Home > Uncategorized > US Army Corps of Engineers Issues BL England Plant Dredging Permit

US Army Corps of Engineers Issues BL England Plant Dredging Permit

Corps Denies Public Hearing Request

Federal Agencies Ignore Obama Climate Adaptation Policy for Vulnerable Coastal Plant

Areas in yellow are flood risk areas based on FEMA flood hazard maps plus the most conservative estimate of sea level rise (0.3 feet by 2050). The entire BL England plant is within this flood zone.  (Source: Pinelands Preservation Alliance, link below)

BL England plant circled in red. Areas in yellow are flood risk areas based on FEMA flood hazard maps plus the most conservative estimate of sea level rise (0.3 feet by 2050). The entire BL England plant is within this flood zone. (Source: Pinelands Preservation Alliance, link below)

The US Army Corps of Engineers, in a Friday afternoon move designed to minimize news coverage, issued a final dredging permit for the controversial BL England power plant in Upper Township, NJ.

The purpose of the permit is:

R.C. Cape May Holdings, LLC proposal [is] to perform hydraulic maintenance dredging to the B.L. England Generation Plant’s intake and outfall located in Great Egg Harbor Bay at Upper Township, Cape May County, New Jersey. The applicant’s stated purpose and need for the proposed work is to ensure an adequate supply of condenser cooling water for the intake, to avoid sediment re-suspension at the outflow and to ensure an adequate mixing regime for thermal discharge. A ten year maintenance permit is being requested for the proposed activities.

We learned of this draft permit very late in the process and were able to submit only cursory general comments, which is the main reason why we asked for an extension of the public comment period (for our comments, see):

Our requests strictly followed the criteria in NJ DEP rules to justify an extension or a request for public hearing. The Corps denied that extension request.

The Corps also denied our request to hold a public hearing, but provided no rationale for either denial. I am not familiar with the Corps rules and the basis for reviewing such requests, but the Corps seems to have just blown the requests off with no basis stated.

But none of that comes as a surprise, as the Corps is not generally perceived to be enthusiastic about dealing with environmental critics in public hearings.

But, what I was surprised by – perhaps because I have little experience in dealing with the Corps permit process – was how the Corps’ decision completely ignored President Obama’s Climate Adaptation Policy, issued on Nov. 1, 2013, so it was binding on the Corps, see:

More recently, that Nov. 1, 2013 Obama Executive Order was expanded upon by a January 30, 2015 Order, see:

The new Order included a proposed new Federal Flood Risk Management Standard that would require federal agencies to select one of three approaches for establishing the flood elevation and hazard area they use in siting, design, and construction:

  • Use data and methods informed by best-available, actionable climate science;
  • Build two feet above the 100-year (1%-annual-chance) flood elevation for standard projects, and three feet above for critical buildings like hospitals and evacuation centers; or
  • Build to the 500-year (0.2%-annual-chance) flood elevation.

I wonder if the BL England intake structures, facility, and dredging plans – or the Corps permit – consider these standards?

The Pinelands Preservation Allaince prepared an analysis of the vulnerability of the BL England plant in terms of sea level rise and storm surge. Maps that show portions of the BL England site as within the flood elevations –

In our comments, we wrote:

3) the plant is located in a coastal hazard zone and is vulnerable to climate change driven sea level rise and storm surge. The issue of coastal vulnerability and all forms of energy and critical infrastructure is a hugely controversial and significant issue to the people of NJ.

Even though the new Federal Flood Risk Management Standard is not legally in effect yet, the Corps had an obligation, under the prior Obama 2013 Executive Order, to consider these kind of climate change vulnerabilities and risks.

Without discussion, the Corps dismissed them, and they spread the blame and pointed fingers at their sister federal agencies for ignoring them too:

No objections to the issuance of this permit were received from other Federal resource agencies (United States Environmental Protection Agency, United States Fish and Wildlife Service, National Marine Fisheries Service and the National Park Service) concerning the effects of the proposed work on resources within their jurisdictions.

