensive to protect, have relatively few people to protect, and whose protection would cause great additional environmental damage. For instance, the report does not make good public policy and economic and environmental sense when it attempts to protect residential and commercial areas on the vulnerable areas of Bolivar Peninsula and West Galveston Island.

These areas are in extremely vulnerable positions with regard to storm surge and place an environmental and economic burden on all other citizens in the Houston-Galveston Area. It would make more sense to buy out these residences and commercial establishments and allow the barrier island, beach, dune, freshwater and saltwater marsh, and prairie ecosystems to function with the natural sediment budget on the coast. These natural coastal ecosystems (communities) have evolved with storms and hurricanes and will re-heal themselves or be altered to another storm surge compatible ecosystem if we allow them to do so.

12) Page 12, 2.2. Alternative Screening Criteria, the Sierra Club believes that several of the alternatives that are proposed (Coastal Spine) do not effectively reduce the risk associated with storm surge/coastal flooding and reduce impacts with regard to the “Environment”.

Coastal ecosystems have evolved to adapt to and change with storm surge. When we talk about damage to these ecosystems from storms or hurricanes we forget that they are already resilient and that changes to these ecosystems due to storms or hurricanes are not bad but the way adaptation occurs in the coastal zone. We also forget about the benefits that storms and hurricanes provide for these coastal ecosystems. New habitats for fish and wildlife are created, new sand/sediments are provided for marshes, new inlets that provide connections to bays, estuaries, and the Gulf of Mexico are created, etc.

Humans may look at these changes as bad but ecosystems have no such problems and simply adapt, change, and evolve as the resilient communities of life that they are. Over time, and we are talking geologic time and not human time, oysters will increase/decrease, seagrasses will increase/decrease, beaches will increase/decrease, marshes will increase/decrease, dunes will increase/decrease. This is okay and is the way these ever changing coastlines naturally operate. Humans must not substitute their views and desires for what the geological, biological, and ecological processes desire.

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Unfortunately, this is what is happening with this report. Humans, instead of keeping out of harm's way and allowing the natural processes to work, want to interfere, manipulate, and stabilize an inherently dynamic and every-changing set of natural processes. Over the long-term this will not work for humans or coastal ecosystems.

13) Page 15, 2.2.2. Central Region: Chambers, Harris, and Galveston County, see above, the GCCPRD states that “This assumption was not based on technical or constructability concerns; rather, it was focused on potential environmental impacts to the bays and estuaries, economic impacts associated with maritime activity and social acceptance by the local community”.

Certainly, environmental impacts appeared to play little role in the development of the Coastal Spine Alternative. It is obvious that such an alternative will result, over time, in the loss of the beach, dunes, freshwater wetlands, salt marshes, and native prairie that exist between it and the Gulf of Mexico (not to mention residences).

It is obvious that economics was the driving force particularly since the GCCPRD aims not to have a locally paid for solution but proposes that the federal government pay for the alternative. This turns people away from doing what needs to be done and in essence gives people a false sense of security and an altered sense of reality that everything will be alright. This social acceptance is predicated on using other people's money to take care of a local problem that we should handle in an environmentally benign way.

14) Pages 15 and 16, 2.2.2.1. Central Region Alternative #1 (CR#1) – High Island to San Luis Pass Coastal Spine, the Sierra Club opposes this alternative. We find it very interesting that the location of the proposal, north or south of State Highway (SH) 87 and FM 3005 is never stated or shown since Figure 7 is so small and indistinct that you cannot see where the “dike” is versus the road. There is no documentation on this figure of where the “dike” will go and tie into the mainland. Since San Luis Pass, the marshes and prairies of High Island, and natural places where the “dike” ties into the mainland, it is very instructive that the report never shows and states the location of these tie-ins and what damage these north and south tie-in segments of the “dike” will have.

15) Page 17, 2.2.2.2. Central Region Alternative #2 (CR#2) – Texas City Levee Modifications and Extensions North (SH-146) and West-Galveston Ring Levee, Reach 3 – Texas City Levee Extension West (Highland Bayou), it is not clear where the University of Houston Coastal Center is, with a very valuable coastal prairie, in relation to the “dike”. There is no discussion about what will happen to this property due to the “dike”. This should be thoroughly discussed so the public and decision-makers know.

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The “Environmental Analysis” fails because it does not document sensitive areas, show geographically how the proposed alternatives will affect these sensitive areas, how these areas can be avoided with impacts minimized, and how all environmental impacts (direct, indirect, connected, and cumulative) will be addressed. The report should analyze not just the direct impacts, 150-foot “footprint” of the proposals, but also the indirect, connected, and cumulative impacts of proposals. These proposed alternatives should be designed around sensitive areas so such areas are protected and preserved and not mostly mitigated.

16) Page 21, 2.3. Alternative Development, the GCCPRD refers to “obstruction of scenic views” but then says nothing about this issue, its intensity, what mitigation will be required, and what the economic losses will be.

17) Page 21, 2.3. Alternative Development, the GCCPRD refers to “environmental feasibility” and that “Once the alternatives were fully defined, the team then assessed the potential impacts that each alternative would have on the environment.” This type of planning is backwards to the way it should be done. What protection of the environment means is not doing something after you define an alternative. It means doing the geological, biological, and ecological work up front to determine where the key environmental areas are and their sensitivities, and then makes alternatives fit in within the protection and preservation of these important coastal ecosystem features. It is unfortunate that the GCCPRD did not do this.

18) Page 22, 3.1. Modeling Approach and Methodology, Page A-1, Appendix A: Storm Surge and Wave Modeling, and Page A-6, A.33 FWA1 2085, it does not make sense to fail to model for the with-action schemes of future year 2035 (construction should be complete by that time). By not modeling the with-action schemes of future year 2035, this baseline, which will include what exists today and what will have occurred by the time construction ends in 2035, will be ignored and forgotten about. This means we have to wait to see if the modeling was correct after 50 years has passed (2085 before determining what has changed). Thus the original impact due to implementation of each alternative at each location is masked. This is not appropriate science.

The modeling only looks at wave heights and periods in the study area. The modeling should also look at linear feet of beach soil lost, eroded, or moved due to storms with the alternatives proposed. Other environmental elements should also be measured by the models so we see what the environmental impacts are using different storm simulations. 19) Page 23, 3.2. Relative Sea Level Rise, the Sierra Club requests that the statement “While the water level changes can be assumed to be uniform along the coastline between Freeport and Sabine” be documented. This statement concerns about 100 miles of coast. Sea level rise certainly will not affect the

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shoreline equally along this area. In fact on Page A-19, the GCCPRD states “the area between Freeport and Lake Sabine, showing an additional 2 to 4 feet increase in maximum WSE due to nonlinear effects of sea level rise. The nonlinear difference can be as large as 2 to 3 times the sea level change.” So the previous statement should be changed or removed because it is not correct.

It is of great concern that Jefferson, Chambers, and Orange Counties have “no subsidence data and do not believe subsidence is a concern in their area.” This means that any subsidence due to water, or oil/gas withdrawal, or sediment deposition is ignored. This is data should be acquired before any further work is done and used in the analysis of alternatives.

