3-16-2026: RE: Section 106 Consultation — IHNC Lock Replacement Project
March 16, 2026
U.S. Army Corps of Engineers New Orleans District
7400 Leake Avenue
New Orleans, LA 70118
RE: Section 106 Consultation — IHNC Lock Replacement Project
Dear Corps of Engineers:
Louisiana Landmarks Society wishes to express our appreciation for the extension of time and the opportunity to submit comments regarding the March 9, 2026 Section 106 consultation meeting on the Inner Harbor Navigation Canal (IHNC) Lock Replacement Project.
I. Concerns Regarding the Pace and Completeness of the Process
While the most recent meeting addressed substantive elements of the draft Amended Memorandum of Agreement (AMOA), Louisiana Landmarks Society remains concerned that the document is being advanced toward execution under an arbitrary internal deadline without adequate resolution of essential procedural matters. We acknowledge the Corps of Engineers’ request for track changes to the document; however, many of our most significant concerns fall outside the scope of currently drafted provisions and require broader deliberation.
II. CIMP and AMOA Coordination
Louisiana Landmarks Society formally
requests a copy of the revised Community Impact Mitigation Plan (CIMP), as well as an in-depth discussion to fully understand the relationship between the CIMP and the AMOA mitigation funds. Without access to this document, it is not possible to fully evaluate where the responsibilities and funding boundaries between the two instruments are drawn. Any party charged with administering the AMOA and/or mitigation funds will face significant operational challenges absent a clear delineation of what is covered by the CIMP and what falls under the AMOA.
We also note that it was stated during the March 9, 2026 meeting that all components of this effort constitute a single, unified project and will be submitted concurrently. If this is correct, it follows that completion of the Section 106 process need not precede finalization of the CIMP. We respectfully ask that the sequencing of these documents be adjusted to allow proper understanding and discussion.
III. Contaminated Soils, Site Security, and Emergency Preparedness
Consistent with our request during the meeting, Louisiana Landmarks Society asks to be directed to all relevant documents pertaining to the removal and transportation of contaminated soils from the project site. We further request that the AMOA include a comprehensive hurricane preparedness plan that addresses how this large construction site will be secured during a storm event, as well as detailed transportation and logistics plans for vehicles, heavy equipment, and water vessels.
IV. Mitigation Fund Administration and Eligibility
Louisiana Landmarks Society reiterates its objection to the use of a lottery system for allocating AMOA mitigation funds. Such a mechanism is, by its nature, arbitrary and does not allow for the exercise of informed judgment by community stakeholders and fund administrators. We urge that the AMOA be revised to permit allocation decisions based on demonstrated need, strategic priority, and prevailing circumstances.
We further note that 25% of AMOA mitigation funding is designated for expenditure outside the current Area of Potential Effect (APE) – an acknowledgement that the effects extend beyond the defined APE. Given that the impacts of this project will be felt throughout the Lower Ninth Ward, we request that the APE be formally extended so as not to limit needed mitigation.
V. Mitigation Fund Adequacy and Economic Adjustment
Louisiana Landmarks Society appreciates the increase in mitigation funding from $3.5M to $20M as well as the provision for inflation-based adjustments. However, we believe that a formula tied solely to inflation is insufficient to protect the purchasing power of the fund over the life of the project. As recent developments in supply chains and trade policy demonstrate, construction costs are subject to a broad range of economic pressures—including material costs, labor availability, tariff impacts, and change orders—that may not be captured by standard inflation indices. We request that the AMOA include a more comprehensive escalation mechanism that accounts for these variables.
VI. Cumulative Effects and Incomplete Section 106 Analysis
Of paramount concern to Louisiana Landmarks Society is the inadequate treatment of cumulative effects within the current Section 106 consultation. While the topic has been raised briefly in prior meetings, a substantive analysis and discussion has not been afforded. A number of concurrent and planned projects in the area will interact with—and be affected by—the IHNC Lock Replacement, and the full scope of these combined effects must be thoroughly evaluated before the process can be considered complete.
VII. Adequacy of the Consultation Process
Louisiana Landmarks Society recognizes the considerable number of meetings that have taken place throughout this consultation. Quantity of engagement is not equivalent to quality, however, and we remain concerned that the consultation has not provided adequate answers to questions asked, nor the opportunity for substantive discussion on the matters most critical to our mission and to the communities we serve.
From the outset of this process, the project has been framed primarily in terms of national economic benefits, with insufficient attention paid to the risks it poses to the City of New Orleans and its historic neighborhoods. Louisiana Landmarks Society continues to question whether, given the project’s $6.22B current price tag, and the underwhelming Benefit/Cost Ratio of 1.03, Congress has fully weighed the project’s benefits and, in turn, its potential consequences. A simple miscalculation in the execution of this project could place not only the Lower Ninth Ward, but the entire City of New Orleans at risk—a city whose geography makes recovery from another catastrophic loss extraordinarily difficult.
Louisiana Landmarks Society remains committed to meaningful participation in the Section 106 process and respectfully requests that the concerns raised in this letter be addressed prior to any advancement of the AMOA toward execution.
Sincerely yours,
Sandra L. Stokes
James R. Logan, IV