The Confined Disposal Facility

What is the story behind the Confined Disposal Facility? 

In early 2019 the Chicago District of the Army Corps of Engineers (“Corps”) published a Draft Dredge Management Plan and Environmental Impact Study (“DDMP/EIS”) proposing to vertically expand a toxic dredge disposal facility, known as a “confined disposal facility” (“CDF”), on the shore of Lake Michigan at the Calumet River. The existing CDF already concentrates over a million tons of contaminated dredge in a 1984 “in-water” structure that was scheduled to close in 2022, but under this new proposal the Corps would build a 25-foot mountain on top of that structure composed of another million tons of toxic waste. https://www.lrc.usace.army.mil/Missions/Civil-WorksProjects/Calumet-Harbor-and-River/ This surprising proposal had been rejected as an option by the Corps for many years. Yet, it appears the Corps is set to finalize this proposal — despite opposition by the Alderman, local residents and organizations, parks advocates, and environmental groups and despite the Lightfoot Administration’s focus on neighborhood equity and protecting Chicago’s drinking water quality.

Why is it a problem? 

The CDF sits literally in Lake Michigan – the City’s water supply. Unlike a properly permitted, lined and monitored modern landfill, the CDF was designed to allow the waters of the Lake to flow in and out of it. The CDF effectively concentrates a million tons of toxic dredge in a sieve at one location directly upstream from Calumet Beach and adjacent to historic Calumet Park and the new Steelworkers Park in the City’s 10th Ward – an environmental justice community already over-burdened with landfills and polluting industrial operations. For mo here to read the CDF OpEd written by FOTP board member Pat Sharkey

What can we do about it? 

We are reaching out to officials at the city, state and federal level letting them know we are against the dangerous CDF. Below are letters and email addresses you can utilize to let your voice be heard.


Sample Letters to advocate against the Confined Disposal Facility

Please use the below sample letter to send emails to as many contacts as you can at different levels of government. You will find their contact information below the sample letter. We are targeting City, State, and Federal Officials to step in in particular ways where they have the power to stop this. We are also asking federal legislators to step in to guide the US Army Corps of Engineers to a more appropriate location.

You can switch out any target in the salutation of the letter (where we have put state legislators as a sample) with other targets listed in the cc: below. Just make sure to include in the cc: list, and include them on the cc: line of your email, any other public officials we have listed and/or also your alderman if you so choose.

Please copy info@fotp.org to your emails so we can track our collective efforts. Let’s work together to right this egregious wrong.


Email (Mayor Lori Lightfoot and Chicago Park District Officials)


Subject Line: URGENT environmental threat to 10th Ward and Chicago Waterways System

To: Mayor Lori Lightfoot

CC:

info@fotp.org

City of Chicago and Chicago Park District officials (scroll to the bottom for links to contact information and emails)

Dear Mayor Lightfoot:

On behalf of Friends of the Parks (FOTP), I am writing to urge your administration to intervene immediately on an extremely urgent matter regarding another attempt by the U.S. Army Corps of Engineers to expand the current Confined Disposal Facility (CDF) that sits on land at the confluence of the Calumet River and Lake Michigan. It currently holds millions of tons of contaminated dredge right on the lakeshore and between two recreational parks, Calumet and Steelworkers, both of which Southeast Side Chicago residents utilize. The Army Corps has already extended the life of this facility which was scheduled to be closed by 2022 and made into parkland – but now, the Corps is putting the 10th Ward and Environmental Justice Communities at risk for continued exposure to toxic dredge and pollutants.

This is extremely time-sensitive because the Army Corps has released their Final Dredge Management Plan and Environmental Impact Statement (“Final DMP/EIS”) and draft Record of Decision for a final comment period until August 17, 2020. Recent FOTP Freedom of Information Act requests have revealed that the City Department of Transportation provided the Corps with a Letter of Intent to take on long-term cost sharing liabilities in May 2020. Additional FOIA requests have informed FOTP that the Chicago Park District also provided a letter of intent in May 2020 in which they admitted that they “expressed interest in the Army Corps pursing another region rather than the existing CDF at Iroquois Landing as that site was intended to be turned into a lakefront park.” These letters reveal that the cities’ cost responsibilities ring in at $10 million at a time when our government is challenged with extremely difficult decisions about how to utilize limited public resources. If the Mayor’s office does not halt the subsidizing of this risky proposal, Chicago taxpayers will be left holding the fiscal responsibilities for maintenance, stabilization, and monitoring of toxic releases from the dangerous facility.

