Catch-22 in South Padre Island
This essay was written in 2019 for an Environmental Policy class assignment in grad school. As of 2025, the 2nd South Padre Island causeway project is underway but it is unclear when construction will commence. “The estimated costs for a project of this magnitude is somewhere between 700 million to $1 billion,” Pete Alvarez, District Engineer with TxDOT Pharr District (Source). On its website, the Cameron County Regional Authority lists that the SPI 2nd causeway is “one of the most critical safety projects in Texas and the most environmentally complex project in the United States” (Source).
I. Introduction
The Town of South Padre Island is expanding into an international ecotourist destination. Not many know about the remote sliver of land off the South Texas coast, but this gem has long been a sought-after vacation destination for anglers, bird-watchers, hunters, and anyone who loves wildlife and the beach. As such, the lives of the town’s residents revolve around the tourism industry and the economy is reliant on visitors. According to their Comprehensive Plan, 56% of all private sector jobs on the island are attributed to the Accommodations and Food Services (hotels and restaurants) sectors and 15 percent are attributed to retail trade (Town of South Padre 2008). Their total dependence on tourism, which fluctuates seasonally, means the majority of associated jobs are low-wage. Average annual incomes per private sector employee on the Island is $14,789, compared to $20,497 countywide and $36,161 statewide (Town of South Padre 2008). To make matters worse, there is currently only one bridge access to the island: the Queen Isabella Memorial Causeway. Busy tourist seasons or hurricane evacuations can cause travel time to be three times longer than the normal trip (Cameron County Regional Mobility Authority 2012). Police have had to close at least one lane hundreds of times and even the entire bridge dozens of times which can completely limit access to and from the island (Cameron County Regional Mobility Authority 2012) This is especially unsafe for residents in emergency situations as there is no hospital on the island (Cuadros 2019).
A second-access project to South Padre Island (SPI) has been in the works for over 2 decades and it is likely going to take much longer (Garcia 2018). The first study TxDOT conducted into a second transportation link occurred in 1997 (Cameron County Regional Mobility Authority 2012). Since then, Queen Isabella Memorial suffered collisions from a small plane and barges, the latter causing 8 deaths and shutting the bridge down for 2 months. During this time, the city “turned into a ghost town, and it wreaked havoc in the county” (Garcia 2018). The town’s economy recovered, but that could be due to the fact Cameron County population has increased 17% from 2000-2019 (Cameron County Regional Mobility Authority 2012). According to the Texas State Data Center, the county is expected to see an additional 33% growth. Many stakeholders agree that the single causeway cannot solely accommodate this amount of growth, which is why SPI also includes a vision statement for 2050 in their Comprehensive Plan that reads:
“A second causeway has been constructed providing an alternative link to the mainland and improved egress for emergency evacuation. The new causeway respects the delicate ecological balance and recreational functions of the Laguna Madre. The design of the causeway and its approach to the island provides a distinctive image as an entry feature or gateway” (Town of South Padre Island 2008).
Several preliminary studies and assessments were conducted to assess the economic and environmental impacts of another causeway. The project is currently (November, 2019) paused at the Environmental Impact Statement, coordinated by the Cameron County Regional Mobility Authority (CCRMA), in the National Environmental Policy Act (NEPA) process. This project was submitted as a toll road to expedite the construction and provide private funding, but after the draft was submitted, TxDOT instituted a ban on new toll road proposals. This ban is expected to last at least another few years (Iglesias 2019).
The Environmental Impact Statement (EIS) for this project highlights the potential for improvement in how developers assess environmental impacts of their projects. I explore the challenges of justifying the development of new infrastructure for social and economic benefits at the expense of the surrounding environment, which, for SPI, is the foundation of their ecotourist economy. I also highlight how the methods employed in this assessment overlook the complex, interconnected character of nature.
II. Overview of the Environmental Impact Statement for the SPI 2nd Access Project
The National Environmental Policy Act (NEPA) is meant to ensure that environmental consequences are considered and publicly available prior to development actions (Council on Environmental Quality Executive Office of the President 2005). The levels of the NEPA procedure include categorical exclusion (for projects with no significant impacts on the environment) an environmental assessment (a more basic, concise impact assessment than the EIS), an EIS, and a Finding of No Significant Impact. The purpose of the act is to identify and assess all environmental impacts to various considered alternatives and report them concisely and in layman’s terms to the public in order to avoid or minimize adverse effects to the human environment (§1500.2 Policy).
