MODA Expansion

Located adjacent to Ingleside on the Bay, MODA Midstream purchased the former Ingleside Navy Base in 2018 and now accounts for 25% of U.S. oil exports. The company has requested an amendment to a TCEQ air pollution permit AND requested a US Army Corps of Engineers permit to build a new dock even closer to IOB for more and larger ships to load oil for export - destroying 10 acres of seagrass/wetlands and a known Karankawan historical site in the process.

CURRENT ACTION NEEDED: Submit Comments by 3/29/21 on MODA Air Quality Permit #122362

Go To https://www14.tceq.texas.gov/epic/eComment/ and enter permit "122362":
Step 1 - Describe your relationship to MODA:

Name, address, and phone number
How far you live and/or work from the MODA Oil Terminal
If you are a member of the Ingleside on the Bay Coastal Watch Association

Step 2 - State your opposition and request (all of these):

I STRONGLY OPPOSE MODA’s application to amend air permit #122362
I request a two-week extension of the deadline for comments on account of the recent freeze and loss of electricity in Texas.
I request that a public meeting be held for the community to express its concerns.

Step 3 - In your own words, state your reasons for opposing, such as (whichever apply):

I and/or a family member suffer from a respiratory illness (name it) making it hard to breathe or causing migraines.
I am concerned about an increase in toxic contaminants being released so close to my home and the negative impact it will have on my or my family's health.
I know that the IOB Coastal Watch Association has recently purchased an air monitor which revealed spikes in emissions during the middle of the night on multiple occasions. I am concerned about the threat this poses to human health and what the impact will be when the caps on emissions are increased for MODA Oil Terminal.
I have learned that MODA’s proposed monitoring to demonstrate compliance with emission limits does not require that VOC, NOx, SO2, or H2S emissions be determined directly. In addition, monitoring of particulate matter will only take place on a quarterly basis. I believe this is entirely insufficient to protect the health and safety of an entire community only a few yards away!
I know that stack testing is a procedure to measure air pollutants emitted into the atmosphere and I am seriously concerned that the results of MODA’s stack testing, which undergird its application, are nowhere available to the public! How is the public to properly evaluate MODA’s proposed amendment without full access to meaningful data?
Anything else that concerns you about this permit in your own words, since that's most effective.

Review Documents

Public Notice - posted 1/29/21, comments due 3/29/21
Application - submitted 1/22/21 (290 pages)
Submit Comments Online for Air Quality Permit "122362"
Review Submitted Comments for TCEQ ID# "122362" (include all Correspondence)

JOIN IOBCWA to help us fight Industrial Encroachment in the Coastal Bend!!!

PENDING DECISION: MODA Expansion Project (USACE Permit SWG-1995-02221)

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 public comments on the USACE permit, 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 and 20 people speaking in opposition to MODA.
On Jan. 27, 2021, MODA submits request to TCEQ to amend Air Quality Permit 122362. Here is a link to the permit application.
All activity on TCEQ notices (including comments from public hearings - including audio) can be found by doing the following:
1. Go to the TCEQ home page at www.tceq.texas.gov
2. Click "View Pending Matters and File Documents"
3. Click "Track the Status" to get to the TCEQ Commissioners' Integrated Database (CID)
4. For TCEQ ID Number, enter "20201351MIS" (dredging) or "122362" (air pollution)
5. Check the boxes for "Include Filings on this Item" and "Include all correspondence from the public on this item"
6. Click the Search button just below the checked items and examine the returned data.

Media Coverage

3/15/20 KRIS-TV 6: The oil tanker, Riverside, rams into MODA's pier as it was leaving the dock fully loaded.
3/8/20 Karakawas Blog: Call to action issued to Karankawa and allies re: MODA's planned disturbance of McGloin Bluff Archeological Site (41SP11)
1/4/21 Nueces County Voter (Instagram): IOBCWA Executive Director discusses MODA's failure to follow Texas Coastal Management Plan.
1/6/21 KRIS-TV 6: IOB citizens report unusual odors to TCEQ, as shared in this story on KRIS-TV 6, featuring IOBCWA President Patrick Nye.
1/16/21 KRIS-TV 6: Indigenous People of the Coastal Bend host prayer service to protest MODA's planned destruction of historic Karankawan site.
2/1/21 KRIS-TV 6: IOBCWA President discusses concerns about impacts to seagrasses from MODA's expansion on KRIS-TV 6 segment.

How You Can Express Your Concerns about MODA Permit #SWG-1995-02221

Email the U.S. Army Corps of Engineers (USACE) in Corpus Christi at 361-814-5847 or swg_public_notice@usace.army.mil
Upload comments to Texas Center for Environmental Quality (TCEQ) at https://www14.tceq.texas.gov/epic/eComment/

Problem #1: Loss of Habitat, Shoreline Protection, Safety, and Sanity:
It will be quite disruptive to the neighboring community of Ingleside on the Bay when MODA starts digging and dredging to construct this new dock. And then they will 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

Recording of TCEQ Public Hearing Held on 12/1 at 7pm

About 60 people attended the nearly 3-hour hearing, with about 20 speaking in opposition to MODA's planned expansion. We've broken down the meeting into 3 separate recordings:

The full 3-hour recording can be accessed here: https://tinyurl.com/MODApublichearing