A little over a year ago, the US Army Corps of Engineers (US ACoE) requested community and stakeholder input regarding the scope of what they should considering in the Environmental Impact Statement (EIS) of their General Reevaluation Report (GRR) proposed deepening and widening of Mobile Bay’s shipping channel, referred to by US ACoE as the Mobile Harbor Federal Navigation Channel.
The letter below was sent by MEJAC to the US ACoE to assist in guiding the scope of US ACoE’s EIS.
MEJAC will be looking for articulate responses to each of the concerns raised in this letter on Thursday, March 16 at US ACoE’s first EIS open house and throughout the GRR process:
Thursday, March 16, 2017
6200 Bayfront Park Drive
Daphne, Alabama 36526
Mobile Environmental Justice Action Coalition
P.O. Box 717
Mobile, AL 36601
February 11, 2016
RE: Public Notice: FP15-MH01-10
Dear Ms. Jacobson:
The Mobile Environmental Justice Action Coalition (MEJAC) was formed in 2013 with the mission being “…to engage and organize with Mobile’s most threatened communities in order to defend the inalienable rights to clean air, water, soil, health, and safety and to take direct action when government fails to do so, ensuring community self-determination”.
MEJAC representatives attended the Mobile District’s January 12, 2016 Public Scoping Meeting for the General Reevaluation Study and Environmental Impact Statement (EIS) to consider deepening and widening Mobile Harbor. This letter identifies the environmental justice issues MEJAC believes should be addressed in the Study and fully analyzed in the EIS to comply with Executive Order 12898. E.O. 12898 requires Federal agencies to assure minority and low-income populations do not experience disproportionately high and adverse environmental and human impacts from Federal activities and projects.
Our organization is most concerned with the indirect, secondary, and cumulative effects that could be induced to occur over time within portions of the Greater Mobile Area as a result of deepening and widening Mobile Harbor. Primary areas of concern are the Africatown Community located on either side of Bay Bridge Road between Three Mile Creek and Chickasaw Creek and the Orange Grove Community located north of Beauregard Street and west of I-65 and Telegraph Road. These two environmental justice communities are located immediately adjacent to Alabama State Port Authority lands and other industrial waterfront properties that depend upon both inland and deep draft navigation.
The potential also exists for other environmental justice communities in the Greater Mobile Area to be affected by the considered enlargement of Mobile Harbor. Extensive rail and truck traffic originate from and have as their destination the Port of Mobile and associated material handling facilities located on both sides of the Mobile River. A wide variety of commodities, ranging from inert to hazardous and flammable are transported to and from the Port each day on the railways and highways that extend from the Mobile waterfront. These overland transportation corridors pass through a wide range of communities and neighborhoods, including those dominated by minority and low-income populations. Even though these communities are located some distance from the Port, they nevertheless have the potential, due to their proximity to major transportation arteries, to be disproportionately affected by Port-related activities should the spill of hazardous or flammable materials in route to or from the Port occur in their vicinity.
MEJAC is also concerned that deepening and widening Mobile Harbor could generate indirect and secondary pressures that could ultimately affect present zoning and land use designations on properties adjacent to and within the Africatown and Orange Grove communities. These two communities are already dealing with a variety of land use issues, including the proposed expansion of an oil storage tank farm and approval of a coal handling facility. The concerns are associated with potential health and safety issues associated with such facilities. For instance, residents of both communities report to us about smelling noxious asphalt and oil fumes on an almost-weekly basis. From oil storage facility Clean Air Act-required Major Source Operating Permits, it is plain to see that these facilities are permitted to release many tons of Hazardous Air Pollutants, all of which are human health hazards, some of which like benzene have no known safe exposure level. Orange Grove residents have maintained frustration with the frequency of upkeep required to keep toxic black coal dust from settling into noticeable piles on their properties.
As is it, community leaders are struggling to not only protect their communities and their residents from such issues, but also to improve their quality of life and to maintain their cultural heritage. For example, through their efforts, Africatown was placed on Mobile’s African American Heritage Trail in 2009 and the Africatown Historic District was designated by the National Park Service and listed on the National Register of Historic Places in 2012. Expansion of the Mobile Harbor project has the potential to introduce a wide range of new land use, zoning, and environmental contaminant challenges for these communities that could threaten their future existence.
Most environmental documents addressing federal projects all too often give only perfunctory attention to environmental justice issues. That must not be the case in the EIS that is to be prepared in connection with the Corps study. MEJAC believes the following steps should be taken and questions addressed in order to assess the potential direct and indirect; primary and secondary; and cumulative effects on the Africatown and Orange Grove communities in particular, as well as other environmental justice communities, as appropriate.
- Identify types of commodities projected to benefit from the project.
- Will any of the anticipated commodities be considered to be hazardous, flammable, toxic, or otherwise deleterious to human health and safety?
- Conduct an air quality analysis model study that includes reliable baselines from these environmental justice communities to assess Clean Air Act “criterion” air contaminants in order to appropriately estimate future potential changes in contaminants of concern to human health and to Mobile County’s present “Attainment” status.
- Assess potential risks to human health and safety as a result of the proposed project.
- Analyze the effects of the project on jobs, income, and other socioeconomic variables that are considered to be indicative of the overall quality of life.
- Identify any other indirect, secondary and/or cumulative adverse socioeconomic and environmental effects potentially associated with project that could impact on the environmental justice communities.
- Will the volume of petroleum products transported via water, rail, and truck be expected to increase?
- Will additional waterfront petroleum storage capacity need to be developed?
- Are increases in coal shipments anticipated and where will any increased coal volumes be stored?
- What future changes will the Alabama State Port Authority have to make to its land holdings along the Mobile River waterfront to accommodate the anticipated commodity movements?
- Identify potential future requirements for additional lands to be converted from existing uses to port and industrial uses as a result of the enlarged ship channel.
- How will the present volume of truck and rail traffic departing from and entering the Port Authority facilities and other waterfront handling facilities be changed?
- Assess the risk for accidents to occur on existing railways and highways.
- Over the 50-year economic life of the project, are any traffic congestion problems anticipated?
One last point to be made, MEJAC highly recommends that the Corps hold an Environmental Justice Workshop in the early stages of work on the Study to give potentially affected low-income communities of color an opportunity to learn about the proposed enlargement of Mobile Harbor, elaborate upon the above listed issues, and voice additional concerns that should be addressed in the study but which may be missed through lack of community engagement.
MEJAC appreciates the opportunity to provide input into the Scoping Process and hopes the Corps will consider the issues we have raised to be relevant to the Study.
Ramsey Sprague, President