So, the entire federal government simply ignored President Obama’s Executive Order on adaptation to climate change – an Order that they are legally bound to implement.

And they did this just at the time Obama issued another Order and proposed new Federal Flood Risk Management Standards.

This is not a minor oversight. Will they be held accountable?

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  415. June 15th, 2015 at 13:08 | #415
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  417. June 15th, 2015 at 14:01 | #417
  418. June 15th, 2015 at 14:19 | #418
  419. June 15th, 2015 at 20:12 | #419
  420. June 16th, 2015 at 00:37 | #420
  421. June 16th, 2015 at 05:23 | #421
  422. June 16th, 2015 at 09:21 | #422
  423. June 16th, 2015 at 17:30 | #423
  424. June 17th, 2015 at 03:03 | #424
  425. June 17th, 2015 at 12:12 | #425
  426. June 17th, 2015 at 17:34 | #426
  427. June 17th, 2015 at 23:09 | #427
  428. June 18th, 2015 at 07:05 | #428
  429. June 18th, 2015 at 07:07 | #429
  430. June 18th, 2015 at 07:16 | #430
  431. June 18th, 2015 at 12:53 | #431
  432. June 18th, 2015 at 20:16 | #432
  433. June 18th, 2015 at 20:19 | #433
  434. June 18th, 2015 at 23:05 | #434
  435. June 19th, 2015 at 00:16 | #435
  436. June 19th, 2015 at 04:11 | #436
  437. June 19th, 2015 at 11:09 | #437
  438. June 19th, 2015 at 13:36 | #438
  439. June 19th, 2015 at 21:40 | #439
  440. June 20th, 2015 at 03:05 | #440
  441. June 20th, 2015 at 03:45 | #441
  442. June 20th, 2015 at 08:10 | #442
  443. June 20th, 2015 at 09:01 | #443
  444. June 20th, 2015 at 13:02 | #444
  445. June 20th, 2015 at 14:41 | #445
  446. June 20th, 2015 at 21:24 | #446
  447. June 21st, 2015 at 07:21 | #447
  448. June 21st, 2015 at 12:36 | #448
  449. June 21st, 2015 at 13:24 | #449
  450. June 21st, 2015 at 15:26 | #450
  451. June 21st, 2015 at 18:39 | #451
  452. June 21st, 2015 at 21:33 | #452
  453. June 21st, 2015 at 23:58 | #453
  454. June 22nd, 2015 at 00:00 | #454
  455. June 22nd, 2015 at 03:21 | #455
  456. June 22nd, 2015 at 21:34 | #456
  457. June 23rd, 2015 at 08:08 | #457
  458. June 23rd, 2015 at 14:12 | #458
  459. June 23rd, 2015 at 21:46 | #459
  460. June 23rd, 2015 at 23:26 | #460
  461. June 24th, 2015 at 01:38 | #461
  462. June 24th, 2015 at 03:02 | #462
  463. June 24th, 2015 at 04:41 | #463
  464. June 24th, 2015 at 05:18 | #464
  465. June 24th, 2015 at 10:15 | #465
  466. June 24th, 2015 at 15:23 | #466
  467. June 24th, 2015 at 15:34 | #467
  468. June 24th, 2015 at 20:44 | #468
  469. June 24th, 2015 at 23:19 | #469
  470. June 24th, 2015 at 23:20 | #470
  471. June 25th, 2015 at 01:42 | #471
  472. June 25th, 2015 at 01:50 | #472
  473. June 25th, 2015 at 03:22 | #473
  474. June 25th, 2015 at 07:52 | #474
  475. June 25th, 2015 at 10:57 | #475
  476. June 25th, 2015 at 16:45 | #476
  477. June 25th, 2015 at 17:17 | #477
