10-21-2025: RE: Comments on Draft Amended MOA Mitigation Measures - IHNC Lock Replacement Project
October 21, 2025
U.S. Army Corps of Engineers
7400 Leake Avenue
New Orleans, LA 70118
RE: Comments on Draft Amended MOA Mitigation Measures - IHNC Lock Replacement Project
Dear Corps of Engineers:
Thank you for the opportunity to comment on the Draft Amended Memorandum of Agreement for the IHNC Lock Replacement Project. We offer the following comments on the proposed mitigation measures discussed during the recent Section 106 consultation meeting.
Stipulation III.B.1 & III.B.2 - Public Interpretation
We support enhanced public access and interpretation features:
- QR codes at the replacement bridge site linking to historical videos and documentation
- Viewing platforms or tour opportunities at the new lock
- Integration with Crescent Park and interpretive features using levee space
- Historical markers incorporating digital content
Stipulation III.A & III.C – Treatment Measures
- We fully support relocation of historic structures, including the pumping station.
Stipulation III.E.1 - Preservation Fund ($600,000)
The proposed $600,000 preservation fund is grossly inadequate for a multi-billion dollar project with a 14-year construction timeline. At $25,000-$30,000 per home for only 15-20 properties, this amount fails to account for:
- Dramatic increases in construction material costs
- The scale and duration of impacts to the Holy Cross and Bywater National Register Historic Districts
- Inflationary pressures over the extended project timeline
- The true scope of preservation needs in affected historic neighborhoods
- Economic support and sustaining/rebuilding economic infrastructure during and after construction
We recommend this amount be significantly increased and calculated as a percentage of total project cost with built-in escalation provisions to account for inflation and project delays. At minimum, 1% of project cost would be more appropriate, consistent with Louisiana state art program standards. We also request that the money not be restricted to the exterior of buildings only.
Fixed Amounts vs. Percentage-Based Funding
Throughout the mitigation measures, fixed dollar amounts fail to account for inevitable cost overruns, timeline extensions, and inflation over 14+ years. We urge USACE to incorporate percentage-based funding with escalation provisions tied to project cost increases and duration extensions. An "if-then" scenario approach would provide more realistic protection for affected communities.
Stipulation III.F.1 - Vibration Monitoring
We strongly support the National Trust for Historic Preservation's recommendation to include specific vibration thresholds directly in the MOA rather than deferring to a future monitoring plan. The MOA must explicitly state that work stops when thresholds are triggered, vibration damage must be repaired at project expense, and monitoring extends to properties beyond the APE if impacts are detected.
Corps Responsibility
While contractor responsibility for construction damage is noted, the MOA should clarify mechanisms for addressing catastrophic failures and ensuring the community is made whole. Ultimately, this is a federal project with the USACE in charge. There are numerous risks not only from vibrational activity, but from vulnerability, including during hurricanes. While we understand USACE will not waive sovereign immunity, and that contractor fault differs legally from engineering fault, there is still potential for catastrophic failures. Whether to individual structures, multiple properties, or critical infrastructure like levees—the MOA must include explicit provisions committing USACE to work with affected parties to find solutions that make the community whole in such scenarios. The absence of such protections leaves vulnerable historic neighborhoods and their residents exposed to potentially devastating losses with no clear path to recovery.
Stipulation III.H.1 - Marketing Relocation of Historic Bridge
If the St. Claude Avenue Bridge cannot be relocated, we request USACE explore retaining it as a monumental sculpture in an upright position (similar to Chicago's bascule bridge preservation). While we understand channel width requirements present challenges, creative solutions should be exhausted. Money currently allocated to assist a purchaser in acquiring the bridge should be used to preserve the historic structure along with an educational display. If the bridge is set for demolition instead of relocation, money allocated for the move should be redirected to benefit the community.
Stipulation III.I.1 - Design Review
This stipulation should explicitly include consultation with the Historic District Landmarks Commission (HDLC) of New Orleans.
Stipulation III.K.1 - Biennial Reviews
Two-year intervals are insufficient for a 14-year project with varying construction intensities. We recommend staggered review periods: more frequent updates every 6 months during intense construction phases, with longer intervals during less active periods.
Transparency Concern
Finally, we remain deeply concerned about the lack of public access to the 350+ comments received during the SEIS public comment period. As noted in the meeting, it has been customary for the Corps to provide a link on their website to access the communities’ comments. For some reason, it has not been provided for this project, leaving stakeholders isolated and in a compromised position awaiting the Corps’ interpretation and dissemination of comments. We urge USACE to provide a link to access these comments as soon as possible so consulting parties can understand community sentiment on these critical mitigation measures.
We appreciate USACE's consideration of these comments and look forward to continued collaboration to ensure adequate protection of New Orleans' irreplaceable historic resources.
Sincerely,
Sandra L. Stokes
James R. Logan, IV