Complete plan published by COE is available at this web site-
http://www.swg.usace.army.mil/reg/pn.asp
Please go and read it and express your own concerns- try to be as specific as possible. Below are a number of concerns that others have delineated.
Below is a sample letter to the Corps of Engineers, letters to TECQ should be about water quality concerns.
Marina Concerns:
1. Insufficient mitigation- there will be a net loss of 5.7 acres of
wetlands. Federal policy is for no net loss of wetlands. Must mitigate
for wetland loss to compensate for loss.
Conservation zone is wetlands that could and should not be impacted
anyway. The uplands being set aside are small narrow swales in between
the wetlands which could not realistically be built on either.
2. This is a public permit for the degradation and use of a public
resource which will then be a private facility. there will be no public
access the the bay from this area, no public fishing area , nor any
public boat launch. The public will suffer from the resultant
degradation of the area without any of the benefits.
3. Bulkheads will prevent loss of wetlands during incremental rising sea
levels projected in the future.
4.. No consideration of the geo- hazard report of the City of
Galveston that placed this project in the red or highest hazardous area.
5. There will be water quality issues with the water n Spanish Grant
canals just like with Anchor Bay's canals tying into the Spanish Grant
canal. Applicant has not demonstrated no water quality degradation.
6. Permit talks of 50' boats- debt of Channel to West Bay will probably
need to be dredged to accommodate draft of 50' boats- no mention of
that.
7. Canal design is essentially more dead end canals which creates
severe water quality issues.
8. Aeration considerations for dead end canals with DO monitoring is
only required for 3 years. The most impact will be occurring after 3
years as the marina and housing becomes more operational and full of
homes.
Monitoring and aeration should be required for the life of the project.
9. Design of canals should be denied due to water quality issues of dead
end canals. The canal area east of Station area is 25% longer than the
longest canal in Spanish Grant which has serious water quality and DO
problems. Consideration of these issues is woefully inadequate in this
permit.
10. There are wetlands south of the proposed Marina on the west side
which will be impacted, directly and indirectly, by the proposed
circulation access channel rather than being renourished by water from
Eckerts bayou, Some of the flow into these wetland would be siphoned off
while the adding reduced DO water into these wetlands. There is no
hydrology study that shows the impact to these wetlands.
11. 600 boat slips and full service boating services will require
tremendous amounts of fuel. Where will the fuel storage tank be built?
As an example, the Yacht Basin services 625 boats a year and uses 1
million gallons of gas a year.
12. Protection of fuel storage from storm damage and spillage is not
addressed.
13. Transportation of fuel into the site is not addressed- it will have
to come in and out a single road- Settegast. Safety and protection of
the citizens and the adjacent wetlands is not addressed.
14. Evacuation of 600 boats prior to storms is not addressed. Will
these boats just end up in Galveston bay or all over the wetlands in the
conservation area??
15. Degradation of adjacent wetlands due to erosion over time is not
addressed- The fill slope ration is 2-1 but the angle of repose for
sand is 3-1 so the sand fill will be silting into the wetlands adjacent
over time. The permit mentions using articulated concrete mats or
concrete rubble revetment along the access and circulation exchange
channels, containing erosion along these surfaces but preventing any
wetland or habitat formation along those channels. the fill along the
north sides of the lots adjacent to the wetland there will erode into
the wetlands. In addition the fill slope ration is too steep to allow
migration of wetlands, thereby effectively destroying the kinds of
wetland there with inevitable sea level rise. No fringe marsh proposed
along these hardened canal edges.
16. permit states all run off from adjacent developed area must be
diverted from the marina basin. This is good for the basin but puts
additional impact on the wetlands. A buffer area needs to be
established around the development for runoff, as well as buffer areas
within the development to accept the runoff before it goes into the
total wetland
area and then into West Bay. There is no management or treatment of
storm water before discharge into wetlands proposed.