20) Page 26, 3.2.2. Historic Subsidence, the Sierra Club does not believe that creating a “regional average” of subsidence makes sense. Because subsidence has occurred differently in different places (is localized) these differences must not be lost by an average when looking at subsidence and relative sea level rise. The Sierra Club is concerned that a more conservative value for sea level rise (higher sea level rise) should be used in the report. Melting of the Greenland ice-sheet and Antarctica is occurring much faster than was anticipated even 10 years ago. Recent concerns expressed by some scientists are that we underestimate what sea level rise will be as well as the increasing level of thermal expansion of water. A worst-case sea level rise scenario should be modeled to determine how any proposed alternative will be affected by this worst-case sea level rise in 100 years. (Appendix 4, Climate Disruption in Overdrive: Submerged Cities and Melting That “Feeds on Itself”, Dahr Jamail, Truthout Report, March 29, 2016)

21) Page 28, 3.4.1. Hydraulic Conditions, the GCCPRD should not average wave heights of seven storms but should model each storm's wave height so that we get a range of heights, including a worst-case analysis.

22) Page 29, 3.4.2. Reach Types, the GCPRD fails to add, for calculation of over-topping rates, the 20:1 ratio that the Coastal Spine Alternative will use. This calculation must be conducted and shown to the public and decision-makers.

23) Pages 29 and 30, 3.4.4. Galveston and the Coastal Spine and 3.4.5. Rainfall and Interior Drainage Requirements, the GCCPRD never states that even with a giant “dike” storm surge will still be created in Galveston Bay. This occurs because of the long fetch (distance in miles) that exists in Galveston Bay. Galveston Bay is 30 miles long, 17 miles wide, averages about 9 feet deep. (Appendix 5, “Galveston Bay”, Wikipedia, January 7, 2016) The report should state what that storm surge will be in Galveston Bay for all proposed alternatives. In addition, there is no indication how the model analyzed storms or hurricanes that moved slowly or stagnated on the coast for several days (like Hurricane Carla in 1961) and therefore would place extreme pressure on internal drainage

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and storm surge backwash systems. The results of modeling in these instances should be reported by GCCPRD so that the public has this information.

The recent rains that just occurred in March 2016 in East Texas and other southern coastal states provide an opportunity to determine how rainfall events affect all alternatives and should be modeled. 100-year and 200-year rainfall events are not sufficient tests particularly since climate change predictions are for our Southeast Texas area to have more and more intense rainfalls. A minimum of 500-year rainfall events should be modeled. (Appendix 6, “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)

4. Environmental Analysis

24) Pages 31-37, Environmental Analysis, environmental impacts have played little role in the development of the Coastal Spine conceptual alternative or other alternatives. It is obvious that the Coastal Spine Alternative will result, over time, in tremendous environmental damage to the Houston-Galveston coastal area and Galveston Bay. More than the 150 foot “footprint” must be analyzed (Page 31, 4. Environmental Analysis and Page D-1, Appendix D: Environmental Analysis) for environmental impacts that include direct, indirect, connected, and cumulative impacts.

The environmental analysis has been perfunctory at best and woefully inadequate at worst. Some of the environmental impacts that have been ignored, incompletely explained, or poorly developed include:

a. The loss of the beach in front of the Coastal Spine. This occurs as storm and hurricane wave energy slams up against the “dike” and soil is eroded and taken down the coast. A perfect example of how this occurs is found at the site of the Galveston Seawall which has no beach unless it is perpetually re-nourished. The cost of this perpetual re-nourishment has been ignored in the report.

b. The loss of the 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 then cause compaction of sand which interferes with animal and plant use and regeneration of the beach zone.

c. The loss of dunes in front of the Coastal Spine. This occurs for the same reason as beach loss.

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d. 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.

e. The loss of native prairie in front of the Coastal Spine. This occurs for the same reason as beach loss.

f. The loss of native prairie, if it is to be replaced and rebuilt, will require a similar large scale mechanical removal, retrieval, deposition, and recreation process as for sand on beaches plus a significant replanting effort of native grasses and herbaceous vegetation (wildflowers).

g. Loss of freshwater wetlands in front of the Coastal Spine. This occurs for the same reason as beach loss.

h. The loss of freshwater wetlands, if these freshwater wetlands are to be replaced and rebuilt, will require a similar large scale mechanical removal, retrieval, deposition, and recreation process as for sand on beaches plus a significant wetlands replanting effort.

i. The loss of residences in front of the Coastal Spine. This occurs for the same reason as beach loss.

j. The loss or degradation of salt marshes on the back bay (Galveston Bay) part of Galveston Island, behind the Coastal Spine. 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 area. The loss of sediment will diminish ecosystems that are dependent on this sediment.

k. The loss of back bay salt marshes, if these wetlands are to be replaced and rebuilt (maintained in perpetuity), will require a similar large scale mechanical removal, retrieval, deposition, and recreation process as for the beaches plus a significant wetlands creation and wetlands planting effort.

l. The loss or reduction of wind generated sediments in front of the Coastal Spine. The Coastal Spine will interrupt and interfere with the sediment budget and movement process and diminish ecosystems that are dependent on this sediment.

m. The loss or reduction of animal and plant species due to fragmentation caused by the Coastal Spine. Animals will have a very difficult time 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.

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This fragmentation of habitat (at least 150 feet wide) not only provides a formidable barrier to movement but also exposes these animals to predation, dessication, and can result in their inability to move from south of the Coastal Spine to north of the Coastal Spine.

Plant propagation and dispersal of seeds and parts will also be interrupted by the Coastal Spine. SH 87 and FM 3005 will be located directly behind the Coastal Spine and this will provide an additional (cumulative) formidable fragmentation and isolation barrier for animals and plants to cross. This can result in genetic isolation and loss of habitat adaptability.

n. The loss of nesting beach for the federally endangered Kemp's Ridley Sea Turtles in front of the Coastal Spine. This occurs for the same reason as beach loss.

o. The loss of wintering or foraging habitat for Piping Plovers in front of the Coastal Spine. This occurs for the same reason as beach loss.

p. The degradation and interruption of the ecological functions/processes that San Luis Pass provides as the most natural coastal pass left on the Upper Texas Coast (Appendix 7, “The Formation and Future of the Upper Texas Coast”, John B. Anderson, Texas A&M Press, 2007).

According to scientist and coastal geologist at Rice University 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 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.”

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Currently, the “conceptual” Coastal Spine does not have a tie into the mainland on its western end, West Galveston Island. A tie-in is needed or excessive erosion of this end of the Coastal Spine will cause damage to the structure and the environments to its west and south. Currently, the “conceptual” Coastal Spine, on its west end, is left hanging with nothing to hold onto.

If a tie-in is made at San Luis Pass then the most natural pass left on the Upper Texas Coast will have its function interrupted and degraded. The circulation of water, the flow of water (amount), the flow of organic matter, sediments, and nutrients, the location and effects on oyster reefs or 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) and the mainland, will all be affected by the location and tie-in of the western end of the Coastal Spine.

