10-22-2025: Request for Public Hearing, Section 106 Review, and Cumulative Impact Analysis - MVN-2007-04294- ENP --- Alabo Street Wharf
October 22, 2025
U.S. Army Corps of Engineers
7400 Leake Avenue
New Orleans, LA 70118
Re: Request for Public Hearing, Section 106 Review, and Cumulative Impact Analysis - MVN-2007-04294- ENP --- Alabo Street Wharf
Dear Ms. Page and the U.S. Army Corps of Engineers,
Louisiana Landmarks Society writes this letter in response to your Sept. 22, 2025 Public Notice and joins the neighborhoods in opposing the proposed Sunrise Foods Grain Terminal at the Alabo Street Wharf. We further
equest immediate implementation of a full National Historic Preservation Act (NHPA) Section 106 review and in due course a public hearing in regard to Permit Application No. MVN-2007-04294-ENP.
Section 106 Review Required
Your public notice describes proposed modifications of existing structures and construction of new structures along the Mississippi River, which concededly trigger the Corps’ permitting authority under RHA Section 10 (and possibly CWA Section 404). In turn, these permitting actions, individually or together, constitute an “undertaking” for purposes of the National Historic Preservation Act and regulations promulgated by the Advisory Council on Historic Preservation. Clearly, a full Section 106 review is needed to consider possible impacts on historic resources.
The proposed Alabo Wharf project sits amidst the surrounding Holy Cross neighborhood, a tranquil, largely residential area dominated by affordable shotgun houses and cottages, and a strong sense of community; this historic neighborhood is a designated historic district under both the National Register of Historic Places and the local Orleans Parish Historic District Landmarks Commission. Individual landmarks within the Holy Cross Historic District include Holy Cross School, the Romanesque Revival St. Maurice Church, and, less than 1,000 feet from the project site, the two Doullut Steamboat Houses, both individually listed themselves on the National Register of Historic Places. The proposed project also sits immediately adjacent to Jackson Barracks, another designated National Register Historic District, considered to be one of the finest specimens of antebellum Federal architecture in the nation. We understand that there are other locally designated or National Register-eligible historic properties in the surrounding neighborhood, which also need to be taken into consideration.
The Corps' federal permit authority triggers Section 106 obligations to assess adverse effects on any and all of these irreplaceable historic resources, including, per the ACHP regulations, “reasonably foreseeable effects caused by the undertaking that may occur later in time, be farther removed in distance or be cumulative.” The industrial operations of the new grain terminal atop the Alabo Wharf will bring visual, atmospheric, and audible intrusions into the historic district, which will be incompatible with the neighborhood’s overall character. Increased traffic, noise and dust pollution, decreased property values, family displacement, and other community disruptions will easily flow from the new grain terminal operations.
A train to move grain from the wharf facility will run through the neighborhood, within feet of historic homes, with noise and physical vibrations threatening century-old structures and fundamentally altering their historic setting. Moreover, on a broader level, this particular wharf expansion and its operations will lead to further industrial expansions in the historic neighborhood in the near future. This expansion may already be underway: we understand that Port NOLA, this project's agent, has commenced plans to demolish the historically significant Slaughterhouse buildings—known for their exemplary 19th-century brickwork and their association with the U.S. Supreme Court's 1873 decision that set the stage for Jim Crow laws.
Cumulative Impact Assessment Essential
The Corps will also need to assess cumulative impacts of this proposed grain terminal combined with the IHNC Lock Replacement Project and other proposed projects in the area. These overlapping undertakings will create compounding disruptions to:
- Navigation and emergency access during concurrent construction and operations
- Transportation infrastructure serving both projects
- Environmental resources already stressed by the proposed lock replacement
- Historic properties facing impacts from multiple federal actions
- Community resilience across multiple parishes
- Economic impact to the local communities
A comprehensive cumulative effects analysis under NEPA and Section 106 is necessary before permit approval.
Community Opposition
Since September 2024, this project has faced overwhelming opposition, including resolutions from the New Orleans City Council (see attached R-25-1, Jan. 9, 2025) and the St. Bernard Parish Council and thousands of petition signatures. When LDEQ granted a public hearing on the air permit, Sunrise Foods withdrew rather than face public scrutiny—a troubling avoidance of accountability.
Unacceptable Impacts
The facility would use a rail line running within 20 feet of homes, crossing 27 intersections in under one mile. Twice-daily (and increasing) grain trains would block emergency access, damage historic structures through vibration, sever public transit, and devastate local businesses. Residents face grain dust exposure, excessive noise, blocked driveways, and property devaluation.
This represents a fundamental departure from historic wharf use. It is important to look at alternative sites, such as the industrial site at Avondale Global Gateway which does not disrupt residential areas.
Louisiana Landmarks Society urges the Corps to hold a public hearing, extend the comment period, and conduct a thorough Section 106 consultation that includes a complete cumulative impact analysis with the IHNC Lock project before any decision is made.
We thank you for the opportunity to submit comments, and for your attention in this matter.
Sincerely,
Sandra L. Stokes
James R. Logan, IV