  478. June 25th, 2015 at 19:39 | #478
  479. June 25th, 2015 at 20:30 | #479
  480. June 26th, 2015 at 01:23 | #480
  481. June 26th, 2015 at 05:29 | #481
  482. June 27th, 2015 at 15:51 | #482
  483. June 27th, 2015 at 17:23 | #483
  484. June 27th, 2015 at 19:02 | #484
  485. June 27th, 2015 at 19:47 | #485
  486. June 27th, 2015 at 21:26 | #486
  487. June 28th, 2015 at 03:39 | #487
  488. June 28th, 2015 at 07:13 | #488
  489. June 28th, 2015 at 07:32 | #489
  490. June 28th, 2015 at 12:39 | #490
  491. June 28th, 2015 at 19:45 | #491
  492. July 1st, 2015 at 10:57 | #492
  493. July 1st, 2015 at 16:51 | #493
  494. July 1st, 2015 at 17:16 | #494
  495. July 1st, 2015 at 19:38 | #495
  496. July 1st, 2015 at 23:34 | #496
  497. July 2nd, 2015 at 03:39 | #497
  498. July 2nd, 2015 at 13:18 | #498
  499. July 3rd, 2015 at 06:43 | #499
  500. July 3rd, 2015 at 10:33 | #500
  501. July 3rd, 2015 at 12:30 | #501
  502. July 3rd, 2015 at 20:12 | #502
  503. July 3rd, 2015 at 20:21 | #503
  504. July 4th, 2015 at 06:28 | #504
  505. July 4th, 2015 at 07:27 | #505
  506. July 4th, 2015 at 19:12 | #506
  507. July 4th, 2015 at 21:40 | #507
  508. July 5th, 2015 at 00:33 | #508
  509. July 5th, 2015 at 07:03 | #509
  510. July 5th, 2015 at 14:41 | #510
  511. July 5th, 2015 at 14:46 | #511
  512. July 5th, 2015 at 21:04 | #512
  513. July 6th, 2015 at 02:59 | #513
  514. July 6th, 2015 at 04:57 | #514
  515. July 6th, 2015 at 08:11 | #515
  516. July 6th, 2015 at 16:22 | #516
  517. July 6th, 2015 at 19:42 | #517
  518. July 7th, 2015 at 02:03 | #518
  519. July 7th, 2015 at 05:56 | #519
  520. July 7th, 2015 at 09:23 | #520
  521. July 7th, 2015 at 11:29 | #521
  522. July 7th, 2015 at 12:43 | #522
  523. July 7th, 2015 at 15:06 | #523
  524. July 7th, 2015 at 19:48 | #524
  525. July 8th, 2015 at 04:06 | #525
  526. July 8th, 2015 at 04:22 | #526
  527. July 8th, 2015 at 05:31 | #527
  528. July 8th, 2015 at 06:48 | #528
  529. July 8th, 2015 at 07:29 | #529
  530. July 8th, 2015 at 11:32 | #530
  531. July 8th, 2015 at 13:47 | #531
  532. July 8th, 2015 at 15:51 | #532
  533. July 8th, 2015 at 16:58 | #533
  534. July 8th, 2015 at 19:17 | #534
  535. July 8th, 2015 at 23:13 | #535
  536. July 8th, 2015 at 23:49 | #536
  537. July 9th, 2015 at 00:55 | #537
  538. July 9th, 2015 at 01:38 | #538
  539. July 9th, 2015 at 02:21 | #539
  540. July 9th, 2015 at 02:24 | #540
  541. July 9th, 2015 at 03:14 | #541
  542. July 9th, 2015 at 04:56 | #542
  543. July 9th, 2015 at 05:06 | #543
  544. July 9th, 2015 at 07:03 | #544
  545. July 9th, 2015 at 08:43 | #545
  546. July 9th, 2015 at 11:13 | #546
  547. July 9th, 2015 at 13:32 | #547
  548. July 9th, 2015 at 14:42 | #548
  549. July 9th, 2015 at 14:44 | #549
  550. July 9th, 2015 at 18:07 | #550
  551. July 9th, 2015 at 19:21 | #551
  552. July 9th, 2015 at 23:08 | #552