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 the Coastal Spine, with or without a tie-in to the mainland. This would result in significant changes in water circulation and habitat conditions in this area.

q. The loss or degradation of the movement of Galveston Island, a barrier island and Bolivar Peninsula, a barrier peninsula, due to the attempt to stabilize these dynamic and unstable systems with the embedded Coastal Spine.

r. The significant diminishment or loss of vistas of the Gulf of Mexico (blocked or altered) by construction of the Coastal Spine. This means that existing recreational and inspirational activities will be significantly altered.

s. The significant diminishment or loss of existing recreational and inspirational activities at San Luis Pass, along the Gulf of Mexico shoreline of Galveston Island, and the back bay (Galveston Bay) of Galveston Island due to the construction of the Coastal Spine.

25) Pages 31-37, Environmental Analysis, the Sierra Club is concerned that existing scientific work, that would contradict the conceptual alternatives, either has not been considered or has been ignored. For instance:

a. “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 8)

This book has a number of strategies that the GCCPRD and the Corps has not considered. The information is specific to Galveston Island and would be extremely useful for an alternative(s) that looks at how to deal with sea level rise, coastal erosion, and where people live on Galveston Island.

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b. “The Formation and Future of the Upper Texas Coast”, John B. Anderson, 2007. (Appendix 7)

A historic and present view of the Upper Texas Coast and the human and geologic processes that shape its form.

c. “The Impact of Global Warming on Texas”, Second Edition, Editors Jurgen Schmandt, Gerald R. North, and Judith Clarkson, 2011. (Appendix 9)

Although somewhat dated, after only 5 years (the science changes fast in climate change) this book gives some views about what may occur on the Texas Coast due to climate change.

d. “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 10)

A map that should be used by GCCPRD to avoid geohazards and sensitive areas on Galveston Island.

e. “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. (Appendix 11)

This document maps out “Biological Resources”, “Environmental Sensitivity Index”, “Hydrography”, “Priority Protection Areas”, and Other Layers as follows:

1. Diving Birds, Gulls/Terns, Passerine Birds, Pelagic Birds, Raptors, Shorebirds Wading Birds, Waterfowl, Fish, Dolphins, Mustelids or Rodents, Upland/Wetland Plants, Submerged Aquatic Vegetation, Alligators, Turtles, Other Reptiles/Amphibians, Bivalves, Crabs, Gastropods, Shrimp, Threatened/Endangered, .

2. Freshwater Marshes, Salt and Brackish Water Mashes, Sheltered Tidal Flats, Sheltered Scarps, Sheltered Riprap Structures, Sheltered Solid Man-Made Structures, Exposed Tidal Flats, Exposed Riprap Structures, Gravel Beaches, Mixed Sand and Gravel Beaches, Coarse Grained Sand Beaches, Scarps and Steep Slopes in Sand, Fine-Grained Sand Beaches, Wave-Cut Clay Platforms, Scarps and Steep Slopes in Clay, Exposed Walls and Other Solid Structures,

3. High Priority, Medium Priority, Low Priority, Caution Area,

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4. Anchorage Area, Audubon Sanctuary, Bird Rookery Area, Coastal Preserve, Municipal Area, National Wildlife Refuge, Park – City or County, State Park/Wildlife Management Area, and Washover Area

This document was mentioned by the Sierra Club to GCCPRD in Phase I report comments. Nothing appears to have been done to analyze and discuss these sensitive areas in the report where the proposed alternatives would be located. The Phase II report should review, discuss, and relate the location and importance of, at a minimum, all of these elements so the public understands which proposed alternative areas have sensitive features.

f. “Living with Geohazards on Galveston Island: A Preliminary Report with Recommendations”, James C. Gibeaut, John B. Anderson, Timothy M. Dellapenna, July 2, 2004. (Appendix 12)

This is a preliminary report that was prepared before the 2007 Galveston Island geohazards map was complete.

g. “Beach replenishment may have 'far reaching' impacts on ecosystems, Science Daily, March 29, 2016 (Appendix 13)

Even supposedly more benign and non-structural alternatives, like beach re-nourishment, have environmental impacts, many which we are finding out about now because we have not studied this alternative well.

All of these references have important things to say about where sensitive areas are, where development should occur, where development should not occur, and what coastal alternatives may make sense. However, it appears as if these documents have not be considered, have been ignored, or have not been used in preparing the alternatives for this report. This means the present “Environmental Analysis” for this report is incomplete and poorly done.

26) Pages 31 and 32, 4.1.1. Hazardous Materials and Page D-1, D.1.1 Hazardous Materials, it is not clear if Texas Commission on Environmental Quality (TCEQ) state superfund sites are listed in Table 2. It would be helpful if a better explanation was given about specific sites that are included in this section.

27) Pages 32 and 33, 4.1.3. Coastal Barriers, Table 4 and Page D-2, D.1.3 Coastal Barriers, the GCCPRD should not just include the direct environmental impact acres but also indirect (secondary), connected, and cumulative impact acres should also be reported so that the public gets a complete picture of spatial environmental impacts on Galveston Island and Bolivar Peninsula..

The 235.98 acres of direct impacts for the Coastal Spine alternative, does not make sense. The Coastal Barriers section should not just cover the Coastal Barrier Resources Act (CBRA) lands. Both Bolivar Peninsula and Galveston

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Island are barrier islands/peninsulas and the proposed alternatives will environmentally impact these lands, whether in the CBRA or not.

Bolivar Peninsula is 27 miles long. The footprint of the Coastal Spine is 300 feet. So a simple calculation of 27 miles x 5,283 feet/mile x 150 feet divided by 43,560 square feet/acre = 491.19 acres that will be directly impacted by the Coastal Spine on Bolivar Peninsula alone. Galveston Island is also about 27 miles long so the direct impacts of the Coastal Spine is also 491.19 acres. This is a total of 982.38 acres of direct impact by the Coastal Spine alternative.

The GCCPRD also ignores or gives little emphasis that there are three significant Houston Audubon Society Preserves on Bolivar Peninsula (Bolivar Flats, Horseshoe Marsh, and Mundy Marsh), a part of Anahuac National Wildlife Refuge, and Galveston Island State Park which will be either cut-off from each other (fragmentation and isolation) and other barrier peninsula habitat or will be significantly impacted or destroyed (Bolivar Flats) due to the construction and long-term operation and maintenance of the Coastal Spine.

28) Page 33, 4.1.4. Threatened or Endangered Species Critical Habitat and Page D-2, D.1.4 Threatened or Endangered Species Critical Habitat, the GCCPRD ignores all sea turtles, in particular Kemp's Ridley Sea Turtle, which occasionally nests on the beaches/dunes of Galveston Island. The beach/dune habitat of this species will be negatively impacted by the Coastal Spine, as mentioned above, due to increased erosion caused by water hitting the “dike” and eroding the beach. The same will occur to the Piping Plover's winter habitat on Galveston Island and Bolivar Peninsula.

As sea level rises there must be sufficient land behind the present beach so that the beach, dunes, freshwater wetlands, native prairie, and saltwater wetlands can move and retreat as the barrier island moves toward the mainland. The Coastal Spine attempts to weld the barrier island/peninsula in place, which over the long term will not succeed. This will result in loss of the beach habitat, degradation of the barrier island/peninsula, and significant degradation or even destruction of the Coastal Spine.