For the past several years, Southeast Side community groups and partners have adamantly opposed this decision and encouraged the Army Corps to pursue a city-led planning process to find another place to store toxic pollutants. But there have been no City Council hearings or a Chicago Park District or City-led public process of any kind to mediate legitimate health and environmental impact concerns with Environmental Justice Communities on the Southeast Side. Now we are running out of time, but you still have an opportunity to put a stop to this – the letters of intent are not binding, and the Chicago Park District Board has not voted to extend the life of this pollution dump for another 25 years.

It is no secret that the Southeast Side has been Chicago’s dumping ground, and voices are clamoring loudly for the end to environmental injustice there. The recent approval General Iron is poised to move into the area near Rowan Park despite vocal opposition, there have been previous high-profile battles regarding petcoke and manganese in the vicinity, and arsenic was recently found in a children’s’ baseball field in walking distance from the CDF. Yet still, the Army Corp claims in their EIS that “no minority or low-income populations would be exposed to disproportionately high adverse human health impacts or environmental effects.” Holding public parkland hostage to house toxic dredge is undoubtedly an adverse health and environmental effect.

We ask the Lightfoot Administration to consider these extremely concerning findings detailed below and work with community groups to find an environmentally just solution to store toxic contaminants far from where our neighbors play and swim:

  • The current facility is already failing to contain toxins, including PCBs, mercury, arsenic and lead, and expanding the structure further makes no sense and ignores legitimate calls for lakefront erosion protections in response to rising lake levels and intensifying storm damage. Discussions are already taking place at the local level to push for lakefront erosion protections, and it’s completely irresponsible to allow this facility to expand on the lakebed with increasing knowledge of the effects of climate change.
  • The existing structure of this facility is 40-plus years old and designed to be maintained for 20 years of storm effects and lake elevation. The entire Chicago Waterways System is at risk for catastrophic contamination further complicated by the increasing frequency and severity of storms. It’s a matter of if, not when, this structure will begin to deteriorate; and when it does the entire region’s drinking water will be at risk in addition to annihilating fish, birds, and other wildlife and their habitats.
  • Prior to the Corps intention to expand the facility, the existing deal would have turned the land over to the Chicago Park District for the purpose of developing a 30-acre lakefront park connected to the existing Calumet Park. Airborne toxics from this mound and the associated dredge handling, drying and storage operations is a pollution hazard to any developments in the CDFs’ vicinity. Eliminating this toxic pollution site from the Southeast Side lakefront provides the opportunity to transform this environmentally degraded area into a robust community with a fully accessible, connected, public park space along the lakefront and riverfront.
  • Additionally, Friends of the Parks has been advocating for the completion of more nearby lakefront parkland at the former USX steel mill site adjacent to what is now Steelworkers Park, across the river from the CDF. The community has a grand vision for a mixed-use development there that would further contribute to the vision to complete Chicago’s connected lakefront path system that is the jewel of the city while also providing massive economic development and renewal for the Southeast Side. To allow the Army Corps to expand their pollution dump within sight of this parcel impedes the full redevelopment of a healthy, sustainable community on this long-disregarded stretch of lakefront.

Please step in now to put a stop to this environmental injustice and preserve the possibility of public trust-protected green space supporting economic development, green job creation and a range of reasonably-priced housing options for the health and benefit of the Southeast Side neighborhoods and all of Chicago.

I ask that the Lightfoot Administration make it clear that the City will not participate in the Corps’ current proposal and will lead a thorough public vetting of the risks, burdens, equities and costs to residents and taxpayers before the City allows dredge material to be disposed of on the Lake Michigan shore or anywhere else in the 10th Ward.

Friends of the Parks is available at your convenience to discuss further or answer any questions you may have. Please contact Public Policy Associate Abigail Johnston at johnstona@fotp.org for more information.

