On Tuesday, February 17, 2015, the U.S. Army Corps of Engineers, Buffalo District (USACE) hosted a public hearing regarding the dredging of Cleveland Harbor at the request of the Ohio Attorney General. We also conducted a media roundtable on Wednesday, February 18, 2015, to address follow-up questions.
At the hearing, I explained how USACE intends to dredge Cleveland Harbor in 2015 without using open-lake placement of dredged sediment.
This article offers a synopsis of my comments and summarizes some of the key points from our short technical presentation for those citizens who were unable to attend the hearing.
Although I confirmed that USACE will not use open-lake placement to manage Cleveland Harbor sediments in 2015, the focus of our hearing was to describe our scientific analysis that concluded sediment in one portion of the Cuyahoga River federal navigation channel met federal guidelines for safe open-lake placement.
After presenting our findings, we listened to the testimony from several state agencies and many of the approximately 80 attendees who braved the cold temperatures to participate in the hearing at the Burke Lakefront Airport in Cleveland. We welcomed the testimony, and listened to our fellow citizens in order to gain a deeper appreciation for the economic importance of Cleveland Harbor and their concerns regarding Lake Erie’s environmental health.
USACE’s partnership with Cleveland extends back to 1789 when military engineers undertook the exploration of Lake Erie’s southern shorelines during the infancy of the Great Lakes navigation system. Cuyahoga River sediment has impeded safe and efficient navigation for nearly two centuries. In 1824, Congress appropriated $5,000 for USACE to construct piers at the river’s mouth to deal with a recurring sand bar.
The Buffalo District was formally established in 1857 and continues to serve the lower Great Lakes, from Massena, New York, in the east, to the Indiana state line in the west. Our District maintains the federal navigation channels and maintains navigation structures that keep 35 harbors open for business.
I’m privileged to serve as Buffalo District’s 72nd commanding officer. As the commander, I am solely responsible for the actions of our District as we accomplish our mission of delivering vital engineering solutions, in collaboration with our partners, to secure our Nation, energize our economy, and reduce risk from disaster.
We stand for public safety and environmental stewardship. We share in the public’s concern for the well-being of Lake Erie. My family, my staff, and their families in Buffalo, Cleveland, and Toledo enjoy and depend on the tremendous natural resources of Lake Erie. We are your fellow citizens and we care about doing our job in a manner that keeps people, the fish they eat, and the water they use safe.
Our portfolio of projects is almost exclusively aligned with environmental restoration and safe navigation programs, the essential elements necessary to sustain the regional economy and our national security. Buffalo District is committed to restoring and preserving Lake Erie as demonstrated by our substantial track record. Examples include: a range of Great Lakes Restoration Program (GLRI) projects that facilitate delisting of Areas of Concern; partnering to reduce point and non-point source pollution through the Ohio Environmental Infrastructure program; delivering numerous Ecosystem Restoration projects; cleaning up radioactive contaminated sites from the 1940s; and, eradicating invasive aquatic species. We’ve been commended nationally for our sustainable “Green Breakwaters” work in Ashtabula, and we’re piloting projects under the national “Engineering With Nature” program to remain on the cutting edge of sustainability.
Dredging Without Open Lake Placement
Since July 2014, we’ve been promoting a dredging strategy for 2015 that represents a possible “win-win” for all stakeholders. Cleveland Harbor is dredged twice annually with a total requirement of about 225,000 cubic yards (CY) of sediment. This strategy calls for confining 180,000 CY of sediment within Confined Disposal Facilities (CDFs) located next to the outer harbor, and deferring the remaining 45,000 CY that cannot fit inside the CDFs until next year. A quarter of the 180,000 CY would be innovatively handled in the port-operated CDF in a manner that supports beneficial re-use as a commodity, opening the door to a sustainable means of dredging for the future.
This strategy costs an estimated $1.5 million more than is allowed for federal investment and requires a non-federal partner to contribute this difference. Lately, this strategy has become less certain because it appears that there are no partners willing or able to cover these costs.
Many wonder why USACE requested that the State of Ohio consider an application to use open lake placement for management of most Cleveland Harbor sediments in 2015 if alternative strategies like the one just described exist.
The answer is twofold:
First, federal regulations mandate that USACE operates in a manner consistent with the “Federal Standard,” and identifies the least cost alternative that is both technically feasible and environmentally suitable according to federal guidelines. The Federal Standard sets the maximum investment the USACE may make and is the basis against which all other alternatives must be compared. Costlier alternatives can be implemented if a non-federal partner contributes the difference.
Second, with rapidly declining CDF capacity, uncertainty in the ability of non-federal partners to contribute costs, and few beneficial use projects readily available to handle the large annual volume of sediment, Cleveland needs a viable alternative to ensure the navigation channel stays open to support the economy; in other words, the harbor needs a backup plan.
