IHNC: 9-3-26
September 3, 2026
U.S. Army Corps of Engineers, New Orleans District
7400 Leake Avenue
New Orleans, LA 70118
Re: Supplemental Comment on the Final GRR/SEIS for the IHNC Lock Replacement Project — Violet
Alternative and the Louisiana International Terminal
Dear Corps of Engineers:
This letter follows up on Louisiana Landmarks Society's August 25, 2026 comments on the Final General Reevaluation Report and Integrated Supplemental Environmental Impact Statement ("Final GRR/SEIS") for the IHNC Lock Replacement Project, building on Section IV of those comments, "The Violet Alternative Was Evaluated in Isolation and Does Not Reflect Current Conditions." For years, Louisiana Landmarks Society continually advocated looking at the Violet site with current information, rather than relying on a 36-yearold decision to discard it as a possibility. And to be clear, we are not advocating that either project, the Inner Harbor Navigation Canal (IHNC) lock or the Louisiana International Terminal (LIT), be built at Violet. Our concern is narrower and harder to dismiss: the Corps has never studied whether siting the two together would be more efficient, less environmentally costly, or less expensive than treating them as unrelated projects. That question deserves a real answer before either project moves forward.
I. Two Studies, One Agency, Same Corridor, Never Considered Together
The Corps has run the Section 106 and environmental review process for the IHNC Lock Replacement Project and the environmental review for the LIT at the same time, in the same district, for the same area that includes the St. Bernard/Violet corridor, yet the two have been evaluated in complete silos. The Corps did not include current information about the LIT's Violet development in its IHNC assessment, and it did not include the possibility of an IHNC lock at Violet in its LIT assessment. These were concurrent studies, run by the same agency, for shipping purposes, in the same area. They could and should have been studied together, at minimum, as one of the alternatives.
The Corps rejected Violet as a lock site because of wetland damage, while at the very same site, during the very same period, it was approving comparable or worse wetland and habitat loss for the LIT, without producing a single analysis that looks at both together.
The Final GRR/SEIS is clear that the only reason Violet was taken off the table for the lock was environmental: USACE "determined that a new lock and connecting channels at the Violet site would result in substantial and unavoidable wetland impacts, rendering the alternative environmentally unacceptable," and cited Executive Order 11990 and the Clean Water Act Section 404(b)(1) guidelines as requiring the existing IHNC alignment instead, since it would "result in no loss of wetland or other fish and wildlife habitat" (Executive Summary, p. vii).
The Corps' own 2025 numbers put that impact at 335 acres of marsh wetland permanently destroyed at Violet — 310 acres from the new channel and lock, plus 25 acres from a new channel along the IHNC–Lake Borgne Surge Barrier (Chapter 3, § 3.6.3.2, p. 87). That same section mentions, almost in passing, that "the Port of New Orleans is continuing to move forward with plans for construction of a $1.8 billion container terminal in St. Bernard Parish" at Violet, the LIT, which has already picked up $300 million in federal grant funding (Chapter 3, § 3.6.3.2, p. 87). There's no wetland, vegetation, or farmland impact accounting for the LIT anywhere in the Final GRR/SEIS or its appendices.
The September 2, 2026 NOLA.com article, "Permit for deep-water terminal provides details into Corps' decision clearing way for new facility" ("'A Tremendous Milestone'"), reports that "(n)egative effects include the permanent loss of more than 416 acres of wetland, more than 500 acres of natural vegetation and nearly 556 acres of prime farmland soil," and that's presumably before counting the new St. Bernard Transportation Corridor highway that goes with it. The same article notes the Corps determined LIT was the "least environmentally damaging practicable alternative."
This overlap traces directly back to the project's history. After the MR-GO closed, the IHNC lock project shifted from its original deep-draft design down to the shallow-draft version now on the table, and the Port of New Orleans dropped out of the project. That's the reason the Port's deep-draft ambitions ended up at Violet instead, as the LIT. The Corps can't treat the lock and the LIT as two unrelated projects when its own history shows the same traffic and the same port interests simply moved from one site to the other once the lock was scaled back, which raises the real question: would siting a major deep-draft terminal and a major navigation project together in the same corridor be more efficient than developing them separately? The Corps has never asked, despite having both studies open at once. It has never looked at whether channel, lock, or approach infrastructure could be shared to reduce total cost; whether marsh disruption at Violet from the LIT and marsh disruption avoided by rejecting a Violet lock are being measured against the same baseline; or whether the new highway required for the LIT adds habitat fragmentation and farmland loss that should inform the lock's own alternatives analysis. Evaluating these two projects in silos, when they were moving through the Corps at the same time and serve an overlapping traffic base, is exactly the kind of piecemeal review NEPA's cumulative effects requirements exist to prevent
The only mention of the LIT's impacts anywhere in the Final GRR/SEIS is a traffic footnote, stating that "changes in traffic levels that might occur as a result of the proposed Louisiana International Terminal (LIT) in St. Bernard Parish were considered to have an insignificant effect on traffic at IHNC," based on 2023 data (Chapter 8, § 8.6, p. 212). Nowhere does the document weigh the efficiencies of siting both projects together, or look at their wetland, habitat, and mitigation costs as a combined whole.
That gap matters. If this much wetland and habitat loss is acceptable for the LIT, the Corps can't turn around and use wetland loss at the same site as the reason a lock there is "environmentally unacceptable." We're asking the Corps to put together a real cumulative effects analysis covering both projects at Violet/St. Bernard — one that directly addresses why two concurrent Corps reviews of the same corridor were never combined, and whether siting them together would be more efficient — before any Record of Decision is issued.
II. These Issues Only Make the Project's Shaky Economics Worse
As we laid out in our August 25, 2026 comments, the Final GRR/SEIS's total cost has climbed to $7.563 billion, up from $6.224 billion in the May 2025 draft just fourteen months earlier (Executive Summary, p. viii), while the benefit-cost ratio dropped to 1.01 over that same stretch. Those benefit numbers are built on a forecast of roughly 21 million tons of traffic through the IHNC by 2025, but 2025 tonnage came in at 14.21 million tons, about 32% below what was projected. A project with margins this thin, resting on a forecast that appears overstated, warrants studying whether the two projects together could help minimize or avoid damage and waste.
Bottom line
Before finalizing the plan or issuing a Record of Decision, we're asking the Corps to: (1) explain why the two projects were not studied in tandem; (2) prepare and publish a cumulative effects analysis covering the impacts of both the IHNC Lock Replacement Project and the LIT in a single report; and (3) study whether siting both at Violet/St. Bernard would be more efficient than developing them separately.
We look forward to hearing back, as with our earlier comments.
Respectfully submitted,
Sandra L. Stokes
James R. Logan, IV