Sincerely,

Your name
Your ward/district/municipality of residence

CC:

Deputy Mayor Samir Mayekar
Michael Kelly, General Superintendent & CEO of the Chicago Park District (CPD)
Pat Levar, Chief Operating Officer, CPD
Steve Lux, Chief Financial Officer, CPD
Avis LaVelle, President, CPD Board
David A. Helfand, Vice President, CPD Board
Donald J. Edwards, CPD Board
Tim King, CPD Board
Martin Laird Koldyke, CPD Board
Jose M. Muñoz, CPD Board
Ashley Hemphill Netzky, CPD Board


Email (Illinois Congresspeople)


Subject Line: URGENT environmental threat to the Chicago Waterways System and the 10th Ward Environmental Justice Community in Chicago 

To: Illinois Congresspeople (Copy and paste the letter below and scroll to the bottom of the page to see a list of links for each official’s contact form)

I am writing to request your immediate intervention to an attempt by the U.S. Army Corps of Engineers to expand the current Confined Disposal Facility (CDF) that sits on land at the confluence of the Calumet River and Lake Michigan. It holds millions of tons of contaminated dredge right on the lakeshore and between two recreational parks, Calumet and Steelworkers, both of which Southeast Side Chicago residents utilize. Your necessary involvement would protect Environmental Justice Communities at a time when the current administration is rolling back hundreds of environmental protections and put public trust land back into the hands of Illinoisans and out of the hands of polluters.

This is extremely urgent because the Army Corps has released their Final Dredge Management Plan and Environmental Impact Statement (“Final DMP/EIS”) and draft Record of Decision for a final comment period until August 17, 2020. For the past several years, Southeast Side community groups and partners have adamantly opposed this decision and encouraged the Army Corps to find another place to store toxic pollutants.

But the Army Corps has made little effort to go out of their way to find an alternative location to store hazardous materials including PCBs, mercury, arsenic and lead right on the lakebed and instead has proposed expanding the already 40-year old structure, which is in the direct path of extreme conditions, vertically for another 25-plus years, although the existing structure was scheduled to close in 2022.

Per Friends of the Parks’ Freedom of Information Act (FOIA) requests, as of May 2020, the Chicago Department of Transportation has provided the Army Corp with a letter of intent to take on cost share responsibilities to the tune of $10 million at a time when our government is challenged with extremely difficult decisions about how to utilize limited public resources. Ifey are not stopped, Illinois taxpayers will be left holding the fiscal responsibility for maintenance, stabilization, and monitoring of toxic releases from the dangerous facility.

It is no secret that the Southeast Side has been Chicago’s dumping ground, and voices are clamoring loudly for the end to environmental injustice there. The recent approval General Iron is poised to move into the area near Rowan Park despite vocal opposition, there have been previous high-profile battles regarding petcoke and manganese in the vicinity, and arsenic was recently found in a children’s’ baseball field in walking distance from the CDF. Yet still, the Army Corp claims in their EIS that “no minority or low-income populations would be exposed to disproportionately high adverse human health impacts or environmental effects.” Holding public parkland hostage to house toxic dredge is undoubtedly an adverse health and environmental effect.

We ask your leadership to consider these extremely concerning findings detailed below and work with community groups to find an environmentally just solution to store toxic contaminants far from where our neighbors play and swim:

  • The current facility is already failing to contain toxins, and expanding the structure further makes no sense and ignores legitimate calls for lakefront erosion protections in response to rising lake levels and intensifying storm damage. Discussions are already taking place at the local level to push for lakefront erosion protections, and it’s completely irresponsible to allow his facility to expand on the lakebed with increasing knowledge of the effects of climate change.
  • The existing structure of this facility is 40-plus years old and designed to be maintained for 20 years of storm effects and lake elevation. The entire Chicago Waterways System is at risk for catastrophic contamination further complicated by the increasing frequency and severity of storms. It’s a matter of if, not when, this structure will begin to deteriorate; and when it does the entire region’s drinking water will be at risk in addition to annihilating fish, birds, and other wildlife and their habitats.
  • Prior to the Corps intention to expand the facility, the existing deal would have turned the land over to the Chicago Park District for the purpose of developing a 30-acre lakefront park connected to the existing Calumet Park. Eliminating this toxic pollution site from the Southeast Side lakefront provides the opportunity to transform this environmentally degraded area into a robust community with a fully-accessible, connected, public park space along the lakefront and riverfront.
  • Additionally, Friends of the Parks has been advocating for the completion of more nearby lakefront parkland at the former USX steel mill site adjacent to what is now Steelworkers Park, across the river from the CDF. The community has a grand vision for a mixed-use development there that would further contribute to the vision to complete Chicago’s connected lakefront path system that is the jewel of the city while also providing massive economic development and renewal for the Southeast Side. To allow the Army Corps to expand their pollution dump within sight of this parcel impedes the full redevelopment of a healthy, sustainable community on this long-disregarded stretch of lakefront.

