A rendering of the proposed grain elevator in the background with the Fee-Fo-Lay Cafe in the foreground, commissioned by the Tulane Environmental Law Clinic. Courtesy of Jo Banner.

A letter in which the U.S. Army Corps of Engineers rejected the cultural resources survey a consulting firm submitted on behalf of Greenfield Louisiana LLC  – the company that’s seeking to construct a grain elevator in a majority-Black, River Parish community – also raised concerns about the project’s potential contributions to the area’s aggregate health and environmental conditions, The Lens has learned. 

Martin Mayer, chief of the regulatory branch in the Corps’ New Orleans district, wrote in the June 24 letter, obtained by The Lens, that the facility’s emissions might adversely and disproportionately affect communities already subject to the effects of pollution. The letter was addressed to the Ramboll Group, a consulting firm hired by Greenfield.

“It is possible that minimal emissions may cause additional health burdens on an already highly environmentally polluted area,” Mayer wrote. “The provided responses do not demonstrate that the facility will not add to the environmental burden of the surrounding communities, just that the modeled emissions are within the acceptable standards.”

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.) 

Greenfield hired Ramboll to act as its agent throughout the permitting process, Ricky Boyett, spokesman for the Corps, told The Lens. Ramboll, in turn, subcontracted Gulf South Research Corporation (GSRC) to conduct a cultural resource survey on the proposed location of the grain elevator project in order to investigate whether construction would harm nearby sites of historical significance. 

The Corps has not received a direct response to its June 24 letter, Boyett said. Ramboll and GSRC did not respond to requests for comment. Greenfield declined to comment when asked whether Ramboll, or any other entity, had responded to the Corps’ queries. 

The Corps is currently conducting a permit review of the project, per its purview under Section 106 of the National Historic Preservation Act. Meanwhile, a state judge in June ruled that Greenfield 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. 

History and prehistory

The grain elevator would be located near former plantations, prompting concerns that there may be unmarked burial sites of enslaved people on the land. 

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 a 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. The Corps’ letter, upon which the Corps’ public statement was based, does not mention the whistleblower’s account. 

GSRC’s submission was inadequate because, in part, it contained incomplete archaeological survey data, Mayer wrote. 

In particular, GSRC failed to survey a tract of land that was identified by the group Coastal Environments, Inc. in 1991 as being a “moderate probability area for prehistoric sites,” the Corps said. 

Jo Banner, who along with her twin sister Joy founded The Descendants Project, a nonprofit that advocates on behalf of the descendants of people once enslaved in Louisiana’s River Parishes, told The Lens that’s a major concern.

“I’m astonished by the lack of research regarding the prehistoric site,” Banner told The Lens. “It’s honestly shocking to see the way that the Army Corps has fleshed it out – to see them point out these resources, a part of our environment, that Greenfield has just inadequately surveyed, measured or ignored,” she said. 

The Descendants Project sued St. John the Baptist Parish last year in order to nullify the zoning ordinance upon which Greenfield’s 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. 

GSRC’s submission also failed to adequately define the boundaries of the WIllow Grove Cemetery, an active cemetery in the area, according to the Corps. 

“The report must provide either additional information demonstrating that the current cemetery delineation is accurate or conduct a cemetery delineation, with special attention paid to the Project [area of potential effect] adjacent to the standing cemetery,” Mayer wrote.

But the single topic the Corps addressed most thoroughly in its letter involved the project’s potential environmental and health impacts. For instance, Mayer concludes that even a marginal increase in pollution could exert a serious, adverse impact on the residents who live nearby the proposed project. 

“Any emission from a facility could add to the already very high pollution burden which is only being felt by [environmental justice] communities,” he wrote. 

Banner, for one, is “pleasantly surprised that this is part of an official document that points out cumulative impact, when we have been saying that we’re drowning,” she told The Lens. “And the last thing you want to do is hand a drowning person a cup of water, no matter how small you think it is.”

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...