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i <br /> <br />the Texas Department of Health should be in place by the time operations <br />begin. <br />Water Quality <br />• The EIS lacks discussion of current water quality for the portion of the bay <br />that would be affected by the construction of this project and subsequent <br />increase in shipping. It noted a few stations with data collected in 1997- <br />1998 but the majority is from Galveston Bay Estuary Program reports <br />dated 1992 and 1994. <br />• The EIS lacks reference to ongoing projects and water quality results from <br />current studies that address dioxin and bacteria which could help <br />determine whether or not the Bayport Ship Channel will be added to the <br />state list of impaired waters. <br />• The EIS lacks discussion on the impact of dredging on water quality for <br />the short or long term. If dredging causes re-suspension of contaminants, <br />the channel would be placed on a list that would require Total Maximum <br />Daily Load studies. <br />• The EIS lacks discussion on the potential impact of increased shipping <br />activity and storm water runoff on water quality. <br />Wetlands/Habitat <br />• Wetlands in the Galveston Bay watershed provide treatment of storm <br />water runoff and buffer floods to reduce storm surges and additionally <br />serve as habitat for wildlife and commercially valuable species. <br />The EIS describes 2.5 acres of wetlands under the jurisdiction of the Corps <br />that will be destroyed and require mitigation and 103.5 acres of non- <br />jurisdictional wetlands. The EIS lacks adequate discussion on the impact <br />of losing these wetlands. <br />• The EIS lacks adequate discussion on the value of wetlands, specific <br />mitigation requirements, or the location of mitigation. <br />Furthermore, we believe that our original concerns remain valid and require a closer <br />examination by the Corps of Engineers. <br />