The executive coordinator of the Cameron County Regional Mobility Authority (CCRMA), Pete Sepulveda, has said the SPI 2nd Access Project “is probably the most environmentally complex project in the nation that Federal Highway is working on” (Rich 2017b). This is because the causeway is designed to be constructed through extremely sensitive and valuable habitat, both on the mainland and bridge portions. The alternate routes all run east-to-west just south of Laguna Atascosa National Wildlife Refuge (LANWR), over Laguna Madre, and to the island.
A map of alternative routes in the 2nd access causeway for South Padre Island.
The draft EIS for this project took nearly 10 years to complete because of the ecological challenges presented to the CCRMA and the environmental consulting firm (SWCA) they hired. The document is over 500 pages and delineates the direct and indirect socioeconomic and ecological impacts from the construction and induced development from the new causeway. Social and ecological needs and purposes were established, and the proposed alternatives were evaluated based on whether they satisfied those needs and purposes. Listed needs and purposes include (1) improving public safety (an alternate hurricane evacuation and emergency response route), (2) enhancing local and regional mobility (relieving traffic congestion), (3) providing infrastructure for economic development (connect the mainland to “new” undeveloped land and provide more labor to the island) and (4) limiting environmental impact (to Laguna Atascosa Wildlife Refuge, endangered, threatened, or rare species, the migratory bird fallout area, the unique and rare hypersaline lagoon, seagrass beds, and publicly-owned parks and recreational areas).
A table of Need and Purpose evaluation criteria to assess the reasoning for a causeway route.
The public and environmental agencies were involved in the screening process. This involved asking a series of yes or no questions pertaining to the Need and Purpose (i.e. does [this alternative] provide an emergency evacuation route?) (shown in table 1). “A specific effort was made to develop the criteria in a manner that provided a binary response. By providing a ‘meets’ or ‘fails to meet’ response to each category, responses that fall into an intermediate ‘gray’ area would be avoided; thus, minimizing the degree of subjectivity in the process. In addition, this binary response system avoids the issue of establishing an arbitrary standard for meeting the criteria (see table 1) (Cameron County Regional Mobility Authority 2012).”
Other transportation alternations like a tunnel and railway were considered, but ultimately the bridge was the only reasonable solution. Thus, the alternatives discussed in the statement are only regarding different routes for the causeway. The final alternatives (shown in figure 1) were assessed in the remaining chapters by their direct and indirect socioeconomic and environmental impacts. Socioeconomic effects included environmental justice communities, traffic and public safety, and public resources. The statement covered a range of ecological impacts delineated by water resources, soils, vegetation, wildlife, and endangered species. What constitutes a direct impact was not clearly defined, but based on a statement provided by CCRMA’s environmental programs manager, they are impacts within the expected footprint of construction and infrastructure (Iglesias 2019). The Council on Environmental Quality’s (CEQ) definition of indirect impacts, as applied in the EIS, are those caused by the proposed action and occur later in time or farther removed in distance but are still reasonably foreseeable. This may include effects related to expected induced growth in the area or related to effects on air and water and other natural systems, including ecosystems (40 Code of Federal Regulations [CFR] 1508.8) (Cameron County Regional Mobility Authority 2012). Each “notable feature” (shown in table 2) was assessed for indirect effects from (1) encroachment (alteration of behavior and functioning of environment by physical, chemical, and/or biological encroachment on the environment), (2) induced growth from development, and (3) effects related to project-influenced development effects. The acreage impacted, or jobs created for economic associations, of (1) past actions (“subdivisions currently being developed expected to continue”), (2) expected impacts (direct and indirect), and (3) reasonably foreseeable actions were summed for a total cumulative effect. Finally, potential mitigation strategies for direct impacts were suggested and described.
Table 3: Notable features for environmental resources in the study area.
III. Results of the Environmental Impact Statement for the SPI 2nd Access Project
In the final phase of alternative route evaluation, several routes were eliminated for displacing any land with existing commercial facilities. The two that remained were the alternatives with the most significant ecological impact. US Fish and Wildlife Service (USFWS) requested alternative 6 to shift from its original placement to an area with more potential ocelot habitat but avoided impacting a known ocelot corridor. This route also directly impacts 19 more acres of seagrass, but because the other route was longer and would cost more, 6 was chosen. All route alternatives were assessed for socioeconomic and ecological impacts, including a No-Build alternative of possible small-scale construction projects that improve traffic congestion.
