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MODA ExpansionMODA Midstream has requested a permit to build a new dock closer to the Brass Turtle for more and larger ships to load oil for export. They will be dredging 43 acres, including 10 acres of seagrass and wetlands next to Ingleside on the Bay (IOB). Please attend the online TCEQ Public Hearing on Tuesday, December 1st, at 7pm and let your opposition be known!
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TCEQ Public Hearing Held on 12/1 at 7pm
About 60 people attended the nearly 3-hour hearing. We've broken down the meeting into 3 separate recordings:
The full 3-hour recording can be accessed here: https://tinyurl.com/MODApublichearing
The full 3-hour recording can be accessed here: https://tinyurl.com/MODApublichearing
Project History and Details
- In February 2020, MODA filed a permit request with the U.S. Army Corps of Engineers (USACE) to expand their west basin toward IOB to include more larger ships. Here are links to MODA's permit application, TCEQ Tier II dredging permit application, and GLO Coastal Management Consistency checklist.
- Several individuals and entities submitted comments, including IOBCWA, Texas Parks & Wildlife (TPWS), U.S. Fish & Wildlife, U.S. Environmental Protection Agency (EPA), and Texas Center for Environmental Quality (TCEQ).
- In September 2020, USACE shared MODA's 95-page response to comments, which also included an Alternatives Analysis (starts p. 39) and a 12-step Mitigation Plan (starts p. 55) of what MODA plans to do in exchange for destroying the seagrass and wetlands).
- In response to concerns from IOBCWA, State Senator Judith Zaffirini and Rep. J. M. Lozano requested that TCEQ hold a public hearing on the Tier II dredging permit aspect of the project, including its consistency (or lack thereof) with the Texas Coastal Management Plan.
- The online hearing was held on Dec. 1, 2020 at 7pm, with about 60 people in attendance.
- All activity on this TCEQ notice (including audio recording of the public hearing) can be found by doing the following:
- Go to the TCEQ home page at www.tceq.texas.gov
- Click "View Pending Matters and File Documents"
- Click "Track the Status" to get to the TCEQ Commissioners' Integrated Database (CID)
- For TCEQ ID Number, enter "20201351MIS" (without the quotes)
- Check the boxes for "Include Filings on this Item" and "Include all correspondence from the public on this item"
- Click the Search button just below the checked items and examine the returned data.
Express Your Concerns about MODA Permit #SWG-1995-02221
- Contact the U.S. Army Corps of Engineers (USACE) in Corpus Christi at 361-814-5847 or swg_public_notice@usace.army.mil
- Contact the Texas Center for Environmental Quality (TCEQ) at https://www14.tceq.texas.gov/epic/eComment/
Problem #1: Loss of Habitat, Shoreline Protection, Safety, and Sanity:
We already know how annoying it was to listen to the banging from MODA as they drilled new pilings over the last couple of weeks. Imagine how disruptive it will be when they drill, dig, and dredge to construct this new dock! And then they have to keep it dredged. They will also be permanently removing what has been fertile seagrasses for flounder and wetlands for seabirds on the Central Migratory Flyway, while leaving the Brass Turtle end of IOB exposed to even more coastal flooding, storm surge, erosion, and relative sea level rise impacts. And let's not forget about the increased possibility of ship collisions, oil spills, and increased fumes and air pollution from generators used while even more ships dock at MODA to load up with oil.
Problem #2: Insufficient Mitigation: To make up for the destruction, MODA is offering to put 70 acres of live oak forest in a permanent easement along the fence line with IOB (see figure below on left). The problem is, this will not make up for the loss of coastal habitat for fish and sea birds. They are also proposing to construct a 2000' breakwater and plant 20 acres of new seagrass - at Port-owned property at Sunset Lake up by Portland (see figure below on right)! How exactly does that compensate IOB for our community's fish and wildlife habitat loss and increased air, noise, and light pollution?
Problem #3: Destruction of Karankawan Site: McGloin's Bluff is a known heritage site of the Karankawa Tribe, who were the first peoples in the region. The area proposed for the additional MODA dock includes further destruction of a known Karankawan archeological site that was eligible for placement on the National Register of Historical Places as described in pp. 8-15 of Current Archeology of Texas. Yet the Indigenous People of the Coastal Bend have not been consulted regarding industrial development taking place here and all around the Coastal Bend.
Solution: Community participation is key! Our legislators are listening; the press is listening; now we need to get TCEQ to listen! Please join us!
We already know how annoying it was to listen to the banging from MODA as they drilled new pilings over the last couple of weeks. Imagine how disruptive it will be when they drill, dig, and dredge to construct this new dock! And then they have to keep it dredged. They will also be permanently removing what has been fertile seagrasses for flounder and wetlands for seabirds on the Central Migratory Flyway, while leaving the Brass Turtle end of IOB exposed to even more coastal flooding, storm surge, erosion, and relative sea level rise impacts. And let's not forget about the increased possibility of ship collisions, oil spills, and increased fumes and air pollution from generators used while even more ships dock at MODA to load up with oil.