29) Page 34, 4.1.6. National Wildlife Refuges and State Parks and Pages D-3 and D-4, D.1.6 National Wildlife Refuges and State Parks, the GCCPRD states that the “Coastal Spine would parallel State Highway 87 on Bolivar Peninsula and State Highway 3005 on the west end of Galveston Island”. However, the GCCPRD does not state how close the Coastal Spine will be to these roads. The public must have this information so that it can review, comment on, and understand all the potential environmental impacts of this proposal.

30) Page 35, 4.1.7. Existing Floodplains, Table 8 and Pages D-4and D-5, D.1.7 Floodplains, the figures given for the 100-year floodplains are not

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complete. For example, almost all areas of Galveston Island and Bolivar Peninsula are in the 100-year storm surge area. But this information is not documented and shown in the report.

31) Pages 36 and 37, 4.2. Tidal Flow Analysis and 4.2.1 Results Summary, the GCCPRD does not state how the west end of the Coastal Spine will be tied into the mainland at San Luis Pass. If the west end will not be tied into the mainland then the GCCPRD must state clearly and show how the Coastal Spine structure will be protected from storm surge and other storm flows and how the area around this west end of the Coastal Spine will be impacted by tides, storm surge, waves, and other wind or water forces that ricochet off the Coastal Spine and cause erosion and sedimentation.

It is not comforting to hear the GCCPRD state that “water quality conditions will likely be minimally affected” and that “This limited change indicates … water circulation to remain undisturbed”. The GCCPRD must state clearly what “minimally affected” and “limited change” means with regard to water quality conditions and water circulation measurements. A 12% to 25% tidal amplitude decrease and a 10% to 25% tidal exchange decrease do not appear to be minimal or limited changes.

5. Gate Analysis

32) Pages 39 and 40, 5.1.3. Bolivar Roads Gate and Page 49, 6.3.5.1 Large Navigation Gate, on Page 39 it is stated that the “width of the entire channel is 1000 feet” and on Page 40 it is stated that “The gate opening would be approximately 840 feet wide … the total channel width would be approximately 840 feet”. On Page C-3, C.1.1. Bolivar Roads Crossing, GCCPRD states that there is “a 1,500-foot wide navigation channel (50 feet deep)”. Page E-2, Bolivar Roads Gate, states that “a main channel depth of 45 feet). Which depth is correct? This means that the total channel width for boats will be reduced from 1,500 feet to 840 feet (660 foot decrease) which is a 44% decrease in total channel width. The safety implications of narrowing the channel are not stated or analyzed. The assumption is that ships that take up 60 feet of water and are 161 feet in beam will use the HSC and are accommodated by the new gates and narrower channel.

Usually if a channel takes a certain ship depth then it is over-dredged (maintenance dredged) 2-5 feet more. It is not clear what size ship will be allowed by the gates. At one place in the report (Page 49) a 60 foot depth is mentioned but there is no indication if this depth includes a maintenance over-dredge depth of 2-5 feet. The report should clearly indicate the depth of the proposal with maintenance over-dredge and give the dimensions in depth of the largest ship the gate will allow into the HSC. The report should state clearly what the environmental impacts are of allowing larger ships in the HSC and Galveston Bay (current dredging is 45 feet deep with an additional sum for maintenance

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over-dredge) including waves, erosion, more dredging and water quality impacts, dredge disposal locations, costs of dredging, costs of disposal of sediments, costs to upkeep the dredge disposal areas, any toxic sediments, etc.

The Sierra Club does not support a gate depth of over 48 feet because the environmental impacts to Galveston Bay, increased salinity, increased predators to oysters, possible worse collision impacts or risks, etc. have not been analyzed in the “Environmental Analysis” and have not been justified. The proposal is to make the gate 60 feet deep so this is a 33.33% increase over the authorized 45 foot depth. Such enlargement is not appropriate and encourages calls for a deeper HSC and thus means the cumulative impacts of a deeper HSC (60 Feet) should be analyzed in this report.

33) Page 42, 5.1.4. Neches River Gate, the same concerns as expressed in 25) above should also be addressed for the Neches River Gate. The current Neches River Ship Channel is 400 feet wide but the gates will reduce this width to 250 feet, a 37.5% decrease (150 feet) over the 400 foot current ship channel width. There will also be a decrease in ship height from 136 feet to 105 feet (31 feet) or a 22.79% decrease.

34) Page 44, 5.2. Gate Selection, the report fails to state what effect that the vertical lift gates will have on erosion and sedimentation in the HSC and nearby channels. The report should analyze this element and report how this will affect dredging or shoaling within or near channels.

35) Page 45, 5.3. Gate Coast Analysis, the report fails to state how large the two artificial islands will be (acres)and how much of the Galveston Bay bottom will be affected by the gates and how much gates will affect the Neches River bottom.

6 Cost Estimation

36) Page 46, 6.1. Cost Estimation Methodology and Page G-1, cost Estimation Methodology, the Sierra Club is very concerned about the employment of “standardization and simplification techniques” for costs. Because the proposed projects will be unique their uniqueness will probably reflect higher costs. The report should state where the more complex, difficult, and unique parts of proposed projects will be and then focus on realistic estimated costs for those aspects. Otherwise the proposed costs may be artificially low and mislead the public and decision-makers about how expensive the proposed projects may be.

37) Page 47, 6.3. Development of Quantities for Levee and T-wall Sections, the report fails to provide in the “Environmental Analysis” what the environmental impacts will be for the barrow operations including how many acres, what kind of land, what the condition of the land will be after the barrow operations, etc. The

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public and decision-makers must have this information so that they can review, comment on, and understand all the potential environmental impacts of the proposal.

38) Page 50, 6.3.7. Levee Sections, the report in the “Environmental Analysis” fails to state how the approach channel to Bolivar Roads will be affected by a 60 foot depth. The report should state clearly whether additional dredging will be conducted in the Gulf of Mexico outside Galveston Bay (cumulative impact) to accommodate 60 foot ships that the gates will allow. The precise environmental impacts should be revealed to the public and decision-makers so that they can review, comment on, and understand all of the potential environmental impacts of the proposal.

39) Page 51, 6.3.10. Pipelines and Utilities Crossings, the Sierra Club does not believe that it is wise to assume that pipelines and utilities that have “sufficient geometry” will incur “no further actions or coasts”. Unexpected difficulties and costs can often occur with pipeline and and utilities crossings especially if the gate permits ships that are 60 feet deep in the HSC. These are direct, indirect, connected, and cumulative environmental impacts that must be addressed. The public and decision-makers must have this information so that they can review, comment on, and understand all the potential environmental impacts of the proposal.

40) Pages 51 and 52, 6.3.11. Environmental Mitigation Elements, the report woefully under reports the environmental impacts and costs that are associated with the proposed projects. The connected, indirect, and cumulative impacts are ignored as outlined in this comment letter. A true benefit/cost ratio calculation would include these costs including the loss of beaches, dunes, wetlands, and coastal prairies in front of Coastal Spine, over time, and the retreating shoreline due to sea level rise and erosion caused by the Coastal Spine. The Neches River Gate will have bottomland hardwood forested wetlands impacts like losses, isolation, and or fragmentation of these important habitats.

