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The Trash Heap
Full Grown Flour Bluffian
Joined: 06 Mar 2006
Posts: 1932
Location: Corpus Christi
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 Posted: Fri Aug 19, 2011 1:17 pm Post subject: PINS Beach Grooming Application for Corps Permit |
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My response to today's Public Notice: | Quote: | This responds to the materials provided by your agency online at http://www.swg.usace.army.mil/reg/notice/PN2011-00400.pdf and
http://www.swg.usace.army.mil/reg/notice/2011-00400.pdf
On its face, Public Notice 2011-00400 seems innocent enough until you read that one of the proposed permit's purposes is to authorize the removal and deposition of sand along with sargassum weed which might interfere with sea turtle hatchlings reaching the sea. That beach grooming would constitute a connected action, as defined by the President's Council on Environmental Quality Regulations for Implementing the National Environmental Policy Act at 40 CFR 1508.25. (a) 1, since it would be adding to the bundle of activities the Department of the Interior agencies, the National Park Service and the Fish and Wildlife Service, have carried out since about 1978 to implement the Kemp's ridley sea turtle recovery plan. Unfortunately, although these activities include some with reasonably foreseeable significant proposed impacts, like the creation of mass ridley nesting events (arribadas) on the beaches of Padre Island National Seashore, their individual and cumulative impacts ( see 40 CFR 1508.25 (a) 2 ) have never been the subjects of an Environmental Impact Statement. That means the Department of the Army, Corps of Engineers, also requires an EIS before authorizing the connected and cumulative impacts stemming from the beach grooming.
Furthermore, if the current proposal involves the removal of seaweed and a few cubic yards of sand from a fraction of an acre of a discrete project area of beach in response to the controlled release of a few hatchlings during the course of each nesting season, it follows that grooming the beach to assist the movements of tens to hundreds of thousands of hatchlings from the uncontrolled arribadas which are the objective of the DOI's recovery activities would require additional 10/404 permits at larger project sites and at as-yet-undetermined locations within USACOE jurisdiction. Thus, the current application is piecemealing and must be rejected according to USACOE Regulations at 33 U.S.C. 325.1(d)(2).
Consequently, the application for the USACOE Permit 2011-00400 must be withheld from further consideration by your agency until the applicant corrects the piecemealing via the provision of more complete information on the scope of beach grooming activities in response to the arribadas long proposed by the applicant and the FWS. Subsequent to this provision, the USACOE still may not approve the proposed grooming action until it and/or the DOI agencies address in an EIS the individually and cumulatively significant impacts of carrying out the Kemp's ridley sea turtle recovery plan.
Thank you for the opportunity to comment. Please place me on your mailing list for future documents associated with this application.
Sincerely,
Johnny French
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The Trash Heap Has Spoken!
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Rebecca of Sunnybrookfarm
Full Grown Flour Bluffian
Joined: 01 May 2008
Posts: 3974
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| Posted: Fri Aug 19, 2011 3:26 pm Post subject: |
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in addition, as a condition of every other beach cleaning permittee (Port Aransas, City of CC, Nueces County, etc) they are supposed to have INDEPENDENT THIRD PARTY turtle patrolers that go in front of any equipment.
where is the park going to get the money to hire a THIRD PARTY INDEPENDENT turtle patrol?
they shouldn't be allowed to use their own patrols when everyone else has to hire a third party.
PF
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| Central Scrutinizer wrote: | | Thanks for the Memories, Ranger Rick. |
| ziacatcher wrote: | | However I bet if you were fishing naked Ranger Rick would have a problem with that |
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sandollar_sa
Horse Mullet
Joined: 14 Jul 2011
Posts: 146
Location: San Antonio, Texas
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| Posted: Fri Aug 19, 2011 5:18 pm Post subject: |
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 Wait just a yam minute. The park doesn't have "room" in it's budget to clear off the weed for it's patrons (who pay for the privilege), but they're wanting to get more taxpayer dollars to clear it for the stinkin turtles?!
Does anyone but me feel a little marginalized here?
Is there usually this much turtle related activity or is this year especially relentless? |
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The Trash Heap
Full Grown Flour Bluffian
Joined: 06 Mar 2006
Posts: 1932
Location: Corpus Christi
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