  553. July 10th, 2015 at 00:18 | #553
  554. July 10th, 2015 at 01:21 | #554
  555. July 10th, 2015 at 02:41 | #555
  556. July 10th, 2015 at 03:16 | #556
  557. July 10th, 2015 at 04:32 | #557
  558. July 10th, 2015 at 06:02 | #558
  559. July 10th, 2015 at 06:17 | #559
  560. July 10th, 2015 at 08:27 | #560
  561. July 10th, 2015 at 09:19 | #561
  562. July 10th, 2015 at 10:17 | #562
  563. July 10th, 2015 at 10:43 | #563
  564. July 10th, 2015 at 13:44 | #564
  565. July 10th, 2015 at 17:13 | #565
  566. July 10th, 2015 at 17:13 | #566
  567. July 10th, 2015 at 17:13 | #567
  568. July 10th, 2015 at 17:13 | #568
  569. July 10th, 2015 at 17:14 | #569
  570. July 10th, 2015 at 17:21 | #570
  571. July 10th, 2015 at 19:48 | #571
  572. July 10th, 2015 at 21:23 | #572
  573. July 10th, 2015 at 22:45 | #573
  574. July 11th, 2015 at 00:52 | #574
  575. July 11th, 2015 at 03:09 | #575
  576. July 11th, 2015 at 03:16 | #576
  577. July 11th, 2015 at 05:51 | #577
  578. July 11th, 2015 at 09:15 | #578
  579. July 11th, 2015 at 09:15 | #579
  580. July 11th, 2015 at 09:16 | #580
  581. July 11th, 2015 at 10:03 | #581
  582. July 11th, 2015 at 10:11 | #582
  583. July 11th, 2015 at 15:39 | #583
  584. July 11th, 2015 at 16:33 | #584
  585. July 11th, 2015 at 20:40 | #585
  586. July 11th, 2015 at 22:02 | #586
  587. July 11th, 2015 at 22:52 | #587
  588. July 12th, 2015 at 01:17 | #588
  589. July 12th, 2015 at 04:35 | #589
  590. July 12th, 2015 at 05:16 | #590
  591. July 12th, 2015 at 12:09 | #591
  592. July 12th, 2015 at 12:12 | #592
  593. July 12th, 2015 at 12:46 | #593
  594. July 12th, 2015 at 13:04 | #594
  595. July 12th, 2015 at 16:40 | #595
  596. July 12th, 2015 at 17:04 | #596
  597. July 12th, 2015 at 18:17 | #597
  598. July 12th, 2015 at 21:08 | #598
  599. July 13th, 2015 at 00:12 | #599
  600. July 13th, 2015 at 01:13 | #600
  601. July 13th, 2015 at 01:42 | #601
  602. July 13th, 2015 at 02:31 | #602
  603. July 13th, 2015 at 03:17 | #603
  604. July 13th, 2015 at 03:39 | #604
  605. July 13th, 2015 at 05:39 | #605
  606. July 13th, 2015 at 06:17 | #606
  607. July 13th, 2015 at 08:40 | #607
  608. July 13th, 2015 at 08:42 | #608
  609. July 13th, 2015 at 10:04 | #609
  610. July 13th, 2015 at 11:22 | #610
  611. July 13th, 2015 at 12:42 | #611
  612. July 13th, 2015 at 13:14 | #612
  613. July 13th, 2015 at 13:41 | #613
  614. August 13th, 2015 at 17:02 | #614
  615. March 9th, 2016 at 06:53 | #615
  616. May 18th, 2016 at 11:14 | #616
  617. June 28th, 2016 at 09:33 | #617
  618. November 26th, 2016 at 03:20 | #618
  619. December 9th, 2016 at 23:45 | #619
  620. December 25th, 2016 at 02:42 | #620
  621. January 25th, 2017 at 09:03 | #621
  622. January 30th, 2017 at 09:50 | #622
  623. May 5th, 2017 at 02:19 | #623
  624. August 22nd, 2017 at 11:30 | #624
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