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<br />70. PHA had determined that developing Spilmans Island would be cost-prohibitive, <br />due to its being a spoil disposal site. <br />71. Earlier this year, acting independently of the Port of Houston Authority, Hams <br />County commissioned a study of the cost of developing Spilmans Island. <br />72. This study by Harris County, dated May 2003, concluded that the cost of <br />development of Spilmans Island was substantially lower than had been determined by the Port of <br />Houston Authority. <br />73. The Galveston District has not considered this new study by Harris County in the <br />DEIS or FEIS for Bayport in evaluating Spilmans Island as an alternative site. <br />74. This study by Harris County is new information that significantly affects the <br />evaluation of alternatives to the proposed Bayport site. <br />(4). NEw TOPOGRAPHIC DATA INCREASES ACREAGE OF JURISDICTIONAL <br />WETLANDS <br />75. Wetlands located in the 100-year floodplain of a navigable water are considered <br />jurisdictional wetlands under the Clean Water Act. <br />76. Some of the wetlands at the Bayport site were determined to be jurisdictional <br />because they are in the 100-year floodplain. <br />77. In December, _ 2002, Harris County and the Federal Emergency Management <br />Agency ("FEMA") released updated topographic information for Harris County as part of a <br />study being conducted of the extent of the 100-year floodplains in Harris County. <br />78. The Galveston District is fully aware of Harris County's on-going study with <br />FEMA through which the release of this new topographic information occurred. <br />12. <br />