In addition, the Beaumont Unit of Big Thicket National Preserve (BTNP) is just north of I-10, where the North Region Alternatives stop. There may be environmental impacts due to these proposed alternatives including floodwaters backing up, altered flow regimes, sediment alterations, erosion alterations, wetlands and vegetation alterations, etc. The report should analyze the potential environmental impacts on the BTNP due to the proposed North Region Alternatives.

7. Economic Modeling

41) Page 53, 7.1. Economic Modeling Approach and Methodology, the Sierra Club believes that the report does not “consider both existing and future conditions” as stated here. The comments in this letter document that many

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environmental impacts have not been mentioned or analyzed and therefore the costs in the future will be much greater than stated. The failure to determine what the costs will be at baseline, 2035, but only at 2085, biases the entire economic analysis.

42) Page 54, 7.3.1.2. Damage Categories, the categories fail to include parks and protected properties, both private and public. In many cases these properties will be destroyed, degraded, fragmented, and or isolated and environmental benefits cannot be restored and are lost forever. The report fails to make such an admission.

43) Page 55, 7.3.1.4. Structure Inventory, the assumption that “No growth in the size or number of industrial facilities was assumed” is an incorrect assumption. We have seen a massive expansions in petrochemical and refining capacities in the past 5-8 years. This will not stop in the future as market conditions change and companies take advantage to increase market share, promote internal efficiency, and reduce costs.

44) Page 56, 7.3.1.6. Vehicle Inventory, the report should determine and use Houston vehicle inventory and values per household and not average out these figures by the use of a Texas average.

45) Page 56, 7.3.1.8. Debris, the report should use the cost figures for debris removal and disposal from Hurricane Ike since this is the storm that occurred most recently in our area and is a better predictor of costs than data collected in Louisiana.

46) Page 57, 7.4. Benefit-to-Coast Ratios, the report states that “A BCR of 1.0 indicates that the total benefits equal the total costs.” This is an incorrect statement. The current BCR only collects information on certain costs and benefits. Many environmental costs, what are called environmental services, either are not calculated or there is no method to calculate their value. The BCR is rigged to emphasize easily calculated human costs/benefits and not those that are associated with the natural environment.

47) Page 60, 7.4.1. Further Considerations – Refinement of Future Conditions Structure Inventory, the “with project condition” will also result in additional floods because of the inhibition of the natural flow of water in the Neches River and Galveston Bay areas. If “future without project damages is likely overestimated to some degree, as are estimates of project benefits” then the report should discuss what the percent error of the model is for damages and benefits and state how the report will correct overestimated damages and benefits so the public and decision-makers know how accurate the figures are.

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8. Alternative Comparison

48) Pages 61 and 62, 8.1. North Region Alternative Comparison, there is no comparison of how many acres of bottomland hardwood forested wetlands will be destroyed, degraded, isolated, and or fragmented. Fragmentation effects are completely ignored. The potential impacts on BTNP must be analyzed for these proposed alternatives. The public and decision-makers must have this information so that they can review, comment on, and understand all the potential environmental impacts of the proposal.

49) Pages 63 and 64, 8.2. Central Region Alternative Comparison, the report fails to state that the Coastal Spine will not eliminate storm surge in Galveston Bay. The report does not state what storm surge will occur in the Galveston Bay even if the Coastal Spine works perfectly. The wind has a 30 mile long and 17 mile wide Galveston Bay to push down on and create storm surge. The public and decision-makers must have this information so that they can review, comment on, and understand all the potential environmental impacts of the proposal.

The report does not state what will happen at the eastern and western ends of the Coastal Spine during storms and hurricanes. Additional erosion, sedimentation, circulation changes, etc. will occur in San Luis Pass and the lands west of the Coastal Spine. The “Environmental Analysis” fails to mention or provide this information. The public and decision-makers must have this information so that they can review, comment on, and understand all the potential environmental impacts of the proposal.

The report does not discuss fragmentation due to the Coastal Spine and how it will affect wildlife and plant populations and Galveston Bay. The public and decision-makers must have this information so that they can review, comment on, and understand all the potential environmental impacts of the proposal.

50) Pages 65 and 66, 8.3. South Region Alternatives Comparison, the report does not state what will happen to lands, waters, wetlands, etc. that exist beyond the east and west ends of the “dikes”. The report should address erosion, sedimentation, flooding, circulation of water, fragmentation and isolation of wildlife and plant habitats, etc. The public and decision-makers must have this information so that they can review, comment on, and understand all the potential environmental impacts of the proposal.

9. The Way Ahead to the Final Report

51) Page 67, 9.2. Extended Economics Benefit Calculations, the report states “telling the “... “full story” of the losses to the economy associated with hurricane events” but fails to tell or calculate the full environmental costs and the benefits and values that will negative impacted for the next 100 years via direct, indirect,

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connected, and cumulative impacts. The report also fails to state the costs of continuing the current policy that encourages people to “live in harm's way (the 100-year floodplain and storm surge area). The public and decision-makers must have this information so that they can review, comment on, and understand all the potential environmental impacts of the proposal.

Appendix A: Storm Surge and Wave Modeling

52) Page A-2, A.1 Model Improvement and Setup, the GCCPRD fails to state what the impact is on the model and its simulation on reality when “Portions of the Texas shoreline south of Freeport were removed to reduce the size of the mesh and improve computational efficiency”. GCCPRD fails to state how when “ground elevation contours were smoothed” this impacted the model and its simulation of reality. If there are instabilities in the model then the GCCPRD should seek out what these are and not eliminate natural resource data to make the model work better. The GCCPRD should find out what is wrong with the model and fix the problem and not the symptoms. Otherwise, the source of instabilities will not be found and will continue to have deleterious impacts on model results.

53) Page A-12, A.3.5 Synthetic Storm Suite, Figure A-10 and Table A-1, it is curious that storms that hit the Galveston Area are all labeled either North Texas or West Louisiana in the table. Where are the storm tracks that came in and hit the Houston-Galveston Area directly? There are no South Texas storm tracks listed in the table yet Figure A-10 mentions South Texas storm tracks.

54) Page A-19, 1.3.6 Nonlinear Changes to Maximum Water Surface Elevation, it is of great concern that “the area between Freeport and Lake Sabine, showing an additional 2 to 4 feet increase in maximum WSE due to nonlinear effects of sea level rise. The nonlinear difference can be as large as 2 to 3 times the sea level change.” If this is true then if sea level rises about 1 foot we are really talking about a 2 to 3 foot change in sea level and if the sea level rises 2.44 feet then we are talking about a 4.88 to 7.32 foot in change in sea level. The GCCPRD should analyze this element more, point it out to the public, and ensure it is not buried in this appendix. Otherwise, people will believe they are safe and that storm structures are adequate when in fact people will not be safe and storm structures will be pounded by higher waters.