Please step in now to put a stop to this environmental injustice and preserve the possibility of public trust-protected green space supporting economic development, green job creation and a range of reasonably-priced housing options for the health and benefit of the Southeast Side neighborhoods and all of Chicago.

Friends of the Parks is available at your convenience to discuss further or answer any questions you may have. Please contact Public Policy Associate Abigail Johnston at johnstona@fotp.org for more information.

Sincerely,
Your name
Your ward/district/municipality of residence

Email (Lt. Gov. Stratton & State Officials)


Subject Line: URGENT environmental threat to the Chicago Waterways System and the 10th Ward Environmental Justice Community in Chicago 

To: Lieutenant Governor Juliana Stratton – LtGovStratton@illinois.gov

CC:

info@fotp.org

Illinois Representatives from Energy & Environment Committee:

Rep. Ann Williams – ann@repannwilliams.com
Rep. Robyn Gabel – staterepgabel@robyngabel.com
Rep. David A. Welter – welter@ilhousegop.org
Rep. Carol Ammons – Assistance@StateRepCarolAmmons.com
Rep. Darren Bailey – Bailey@ilhousegop.org
Rep. Tim Butler – butler@ilhousegop.org
Rep. Dan Caulkins – caulkins@ilhousegop.org
Rep. William Davis – williamd@ilga.gov 
Rep. Daniel Didech – Info@repdidech.com
Rep. Mary Edly-Allen – info@repedlyallen.com
Rep. Sonya M. Harper – repsonyaharper@gmail.com
Rep. Barbara Hernandez – Repbarbarahernandez@gmail.com
Rep. Frances Ann Hurley – repfranhurley@gmail.com
Rep. Lindsey LaPointe – RepLaPointe@gmail.com
Rep. Theresa Mah – rep.theresamah@gmail.com
Rep. Michael T. Marron – mike@repmikemarron.com
Rep. Joyce Mason – info@repjoycemason.com
Rep. Deanne Mazzochi – mazzochi@ilhousegop.org
Rep. Charles Meier – repcmeier@gmail.com
Rep. Chris Miller – chrismiller2019gop@gmail.com
Rep. Anna Moeller – staterepmoeller@gmail.com
Rep. Bob Morgan – info@repbobmorgan.com
Rep. Thomas Morrison – morrison@ilgop.org
Rep. Michelle Mussman – staterepmussman@gmail.com
Rep. Nathan Reitz – repnreitz@gmail.com
Rep. Dave Severin – severin@ilhousegop.org
Rep. Nicholas K. Smith – repsmith34@gmail.com
Rep. Andrea Thapedi – rep32district@gmail.com
Rep. Dan Ugaste  – ugaste@ilhousegop.org
Rep. Lawrence Walsh, Jr. – statereplarrywalshjr@gmail.com
Rep. Keith R. Wheeler – office@repkeithwheeler.org
Illinois Senators from Environment and Conservation Committee:
Sen. Melinda Bush – melinda@senatormelindabush.com
Sen. David Koehler – 46illinois@gmail.com
Sen. Sara Feigenholtz – sara@senatorsara.com
Sen. Laura Fine – laura@senatorfine.com
Sen. Pat McGuire – senatorpatmcguire@sbcglobal.net
Sen. Julie A. Morrison –morrison@sentatedem.illinois.gov
Sen. Heather A. Steans – steans@senatedem.illinois.gov
Sen. Jim Oberweis – senatoroberweis@gmail.com
Sen. Jason Plummer – senator@senatorjasonplummer.com
Sen. Dave Syverson – info@senatordavesyverson.com
IL State officials representing the district the CDF is in:
Sen. Robert Peters – info@senatorrobertpeters.com
Rep. Curtis Tarver – office@repcurtisjtarverii.com

Email Text:

Dear Lt. Gov. Stratton,

In light of your role as the Chair of the Rivers of Illinois Coordinating Council, advising and making recommendations to the governor on projects related to rivers and encouraging communities to develop environmentally sustainable watershed management, I write to make you aware of an extremely urgent matter affecting an already overburdened Environmental Justice Community on Chicago’s Southeast Side, at the confluence of the Calumet River and Lake Michigan.

The issue represents significant environmental and health risks, about which a broad cross-section of community constituents and regional stakeholders submitted public comment to the Army Corps of Engineers in an effort to redirect this process toward a more suitable outcome for the 10th Ward, all of Chicago, and the Great Lakes region. Now your intervention is called for.

