Dear Lt. Colonel Beaudoin:
It has come to our attention that the Ohio Environmental Protection Agency (OEPA) and the U.S. Army Corps of Engineers (USACE) disagree about the appropriate disposal of dredged sediment from the Cuyahoga River and Cleveland Harbor. It is our understanding that the USACE believes that the sediment can be placed in Lake Erie without environmental harm and has exclusively pursued the open lake disposal option despite OEPA's belief that the sediment does not meet the environmental standards necessary for this disposal method.
The USACE has recently issued the maintenance dredging request for proposal (RFP) for the Cuyahoga River. This RFP did not include a contingency for placing the dredged sediment in the confined disposal facilities (CDF) should USACE not receive the necessary permit from OEPA for open lake disposal. As you know, dredged sediment from the harbor and river has been placed in the CDFs for decades and sufficient capacity remains for at least two years' worth of additional dredging. In fact, the FY 2014 Omnibus appropriations bill passed by Congress provided the USACE sufficient funding to dredge and dispose of the sediment in the CDF. We are concerned that by failing to include the CDF option in the current RFP, USACE will needlessly delay dredging activities this year.
The maintenance of the Cuyahoga River, Cleveland Harbor, and Lake Erie is critical to Northeast Ohio's economic well-being as the region relies upon the movement of goods across the Great Lakes navigation system. All efforts must be made to ensure timely dredging of the river. Delays would needlessly harm the industries and businesses which rely on the river. We request that USACE immediately amend the bid documents to include a contingency so that all dredged sediment from the Cuyahoga River and Cleveland Harbor can be placed in the CDFs should the OEPA not approve open lake disposal.