17. No addition of chemicals (fertilizers, weed-killers,
pesticides,etc.) outside the buildings must be a condition of the permit
to prevent pollution of the wetlands, especially if there are no buffers
to the wetlands. This is a serious impact to the flora and fauna of the
eco system.
18. Eckerts Bayou will be impacted by the depleted DO water moving in to
it from the circulation canal. This will add to the cumulative impact
of the proposed wastewater discharge into Eckerts by the City of
Galveston wastewater treatment plant at Eckerts. This discharge will
likely only occur during high use summer months . just when the DO
levels are likely to be impaired in the canals and access channel.
19. there is a small pond on the maps north of the access channel not
addressed as an impact, in the permit. Will the morphology character of
this pond change with the adjacent dredging of the access channel?
20. the development of the uplands adjacent to the wetlands completely
blocks the wetland tot the north with the wetlands to the south,
fragmenting habitat and species use, and creates an indirect impact by
preventing the migration of species from the wetlands to uplands and
blocking migration of the wetlands. Also blocks the migration of
species from one section of the wetlands to another creating indirect
impact.
21. There is no spoilage site for maintenance dredging.
________________________________________________________________________
____
MARQUETTE PRESERVE PERMIT
Army corps of Engineers permit #SWG-2007-1958
1. There are many aspects of this permit that can not be commented on
because the application is incomplete. Hydrology studies, archeology
studies, beach erosion, water quality. Please re-notice this permit for
public comment once the reports and studies have been submitted. The
alternative analysis for the mixed use development indicates there is an
avoidance alternative. The avoidance i snot included for public review
and comment. There is also no practicable reason given for why the
avoidance alternative was ignored.
2. There is insufficient mitigation for the wetland impacts. In
particular there is a direct net loss of 65 acres of wetlands with no
provision for "no net loss" of wetlands. Even with the enhanced 10
acres
of palestrine wetlands there is a loss of 65 acres- no mitigation to
prevent net loss.
3. The conservation zone is not contiguous but broken up islands of
space surrounded by highways or housing development. Habitat corridors
and buffers should be provided within the property boundaries to allow
the conservation zones to be connected. Studies vary on necessary width
of corridors or buffers from 75 to 400 feet. It seems reasonable to
require
75 ft corridors with a 10 foot easement buffer for an 85 foot corridor
between buildings and the conservation zone areas.
4. There is no identification of the cumulative direct and indirect
impacts of this project on the wetlands and natural resources of West
Galveston Bay.
5. Wetland swales in Tract 7 being filled is necessary for drainage and
flow.
6. Marquette Development Scenario- with project shows a impact to areas
within development timeline for 5 years. Marquette has told the City of
Galveston that the development timeline will be 20 years. The
differences in impact need to be accounted for. Did the alternative
analysis follow a 20 year build out or a 5 year build out?
7. There is no mitigation plan. The party ultimately responsible for
mitigation is not identified.
8. There is no functional analysis of the wetlands to be impacted and
the proposed mitigation that demonstrates adequate compensation.
9. Storm water management is not addresses. Treatment of storm water
before it is to discharge to the conservation zone, Eckerts Bayou, and
West Bay is not provided. Detention or slowing of storm water is not
addressed. The baseline hydrographic conditions of wetlands within the
conservation zone will be adversely affected by the proposed project.
10. Permit mentions additional wetland construction within the
conservation zone but there is no details of this.
11. The permit states that he HEP indicates the "no- action permit
would result in near total development of all non-jurisdictional uplands
and the resultant isolation of brackish jurisdictional wetlands." This
is an assumption without justification.
12. Permit states the HGM (hydrogeomorphic evaluation) for palustrine
habitat is still in process and yet prematurely assumes all will be
well.
SAMPLE LETTER
Gulf of Mexico fish stocks. USACOE needs to consider the enormous contributions
made by commercial and recreational fishing to the Texas economy, and the real threat
that wetlands destruction proposed by projects like Marquette, Anchor Bay, Spoonbill
Cove, etc will have on the water quality and fishing stocks of Galveston Bay.