Originally brought into this issue because the pollution dump that is the subject of this letter is immediately adjacent to Calumet Park and was scheduled to be closed in 2020 and turned into public parkland, Friends of the Parks (FOTP) is an Illinois not-for-profit organization founded in 1975 and dedicated to promoting healthy parks in the City of Chicago. Our mission includes ensuring park lands are equitably distributed and managed across the city to support healthy communities and a healthy environment.

The Army Corps of Engineers is attempting to expand and extend the life of a pollution dump right on Lake Michigan at the confluence of the Calumet River. If they are not stopped, they will be further putting residents on the Southeast Side and the entire Chicago region in danger for the next 25-plus years. This facility, which is already leaching toxins into the water supply per documents that FOTP forced the Army Corps to make public, was constructed by the Corp in 1984 for the purpose of storing highly contaminated toxic dredge.

And now, as of July 17th, 2020, the Army Corp has released their Final Dredge Management Plan and EIS (“Final DMP/EIS”) and draft Record of Decision for a final comment period until August 17, 2020. Friends of the Parks adamantly requests that you use your executive powers to take this issue on as the Chair of the Rivers of Illinois Coordinating Council and urge Governor Pritzker, Illinois General Assembly, and the Illinois Environmental Protection Agency to stop the Army Corps in its tracks as it seeks to prolong the Chicago Waterways System’s risk for contamination.

It is now absolutely necessary that you use your executive powers to stop this attempt because the State of Illinois did not intend for the purpose of this land to be debated. In fact, the Illinois General Assembly made that decision in 1994 when they legislated the property as public trust land and transferred ownership to the Chicago Park District for the purposes of being converted into a public park. But the Chicago Park District has not fulfilled their end of the deal, even though the land has already been conveyed to them for expansion of the adjacent Calumet Park. The life of this pollution dump has been repeatedly extended beyond what the Illinois General Assembly authorized. And the Chicago Park District has yet again signed on as a cost-share partner to the Army Corp plan to further extend the life of this hazardous facility filled with PCBs, mercury, arsenic and lead right on the lakebed and adjacent to the Calumet River and Calumet Park, with Steelworkers Park within view on the other side of the river.

Since early 2019, FOTP has been actively calling for appropriate public vetting of this serious threat. But that process did not occur at the city level, and now time is running out. Per FOTP’s Freedom of Information Act (FOIA) requests, as of May 2020, the Chicago Department of Transportation has provided the Army Corp with a letter of intent to take on cost-share responsibilities to the tune of $10 million at a time when our government is challenged with extremely difficult decisions about how to utilize limited public resources.

This is not only another attempt at giving the short end of the stick to the 10th Ward and neighboring communities; but considering the increasing frequency and severity of storms contributing to massive lake erosion all along the shoreline, there is a looming threat to the structural stability of this facility. Its failure would put the entire region’s drinking water at risk in addition to annihilating fish, bird, and other wildlife and their habitats.

The current facility is already 40-plus years old and failing to contain toxins; expanding the structure vertically by 25 feet in the direct path of extreme conditions makes no sense. Your constituents and Illinois taxpayers will be left holding the fiscal responsibility for maintenance, stabilization, monitoring and toxic releases from this dangerous facility.

It is no secret that the Southeast Side has been Chicago’s dumping ground, and voices are clamoring loudly for the end to environmental injustice there. The recent approval General Iron is poised to move into the area near Rowan Park despite vocal opposition, there have been previous high-profile battles regarding petcoke and manganese in the vicinity, and arsenic was recently found in a children’s’ baseball field in walking distance from the CDF. Yet still, the Army Corp claims in their EIS that “no minority or low-income populations would be exposed to disproportionately high adverse human health impacts or environmental effects.” Holding public parkland hostage to house toxic dredge is undoubtedly an adverse health and environmental effect.

I implore you to take this urgent environmental threat seriously and coordinate with Governor Pritzker and the Illinois Environmental Protection Agency regarding the dire effects of environmental racism and contaminated waterways to Southeast Side communities if the Army Corps is not stopped. The Corps has used and abused the communities’ parkland and the treasured lakefront for long enough.

Friends of the Parks is available at your convenience to discuss further or answer any questions you may have. Please contact Public Policy Associate Abigail Johnston at johnstona@fotp.org for more information.

