U.S. Army Corps of Engineers 

Attn: George DeLancey, CELRL-RD-MCE 

Lrl.regulatorypubliccomment@usace.army.mil 

 Re: LRL-2021-00750-gjd 

Dear Mr. DeLancey:

Please accept this letter sent both by email and postal mail as the comments of Valley Watch, Inc., a not-for-profit organization headquartered in Evansville, IN whose stated purpose is: “To protect the public health and environment of the lower Ohio River Valley.” Since our formation in 1981, we have worked tirelessly to maintain a semblance of balance between natural, recreational, and industrial uses of our precious Ohio River.

It is in that capacity that we write these comments on the above-referenced proposal currently under review by the US Army Corps of Engineers (Corps). 

First, we ask that the Corps conduct a full-scale public hearing on this proposal prior to taking action on it. We do not recall a recent single issue before the Corps that would negatively impact so many people and is so not needed for the conduct of commerce on the River. 

Dredging and Tow Boat Activity will jeopardize Evansville’s drinking water

Nearly 200,000 human beings rely on the River for drinking water supplied by the Evansville Water and Sewer Utility a couple of thousand feet downriver from the dredging and mooring proposed in this public notice. That water will be severely impacted both by additional mooring and towboat activity that will occur as well as the long-term dredging of rock and sand.

Silt and other debris will continually find its way to Evansville’s drinking water intake. Long submerged contaminants that have been sequestered for decades, if not centuries will be disturbed. Those would include toxic chemicals that last forever, like PCBs and PFAS that will necessitate significant and costly activated carbon treatment that will then have to be adequately removed and properly disposed of. Dispersal of those toxics will not happen sufficiently in such a short distance to mitigate the problem. Pooling of those chemicals is highly likely behind the large dock at Marina Pointe, at Evansville’s water treatment intake, along the entire area known as Dress Plaza, at the new dock housing LST 325, and all along the industrial area that runs a couple of miles before exiting Evansville. 

Aesthetics, Odors, And Recreation On Evansville’s Waterfront

Anything that smells from being disturbed by proposed dredging would have an awful impact on the residents and commercial entities immediately downriver, like Marina Pointe and Tiki Time restaurants, Mickey’s Kingdom children’s playground, the Evansville Museum, and, of course, residents who live in Harbour’s Edge luxury housing development. 

Numerous problems can be foreseen for recreational boaters that dock at Inland Marina or visit the area for food and fun. Increased siltation at the mouth of Inland Marina could potentially be so great that ingress and egress would be badly limited causing financial hardship for the Marina and frustrating weekends for recreational boaters. 

Of course, current recreational use of the River as it passes downtown Evansville would be impacted, both from the land and from the water since the dredge material that escapes would stay relatively concentrated along the northern shore, causing discoloration of the River as it passes one of the nicest waterfronts anywhere on Ohio. In a worst-case scenario, the aesthetics of the Evansville Riverfront could be blemished for as long as the proposal is allowed to operate. Evansville has invested millions in new trails along the River and the use of those highly used trails are likely to be negatively impacted should this proposal be allowed to go forward.

The Ohio River Has Value Well Beyond Transportation And Commerce

While we acknowledge that public policy often favors industrialization and commerce, it is a simple fact that the Ohio River has value far beyond those goals. Currently, there is discussion among the Corps and the Ohio River Basin Sanitation Commission about the “restoration” of the River and its tributaries. A reference point for such restoration is hard to pinpoint. Obviously, as industrial development has taken place, the idea of restoring the River to its original flow is nearly impossible.

However, that does not mean that the entire River should be deemed an industrial corridor where recreational boating is no longer safe or even attractive. Already, numerous coal power plants supplant otherwise beautiful shorelines up and down its length on both sides. Already, numerous ports are in place to foster commercial shipping of a vast number of bulk commodities, some small and some very large. Already, hundreds of barge mooring areas block viewing from adjoining land and beach access for pleasure boats. Already, towboat churn keeps the River from ever being completely clear, resulting in turbid water as boats with massive engines churn the channel during all but a few days a year when water depth prohibits barge transport.

In 2021, the potential for the River for most people is not seen as an industrial corridor or sewer for waste. Indeed, it is increasingly understood that our River is our greatest asset, both for recreation and wildlife. In fact, just upriver on the south shore, a new Green River Wildlife Refuge is underway. There is a discussion that the “purchase” area for that Refuge should incorporate the proposed site since it is a haven for an abundance of species. Bald eagles are an increasingly common sight in the immediate area of this proposal and both commercial and recreational fishing is coming back. To our knowledge, there has been zero assessment of wildlife that would be disturbed along the shore and inland of this proposal, including the endangered Indiana Bat. A thorough environmental assessment of wildlife near and in the impact zone of this proposal should be undertaken prior to a public hearing and issuance of this permit.

To ignore these fundamental quality of life issues would a be a dereliction of the Corp’s duty to protect the River as well as the communities that rely on it fun and quality of life.

The time has passed when permits like this should be routinely issued without regard to the ever-larger picture and the future of our commonwealth.

Just because a single business entity desires to make big bucks from using that commonwealth, does not make it good or moral. Indeed, such a use for this particular resource will jeopardize the well being of thousands of citizens who must rely on the judgment of the US Army Corps of Engineers to protect and adjudicate their interests as well as those who are now attempting to degrade our quality of life and health for monetary gain.

Alternatives 

The applicant for this permit does not have to build here to achieve its goals. There are ample alternatives for such an operation both up and downriver even nearer what we are assuming is the intended target, the construction of what is known as the I-69 Ohio River Crossing. An easy survey of other possible sites showed numerous alternatives both along both sides of the Ohio River as well as near the mouth of the Green River.

Of course, there is also the “no-build” alternative that would preclude such an operation in its entirety. 

While Valley Watch does not desire to eliminate the prospect for Meuth to build and dredge in another location, we strenuously object to the issuance of this permit due to the issues outlined in this letter. 

In fact, we believe that the numerous and important impacts of this proposal warrant, at the very least, a complete Environmental Assessment if not a thorough Environmental Impact Statement as outlined in the National Environmental Policy Act. This permit is a “Significant Federal Action” impacting thousands of citizens. It should be treated as such.

Thanks for the opportunity to file these comments and we reiterate the need for cautious assessment of our concerns and real study of the issues we have outlined in this letter. And again, we ask that an official Public Hearing be held to allow Evansville residents to weigh in on something that could have serious ramifications for the entire city moving forward.

Sincerely,

John Blair, President-Valley Watch

FOOTNOTE: It should be noted that several units of the Evansville Government have also weighed in to oppose this proposal. The Mayor’s office, the Evansville City Council, the Evansville Water, and Sewer Utility, and the Levy Authority have all filed strongly worded comments that hopefully will be influential to the Corps’ decision. I am hopeful that Senators Young and Braun as well as Congressman Buschon will express strong opposition to the project as well since it is their constituents who will be impacted most. Unfortunately, our US congressional delegation often seems to dismiss problematic environmental health concerns in favor of anything that will create even a few jobs.