Texas pitcher plant bog in peril

[meadowview]

Hi Folks:

I'm sending in our public comment to a USACE public notice about a road that is planned to be put through a pitcher plant bog in Texas (see
www.swf.usace.army.mil/pubdata/environ/regulatory/public/pn/2010_12/PN_SWF-2009-00404.pdf). Public comment has been extended until tomorrow, Jan. 27. Among several issues here is that the compensation for destroying part of a pitcher plant bog will go to a mitigation bank for FLOODPLAIN species. Mitigation should go to restoring, purchasing, or creating in-kind pitcher plant habitat, not floodplain habitat.

I've talked to the Corps representative mentioned in the notice and he was very helpful and sincerely interested in constructive public comment. Here's you chance to make a suggestion.

Sincerely,

Phil Sheridan, Ph.D.
Director
Meadowview Biological
Research Station

[ICPS-bob]

I agree that the proposed mitigation is inadequate:

Therefore, the applicant has proposed a preliminary compensatory mitigation plan involving the acquisition of wetland credits from the Pineywoods Mitigation Bank. The bank is located in the Neches River floodplain, and the project site is located within the primary service area of the bank. The applicant proposes to compensate for temporary and permanent impacts to 2.08 acres of high quality forested wetland at a ratio of 3 functional credit units per one acre of impacts, totaling 6.3 functional credit units.

The Pineywoods Mitigation Bank (www.pineywoodsbank.com/) is certainly not an "in kind" mitigation. It trades S. alata habitat for bottomland forested wetland.

The statement in the Alternatives section is a strawman.

However, this street is in the City of Tyler’s Master Plan and it is likely that it would be built eventually.

City Master Plans can be changed when important ecological considerations surface.

You can see the S. alata bog area on Google Earth at
32.330° Latitude and -95.345° longitude. Photos coverage is available for 1995, 2005, 2009, 2010

[baylorguy]

As my profile states I am in San Antonio, Texas. Please let me know if there is anything that I can do in addition to contacting the representative listed in the report. I shudder to even think that an entire population is in danger.

[ICPS-bob]

This gets more interesting. Notice that the mitigation is the acquisition (purchase) of wetland credits from the Pineywoods Mitigation Bank -- which is owned by the Pineywoods East Texas Investment Partners, LLC.

We are pleased to announce today the purchase of the nation’s second largest wetland mitigation credit bank from GMO, Neches River Corridor, LP for approximately $16.2 million by the Pineywoods East Texas Investment Partners, LLC (PETIP).

So, there is money to be made by selling wetland credits to developers as offsetting mitigation when they destroy wetlands elsewhere. It would be interesting to investigate the profits associated with owning a mitigation credit bank.

[Michael]

Hi Phil -- thanks for bringing this to peoples attention. I know this is short turn around for folks.

Will they except letters via fax or email tomorrow? Is there anyone in particular a letter should be addressed to?

Curiously, Mike

[meadowview]

Hi Mike:

You can send a letter attached via e-mail today, then mail hard copy. The contact at the Corps is Mr. Fred Land ([e-mail]).

Best,

Phil

[Michael]

Thanks Phil!

I'll get something out this morning! I hope others can take a quick moment and contact them.

Mike

[Brian Barnes]

Thanks Phil for bringing this up.

I'm on it! Sending an email now to said email address...

Brian Barnes,
ICPS Director of Conservation

[meadowview]

Hi Folks:

I just sent the letter to the Corps. It's 2 pages, can I post it here?

I talked to the consultant, Jeremy Rowden, working on the project and he seems like a decent fellow. I made a number of suggestions, including that the road not be built and why. They made great effort to avoid damaging the bog but the bottom line is this sort of thing always has some, negative impact. Also, this bog is in the northern part of the range in Texas in the post oak belt in Smith County and is very valuable from a range wide perspective.

Best,

Phil

[marcel]

I would prefer a link to a letter to the letter itself due to it's size Phil, but if that's not possible you can go ahead.

[meadowview]

Hi Folks:

Here is the text of the letter I sent today to the U.S. Army Corps of Engineers regarding the road impacting the Texas pitcher plant wetland.

"January 27, 2011

Mr. Frederick Land
U.S. Army Corps of Engineers
Fort Worth District

Re: Permit SWF-2009-00404

Dear Mr. Land:

I have reviewed the above cited public notice and have the following comments.

1. The best and most preferred thing that could happen is to simply not build the road through this wetland. While we understand that great effort has been made to minimize impact, and that there are fundamental economics behind the application, there is no getting around ultimate negative impact to the valuable wetland habitat (specifically the pitcher plant bog). Our organization is dedicated to the preservation and restoration of pitcher plant bogs and associated ecosystems. The location of this project is in a critical part of the range of Sarracenia alata (The West Gulf Coast Pitcher Plant) since it is in the northern part of the range and post oak belt. Our experience and study has found that the proposed activity is ultimately detrimental to pitcher plant habitat through siltation, increased storm water flows, and degradation of the complex nutrient and groundwater systems found in pitcher plant habitats.
2. If the road must be built I have several options/suggestions that are preferable to the currently proposed mitigation in floodplain wetlands. Compensation of impact to pitcher plant habitat (which includes the cited forested wetland disturbance in the application - that area was most likely pitcher plant habitat but has succeeded to forest) should be directed to mitigation in pitcher plant wetlands, not floodplain ecosystems.
a. On-site enhancement of pitcher plant bog. This option was discussed in the application but precluded because of development pressures. However, we have successfully used a skid-steer with attached mulching blade to enhance pitcher plant habitat. This tool can be used in conjunction with, or in place of (most likely in this case of an urban setting), prescribed fire as an enhancement method.
b. Transplantation of sensitive plant species from disturbance area to other parts of the bog or to our National Sarracenia Collection at Meadowview. We would be happy to add propagules of this valuable pitcher plant system to our managed collection.
c. Road design and storm water management. The use of porous pavement, infiltration devices, and appropriate aggregate material in outflow devices (use of sandstone or quartz versus high pH limestone or mineral containing rock that adversely impact bog chemistry and enhance weed invasion) to attenuate the negative effects of storm water flow, temperature, and pollution.
d. Mitigation. Three preferred options in hierarchical order.
i. In-kind preservation of a local pitcher plant habitat
ii. Creation of local, synthetic pitcher plant wetland
iii. Regional preservation of pitcher plant habitat
iv. Compensation via purchase of pitcher plant bog in
Virginia for Meadowview

Please let me know if you have any questions about my comments and require further supporting material.

Sincerely,

Phil Sheridan

Phil Sheridan, Ph.D.
Director

[Michael]

Hi Phil -- looks like a good letter. I also sent a letter (it's a little long to post here). I heard from a couple folks who were also going to provide feedback.

Let's keep an eye on this one!

Thanks again for flagging attention on it...

Mike