Appendix B: Return Water Level Analysis

55) Pages B-1 and B-2, B.1 Statistical Model, in one place the GCCPRD mentions “254 synthetic storm simulations and outputs” and in another place it says “254 storms”. This is confusing. Use the same terminology each time you talk about the same thing.

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This entire section is full of modeling gobble-de-goop talk. Talk English so people can understand and not “... the weighting of storm parameters from a sampling set using a quadrature scheme for integration … and it employs a response surface interpolation method for central pressure deficit and heading, and a quadrature integral based weighting scheme for radius of maximum wind and storm forward speed”. The public and decision-makers and most “normal people” do not understand a word of this techno-speak. Serve the public like you are supposed to, be transparent, and speak in words that people can understand.

56) Pages B-2 through B-5, B.2 JPA Model Sensitivity Tests, the GCCPRD states that “shows that the 1% return SWLs estimated by the JPA model are generally 1 to 2 feet higher than those from the Texas FEMA FIS.” The GCCPRD should state what real word measurements document of SWLs in real storms are.

Page B-3, GCCPRD states that “behavior and outputs of the JPA model are reasonable”. The GCCPRD should define what “reasonable” means in this case. The GCCPRD should provide the public and decision-makers with the percent error of the models so that people understand how accurate and precise they are.

57) Page B-6, B.3 Return Analysis Results, the GCCPRD states “are deemed unreasonable” and “substantially reduces flood risk”. The GCCPRD should state what these phrases mean. The GCCPRD should state what the flood risk is now and what is a “substantial reduction” of this flood risk.

Appendix C: Tidal Impact Analysis

58) Page C-1, Appendix C: tidal Impact Analysis, the GCCPRD states that “environmental conditions will likely be minimally affected”. With regard to “environmental conditions” the GCCPRD should state what these are. If the answer is “tidal amplitude” then it is important that GCCPRD tells the public and decision-makers that “tidal amplitude” is not the only “environmental condition” that the Coastal Spine Alternative will have. GCCPRD should list the other “environmental conditions” that the Coastal Spine will have. The Sierra Club mentions many of these in this letter. The public and decision-makers must have this information so that they can review, comment on, and understand all the potential environmental impacts that the Coastal Spine Alternative will have.

59) Page C-5, C.2 Model Setup, the period used for model simulations was August 14, 2012 through November 1, 2012. This is a period when rainfall was not up to normal, after the drought of 2011. The Sierra Club is concerned that using this time period gives a false sense of tidal impacts because the water levels are lower versus what they would normally be when a normal amount of rainfall and inflow from rives and streams occurs.

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Page C-7, documents that the exact gate dimensions were not used in the model. Modeling what will not be installed is not an appropriate way to get an accurate answer of what is needed. The actual dimensions of the gates should be modeled.

60) Pages C-9, C-18, C.3.1 Tidal Amplitude Comparison, the 12 to 25% reduction in tidal amplitude documents significant reductions that must be mitigated. These changes contradict the statement on Page C-1 and Page C-36 (C.3.5 Environmental Implications) that “alternatives examined result in a change in tidal amplitude of less than 10% for a range of tide conditions … both achieve coastal storm risk management objectives, while minimizing environmental impacts in the study area”. Coastal storm risk management objectives should not take precedence over ecological and biological needs. This is not acceptable performance and not acceptable as an environmental impact.

The GCCPRD never states why a 10%, 12%, and 25% reduction or a range of 12 to 25% or 10 to 25% reductions of tidal amplitude is acceptable with regard to environmental impacts. GCCPRD does not state in ecological and biological terms what these losses mean and why or why not they are acceptable. The analysis fails to address winter winds and their impacts on tidal amplitude and how the Coastal Spine will affect tides during these conditions.

Appendix D: Environmental Analysis

61) Pages D-5 and D-6, D.1.8 National Wetland Inventory and D.2 Tidal Flow Analysis, more than wetlands and tidal flows will be impacted by these alternatives. Some of the environmental issues include erosion, sedimentation, barrier island deterioration, dune loss, beach/shoreline loss, seagrass bed losses and changes, oyster reef changes and losses, organic matter and nutrient changes and flows, etc. This “Environmental Analysis” is woefully incomplete.

It is very disingenuous to say that “Limited changes to the water column would allow the natural environment driven by water circulation to remain basically undisturbed” when GCCPRD does not define what “limited changes”, “natural environment”, and “basically undisturbed” mean with regard to this statement. All information suggests the opposite; that significant changes will occur with regard to gates and water circulation, flow amounts, and sedimentation.

62) Pages D-6 and D-7, D.3 Environmental Mitigation Elements, the GCCPRD does not include damages to Houston Audubon Society Preserves including fragmentation and isolation. The costs for mitigation are significantly underestimated since all direct, indirect, connected, and cumulative impacts are not addressed and their costs are not acknowledged and calculated.

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Appendix E: Gate Modeling and Design

63) Pages E-1 through E-4, Bolivar Roads Gate and Page E-8, Design Elevations, the Sierra Club does not support a gate depth of over 48 feet because the environmental impacts to Galveston Bay, increased salinity, increased predators to oysters, possible worse collision impacts or risks, etc. have not been analyzed in the “Environmental Analysis” and have not been justified. The proposal is to make the gate 60 feet deep so this is a 33.33% increase over the authorized 45 foot depth. Such enlargement is not appropriate and encourages calls for a deeper HSC and thus means the cumulative impacts of a deeper HSC (60 Feet) should be analyzed in this report. If a deeper gate is proposed for Suezmax and New Panamax ships then the environmental impacts of allowing and encouraging such deeper ships in the HSC should be in this report.

This is particularly true since the GCCPRD states on Pages E-3, E-4, and E-8, “It is assumed that the Houston Ship Channel will be dredged again to a maximum channel depth of at lest 55 or 60 feet. Inability to accommodate such ships with larger drafts will not be conducive to sustainability of this important port. Accordingly, any future hurricane protection structure for this area should consider these exceeding depths and incorporate them within the design … Based on the discussion above related to the possibility of Port of Houston accommodating the new larger ships, also known as New Panamax, it is expected that the bottom sill elevation of the Bolivar Roads Gate needs to be fixed at 60.0.”

If the GCCPRD is going to be a cheerleader and public relations proponent of deepening the HSC to the point of designing and constructing gates that accommodate deeper draft boats then the GCCPRD should clearly state what the additional impacts are of a 55 or 60 foot deepened HSC in this report. Otherwise, GCCPRD should stay out of this other project proposal. The public and decision-makers must have information on all potential environmental impacts so they they can review, comment, and understand the proposal. Absolute transparency is needed.

64) Page E-8, Design Elevations, the same concerns about the Bolivar Roads Gate depth as mentioned above exists for the Neches River Gate since it is authorized for 48 feet but is currently at 40 feet (Page E-5, Neches River Gate, “The ship channel (Figure 1) is 400 feet wide and 40 deep.”) and the “sill elevation or the gates at these locations shall be -52.0.” The environmental impacts of a 52 foot depth for the Neches River Gate and ship channel must be analyzed and revealed in this report. The public and decision-makers must have information on all potential environmental impacts so they they can review, comment, and understand the proposal. Absolute transparency is needed.