Marquette Development has not taken into account the fact that much of its proposed
project would be sited with the “imminent geo-hazard zone” as described by Jim Gibeaux,
John Anderson, and Tim Delapena in the study commissioned (and then ignored) by
City of Galveston, 2007. The geo-hazard report recommends a building moratorium
in the “imminent geo-hazard zone” not only for the safety of the construction projects
and their inhabitants themselves, but for the preservation of the integrity of the
geology of Galveston Island, which such projects as Marquette’s threaten.
Sincerely,
Mark Muhich, chairman
Sierra Club Galveston Group
What Some Of You Have To Say About The Marquette Development
Marquette plan undermines
West End density
Any discussion about development anywhere on Galveston Island must address the concerns of all Galvestonian’s.
In my opinion, every resident of this Island should be concerned, involved and have the chance to comment and vote towards our eventual destiny as a community.
Having an understanding of what development can and cannot do is critical to making an informed decision.
In my notes below, I will try to make those differences clear and outline some actions our city can, and is taking, to make life more enjoyable on our Island for everyone
We know that our wetlands and our open areas on the West and East End are threatened. Perhaps because we have assumed that the farmers and ranchers living and working there would continue to provide us natural beauty free just as they always have done.
Only now are we discovering that others consider these very same open and ecologically sensitive environments in fact, to be under priced acreage ripe for development on a massive scale.
But, think about all of these changes from the perspective of those who live in the community between the East End and Sixty First Street.
To date, the development boom has brought little in the way of positive improvements to streets, drainage or the ability to own a home on our Island.
We still have no public swimming pools, the seawall lacks respectable restroom facilities and our city remains perpetually under funded.
Even those aspects of our economic and social life that had us cheering just a few years ago now are in a constant grab and run posture with City Hall and economic groups like the Park Board. Less money available has hurt just about everything from the downtown arts to Mardi Gras.
We are not doing well as a community and everybody would be advised to pay attention to the difference between development’s promise and our city’s reality.
The City Center has, in truth, experienced a negative impact, not a positive one.
Economic development interests have chased the building boom like a carrot on the proverbial stick at the expense of Commercial Development, which, research shows, benefits any city much more than residential.
The center of Galveston has experienced a backslide in its quality of life (more traffic, increased taxes, fewer neighborhood residents), and that reversal of fortune will continue as long as we allow others to take the best from our community without returning something back to its residents.
The much hyped tax base increases should already be considered spent, and then some.
Every penny will be needed to keep up with increased demands for roads, drainage, water lines and other necessities of living resulting from new developments.
I predict that the ancient drainage system and streets in the central city will continue to receive short shift e.g. Harborside Drive.
New developments on the East and West End are now a primary factor in hollowing out the city’s core.
Perhaps the most striking display demonstrated by East End developers is the purchase of specimen palms from city center neighborhoods and moving these plants to new developments. We no longer have a historic community. Historic Galveston is now being used as one big nursery.
It does not have to end this way and some on City Council recognize this. A recent action to start the East End preserve, by our mayor, is one step in the right direction.
Most notable was a developer on the East End making the first large contribution. But this small step is not enough and much more accountability is required.
The Island needs a coalition of residents (from East End to West End) that are engaged to ensure our government does the responsible thing by providing a certain quality and standard of living for the future of every resident.
Some in Galveston (and a few in government) have asked me what I would do if I could. While the answer is not easy, it is simple.
First, lets halt massive, out-of-scale, irresponsible development long enough to get our own house in order. If not, our house will be paying for this mistake for years to come in taxes and through bond elections.
Second, when we vote next time, vote for any official who has the entire city at heart. A voter alliance from east, west, and central will make sure we have a planned and visionary future for our children.
Third, if you hear any elected official endorse planned, sustainable development on our Island, listen carefully. If you do not hear planned or sustainable development mentioned or if you hear economic development as the rally, ask questions and insist on straight answers.
