This letter was sent from the Texas Parks and Wildlife Department to the Corps of Engineers on January 25, 2005 communicating their comments, recommendations, and concern on the Lake Texoma Shoreline Management Plan update.
We applaud the Texas Parks and Wildlife Department for their concerns about the short and long term health of Lake Texoma and related fisheries and wildlife. Their opinions should be carefully considered by all involved.
January 25, 2005
Mr. Ron Jordan Lake Texoma Area Office U.S. Army Corps of Engineers 351 Corps Road Denison, Texas 75020-6425
Re: Lake Texoma Shoreline Management Plan
We appreciate the opportunity to provide comments on the Lake Texoma Shoreline Management Plan (SMP). As the agency responsible for protecting and managing the fish and wildlife resources of Texas, and for providing quality public access to those resources, Texas Parks and Wildlife Department (TPWD) staff is concerned about activities that may have detrimental effects on public natural resources, There is currently considerable pressure on portions of the lake and shoreline from existing and proposed development, and recreation access and demographic trends indicate that this pressure will only increase, it is important that the lake and adjacent shoreline areas continue to be managed to provide good quality habitat for fish and wildlife populations and esthetic opportunities to support the activities of sportsmen and recreationists. Public access to those resources should be provided by means that are not detrimental to the resources.
The current SMP allocates the lake shoreline into different classifications that provide a range of intensity of public access and protection for natural resources. TPWD encourages the Corps of Engineers to at least maintain current levels of classifications of protected and esthetic areas and to strictly enforce existing classifications. Proposed changes of shoreline classification or development on public lands should require public input and coordination with appropriate state resource agency(ies) as part of the completion of an Environmental Impact Statement.
Consideration should be given to returning protected status to important habitat areas that are currently classified for limited development. Development and vegetation alteration within and adjacent to the lake adversely affect fish and wildlife habitats, water quality, and the ability of the public to freely access the shoreline by trail or boat. Higher Intensity recreation infrastructure like parks, golf courses, or private boathouses. such as have been proposed in the vicinity of Grandpappy Point for example, would have significant adverse impacts that could be avoided by implementing a protected shoreline classification.
In addition to terrestrial habitat and water quality impacts from this kind of development, TPWD staff is concerned about the direct and cumulative adverse impacts from continued construction of new private boat docks. While private boat docks are governed by the same rules as commercial boat docks regarding fuel and sewage handling, they are already too numerous for much more than casual inspection. Construction of private boat docks also has direct adverse impacts to on-shore and near-shore fish and wildlife habitats and the stability of the shoreline. Due to the shallowness of some coves, such as Little Mineral Cove East, dredging would be required to access private docks. The credible nature of soils in the area may also require bulkheading to stabilize the shoreline.
Dredging and bulkheading adversely impact fish spawning and nursery areas. Additional private boat docks also detract from esthetics of public recreation areas. Finally, private boat docks tend to limit public access to the shore by boat, particularly in wind-protected areas and coves.
In areas not currently being mowed, the current SMP allows a maximum 30-foot-wide strip of public land to be altered as a buffer for private properties, including mowing, brush-hogging, and tree trimming. Mowing and brush-hogging is allowed from 1 April to 15 November. TPWD staff believes that buffers desired by private landowners between existing managed public lands and private property should be created by activities on the private property rather than by degrading public natural resources. A 30-foot mowed buffer would adversely Impact over 3.6 acres of public habitat resources per mile of public, private land interface. On a large lake such as Lake Texoma. this has the potential to allow the unnecessary cumulative loss of hundreds of acres of public resources. Clearing and frequent mowing also tend to favor the spread of exotic turf grasses and other species from adjacent private lots onto public land. to the detriment of native grasses and ground cover species. This further degrades the quality of public land as wildlife habitat. In addition, the allowed tree trimming, mowing and brush-hogging season coincides with the nesting period of many native birds. including ground-nesting birds. The Migratory Bird Treaty Act (MBTA) implicitly prohibits the intentional and unintentional take of migratory birds, including their nests and eggs: therefore, measures should be taken to avoid impacting them. TPWD staff therefore recommends that the clearing allowance be removed when the SMP is reviewed and updated. If clearing is to be allowed, it should be more restricted in time and frequency to minimize adverse impacts, avoid the nesting period of ground-nesting birds native to the area, and maintain compliance with the MBTA. Activities such as tree felling and vegetation clearing or mowing should occur outside of the April 1 - July 15 migratory bird nesting season. If migratory birds or their nests are present, they should not be disturbed and the U.S. Fish and Wildlife Service should be contacted at (817) 277-1100.
Again, we appreciate the opportunity to provide comments on this plan and look forward to future coordination on the conservation of this important natural and recreational resource. Questions can be directed to Tom Heger in Austin (512- 389-4592).
Sincerely.
Phil Durocher Director of Inland Fisheries Division PD:JRM:TGH:dh