Many stakeholders wonder why the cost of dredging is so important to USACE when evaluating dredge management alternatives. If non-federal partners are unwilling or unable to contribute costs, then why doesn’t the federal government use more taxpayer dollars to dredge in a manner of the State of Ohio’s choosing?
One reason is to ensure consistent application of national policy across all of the states, so that limited funds are distributed equitably.
Our nation is also facing a growing crisis related to the condition of our infrastructure. In simple terms, infrastructure requirements across the U.S. far exceed the investments our country is making, and that means there isn’t enough money to go around. We must be good stewards of both the environment and taxpayers’ money.
The Federal Standard in Cleveland
Cleveland’s federal navigation channel extends six miles upstream from the mouth of the Cuyahoga River. The Federal Standard in the lower five miles of the river (“lower river channel”) remains CDF confinement. These sediments are unsuitable for open-lake placement in part because they have not been recently sampled and tested.
The Federal Standard for sediments dredged from the uppermost mile of the channel (“upper river channel”) is open-lake placement. Sediments from the upper river channel have been sampled, tested, and evaluated with more rigor and scrutiny than in any other Great Lakes harbor. This area is dredged twice annually and does not contain legacy sediments within the navigation channel; rather, the navigation channel sediment originates largely from the Cuyahoga Valley National Park and is deposited due to heavy storm events.
USACE evaluates the suitability of sediment for open lake placement in accordance with Clean Water Act Section 404(b)(1) Guidelines based on protocols prescribed in the “Great Lakes Dredged Material Testing and Evaluation Manual,” and the “Inland Testing Manual.” These manuals provide formal regional and national guidance developed and adopted in concert with the U.S. Environmental Protection Agency (EPA).
Federal scientific experts at the regional and national level have thoroughly reviewed Buffalo District’s analysis and have unequivocally supported our conclusions regarding the suitability of dredged upper river channel sediments for open-lake placement.
To be clear, if the scientific analysis concluded that our actions would have suggested unacceptable risks due to PCB bioaccumulation or other environmental concerns, then I would not determine open-lake placement as the Federal Standard for the upper river channel sediments.
Open-lake placement of upper river channel sediments is safe for Cleveland’s drinking water because the sediments are chemically and physically similar to those on the lake bottom, and the one square-mile placement area is located over nine miles from shore and in sixty feet of water.
In addition, PCB levels in fish will not meaningfully increase as a result of open lake placement of upper river channel sediments. PCB concentrations in the upper river channel sediments are nearly identical to concentrations in existing lake-bottom sediments. While an increase in bioaccumulation in sediment-dwelling worms was evidenced through laboratory testing in some cases, the increase would not translate into any measureable increase in fish due mainly to very low exposure. Finally, laboratory testing on sensitive test species has shown that placement of upper river channel sediment in the lake will not result in toxicity to aquatic organisms.
Encouragingly, Cleveland’s sediment has cleaned up greatly over the years based on enforcement of the Clean Water Act. In fact, the PCB concentrations in the upper river channel sediment are about half less than the criteria used to measure success when cleaning up Areas of Concern associated with the EPA’s GLRI program.
End of the CDF Era
Cleaning up channel sediments has taken longer than originally planned. CDFs were initially built with a 10-year design life. Many thought that would be enough time to confine all of the contaminated sediment; however, most CDFs have been re-worked and used for over 40 years. Many of Ohio’s CDFs are nearly full and USACE seeks to the preserve the remaining space for sediment unsuitable for open-lake placement or other management methods.
Based on decreased pollution and extraordinary construction costs for new CDFs, it’s important to understand that across the Great Lakes we are approaching the end of the CDF-era as we have known it. When conditions are right, beneficial use of dredged sediment may be a way of the future. Ohio’s CDFs could replicate results elsewhere in the Great Lakes and serve as sites to receive, wash, sort, and prepare sediment as a commodity.
It’s important to evaluate the sediment using a rational scientific method, rather than making assumptions based on recollections of the 1950’s and 60’s. After all, the most practical beneficial uses occur in the open water like habitat restoration, beach / littoral nourishment, or capping over contaminated areas of the aquatic environment. While many upland uses of dredged sediment exist such as topsoil creation, construction materials, or filling in basements, the associated transportation costs often prove to be cost-prohibitive.
What’s Next for 2015
USACE is committed to dredge Cleveland Harbor in 2015 without open-lake placement. At this time, we will dredge the lower 5 miles of the Cuyahoga River federal navigation channel and confine the sediment within the federally-operated CDF at full federal cost. We will assist Cleveland's Port Authority to dredge and confine the final uppermost mile of the channel if they are able to identify an appropriate partner who can pay for increased costs as compared to the Federal Standard of open-lake placement.
USACE fully recognizes the importance of dredging Cleveland Harbor to maintain the federal navigation channel for safe navigation and economic viability of the region.
To learn more about our District’s mission, please contact our Public Affairs Office at 716-879-4410.
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