Fourth, get involved. Demand your Council Representative initiate proposals for Park Development fees and Impact fees so that people who want to buy in our city, contribute to making it a city worth living and become residents.
Fifth, understand that other cities have faced development pressures and are the better for having done so. Responsible government, knowledgeable, united citizens who do not believe in instant cures, and sustainable, planned development have reliably produced cities and residents that equally share a worthwhile future.
Ted Eubanks
Ted Eubanks is a nationally recognized consultant, innovator and author dedicated to governments and municipalities pursuing ecological and sustainable development. He is a founder of Fremata, Inc., a consulting organization that assists clients in policy, guidelines, planning and implementing for communities under pressure to grow and relinquish the environment and culture that originally made them attractive and desirable.
Ted Eubanks is a tireless advocate of sustainable, economic development, a significant contributor to the Galveston community, and a man with a practical and positive vision for our Island. Ted lives in Galveston’s Central Core neighborhoods and is very active in community and government activities in support of planned development.
"PROUD PARENTS"
by: Bob Moore
The photograph "Proud Parents" is an example of just one of the many species of migrant birds we enjoy here on our Island between October and March of every year. Sandhill Cranes are one of fifteen species of Cranes found throughout the world. These "Proud Parents" are models of success. They have achieved another anniversary of successful living. This particular pair of Sandhills have come to this same spot where this picture was taken for the last five years. Each time they have arrived, they bring a young offspring with them. Their juvenile reaches maturity by the time they start their journey back to the Artic Circle in March. They build new nests, lay two eggs, and start their life cycle again.
These noble birds overcome the harshest elements of nature. In their evenings here on the Island they fly at dusk to the same roosts they have used for years in the wetlands of West Bay. They congregate with larger flocks of between 50 to 100 others. Cold sheets of rain pound them incessantly during their winter. While standing on their feet all night, they successfully defend themselves from predators. The ongoing destruction of wetlands repeatedly destroys their roosts. Against all adversity, they continue doing what they were made to do: to fly, shout their resonant calls, prance and dance their courtship antics, mate, lay their eggs, hatch their young, and then fly thousands of miles back south to their winter home again. Sandhill Cranes are one of only two species of Cranes that inhabit the North American Continent. The nearly extinct Whooping Cranes are their cousins.
If you sometimes think that life is getting too tough for us humans, give yourself a break and drive down Settegast Road to see these beautiful creatures during the day. They will remind you that nothing is impossible with God. These elegant members of the animal kingdom have overcome difficulty for the past 40 to 60 million years, survivors of the Eocene period. You can hear in their guttural calls instructions for a successful life. With courage and dignity they demonstrate for mankind their simple formula for success: take from the earth only what you need to live; and give back to life all the beauty you were created to make. Date: February 16, 2007
DEVELOPMENT IS NOT ALWAYS GOOD
The old saying that: "A rose by any other name would smell as sweet"… is not true when referring to a "development."
In his power point presentation at the Pirates Beach Country Club on Saturday, May 19, 2007, Mr. LeBlanc made many denials that he was an "advocate for the Marquette development," yet continued in his verbal and written presentation to sell it! He led us to believe that "development is inevitable" and implied that the City was without authority to stop Marquette’s proposal. His outline explained that ... private property owners rights dominates our City’s best interests. His only critical remark: "Traffic impact: Could be a problem…"
The United States Supreme Court in the case of Lucas v. South Carolina Coastal Council505 U.S. 1003 (1992) gives our City the right to protect Galveston’s best interests first, superior to private land ownership. In that case, the Court ruled that prevention of development under a State Statute did not amount to a taking without compensation, "when a regulation is designed to prevent "harmful or noxious uses" of property akin to public nuisances, and where there is a finding that new construction in the coastal zone threatened a valuable public resource." That language compels our City to deny the requested Zoning Changes and Specific Use Permits of Marquette. Why?
Over 40% of the Marquette land is "wetlands." Wetlands belong to all Americans. Wetlands are that critical piece of nature’s puzzle so vital to both humans and wildlife. The beaches and the bays belong to all citizens of our country. Mr. LeBlanc’s made no mention of the full destruction of wetlands by Marquette nor the acceleration of our beach erosion.
