Letter to the Hon. Gina McCarthy, Administrator, Environmental Protection Agency - Support for Final Designation of Open-Water Disposal Sites

Letter

Dear Administrator McCarthy:

We write to reaffirm our strong support for the final designation of an Eastern Long Island Sound Disposal Site (ELDS). Since the first request for a regional Dredged Material Management Plan (DMMP) in 2005, our region has worked towards building a comprehensive management framework with the Army Corps of Engineers and the EPA to meet long-term dredging and placement needs.

As you know, the EPA's preferred ELDS location, located south of the Thames River Estuary, would consolidate the current New London and Cornfield Shoals Disposal Sites into an area that is two square nautical miles and will be able to meet the dredging needs of eastern Long Island Sound for the next 30 years. As noted in the rule, designation of the ELDS would provide "an environmentally sound, open-water disposal option for possible use in managing dredged material from harbors and navigation channels in eastern Long Island Sound and its vicinity in the states of Connecticut, New York, and Rhode Island." We agree, and believe that approval of this designation is vital to the future of the Long Island Sound region.

Without access to an ELDS it is expected that transporting dredged materials to other sites, like the Rhode Island Disposal Site, will increase carbon emissions from ships and risk of dredged material spills as transport distance is extended. Moreover, the use of the Rhode Island Sound Disposal Site's limited capacity for LIS dredging will have cascading effects on projects throughout Southern New England. Our states have been responsibly dredging in eastern Long Island Sound for over 30 years, which was recently confirmed with an A- rating on the 2016 Long Island Sound Report Card. And, while the ELDS provides a framework for continuing open-water disposal of dredged material, this proposed rule reaffirms the Long Island Sound region's focus on finding sustainable on-land solutions for suitable dredged materials.

In addition to the critical goal of protecting Long Island Sound and its resources, access to ELDS is absolutely vital to the economy of our states and districts -- and that of the entire Long Island Sound region. According to the aforementioned DMMP, economic activities that utilize Long Island Sound waterways contribute more than $9 billion annually in economic output. Additionally, these economic activities support more than 55,000 jobs in the Long Island Sound region. As important, our region is host to a range of federal and military facilities dependent on the viability of accessible and cost-effective placement options. These include facilities like Naval Submarine Base New London and premier submarine builder Electric Boat, with facilities in both Connecticut and Rhode Island.

Approval of the ELDS is critical to maintaining the economic vitality of the Long Island Sound region -- and, in particular, to the maritime, economic, military and recreational interests that rely on it. Long Island Sound is an economic and ecological treasure that we all seek to preserve, and we believe that the ELDS maintains that goal. We must continue to embrace our maritime heritage and support this balanced, sustainable proposal to responsibly manage dredging activities in the sound.

We urge the swift approval and adoption of the ELDS rule without delay. Thank you for your attention to this urgent issue for our region.