Mobile Baykeeper submitted a comment letter on the study released by the Corps on the Mobile Ship Channel expansion project. The letter was on behalf of Mobile Baykeeper’s 4,500 members, Board, the Peninsula of Mobile, and Conservation Alabama. Hundreds of community members, several community groups, and local scientists also submitted their own comment letters. The common thread among the letters was the need for the Corps to address major flaws in the study to ensure our natural resources are protected.
We recently submitted comments to the United States Army Corps of Engineers and the Alabama Department of Environmental Management (ADEM) regarding the application to fill nearly five (5) acres of wetlands in the Dog River Watershed to expand a housing development.
We have significant concerns with the amount of wetlands proposed to be filled in the Dog River Watershed, a predominantly developed watershed, that faces constant threats from flooding, shoreline erosion, storm surge, stormwater runoff, and other water quality issues.
You can write your own letter here or by scrolling to the end of this blog post. You will also find a copy of Mobile Baykeeper's comments included at the bottom of this page.
Why is this important?
Dog River is a vital resource in Coastal Alabama for many reasons. It is home to both full-time residents and visitors. Its local restaurants serve fresh, delicious seafood that come straight from the river. It serves as a favorite pastime for many families who spend their days swimming, fishing, boating, and playing on the river. The river plays a crucial role to the health and well-being of our community, environment, and economy. For these reasons we have concerns about filling these wetlands.
What has been done?
The Dog River Watershed Management Plan (DRWMP) was recently published by Mobile Bay National Estuary Program. This plan uses scientific analysis and input from all types of stakeholders, residents, businesses, MAWSS, environmental organizations (including Dog River Clearwater Revival and Mobile Baykeeper) and others within the Dog River Watershed to show the issues impacting the watershed. It also provides clear strategies to reduce pollution and improve water quality.
The wetlands proposed to be filled are part of a vital area of wetlands recommended to be preserved by the WMP.
More generally, the WMP recommends acquiring and preserving existing natural wetlands and creating constructed stormwater wetlands...not filling them. The plan states “The overall health of the greater Dog River Watershed depends upon the existence of its wetlands.” And goes on to say that the watershed has suffered from a drastic loss of wetlands and highlights that the greatest loss of wetlands in the Watershed has occurred as a result of filling wetlands for development.
“Although the loss and conversion of habitat is challenging and expensive to reverse, it is critical to protect and preserve remaining areas of ecological significance such as forests, wetlands, and stream floodplains, which provide a natural filter for pollutants, pathogens, sediment, etc. Failure to protect these wetlands, shorelines, marshes, and forests will exacerbate negative impacts described throughout this WMP.”
-Dog River Watershed Management Plan
The evidence in the Watershed Management Plan makes it clear why additional wetland fill in the Dog River Watershed will have serious negative effects on water quality and the safety and resilience of communities, infrastructure, and resources located within the watershed.
Mobile Baykeeper's main concerns include:
The location of the proposed project is a major concern. The Dog River Watershed is plagued with several issues including flooding, storm surge, shoreline erosion and water quality degradation; any amount of wetland fill will worsen these problems. Furthermore, the proposed wetlands to be filled are considered highly ecologically important to the watershed as a whole.
To fill wetlands you must show that there are no other practical alternatives. Houses do not have to be built in wetlands and, in the case of this application, it is clear that the applicant hasn't done everything practical to avoid wetlands.
If this application is approved:
Mobile Baykeeper urges the Corps to require the applicant to fund restoration and preservation projects identified within the Dog River WMP to fulfill the mitigation requirements. When wetlands are filled, the developer is required to mitigate (lessen) the harm caused by this wetland fill. The Dog River WMP clearly spells out needed restoration and preservation projects in the watershed. If these wetlands are filled, the harm that is caused by that fill can be lessened, or mitigated, by funding these critical projects.
Mitigation should preferentially seek to restore nearby wetlands. Performing required mitigation nearby helps ensure the least negative impact to water quality in the watershed.
Appropriate protection measures should be clearly demonstrated to ensure red clay doesn't fill Halls Mill Creek and Dog River during construction. For protection of the watershed and nearby residents, we strongly encourage the incorporation of Low Impact Development practices into the project to the maximum extent.
- To minimize negative impacts, inspections should be conducted - at least twice a week and after any rainfall of 0.50 inches or greater and a comprehensive plan be created to lay out best management practices and monitoring activities for the project.
The Dog River Watershed Management Plan was created to be an active guide for policy makers, watershed resource managers, and decision makers to strategically manage and protect the watershed. We rely on the health and beauty of Dog River for swimming, fishing, boating, delicious seafood, property values, and so much more.
Mobile Baykeeper urges the Corps to not dismiss the concerted effort made in the WMP and adequately consider it when evaluating this application. Given the above concerns, Mobile Baykeeper recommends denial of this wetland fill application.
Want to write your own letter to encourage these wetlands be protected and not filled?
We've spelled out our main concerns in the pre-drafted letter below. Feel free to edit it until it fits your concerns or just hit send to send your own letter to the Corps and ADEM recommending that they follow the Dog River Watershed Management Plan and protect these important wetlands!
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