St. Bernard Parish Government (SBPG) concurs with the United States Army Corps of Engineers (USACE) that the referenced project may “significantly impact the quality of the human environment” (USACE, 2020, p. 1). Please see the below comments, questions, and concerns from SBPG regarding potentially significant issues that should be taken into consideration during the upcoming Environmental Impact Statement (EIS) process.
- SBPG is concerned that the operational regime is too ambiguous and has not been properly vetted by critical stakeholder groups.
- SBPG is concerned that the operational regime will continue to evolve in a manner that exacerbates adverse impacts over time.
- SBPG is concerned that the nutrients and contaminants will adversely impact water quality throughout the Breton Basin.
- SBPG is interested in learning more about the sediment-to-water ration being delivered and how the proposed project is expected to perform compared to alternative methods of sediment delivery.
- SBPG is concerned that the land-building capacity of the proposed project is overstated and that the project will likely cause land loss and increase flood risk.
- SBPG is concerned that the natural and human environment (including the local economy) cannot sustain the further loss of productive habitat.
- SBPG is concerned that an additional source of freshwater entering the Breton Basin will place southeast Louisiana in a constant state of environmental and economic crisis that exceeds federal, state, and local capacity and resources.
- SBPG is concerned that the proposed project poses an existential threat to dolphins in the Breton Basin.
- SBPG is concerned that the proposed project will damage or destroy the very natural resources and economic functions that federal, state, and local officials have been tasked with restoring in the aftermath of the Deepwater Horizon event.
- SBPG is concerned that properly mitigating the adverse impacts associated with the proposed project is not feasible and that litigation may cause CPRA and other stakeholder groups to exhaust valuable time and resources.
- SBPG is concerned that the proposed project may do irreparable harm to cultural resources, employment, and income, property taxes, tax revenue, community cohesion, and recreation in eastern St. Bernard Parish.
- SBPG is concerned that the proposed project may disproportionately impact cultural resources, employment, and income, property values, tax revenue, community cohesion, and recreation among minorities, those living in poverty and minority and women-owned businesses.
- SBPG would like the EIS to address the legacy of environmental and economic harm inflicted on St. Bernard Parish as the result of failed public infrastructure projects and other government interventions.
This document can also be viewed in its entirety on the St. Bernard Parish website, under the Coastal Division page.