Letter to Jo-Ellen Darcy, Assistant Secretary of the Army, Civil Works - End Sediment Dumping in Lake Erie

Letter

Dear Assistant Secretary Darcy:

We write today in support of a proposed project modification request pursuant to section 7001 of the Water Resources Reform and Development Act of 2014 (128 Stat. 1360-1364) submitted by the Cleveland-Cuyahoga County Port Authority ("Port of Cleveland") on September 23, 2015.

The project modification would clarify -- for the Cleveland Harbor Project only -- that the Federal standard mandating the use of the least costly, environmentally acceptable dredging plan not include placement of the dredged sediment into Lake Erie, unless approved by the State of Ohio under Section 401 of the Clean Water Act. The modification assures the continued federal maintenance of the Cleveland Harbor Project with upland confined placement of all dredged material. This has been the method of dredged material management since the early 1970s. Extensive study by the Ohio Environmental Protection Agency determined sediment in the Federal channel remains contaminated, posing a potential threat to the local drinking water supply and the level of contaminants accumulating in the Lake's aquatic populations.

The continued maintenance of the Cleveland Harbor Project is critical to the Great Lakes region and the nation. Nearly 18,000 jobs and $1.8 billion of economic activity are tied to the approximately 15 million tons of cargo, primarily iron ore, limestone, steel, heavy machinery and equipment, moving through the Port of Cleveland and the Cuyahoga River channel each year. The Port of Cleveland also provides the only regularly scheduled service to Europe for containerized and non-containerized cargo on the Great Lakes.

The Port, working in conjunction with the State of Ohio, has been an innovative, national leader in creating a viable plan for intercepting commercially valued, bed-load material before it enters the Federal channel. This program has the potential to reduce the annual volume of maintenance dredged material by as much as 15 percent. The Port is also undertaking, as part of its Confined Disposal Facility (CDF) 12 capacity management plan, the harvesting of dredged material for reuse in community improvement and road construction projects. Recycling the sediments will extend the useful life of the CDF and reduce the need to invest in new facility construction.

There has been a great deal of debate surrounding the placement of sediments dredged from Cleveland waters and uncertainty as to whether funded maintenance dredging will be completed on schedule each year. Meanwhile, the concerns of the State and its citizens over the quality of Lake Erie have resulted in a policy decision to soon halt open water placement throughout the State. We share these concerns and support the project modification request by the Port of Cleveland. We believe inclusion of this project modification in the upcoming annual "Report to Congress on Future Water Resources Development" meets the 5 criteria under Section 7001(c)(1)(a) of the Water Resources Reform and Development Act of 2014. This modification will avoid the yearly, unproductive standoffs threatening to injure a major economic engine for the region. The Port should be allowed to continue managing sediments of questionable quality in confined disposal areas to ensure a safe, quality environment for the citizens of Northeast Ohio.

Thank for your attention to this proposal.