Sincerely,
Your name
Your ward/district/municipality of residence
Cc:
Illinois House Energy & Environment Committee
Illinois Senate Environment and Conservation Committee
Illinois State Senator Robert Peters
Illinois State Representative Curtis Tarver II

Email (Environmental Protection and Energy Committee – City Council)


Subject Line: URGENT Environmental Protection Matter in the 10th Ward

To:

Environmental Protection and Energy Committee Members:

Alderman Burke, ward14@cityofchicago.org 
Alderman Cappleman, ward46@cityofchicago.org
Alderman Cardenas, ward12@cityofchicago.org
Alderman Cardona, Jr., ward31@cityofchicago.org
Alderman Dowell, ward03@cityofchicago.org
Alderman Hadden, office@49thward.org
Alderman Hopkins, ward02@cityofchicago.org
Alderman La Spata, info@the1stward.com
Alderman Martin, info@aldermanmartin.com
Alderman Nugent, ward39@cityofchicago.org
Alderman Reilly, ward42@cityofchicago.org
Alderman Rodriguez Sanchez, info@33ward.org
Alderman Smith, ward43@cityofchicago.org
Alderman Taylor, jeanette.taylor@cityofchicago.org
Alderman Waguespack, ward32@cityofchicago.org 

CC:

info@fotp.org

Chicago City Council Members (emails below)

Email Text:

Dear Environmental Protection and Energy Committee Members:

I write to make you aware of an extremely urgent matter affecting an already overburdened Environmental Justice Community on the Southeast Side.  The issue represents environmental and health risks, about which a broad cross-section of community constituents and regional stakeholders submitted public comment to the Army Corps of Engineers in an effort to redirect this process toward a more suitable outcome for the 10th Ward and all of Chicago.  Now your intervention is called for.

Originally brought into this issue because the pollution dump that is the subject of this letter is immediately adjacent to Calumet Park and was scheduled to be closed in 2020 and turned into public parkland, Friends of the Parks (FOTP) is an Illinois not-for-profit organization founded in 1975 and dedicated to promoting healthy parks in the City of Chicago. Our mission includes ensuring park lands are equitably distributed and managed across the city to support healthy communities and a healthy environment.

The Army Corps of Engineers is attempting to expand and extend the life of a pollution dump right on Lake Michigan at the confluence of the Calumet River. If they are not stopped, they will be further putting residents on the Southeast Side and the entire City of Chicago in danger for the next 25-plus years. This facility, which is already leaching toxins into the water supply per documents that FOTP forced the Army Corps to make public, was constructed by the Corp in 1984 for the purpose of storing highly contaminated toxic dredge. It was meant to close in 1994 and be converted in a public park. But it didn’t close, though the land has already been conveyed to the Chicago Park District for expansion of the adjacent Calumet Park. And for decades the Corp has continued to fill this facility with PCBs, mercury, arsenic and lead right on the lakebed and adjacent to the Calumet River and Calumet Park, with Steelworkers Park within view on the other side of the river.

And now, as of July 17th, 2020, the Army Corp has released their Final Dredge Management Plan and EIS (“Final DMP/EIS”) and draft Record of Decision for a final comment period until August 17, 2020. Friends of the Parks calls upon this committee to use its legislative and leadership powers to stop the Army Corps in its tracks and stand up to the Chicago Park District for withholding a lake-front park from the 10th Ward. Under the Lakefront Protection Ordinance and the long-established public trust doctrine, City Council has a responsibility to review and deny any proposal that would misuse public trust land intended to be a city park.

Since early 2019, FOTP has been actively calling for appropriate public vetting of this serious threat.  And now, per FOTP’s Freedom of Information Act (FOIA) requests, as of May 2020, the Chicago Department of Transportation has provided the Army Corp with a letter of intent to take on cost-share responsibilities to the tune of $10 million at a time when the City is challenged with extremely difficult decisions about how to utilize limited public resources.Additionally, the Chicago Park District has committed to allow this public trust land, which it has the responsibility to steward on behalf of all Chicagoans and Illinoisans, to be utilized at no cost for on-going dumping on this site. There have been no City Council hearings and there has been no Chicago Park District or City-led public process of any kind.

This is not only another attempt at giving the short end of the stick to the 10th Ward and neighboring communities; but considering the increasing frequency and severity of storms contributing to massive lake erosion all along the shoreline, there is a looming threat to the structural stability of this facility. Its failure would put the entire city’s and region’s drinking water at risk in addition to annihilating fish, bird, and other wildlife and their habitats. The current facility is already 40-plus years old and failing to contain toxins; expanding the structure vertically by 25 feet in the direct path of extreme conditions makes no sense. Chicago’s taxpayers will be left holding the fiscal responsibility for maintenance, stabilization, monitoring and toxic releases from this dangerous facility.

