Greenfield Louisiana LLC, the Colorado-based company seeking to build a controversial grain elevator in St. John the Baptist Parish, has continued work on the project using a consulting firm that a former employee-turned-whistleblower accused of misconduct, documents obtained by The Lens show.

Greenfield hired the company, Gulf South Research Corporation (GSRC), to conduct a “cultural resource survey” on the proposed location of the grain elevator project to investigate whether construction would harm nearby sites of historical significance. The grain elevator would be located near former plantations, prompting concerns that there may be unmarked burial sites of enslaved people on the land. 

But GSRC’s report, submitted in October 2021 to state and federal agencies, including the Army Corps of Engineers, as part of Greenfield’s permitting process, said that the company found no evidence of any unmarked graves. The finding, however, came under public scrutiny after the whistleblower account emerged, as reported by ProPublica, claiming Greenfield improperly pressured GSRC to alter its true findings. The whistleblower, Erin Edwards, asserted that her stated concerns that the proposed site may harm cultural resources, like the unmarked burial grounds of those once enslaved in the area, were elided from GSRC’s final version.

In late June, about a month after ProPublica published its investigation, the Corps publicly stated that it found the report submitted by GSRC to be insufficient. But months later, Greenfield has retained the company for ongoing consulting work. 

The Lens obtained a copy of the minutes and meeting notes from the September meeting the Corps held for the project, under the purview of Section 106 of the National Historic Preservation Act, which shows that at least one representative of GSRC was present. According to the minutes, that employee, GSRC’s current architectural historian, denied Edwards’ assertions. The employee’s name is not identified in the minutes, but the firm’s website lists Alexis Thomas as its current architectural historian. 

The Corps confirmed there is an ongoing professional relationship between Greenfield and GSRC. 

The Corps “understands that [Greenfield] through their agent has hired GSRC as [an] independent consulting firm to develop information relevant to Section 106 consultation such as archaeological survey, built-environment survey, historic research and viewshed analysis,” Ricky Boyett, spokesman for the Corps, told The Lens. 

That Greenfield continues to employ the services of GSRC raises serious questions about the trustworthiness of whatever work product the firm may ultimately render, given the assertions laid bare by Edwards, Lisa Jordan, director of the Tulane Environmental Law Clinic — who’s helping to represent the group Stop the Wallace Grain Terminal in its litigation opposing the project — told The Lens. Jordan also spoke out during the Section 106 meeting to raise concerns, she said. 

“You’ve got a company that’s [the subject of] a credible accusation of allowing, basically, the permit applicant to dictate what the conclusion of the report is, and to essentially even write part of the report,” Jordan told The Lens. “That’s our concern: the integrity of the process. And we remain concerned about that.”

Greenfield’s chief operating officer Cal Williams defended GSRC’s work in a written statement.

“Greenfield takes seriously its responsibility to provide regulatory agencies with accurate and complete information consistent with the regulatory requirements. Gulf South Research Corporation (GSRC) was selected because they are the leading firm conducting these types of evaluations in the region. Greenfield did not make changes or mandate any changes to the working draft of the report.”

GSRC did not respond to a request for comment. 

Greenfield bought the tract of land at issue in 2021 for $40 million. The company plans to build an enormous grain elevator on the property, worth more than $400 million, that would include 54 grain silos, a conveyor belt, railroad infrastructure and a dock. (Under a tax abatement deal, the company has agreed to transfer ownership to the Port of South Louisiana — a public agency that does not pay property taxes — in exchange for annual payments in lieu of taxes, an agreement that could cost St. John Parish more than $200 million over 30 years, according to an analysis by the group Together Louisiana.) 

The Descendants Project, a nonprofit led by twin sisters Jo and Joy Banner that advocates on behalf of the descendants of people once enslaved in Louisiana’s River Parishes, sued the parish last year in order to nullify the zoning ordinance upon which the construction would rely. St. John is located in the so-called chemical corridor along the Mississippi River between Baton Rouge and New Orleans, thus named because of its high concentration of industrial facilities. 

Joy Banner is also concerned with GSRC’s continued involvement in the project, she told The Lens, and would like for the Army Corps of Engineers to take a more active role in overseeing the Section 106 process, as it relates to the relationship between GSRC and Greenfield, she said. 

“From what I’ve seen, it didn’t seem like the Corps was really putting any energy into investigating or making Greenfield choose another firm,” Banner said. “And I think with the implications, and with the accusations, again, I think there needs to be an investigation of what happened.”

Boyett told The Lens that the Corps will “work with [Greenfield] to ensure that any submitted documentation meets all applicable standards and guidelines.”

Boyett added that conducting an investigation into the firm’s work process would be outside of the Corps’ purview.

Banner isn’t the only member of a consulting party in the Section 106 review process who would like the Corps to take a more forceful approach. 

The Corps has yet to issue a permitting decision on the project, but Greenfield has been allowed to begin preliminary work.  In August, the nonprofit National Trust for Historic Preservation sent a letter to the Corps objecting to the fact that Greenfield has initiated that work without a permit and asking the Corps to intervene. 

“Given the tremendous level of concern and public scrutiny regarding this permit application, both within the local community and from multiple national organizations, as well as from the Advisory Council on Historic Preservation, we strongly encourage the Army Corps to warn the applicant to cease and desist from its preconstruction activities,” Elizabeth Merritt, deputy general counsel, and Chris Cody, associate general counsel at National Trust, said in the letter. 

In response to National Trust’s letter, Martin Mayer, chief of the regulatory branch in the Corps’ New Orleans district, wrote in his own letter, shared with The Lens by the Corps, that because Greenfield is not adding fill or dredged material in potential U.S. waters, then the Corps does not have the authority to pursue an enforcement action. The Corps, however, has put Greenfield on notice that it is proceeding “‘at risk’ in non-jurisdictional areas,” because the Corps has not yet issued a permit, Mayer said.

The President’s Advisory Council on Historic Preservation, a federal agency charged with protecting historic sites, previously raised its own misgivings about the project’s potential impacts in a letter to the Corps.

In spite of the concerns, a state judge in June ruled that the company could initiate pre-construction work, which allowed the company to begin pile driving on the site — an activity that also took place during Juneteenth, the federal holiday recognizing emancipation.

For Banner, the stakes are high for her community, she said. While respectful of the Section 106 review process, she would still like for the Corps to take a more assertive stance, she said. 

“We’re trying to have a process that is objective, right?” she said. “However, If Greenfield is being accused of hiding important historical resources, which may include burial grounds, then being objective –  if you’re not applying the pressure, then that has given them an advantage,” she said. 

This story has been updated to include additional comments from the U.S. Army Corps of Engineers and a statement from Greenfield.

Joshua Rosenberg

Joshua Rosenberg covers the environmental beat for The Lens. Joshua is a Report for America corps member, and is working in collaboration with the Mississippi River Basin Ag and Water Desk. Prior to joining...