JUL 3 1 2014 July 30, 20 l 4 Life's better outside.' Commissioners Dan Allen Hughes, Jr. Chairman Beeville Ralph H. Duggins Vice-Chairman Fort Worth T. Dan Friedkin Chairman-Emeritus Houston Roberto De Hoyos Austin Bill Jones Austin James H. Lee Houston Margaret Martin Boerne s. Reed Morian Houston Dick Scott Wimberley Lee M. Bass Chairman· Emeritus Fort Worth Carter P. Smith Executive Director Mr. Robert Jones Regulatory Branch U.S. Anny Corps of Engineers 515 l Flynn Parkway, Suite 306 Corpus Christi, TX 78411-4318 Re: Permit Application Number SWG-2014-00460 Lydia Ann Channel Moorings, LLC Dear Mr. Jones: Texas Parks and Wildlife Department (TPWD) has reviewed the Public Notice for permit application number SWG-2008-00450, dated July 18, 2014. The applicant requests authorization to install 82 individual mooring dolphins, 100-feet apart, on the east side of the Lydia Ann Channel to provide temporary mooring for barges and tug boats inside the Lydia Ann Channel. The mooring structures will be 24inch steel pipe with rubber tires acting as bumpers, concrete filled, and extend 30feet below the bottom surface of the channel. The applicant states the project site contains open water estuarine habitat and sandy unconsolidated bottom. The applicant does not propose any mitigation for proposed impacts. The project is located in the Lydia Ann Channel in Corpus Christi Bay, Aransas County, Texas. This project was presented to Resource agencies at the June 2014 Corpus Christi U.S. Anny Corps of Engineers (USACE) Joint Evaluation Meeting (JEM). Comments and suggestions provided to the applicant included the need to acquire a lease from the Texas General Land Office (TxGLO); to identify, avoid and/or compensate for the potential impacts to seagrass beds in the immediate project vicinity; and to have an emergency pollution action plan. The applicant did not address the above items in the PN project description. TPWD recommends that the applicant address the above three items, as recommended during the JEM. In addition, the applicant should provide information on how the mooring dolphins will be installed in the channel. Due to the proximity of the channel to the Aransas jetties and the Gulf of Mexico, there is a high probability of marine mammals and/or sea turtles in or near the project area. TPWD recommends the applicant develop a monitoring program and action plan, during the mooring dolphin installation, to ensure marine mammals and sea turtles will not be impacted. The applicant should coordinate with the TxGLO Oil Spill Response Division and the U.S. Coast Guard to develop a risk assessment of the local habitats and a pollution response plan. The applicant should provide to the USACE and the resource agencies revised project plans which address the above recommendations. 4200 SMITH SCHOOL ROAD AUSTIN, TEXAS 78744·3291 512.389.4800 www.tpwd.texas.gov To rnan:Jqe . 1nd conservfl ~f1e r1Jtur.1! ;,nil ·::u!tii: .1' r :·::.·Y.irc·:·s ot i 1 ~-.: ~s 1nr1 to prrJvide huntinq, f:sh1nq ,3nd Gu~ctoor .: ,i LI ._'1·'.~~·\·11.~-·1': of :~r.:s(•nt .1:1d future generations. 1 USACE0039 JUL 3 1 20\4 Mr.Jones Page 2 of2 July 30, 2014 TPWD appreciates the opportunity to provide comments and recommendations for this project. Questions can be directed to Paul Silva (361-825-3204) or Leslie Koza (361-825-2329) in Corpus Christi. Sinc;97. y, ~ /§bti ~~/~/,. Rebecca Hensley ./ Regional Director, Ecosystem Re urces Program Coastal Fisheries Division l. RH:LK:PS USACE0040