It is no secret that the Southeast Side has been Chicago’s dumping ground, and voices are clamoring loudly for the end to environmental injustice there. General Iron is poised to move into the area near Rowan Park despite vocal opposition, there have been previous high-profile battles regarding petcoke and manganese in the vicinity, and arsenic was recently found in a children’s’ baseball field in walking distance from the CDF. Yet still, the Army Corp claims in their EIS that “no minority or low-income populations would be exposed to disproportionately high adverse human health impacts or environmental effects.” Holding public parkland hostage to house toxic dredge is undoubtedly an adverse health and environmental effect.

Chicago public officials must demand that the Mayor’s Office explain its commitment to spend on this issue without a public vetting process to ensure an environmentally safe and modern solution for managing toxic dredge from the Chicago Area Waterways System without dumping it in the 10th Ward. I look forward to seeing this very urgent matter considered by the City Council.

Friends of the Parks is available at your convenience to discuss further or answer any questions you may have. Please contact Public Policy Associate Abigail Johnston at johnstona@fotp.org for more information.

Sincerely,

Your name
Your ward/district/municipality of residence


Email (Chief Sustainability Officer – Angela Tovar)


Subject Line: Welcome to your new role and urgent need for your attention to the Confined Disposal Facility on the Southeast Side 

To:

Chief Sustainability Officer – Angela Tovar, Angela.tovar@cityofchicago.org 

CC:

info@fotp.org

Chicago City Council Members (emails below)

Email Text:

Dear Ms. Tovar: 

We write to welcome you to your new role as Chief Sustainability Officer and to request a meeting with you as soon as possible to bring you up to speed on an urgent matter regarding an Environmental Justice Community on the Southeast Side of Chicago. Friends of the Parks (FOTP) is an Illinois not-for-profit organization founded in 1975 and dedicated to promoting healthy parks in the City of Chicago. Our mission includes ensuring park lands are equitably distributed and managed across the city to support healthy communities and a healthy environment. 

This letter is to request a meeting in follow-up to our meeting with former Acting Chief Sustainability Officer Elise Zelechowski regarding the existing confined disposal facility (“CDF”), constructed by the Army Corps of Engineers in 1984 and which currently sits on Lake Michigan between Calumet and Steelworkers’ Park in the 10th Ward. The group of Southeast Side advocates and Friends of the Parks board and staff who met with her per-COVID-19 were promised follow-up response which never took place. 

We understand that as a former resident of the 10th Ward, you are deeply connected to this community and understand the burden that this community carries of being a dumping ground. And we were pleased to see that at this weekend’s public meeting regarding General Iron, you announced a reform agenda. This makes the time even more ripe for our coalition to make sure you understand and can consider in your reform plans the environmental danger inherent in the continued operation of CDF on the shores of Lake Michigan and the Calumet River that is already leaking toxins into the water supply—let alone its expansion. We cannot allow another threat to go unchecked to Southeast Side Environmental Justice Communities. 

This letter warrants your immediate attention to this issue as time is running out. On July 17, 2020 the Army Corps of Engineers finalized a Dredge Management Plan and EIS (“Final DMP/EIS”) and Record of Decision for a final comment period that will last until August 17, 2020. There is overwhelming public opposition for yet another environmental threat to the Southeast Side community. 

These reasons outline the need for you to take immediate action on this issue: 

  • The Corp’s proposal for a 25-foot, vertical expansion of the CDF to house an additional million cubic yards of toxic dredge right on Lake Michigan is an egregious attempt at papering over a hazardous facility that has been a threat for years. Currently, landfill expansions in the city of Chicago are banned, but the Army Corps has skirted around this moratorium by not classifying dredge as a “waste”. 
  • There are a number of toxic contaminants found in the CDF’s mountain of dredge including PCBs, mercury, lead and arsenic. (Arsenic, as you probably know, was recently found in a children’s baseball field in walking-distance from the CDF). Considering the inevitable possibility of violent storm surge, stormwater run-off, and erosion, the CDF is a threat to nearby southside beaches, harbors, fish and wildlife, and drinking water across Chicago and the region. 
  • The structure of the existing CDF is nearly 40 years old; the effects of climate change on Lake Michigan are only going to exacerbate damage to the facility and as a result cause catastrophic damage to Chicago’s lakeshore. 
  • There is a high risk of airborne toxics associated with dredge handling, drying and storage that puts homes, businesses, Calumet and Steelworkers’ Park, and future developments at risk. 
  • Finally, the location of this proposed expansion is on public trust land owned by the Chicago Park District and required by law to be returned to them for use of a public park – yet there has been no city planning process on this issue. 
  • The Southeast Side of Chicago already has been exposed to a disproportionate number of environmental health threats – including the current threat of General Iron’s relocation to a site near Rowan Park and the high number of industrial plants in that vicinity. 