The main adverse economic impacts discussed were those associated with the causeway being tolled. It was estimated that 5,000-6,000 people currently commute for work across the existing causeway, and trips are expected to increase nearly 50% by 2030. Using this projection, they concluded that 7,950-9,976 daily commuting trips would be made across the 2nd Access Project. The statement acknowledges that daily commuters would feel the greatest effect of tolling. Based on their own calculations that roughly 40% of their study area were “environmental justice” populations (low-income and/or nonwhite), the commuters from this population “would require a greater proportion of household income of low-income users. However, this relatively minor fiscal impact would be off-set by the anticipated public safety, mobility and economic benefits of the proposed project. (Cameron County Regional Mobility Authority 2012)”. Further, they claimed that the Queen Isabella Memorial Causeway will remain a non-tolled substitute. The cumulative regional economic impact from the causeway was estimated at 113,150 jobs by 2045 (Cameron County Regional Mobility Authority 2012). Throughout the statement, any ecological impacts were justifiable because of the economic growth in the region, as well as the increase in accessibility to ecotourist areas.
The cumulative ecological impacts as calculated include about 20,000 acres to threatened and endangered species, 21,000 acres to rare vegetation and seagrasses, and 22,536 acres to migratory birds. Alternative 6, the preferred route, directly impacts 470 acres of habitat. The EIS recognizes the critical role seagrass beds play, particularly in the lower Laguna Madre. The lower Laguna Madre constitutes the entire study area and makes up more than 75% of seagrass beds on the Texas coast (Onuf and USGS n.d.). Because the east-to-west bridge would shade intensely on the Laguna, significant changes in the community structure would occur. Increased turbidity from the changes in wave hydrology would increase turbidity and reduce light penetration as well. The EIS provides a 2009 analysis of the species diversity and cover, as well as a model estimating the required acreage needed to mitigate the effects of predicted shading. The only anticipated impact related to induced growth for seagrasses was increased development would “likely lead to increased recreational boating in seagrass beds that have previously been fairly isolated from such impacts” (Cameron County Regional Mobility Authority 2012). Climate change and sea level impacts were also notably absent from the document. Alternative 6 impacts 13.54 acres of Piping Plover critical habitat and 107.82 acres of ocelot habitat. Habitat fragmentation was referenced in terms of ecosystem relationships and diversity. The named encroachment-alteration effects on the National Wildlife Refuge was “endangered species habitat fragmentation”, however they claim the construction of the project would “provide better access to the [refuge]. (Cameron County Regional Mobility Authority 2012)” The mitigation strategies mostly entail public agencies (LANWR or USFWS) purchasing land to be conserved and managed. Another strategy listed was donation to agency restoration projects. The possible implementation of wildlife corridors in the causeway would involve planning and coordination with USFWS. The estimated acreage needed for mitigation only accounts for direct impacts.
IV. “Fatal Flaws”
The problematic nature of this EIS is revealed throughout the document but begins in the preliminary screening. As mentioned, a focused effort was made to evaluate the project using criteria that elicited binary responses. This makes sense for social and economic needs and purposes because the project either conforms to the social need or it does not. Either the project provides an alternative route to SPI or it does not, either it is consistent with regional development plans or it is not. However, the complex, continuum behavior of nature does not conform to binary rulings. The criteria used to assess environmental impacts were aimed at minimizing impacts. Each alternative was evaluated as whether it would minimize impact to each notable feature. This presented challenges because the burden to prove impacts will be minimized rests on the mobile authority who is biased towards wanting the development to take place.
The body of the EIS thoroughly assesses impacts according to certain vegetative communities, endangered species, and water bodies. It also briefly mentions purchasing land to supplement the land to be impacted (although only land that would be directly impacted). However, it does not explicitly explain how purchasing other land actually minimizes impacts. Further, the statement acknowledges that an effect of induced growth is that property taxes in the surrounding area will increase, making it more difficult for public agencies to purchase. During the initial screening process, direct impacts to wildlife refuges were considered to be “fatal flaws”, however indirect impacts were not. Since the mitigation strategy described may not actually be feasible, the EIS fails to effectively minimize impacts.