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65) Page E-12, Artificial Island for Support Structure, the report fails to state how large each of the two artificial islands will be and how much Galveston Bay bottom will be filled. The report should state clearly what the environmental impacts are and how they will be mitigated. Absolute transparency is needed.

66) Page E-14, Scour Mitigation, the report should state how much the velocity of water will increase due to narrowing of the channel and where erosion and shoaling will occur, how much will occur, and how these environmental impacts will be mitigated.

67) Page E-14, Machinery and Pages E-22 through E-24, the report should state how large the pumps will be, how they will be powered, what back-up pumps or power systems will be used, and what additional air or water pollution will be created by these systems. The report should state for pumps “required to de-water the gate within a reasonable amount of time after the flood water recedes” what a “reasonable amount of time” is. The report should also state how the pumps that will deal with internal rainfall and stream and river flow when the gate is closed will be powered, what back-up pumps or power systems will be used, and what additional air or water pollution will be created by these systems.

If these pumps fail to close the gate and or remove water when the gate is closed the report should state what the environmental impacts are, what the cost is of failure, and how this will be mitigated.

68) Page E-16, Maintenance De-watering, the report should state how de-watered gate water will be monitored to ensure that it is not polluted and needs to be treated.

69) Page E-17, Model Methodology and Development, the GCCPRD states that one of the tree selected flows represents “worst case flows for the Neches River”. In March 2016 the Sabine River hit a flood higher than anything seen since 1884. (Appendix 6) The GCCPRD should model this flood flow and determine how the proposed alternatives affect the flow, circulation, volume, land flooded by the Neches River.

70) Page E-22, Access roads and bridges, the GCCPRD states “new roads, and bridges may need to be constructed on the land side to connect with the roadway on top of the combi-wall.” The GCCPRD should show approximately where these roads and bridges will be and the environmental impacts this will have.

71) Page E-23, Operation & Maintenance (O&M), if steel sector gates are transported by barge to offsite maintenance and repair facilities the GCCPRD should state what impacts this type of transportation will have to the area.

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With regard to electrical systems and back-up power generators the GCCPRD should state how many will be needed, how large they will be where they will be located, how many diesel storage tanks will be required, and what environmental impacts the use and installation of this equipment will have.

Appendix G.1 Cost Estimation

72) Page G-1, Data Cost Library Description, apparently nonstructural solution are not considered seriously since “The cost library contains all the structural protection elements from which unit costs were derived.” So much for fairness and a lack of bias.

73) Page G-1, Identification and Sizing of Major Structures, past iterations of the Coastal Spine Alternative had SH 87/FM 3005 elevated as the “Ike Dike”. The GCCPRD should state clearly whether this version of this conceptual alternative is still being considered or not. The public and decision-makers must have this information to review, comment on, and understand all potential environmental impacts of the proposal.

74) Page G-1, Highway and Railroad Crossings, the GCCPRD states “Minor crossings … were not included in this analysis”. The public and decision-makers must have this information to review, comment on, and understand all potential environmental impacts of the proposal. The GCCPRD should state what impacts it will have on these “minor crossings” what the mitigation will be, what it costs, and how “minor crossings” are defined.

75) Page G-2, Drainage Structures, the GCCPRD “assumes” that box structures will be used as drainage structures and “assumes” that areas with existing protection have adequate existing drainage structures”. The basis for these assumptions should be provided. The GCCPRD should not make such assumptions unless they have a factual basis.

Many local areas flood during rains even even though they are in an area that has existing protection. The overall disruption of the overland flow pattern and volume due to each of the alternatives is not provided in the report. 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 the alternatives. But no modeling or study apparently went into looking at this specific situation and now it will be affected by each alternative.

It would seem that GCCPRD is attempting to bias the decision about alternatives when it fails to even consider this overland flow pattern as well as the protection of the HSC in in the Central Region Alternative #2 (CR#2), Texas City Levee Modifications and extensions North (SH-146) and West-Galveston Ring Levee. After all, by not providing protection to what is acknowledged as the most dangerous risk to Galveston Bay and to certain communities on Galveston Bay

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the GCCPRD automatically creates public opposition to one alternative and thus support for the Coastal Spine Alternative. The Sierra Club has seen this type of action before and the Texas Tribune article, “Houston-area Residents Protest Hurricane Plan”, as enclosed, speaks it its effectiveness. The Sierra Club is concerned about the fairness of this GCCPRD report and its obvious bias on behalf of the Coastal Spine Alternative.

The Sierra Club brought this issue of fairness and bias to the GCCPRD's attention in our Phase I report comments. The Sierra Club states, “Page 112, 9.2 North Region Draft Alternatives, GCCPRD has limited alternatives to be studied almost only to structural alternatives. There is no analysis provided which shows how alternatives were screened in the Step 1 process of “identify and scope the full range of alternatives”. There is nothing in the SSSS Phase I report which states why the alternatives that will be studied have been chosen, what criteria were used to make such decisions, and why these criteria were chosen. There is no mention of how the alternatives chosen will impact bottomland hardwood, cypress-tupelo swamps, and other wetlands in the Sabine River, near Sabine Lake, on the Neches River, in Orange County, on Adams Bayou and on Cow Bayou, Big Thicket National Preserve, etc.

The Sierra Club is concerned that some alternatives are so damaging that they are being looked at and will be rejected so that other alternatives will appear more “reasonable”. Without any criteria provided that were used to “identify and scope the full range of alternatives”, an explanation of why these criteria were chosen, survey or scoring sheets that show how these alternatives were ranked, etc.; the public has no information about how this screening or selection process and the method used for scoring operated and why it was chosen. Such actions keep the public in the dark instead of being transparent.

The “buyout alternative” should not just be ”selective” it should be “significant” and “large” because there are a significant number of homes, businesses, and properties that are in danger and more that will be in danger in the future due to sea level rise (climate change). One way to utilize this alternative is to focus on how many weekend homes there are and their removal. Most alternatives listed in the SSSS Phase I report are overwhelmingly structural in nature when a more balanced approach should be presented.”

This concern remains and the Sierra Club believes the GCCPRD has produced a biased and unfair Phase II report which either does not analyze all reasonable alternatives or so constructs some alternatives so they have little chance of actually being chosen and implemented.

76) Page G-3, Development of Quantities for Levee Sections, GCCPRD “assumes” that borrow areas with suitable material will be located within 10 and 30 miles of the Coastal Spine Alternative. The basis for these assumptions should be provided. The GCCPRD should not make such assumptions unless

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they have a factual basis. The GCCPRD fails to detail and discuss the mitigation required for barrow area operations. GCPRD should define what it means when it uses the phrase “minor regional subsidence”.

77) Page G-3, Proposed Levee Profile, GCCPRD should define what it means when it uses the phrase “minimal armoring”. The GCCPRD should provide a figure profile which documents how 3H:1V, 4H:1V, and 20H:1V are different from each other. The GCCPRD should state clearly what “Additional ROW could be needed for future levee lift events to address future conditions” means and where, how much, costs, etc. this will result in. Certainly, this must be done under cumulative impact since such additional ROW and structural modification and construction costs are “reasonably future foreseeable actions” with cumulative impacts.

