12-15-2025: RE: Section 106 Consultation - IHNC Lock Relocation Project - Request for Enhanced Mitigation and Clarification
December 15, 2025
U.S. Army Corps of Engineers
New Orleans District
7400 Leake Avenue
New Orleans, LA 70118
RE: Section 106 Consultation - IHNC Lock Relocation Project - Request for Enhanced Mitigation and Clarification
Dear Members of the U.S. Army Corps of Engineers,
Louisiana Landmarks Society appreciates Colonel Autin’s time and productive dialog during the site visit to the Lower Ninth Ward on December 9, 2025. We thank all participants who contributed to making this an informative session where residents felt genuinely heard.
We also acknowledge the progress achieved during the last Section 106 meeting regarding mitigation measures. However, considerable work remains, as numerous critical matters are still unresolved. We look forward to the meeting this week to continue the discussion but wanted to send this to you in advance.
Preservation Mitigation Fund: Methodology and Adequacy
Request for Transparent Verification: We request detailed documentation of the methodology used to establish the $3.5 million preservation mitigation fund. Understanding this calculation's basis is essential to evaluating whether it adequately addresses the project's impacts.
Recommendation for Percentage-Based Calculation: We continue to assert that the preservation mitigation amount should be calculated as a percentage of overall project costs and substantially increased. The project timeline spans thirteen to twenty years, making it impossible to anticipate the full range of variables including construction cost fluctuations, tariff changes, delays, unanticipated damage, and evolving preservation needs.
According to the Supplemental Draft Integrated General Reevaluation Report and SEIS, the lock relocation project is currently estimated at $6.22 billion. The proposed $3.5 million represents only 0.05 percent of this total. Increasing this to even 0.1 percent would yield $6.22 million—still representing just one-tenth of what Louisiana's Percent for Art program dedicates to cultural projects. This proven model demonstrates the viability of percentage-based calculations. The mitigation of entire historic neighborhoods surely warrants at least comparable consideration.
Fund Administration Structure: The mitigation fund's administration requires substantially more planning, with clear structures established before signing the Amended Memorandum of Agreement (AMOA). We strongly oppose distributing funds through a lottery system. Instead, we propose establishing a mitigation trust fund that can:
- Generate investment income for sustainability
- Ensure long-term administration throughout the construction period
- Provide adequate resources for at least one year beyond construction completion
- Address unforeseen disruptions or setbacks beyond the project's direct scope
Adaptive Management Provisions: We request that the AMOA include provisions allowing mitigation fund parameters to be amended as circumstances warrant. No one can accurately forecast expenditure needs two decades into the future. We recommend that while the fund should have a designated administrator, grant awards be guided by an advisory board of community leaders in the Upper and Lower Ninth Wards with comprehensive understanding of the area's specific preservation needs.
Area of Potential Effect (APE) Reassessment
We question the adequacy of the Area of Potential Effect established at the outset of this process. The Corps has indicated that forty percent of the preservation mitigation fund will address buildings outside the designated APE. This allocation suggests the original APE was insufficiently defined and necessitates revisiting and expanding the APE to accurately reflect the project's true impact area.
Community Impact Mitigation Program (CIMP) - Exhibit E
We understand that the CIMP Exhibit E, currently $120 million, addresses mitigation outside the $3.5 million
allocated for historic preservation. We have deep concerns about the economic impacts on communities facing adverse effects during the prolonged construction period.
The business community is essential to neighborhood viability. These establishments have worked valiantly to recover and sustain themselves since the levee breach following Hurricane Katrina. Subjecting them to thirteen to twenty years of construction is certain to impose severe hardship, and the extent and manner of mitigation will be crucial for their survival.
Although substantial funding is allocated, no guidelines or specifics exist regarding fund utilization. Louisiana Landmarks Society requests a separate meeting dedicated to discussing the CIMP and establishing clear guidelines for mitigation expenditures.
Safety and Environmental Protocols
We request a comprehensive safety plan addressing:
- Removal and transport of contaminants from the construction site
- Protocols for securing the area during high-risk events such as hurricanes or severe storms
- Explicit designation of construction companies and the Corps as responsible parties for these safety measures
Additionally, we request the opportunity to review contracts with contractors to ensure they are held accountable for unforeseen damage and safety violations, and that they fully understand and comply with heightened historic sensitivities required in these neighborhoods.
Additional Unresolved Matters
Traffic Congestion Analysis: We request clarification regarding the analysis of traffic congestion resulting from the project scope, including the cumulative traffic impacts from other projects in the area.
Cumulative Effects Coordination: We believe it is critical to discuss the cumulative effects of all concurrent projects in the area and how they will be coordinated to minimize community disruption.
Public Engagement
Our recent conversations with neighbors revealed serious concerns that numerous questions remain unaddressed to residents' satisfaction. We request another public meeting featuring a presentation and question-and-answer session—rather than breaking into separate tables and stations—so that questions and concerns may be comprehensively addressed in a transparent forum where all participants can hear the responses.
Path Forward
Louisiana Landmarks Society looks forward to continuing dialogue and working collaboratively toward solutions that adequately protect our historic neighborhoods and communities. We believe the investments being made in this essential infrastructure project must be matched by proportional commitments to preserving the cultural fabric and economic vitality of the communities it affects, while minimizing risks to their future—physically, culturally, and economically.
Thank you for your continued attention to these critical concerns.
Respectfully submitted,
Sandra L. Stokes
James R. Logan, IV