At this point, MEJAC has been engaged in the US Army Corps of Engineers (the Corps) General Reevaluation Report (GRR) Study for more than two years now and very little of our input has seen adequate response from the Corps.
A little over a year ago, MEJAC reacted to the Corps having yet to respond to the initial GRR Scoping input provided a year prior when they announced their first public meeting to gather input for their GRR Study on the proposed enlargement of the Mobile Bay shipping channel, referred to by the Corps as the Mobile Harbor Federal Navigation Channel.
Residents and regional environmental justice advocates have been raising concerns from day one about the impacts of Ship Channel Enlargement. And we still have many concerns:
• What are the study parameters for air quality and traffic?
• When will the public be brought to understand how the air quality baselines are being identified and assessed?
• What air quality pollutants will be analyzed in the baseline and projected “with project” assessments?
• How are “with project” air quality impacts, with respect to increased commodity traffic collateral emissions (i.e. hazardous petrochemical storage tank vapors, coal dust, diesel engine soot, etc.), being assessed?
• When will the future EJ focus group meeting dates be set with enough time to substantively contribute to the Draft SEIS and GRR Study Reports?
• Will there be follow up meetings with EJ focus group participants to facilitate the best understanding of how and why the GRR responded to their questions and concerns?
Today, MEJAC mailed the following letter the to the Corps outlining many questions we still have along with new concerns gleaned after three public meetings and one environmental justice focus group meeting with Africatown community members.
U.S. Army Corps of Engineers
P.O. Box 2288
Mobile, AL 36628
RE: February 22, 2018 Public Meeting and EJ Focus Group follow up
To PD-F of the U.S. Army Corps of Engineers Mobile District:
In review of public statements from officials involved in the Mobile Harbor GRR Study it became apparent that our agency needed to both reiterate the concerns MEJAC and community members have raised about the scope of the Army Corps of Engineers GRR Study into the impacts of the proposed deepening and widening of the Mobile Harbor Ship Channel and to ask a few follow up questions based on our information shared at the public and focus group meetings. Some things are just being left out of the public discourse around the GRR Study and the projected activities.
At the Africatown EJ Focus Group meeting on September 28, 2017, Corps representatives explained that a baseline air quality evaluation of environmental justice communities would be developed and that the estimated impacts of the deepening and widening of the Mobile Harbor Ship Channel would be compared to it. It was also stated that there are currently scoped no more than three specific air modeling studies to answer specific questions.
During a lively exchange therein, Corps representatives succinctly restated concerns from community members about how the study’s scope needed to analyze increases in emissions from products industries like bulk petrochemical storage and transmission from increased throughput due to the ability of products to move more quickly through port facilities owing to the deepening and widening project. To cap off that discussion, Mr. David Newell requested that Corps representatives documented their notes from the evening how the emissions captured in the models needed to reflect projected increases in commodities due to increased flow of traffic moving those commodities through port related facilities. Because of how dangerous petrochemical fumes are, this is a consideration of particular importance to residents and regional EJ community advocates, and we would like assurance that this will indeed be factored into the Corps’ air quality studies and addressed in the analyses conducted for the Draft GRR and integrated supplement to the Environmental Impact Statement.
We would also like to reiterate a concern that MEJAC expressed in our February 11, 2016 public comment on the GRR Scoping Meeting that the baseline for each EJ community be reliable and that both the model and the baseline assess Clean Air Act criterion air contaminants. Our concerns with modeling for baseline assessment persists due to what many reasonable people would consider a dearth of information with which to guide a reliable air quality baseline. We are disappointed that actual monitors will not be employed to take actual measurements and feel like this is the only responsible way to truly assess the air quality impacts of the Alabama State Port Authority’s current level of activities and how the enlargement of the Mobile Harbor project could influence existing conditions.
At another point during the Africatown EJ Focus Group meeting on September 28, 2017, residents inquired about a follow up meeting with the EJ Focus Group participants in order to clearly communicate how the Corps responded to the concerns raised in the focus group settings. MEJAC would like to encourage this consideration as it would help ensure that directly impacted residents remain engaged participants in the project consideration process.
At the February 22, 2018 GRR Town Hall meeting, a MEJAC representative asked about the status of the other EJ focus group meetings similar to the one held in the Africatown community that are to be held for the Orange Grove and Down the Bay communities. The audience received assurances from the Corps that future EJ focus groups are planned. However, MEJAC has concerns about the impact of concerns from these communities will have on the SEIS since the Draft GRR is due to be completed in just a couple of months and those meetings have not even been scheduled. Down the Bay residents have expressed a great deal of concern to MEJAC, and we want to ensure that a reasonable amount of time is provided ahead of the focus group meeting to ensure their attendance.
Therefore, MEJAC requests the Corps to provide a detailed schedule as to how it proposes to conduct all remaining focus group meetings; perform all air quality and traffic studies; and encapsulate the results of these analyses into the Draft GRR and SEIS.
To reiterate in summation, our main questions in this letter are:
If the GRR Study is limited to three air quality modeling studies, what questions will be answered by these studies?
When will the public be brought to understand how the air quality baselines are being identified and assessed?
What air quality pollutants will be analyzed in the baseline and projected with project assessments?
How are with project air quality impacts, with respect to increased commodity traffic collateral emissions (i.e. hazardous petrochemical storage tank vapors, coal dust, diesel engine soot, etc.), being assessed?
When will the future EJ focus group meeting dates be set?
Will there be follow up meetings with EJ focus group participants to facilitate the best understanding of how and why the GRR responded to their questions and concerns?
Once again, MEJAC appreciates the opportunity to provide input, and we pray the Corps and all involved with the GRR Study will find relevance and importance in the concerns and questions raised by our agency and by the communities we serve.
Ramsey Sprague, President