78) Page G-5, Development of Cost Elements, GCCPRD states that “Note that elevations listed were selected to address not only present conditions, but are sufficient to address future conditions as well.” The GCCPRD should state what assumptions were used to determine future conditions, what these future conditions are, and now far into the future GCCPRD is looking. This is particularly important when it relates to sea level rise and other climate changes. If future conditions are already taken into account (100 years or more in the future) then GCCPRD should be able to state clearly what the assumptions were to address these future condition in this proposal now. This further emphasizes that GCCPRD should be able to determine and tell the public and decision-makers what additional ROW and structural modifications and constructions costs could arise from each alternative (cumulative actions) and their cumulative impacts.

Although estimated costs are given, with 20-40% overage costs tacked on, the GCCPRD does not provide the public with any information about how accurate these cost estimates are particularly since they are for construction done several decades in the future, involve extremely large structures, and involve highly complex engineered potential alternatives.

79) Pages G-7 and G-8, Levee Sections, the GCCPRD states that it has taken into account “future sea level rise and has a 25% overbuild factor. It is very important that the public and decision-makers know who will fund any potential alternatives and how much the actual costs are. Although estimated costs are given, with 20-40% overage costs tacked on, the GCCPRD does not provide the public with any information about how accurate these cost estimates are particularly since they are for construction done several decades in the future, involve extremely large structures, and involve highly complex engineered potential alternatives.

Future sea level rise estimates, assumptions, and predictions are changing rapidly. Articles enclosed like that from the EPA website, the one entitled

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“Climate Disruption in Overdrive: Submerged Cities and Melting That “Feeds on Itself””, and the one entitled “Rising Waters: How Fast and How Far will Sea Levels Rise?” (Appendices 1 and 2), all point to greater sea level rise that will occur quicker than predicted in the past. That is why it is crucial for this report to have a real “worst-case scenario” regarding sea level rise and not simply deal with something less.

That is why it is particularly of concern when the GCCPRD talks about a 100 year project but then admits that “Lifts to meet target levee elevation over the next 50 years were assumed to fall under the umbrella of future operations and maintenance cost”. What this means is that significant changes to the Coastal Spine Alternative, for instance, are being hidden in O&M costs and not stated upfront as they should be. The 100 year costs for O&M and for “lifts” should be provided to the public and decision-makers to review, comment on, and understand all potential environmental impacts of the proposal.

80) Page G-8, Floodwall Sections and Page G-9, Real Estate, Right-of-Way, and Structures, the GDDPRD must state how good it is to rely on “professional judgment” when sea level rise and other climate change factors are changing for the worse each year. “Best professional judgment” is most helpful in situations (apparently GCCPRD does not use “best” in this report) where you are translating experience to something that is within the experience and insight of the people making the predictions. Climate change is not like that and BPJ will not be sufficient to come up with a workable, long-term, solution.

Page G-8, the GCCPRD should do more than “avoid wetlands where it is “practicable”. Where it is “possible” GCCPRD should avoid wetlands and should not prepare alternatives first and then fit sensitive areas in around them but should be designed first with the idea that sensitive areas will not be impacted.

Page G-9, Table 2, the ROW valuations do not take into account federal, state, local, and private conservation easements and protected lands and utility right-of-ways and their costs. This means the table underestimates the costs that will be paid to replace these lands.

81) Page G-9, Pipelines and Utilities Crossings, the GCCPRD should also mention power-lines as being important ROW crossings.

82) Pages G-10 and G-11, Wetland Mitigation, Table 5, use of National Wetland Inventory (NWI) maps by GCCPRD underestimates the wetlands that will be destroyed because NWI maps do not document all wetlands that exist in an area. Therefore the costs of mitigation for wetlands and other ecosystem losses are underestimated.

83) Appendix G.2, Consolidated GCCPRD Cost Estimate, the GCCPRD uses Spellbottom Mitigation Bank to determine bottomland hardwood forested

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wetlands mitigation bank costs. The location of the Spellbottom Mitigation Bank is about 60 miles north of where the bottomland hardwood forested wetland impacts will occur. The Sierra Club questions whether using costs for a mitigation bank that may not be in the watershed where losses may occur and where mitigation costs may be different than those closer to the cost is appropriate.

84) Appendix G.3, Data Library of Costs, the GCCPRD uses an average of a range of costs 25-35% for the contingency cost chosen, 30%, for calculating costs for this Data Library. However, in the Phase II report 25% and 40% contingency costs are used. The GCCPRD should clearly state why different contingency costs were used and why the one chosen for most of the cost (25%) is less than the 30% contingency cost used in the Data Library.

85) At the March 22, 2016 public meeting, the video on the report kept saying that these alternatives were “conceptual” only. However, the GCCPRD does not define what “conceptual” means so the public and decision-makers do not know how it defines this word. In the Merrian-Webster's Collegiate Dictionary, 11 th

Edition, “concept” is defined as “something conceived in the mind (thought, notion)” or “an abstract or generic idea generalized from particular instances”.

The GCCPRD should make it plain to the public what its use of the term “conceptual” means. The GCCPRD should state the foundation of “particular instances” that these concepts are based upon. In other words, the assumptions made.

86) A number of models are used throughout the report. Some of these include RSMeans, USACE Civil Works Construction Cost Index, ADCIRC, UnSWAN, Federal Emergency Management Agency Flood Insurance Study, Joint Probability Method with Optimal Sampling, etc.

All of these models are only so accurate and precise. The public and decision-makers should be told how accurate and precise each model is. This can be done by providing the plus or minus percent error that each model operates at. The cumulative plus or minus percent error for several models that operate together should also be given so the public and decision-makers know how accurate the numbers or answers are that each model provides.

87) This report ignores climate change in most respects like the Phase I report did. Climate change has altered existing local ecosystems and makes it more difficult for plants/animals to adapt successfully to changed ecosystems across the landscape. GCCPRD, as a part of this SSSS, should prepare and include in the report a climate change Resilient Habitats Plan (RHP).

The RHP assesses the biological and ecological elements of the study area and the effects that climate change has had and will have on the Upper Texas Coast

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where alternatives will be implemented. The RHP would assist plants/animals/ ecosystems to adapt to climate change and would require monitoring of changes and mitigation measure effectiveness. The RHP would be based on:

1. Protection of existing functioning ecosystems in the report study area.

2. Reduction of stressors on the ecosystems in the report study area.

3. Restoration of natural functioning ecological processes in the report study area.

4. Use of natural recovery in the report study area.

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

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

7. Reduction of climate change emissions in the report study area.

The Sierra Club strongly urges that the GCCPRD prepare and implement a RHP for the report as we requested GCCPRD to do for the Phase I report.

The Sierra Club supports a SSS plan that protects coastal environments, keeps the public safe, and does not allow the public to be put or stay in harm's way. Unfortunately, the Phase II report does not do this. The Sierra Club appreciates this opportunity to comment. Thank you.

Sincerely,

Brandt MannchenConservation CommitteeHouston Regional Group of the Sierra Club5431 CarewHouston, Texas 77096713-664-5962brandtshnfbt@juno.com

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