The risk of losing our FEMA Flood Insurance or our Texas Windstorm Insurance by adding another "small city" in the middle of our unprotected and fragile barrier island was not mentioned, nor about the loss of emergency funding from FEMA because of our City’s failure to have a Hurricane hazard mitigation plan.
Our City Council could refrain from making any decisions about Zoning Changes and Specific Use Permits until the Corps of Engineers has processed Marquette’s application to obtain a permit to destroy our wetlands, our beaches and West Bay by this development’s silt and urban runoff. Marquette applied last year for a Corps’ permit, but then withdrew its application in May.
Please urge our City Council to defer taking any action on Zoning Changes and Specific Use Permits for Marquette until the developer has first obtained all Federal and State permits to allow the environmental destruction and to put our insurance coverage’s at risk. Then we will know the truth about the risks we share and the loss of our rights before our City chooses its course for us. We should have the right of full disclosure and an objective investigation of all the facts by our Federal and State agencies before such a crucial decision is made by our City.
About Bob Moore:Bob Moore has been an energetic outdoorsman and naturalist which developed from his many years of hunting and fishing since he was a boy. His environmental activism grew out of his love and passion for nature. As a young lawyer, his love for the beauty of nature was reflected in much of his early work for the extension of environmental legislation.
Through litigation and Public Activism he has donated much of his available time in working to prevent the continuing environmental damage of the waters and wetlands adjacent to West Galveston Bay. These environmental threats are caused by industrial water pollution from Chocolate Bayou and Texas City, second-home real estate development on West Galveston Island, oil and gas drilling activities and air pollution.
ERIC BERGER is the Sci Guy with the Houston Chronicle Here he talks about Galveston and the perils of a sand bar being over developed. You can check out the article in it's entirety here:
http://blogs.chron.com/sciguy/archives/2007/03/galveston_islan.html
"A few years ago Galveston's political leaders, realizing that their island had become increasingly popular with developers, but also realizing that natural forces were working against the barrier island, did a smart thing. They asked scientists -- at the University of Texas-- to determine what parts of their island were most at risk from erosion and rising sea levels. In other words: what parts of Galveston Island should remain undeveloped?"
The study led by Jim Gibeaut, a well respected state geologist, the study has some stark conclusions for the people of Galveston:
- Nearly all the development along the beach front west of the sea wall that protects the core of the island is in red or yellow zones, where Gibeaut says development should not occur.
- Gibeaut said data from the study used to create the map shows that the island will gradually shrink within the next 60 years as it sinks while sea levels rise and the waves slowly chop away the beach.
"The island is in a squeeze play," Gibeaut said.
The sea level is rising at about 6.5 millimeters, or about one-quarter inch, a year, based on data recorded since 1909 from a tide gauge at Pier 21 in Galveston, he said. Gibeaut called the rise "scary" in his appearance before the City Council and Planning Commission on March 8.
Will Galveston planners take the recommendations to heart? I'm not particularly hopeful.
"After Gibeaut's presentation to the City Council and Planning Commission, Councilman Danny Weber was openly skeptical, asking why geologists had not based the study on more favorable data from the past 25 years and used it for their projections. "
"I don't share the same feeling of doom and damnation they share for the island," Weber said in an interview. He said the report showed that a sand retention system was needed to preserve the beaches."
It's one thing to ignore the scientists. It's another thing to willfully misinterpret the data. Here's the water level data for Pier 21, for the last century. The trend seems pretty clear to me -- and the graph doesn't factor in erosion.

Accordingh to Berger....
"Galveston has but a few years to impose mandates on new construction, because in a short while the island's entire west end will be developed. No one's saying people can't live near the beach. What the scientists are suggesting is that it would be prudent to a) avoid development in areas where there will be frequent wash-overs; b) build back from the beach; and c) build at greater elevations."