The mitigation strategies suggested also were at fault of having a binary, simplified framework that does not apply to the inherent complexities of an ecosystem. Similar to the cap-and-trade greenhouse gas policy, it was assumed that acres could be selected and traded between development and conservation. Even though habitat fragmentation is mentioned as a negative impact, if the land being potentially purchased is near or adjacent to the impacted acres, the mitigation strategy was deemed effective. This ignores the fact that not all habitats are of the same quality and the focal species in question will still be at risk (the EIS states that “wildlife would be expected to either move to areas away from the roads and other development”). Ecosystems do not behave in pieces, but as a whole. This fragmented structure is reflected in the very architecture of the EIS, which assesses impacts of certain environmental conditions independent of one another. Additionally, those environmental conditions are always specifically related to ecosystem services provided to humans, including charismatic fauna and flora that encourage ecotourism or enhance other economic benefits. In this respect, the anthropocentric mindset of demarcating land into property squares and logically separating and evaluating aspects of the ecosystem independent of each other undermines the capability to accurately assess the holistic impacts of the project.
The EIS continually justifies the project by describing the potential for enhanced accessibility to the island and wildlife areas which will improve economic development for the ecotourism-dependent island. However, the EIS does not assess the effects on the local tourism economy from the direct and indirect impacts to the wildlife areas. Indirect impacts related to induced growth were discussed, but the impacts and costs of providing visitation infrastructure—such as restrooms, trails, and parking— for currently inaccessible natural areas are not considered. The costs associated with nourishment, restoration, and management involved with the visitation of these areas are also not considered.
V. Conclusion
EIS’s such as this one are intensely challenged because as the project’s projected impacts increase in severity and magnitude, it becomes more difficult to compare societal needs with ecological needs. The environment consists of species at risk of becoming extinct, and who require continuous, unpolluted, specialized habitat. Society constitutes people that require incomes, healthy communities, and accessibility to life-enhancing experiences, particularly in nature. The SPI 2nd Access Project is unique in that the justification for the environmental impacts of the project is to support the local economy that is dependent on preservation of the environment. It is clear this is an anthropocentric perspective; as long as humans are able to access and further utilize the environment, the development impacts are justifiable.
The twisted irony of conducting an EIS for a project that will inevitably lead to significant environmental impacts is that no matter how thoroughly the impacts are assessed, the socioeconomic reasoning for the project will always trump the ecological impacts. If the project provides the public and stakeholders with enough researched evidence explaining how impacts were minimized, then the EIS met its purpose. It is challenging, if not impossible, to compare jobs created to acres impacted, particularly when the jobs in question rely on the acres impacted.
The executive director of CCRMA, Sepulveda, recently provided an update on this project. There is a new design for the bridge that is being considered. Rather than construct a single bridge structure connecting all the traffic lanes, he mentioned a twin structure that would separate the two directions (Rich 2017a). He claimed this would reduce the required mitigation acres for seagrass from 130 acres to 6 or 7 which would reduce the cost of the project substantially (Rich 2017a). After asking the environmental program manager, Mark Iglesias, he confirmed this was an estimation of reduction in direct impact (Iglesias 2019). The bridge could still potentially indirectly impact many more acres of seagrass as well as terrestrial habitat, however, as previously mentioned, only directly impacted acres require mitigation efforts.
References
Cameron County Regional Mobility Authority. 2012. “Draft Environmental Impact Statement South Padre Island 2nd Access Project.”
Council on Environmental Quality Executive Office of the President. 2005. 1500–1508 REGULATIONS For Implementing The Procedural Provisions Of The NATIONAL ENVIRONMENTAL POLICYACT.
Cuadros, Alfredo. 2019. “Efforts Underway to Bring Hospital to SPI.” KVEO.com.
Garcia, Raul. 2018. “Second South Padre Island Causeway Quest Stalls.” The Monitor.
Iglesias, Mark. 2019. “CCRMA Interview.”
Onuf, Christopher, and USGS. “Laguna Madre.” Seagrass Status and Trends in the Northern Gulf of Mexico: 1940-2002.
Rich, Kevin. 2017a. “Sepulveda Outlines Second Causeway Plan Changes.” Port Isabel-South Padre Press.
———. 2017b. “Sepulveda: Second Causeway Closer than Ever.”
Town of South Padre. 2008. “Town of South Padre Island Comprehensive Plan.”