Problem #2: Insufficient Mitigation: To make up for the destruction, MODA is offering to put 70 acres of live oak forest in a permanent easement along the fence line with IOB (see figure below on left). The problem is, this will not make up for the loss of coastal habitat for fish and sea birds. They are also proposing to construct a 2000' breakwater and plant 20 acres of new seagrass - at Port-owned property at Sunset Lake up by Portland (see figure below on right)! How exactly does that compensate IOB for our community's fish and wildlife habitat loss and increased air, noise, and light pollution?
Problem #3: Destruction of Karankawan Site: McGloin's Bluff is a known heritage site of the Karankawa Tribe, who were the first peoples in the region. The area proposed for the additional MODA dock includes further destruction of a known Karankawan archeological site that was eligible for placement on the National Register of Historical Places as described in pp. 8-15 of Current Archeology of Texas. Yet the Indigenous People of the Coastal Bend have not been consulted regarding industrial development taking place here and all around the Coastal Bend.
Solution: Community participation is key! Our legislators are listening; the press is listening; now we need to get TCEQ to listen! Please join us!
MODA's Expansion Request - Unavoidable Impacts???
Since buying the former Ingleside Navy Base from the Port of Corpus Christi in 2018, MODA has been constructing oil storage tanks to store Permian Basin oil for exporting to foreign countries. As a result, the old Navy pier has seen nearly constant use by every-larger ships, such as VLCCs (very large crude carriers) and Suezmaxes. Most ships run off generators while loading their cargo, and IOBCWA has recorded significantly higher air pollutants near the Brass Turtle than in other parts of IOB. We have also observed plumes from dredging and ship traffic that are causing silting of seagrasses in the submerged lands off Bayshore Drive. Now, as shown in the figures below, MODA wants to build another dock - even closer to the Brass Turtle - nearly doubling the number of ships! We are concerned that the loss of about 9 acres of seagrass and an acre of wetlands adjacent to IOB will impact area fish and wildlife and that increased traffic at the convergence of two ship channels will jeopardize boater safety and increase air, noise, and light pollution. We also question the need for the project, since oil prices have taken a nose dive - even going negative for awhile during this pandemic. IOBCWA's stance is that MODA should drop this project altogether. MODA says these impacts are unavoidable and that “The consequences of not building the project would result in potential loss of economic growth within the surrounding area and would not meet the needs of Moda's existing and committed future client base”. Is it the job of the Texas Commission of Environmental Quality (TCEQ) to make sure a private industry can meet the needs of its private customers - many (or even most) of which are in foreign countries?
Proposed West Basin Expansion Project closer to Brass Turtle - including seagrasses and wetlands to be destroyed
ARCHIVE: INFORMATION ABOUT 12/1/20 PUBLIC MEETING
Log In: Go to https://www.gotomeeting.com/webinar/join-webinar and enter Webinar ID 770-318- 739. Click HERE for the notice and more details.
Why You Should Care: MODA wants to dredge 43 acres (which will destroy 9 acres of seagrass and 1 acre of wetlands) adjacent to IOB to build a second dock EVEN CLOSER to the Brass Turtle and IOB, increasing number of ship berths to allow more oil tanker traffic on La Quinta Channel.
Participate: During the meeting, ask questions and comment on TCEQ granting MODA's 401 Tier II Certification to dredge. You might include:
Desired Outcomes: To convince TCEQ not to allow MODA to construct a new dock closer to IOB by denying 401 Certification.
Log In: Go to https://www.gotomeeting.com/webinar/join-webinar and enter Webinar ID 770-318- 739. Click HERE for the notice and more details.
Why You Should Care: MODA wants to dredge 43 acres (which will destroy 9 acres of seagrass and 1 acre of wetlands) adjacent to IOB to build a second dock EVEN CLOSER to the Brass Turtle and IOB, increasing number of ship berths to allow more oil tanker traffic on La Quinta Channel.
Participate: During the meeting, ask questions and comment on TCEQ granting MODA's 401 Tier II Certification to dredge. You might include:
- Your personal and family experience with fishing, boating, and living in or near the area
- Observations of how fishing/recreation/air/water has changed since MODA took over the old Navy base in late 2018
- Concerns about what will happen to fish/birds/IOB with more dredging, silting, air & noise pollution, ship traffic, erosion, spill/collision, etc.
- Request that MODA not be permitted to build the new dock next to IOB since it will harm our city by removing habitat & coastal buffer
Desired Outcomes: To convince TCEQ not to allow MODA to construct a new dock closer to IOB by denying 401 Certification.