Letter to Gina McCarthy, EPA Administrator - Connecticut And Rhode Island Congressional Delegations Write To EPA In Support Of Eastern Long Island Sound Dredged Material Disposal Site

Letter

Dear Administrator McCarthy:

We write to share our support for the Environmental Protection Agency's (EPA's) proposed rule to designate a new Eastern Long Island Sound Dredged Material Disposal Site (ELDS). Since the drafting of the Dredged Material Management Plan (DMMP) last year, stakeholders on the federal, state, and local levels have worked with the regional branches of the EPA and Army Corps of Engineers to ensure that this comprehensive management framework shape the designation and management of our open-water disposal sites in Long Island Sound.

This is why we strongly support the approval of the EPA's rule for the designation of the ELDS. The EPA's preferred ELDS location, located south of the Thames River Estuary, would consolidate the current New London and Cornfield Shoals Disposal Sites into an area that is two square nautical miles and will be able to meet the dredging needs of eastern Long Island Sound for the next 30 years. As noted in the rule, designation of the ELDS would provide "an environmentally sound, open-water disposal option for possible use in managing dredged material from harbors and navigation channels in eastern Long Island Sound and its vicinity in the states of Connecticut, New York, and Rhode Island." We agree, and believe that approval of this designation is vital to the future of the Long Island Sound region.

While the ELDS and other open-water disposal sites are exceedingly important to maintaining the dredging needs of Long Island Sound, it is also important that we consider alternative placement of dredged material when appropriate. To that end, this proposed rule continues the effort of the DMMP to identify and evaluate environmentally sound, on-land disposal options for certain dredging projects. In fact, in our region, dredged materials have not only been used for shoreline replenishment, but also for capping landfills and brownfields sites upland.

As representatives from the region, we understand firsthand the importance of preserving and protecting the environment in and around the Sound for future generations to enjoy. The environmental soundness of Long Island Sound dredging is a clear focus of the ELDS. The proposed rule is consistent with the federally-approved Coastal Zone Management Plans for New York, Rhode Island, and Connecticut. Furthermore, it should be noted that without access to the ELDS, it is expected that transporting dredged materials to other sites, like the Rhode Island Disposal Site, will increase carbon emissions from ships and risk of dredged material spills as transport distance is extended. Our states have been responsibly dredging using open-water placement for 35 years and we believe that swift adoption of the ELDS, along with an increased effort to find sustainable on-land solutions for suitable dredged materials, will provide the Long Island Sound region with a balanced approach for future waterway maintenance projects.

In addition to the critical goal of protecting Long Island Sound and its resources, access to ELDS is absolutely vital to the economy of our states and districts -- and that of the entire Long Island Sound region. According to the aforementioned DMMP, economic activities that utilize Long Island Sound waterways contribute more than $9 billion annually in economic output. Additionally, these economic activities support more than 55,000 jobs in the Long Island Sound region. As important, our region is host to a range of federal and military facilities dependent on the viability of accessible and cost-effective placement options. These include facilities like Naval Submarine Base New London and premier submarine builder Electric Boat, with facilities in both Connecticut and Rhode Island.

Approving the ELDS is of critical importance to support navigation-dependent industries that border and traverse eastern Long Island Sound. The proposal states that shipping bulk materials, petroleum fuels, recreational boating and fishing, commercial fishing, interstate ferry operations, and military navigation all lend a hand to the Long Island Sound region's economic output. We must continue to embrace our maritime heritage and support this balanced, sustainable proposal to maintain our dredging needs.

We believe that this rule accomplishes this important goal, and we urge its adoption.