The City of Chicago and the Chicago Park District have the ability to stop this in its tracks before we put the Southeast Side of Chicago at risk for another 25-plus years of environmental abuse. There must be a public, city-lead initiative to vet the risks, burdens, equities, and costs to residents and taxpayers and a real effort to find a sustainable, equitable solution. The City must not allow dredge materials to be disposed of on the Lake Michigan shore or anywhere near the 10th Ward. 

To reiterate, FOTP adamantly requests that you put this issue at the top of your agenda as the new Chief Sustainability Officer. We look forward to a response with potential meeting times and dates so that we can more thoroughly brief you on this very urgent matter. 

Sincerely, 

Your name
Your ward/district/municipality of residence

Cc: 

Chief Equity Officer Candace Moore 

CDOT Commissioner Gia Biaggi 

Chicago City Council


Contact Information

Illinois
Governor J.B. Pritzker: https://www2.illinois.gov/sites/gov/contactus/Pages/VoiceAnOpinion.aspx Lt. Governor Juliana Stratton: LtGovStratton@illinois.gov
25th District Rep. Curtis Tarver: office@repcurtisjtarverii.com
13th District Senator Robert Peters: info@senatorrobertpeters.com
Illinois General Assembly: http://www.ilga.gov/

ILEPA
John J. Kim, Director General: EPA.ContactUs@illinois.gov
Barb Lieberoff: Barb.Lieberoff@illinois.gov
Environmental Justice Coordinator, Chris Pressnall: Chris.Pressnall@Illinois.gov

City of Chicago
Mayor Lori Lightfoot:  communityengagement@cityofchicago.org
Chief Sustainability Officer, Angela Tovar: Angela.tovar@cityofchicago.org
City Council: https://chicago.legistar.com/People.aspx, https://www.chicago.gov/city/en/depts/cdot.html
Gia Biagi – Commissioner Chicago Department of Transportation:gia.biagi@cityofchicago.org
Michael Kelly, CEO, Chicago Park District: Michael.kelly@chicagoparkdistrict.com 
Pat Levar, Chief Operating Officer, Chicago Park District: Patrick.levar@chicagoparkdistrict.com 
Chicago Park District Board of Commissioners: commissioners@chicagoparkdistrict.com 

Federal
Congresswoman Robin Kelly: https://robinkelly.house.gov/contact
Senator R. Durbin: https://www.durbin.senate.gov/contact/email
Senator T. Duckworth: https://www.duckworth.senate.gov/connect/email-tammy
Congressman Chuy Garcia: https://chuygarcia.house.gov/contact/email-me
Congressman Bobby Rush: https://rush.house.gov/contact/legislative-issues
Congressman Danny Davis: https://davis.house.gov/email-me/
Congressman Mike Quigley: https://quigleyforms.house.gov/forms/writeyourrep/
Congresswoman Jan Schakowsky: https://schakowsky.house.gov/zip-code-lookup?form=/contact/email-me
Congressman Brad Schneider: https://schneider.house.gov/zip-code-lookup?form=/contact/email
Congresswoman Lauren Underwood:https://underwood.house.gov/zip-code-lookup?form=/contact/email-me


Public Comments Submitted in August 2019 to the U.S. Army Corps

Below are public comments submitted from community organizations and stakeholders in response to the U.S. Army Corps of Engineers’ (“ACOE”) April 2019 Draft Dredged Material Management Plan and Integrated Environmental Impact Statement (“DMMP/EIS”) for the Chicago Area Waterway System in the Calumet region. 

Alliance for the SouthEast (ASE)
Southeast Environmental Task Force
Friends of the Parks
Openlands
Sierra Club of Illinois
Alderwoman Susan Garza
United States Environmental Protection Agency

Public Comments Submitted in August 2020 to the U.S. Army Corps

Alliance for the SouthEast (ASE)

Openlands/Sierra Club of Illinois