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 Mayor Lightfoot and the Illinois Environmental Protection Agency 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 (Illinois EPA)


Subject Line: Request for Public Hearing on CDF BUD Application

To:
Chris.Pressnall@Illinois.gov

CC:
EPA.ContactUs@illinois.gov
communityengagement@cityofchicago.org
elise.zelechowski@cityofchicago.org
info@fotp.org
gia.biagi@cityofchicago.org
Ward10@cityofchicago.org
candace.moore@cityofchicago.org
info@senatorrobertpeters.com
office@repcurtisjtarverii.com
Michael.C.Padilla@usace.army.mil

Email Text:

Mr. Chris Presnall
Environmental Justice Officer
Illinois Environmental Protection Agency
1021 North Grand Avenue East
Springfield, IL 62702
Re: Request for Public Hearing and Spanish Translation; Beneficial Use Application -20-001
Dear Mr. Pressnall:
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. We are writing to raise a health and parks issue affecting an Environmental Justice Community with you today.
By this letter, FOTP formally requests that the Illinois Environmental Protection Agency (IEPA) hold a public hearing on the Beneficial Use Application (BUD 20-001) filed the U.S. Army Corps of Engineers. We further request that such hearing be held in the evening or on a Saturday, in person and at a location in the neighborhoods of South Chicago or East Chicago which would be most impacted by proposed “beneficial use”.
A public hearing is required in this instance for many reasons:
  • The proposed “beneficial use” involves approximately 500,000 cubic yards of contaminated dredged material which would be dried and processed in the open air and permanently placed and effectively disposed of in an Environmental Justice Community in the 10th Ward of the City of Chicago.
  • The “beneficial use” of this massive quantity of contaminated dredge material is proposed in order to create a vertical 25-foot high mountain of dredge material directly adjacent to the waters of Lake Michigan, inevitably subject to violent storm surge, stormwater run-off, erosion and releases to both the surrounding Lake and air.
  • Even more troubling, this alleged beneficial use is proposed to take place directly adjacent to and between historic Calumet Park and new Steelworkers Park, and upstream from Calumet Beach and in close proximity to four other CPD parks and four other beaches, all of which risks human exposure to toxic air and water releases by already burdened residents of the surrounding Environmental Justice Communities. For an understanding of the proximity of these parks and beaches to the proposed “beneficial use” location see attached the Google Earth aerial photo of the area.
  • Finally, the proposed location of this alleged “beneficial use” is on public trust land owned by the Chicago Park District and required by law to be returned to the CPD for use as a public park – a use which would put residents of these communities at further risk of exposure to the contaminants in this contaminated dredge material.
In addition to being Environmental Justice Communities, South Chicago, East Chicago and neighboring South Deering and Hegwich, have large Spanish-speaking populations. Therefore, FOTP also requests that all notices pertaining to this Application, as well as the Application itself and all accompanying attachments, be translated into Spanish and that a Spanish translator be provided at the public hearing.
Further, as many residents of the surrounding Environmental Justice Communities do not have access to computers in their homes which would allow them to participate in a public hearing remotely during the Covid-19 crisis, it is essential that any action on this Application be postponed until such time as a safe in-person IEPA public hearing can be held in the local community.
Sincerely,
Your name
Your ward/district/municipality of residence
Cc:
Director John Kim, IEPA
Chief Kyle Rominger, Bureau Land – IEPA
Col. Aaron Reisinger, U.S. Army Corps of Engineers – Chicago District Commander Project Manager Mike Padilla, U.S. Army Corps of Engineers – CAWS CDF
Mayor Lori Lightfoot, City of Chicago
Deputy Director Elise Zelechowski, Deputy Director of Policy, City of Chicago
Alderman Susan Sadlowski-Garza, 10th Ward
Illinois Representative Curtis Tarver, II
Illinois Senator Robert Peters
U.S. Congresswoman Robin Kelly
U.S. Senator Dick Durbin
U.S. Senator Tammy Duckworth

Email (Mayor)


Subject Line: Stop the Expansion of the CDF

To:
communityengagement@cityofchicago.org
elise.zelechowski@cityofchicago.org

CC:
info@fotp.org
gia.biagi@cityofchicago.org
Ward10@cityofchicago.org
candace.moore@cityofchicago.org

Email text:

Dear Mayor Lightfoot,

On this 50th anniversary of global Earth Day, I write to ask you to bring your leadership to an issue of concern to all Chicagoans, Illinoisans, and, in fact, everyone who gets their drinking water from the Great Lakes. If the Army Corps of Engineers gets its way, they will expand and extend the life of a pollution dump on the shore of Lake Michigan and the confluence of the Calumet River, in an environmental justice community no less. They need to be stopped.

We are extremely concerned by your administration’s statement that appeared in Blockclub Chicago today. It suggests that you are unaware that the current site that the Army Corps of Engineers (“Corps”) wants to push forward with was not even a subject of discussion in most of the “public” dialogue about the confined disposal facility (CDF). They were looking at a number of other sites but were not even talking about keeping it in the same spot until 2019. The suggestion that they have done well by the public in terms of their process and due diligence is just inaccurate and unacceptable; it does not stand up to your stated principles of community engagement, transparency, and accountability. And this certainly is an issue that does not pass the equity test.

It was not until early 2019 the Chicago District of the Army Corps of Engineers surprised all of us who had been a part of the process by publishing a Draft Dredge Management Plan and Environmental Impact Study proposing to vertically expand the toxic dredge disposal facility 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.

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 in May–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.

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.

The Corps has provided no evidence that the Pollution Control Board’s stringent Lake Michigan Basin water quality standards are being maintained in the vicinity of the CDF or will be met following this expansion. In fact, the Corps initially provided no water quality data to support its DDMP/EIS and simply relied on the cynical assumption that the Southeast Side of Chicago and its lakefront waters are already contaminated.

This new 25-foot high hill of toxic waste will be permanently perched on the shore and subject to storm surge and rising Lake Michigan waters. What could go wrong? Well, for example:
Lake water flowing in and out of the CDF and waves crashing over its surface, as well as its exposed drainage, storage and drying operations, are likely to release the PCB’s, mercury, lead and other toxic contaminants in the dredge into Lake Michigan – contaminating the City’s drinking water and endangering residents using local beaches and harbors.
In a worst case, a structural failure of the CDF could be environmentally catastrophic for Lake Michigan and our region.
Day-to-day operations at the expanded CDF include air drying of toxic sediment which is likely to result in the release of airborne toxics, including volatilized PCBs, into the local community and adjacent parks, exacerbating air pollution in a community already highly impacted by air pollution, which we have now learned is a likely factor in COVID-19 related mortality rates.
Airborne and waterborne releases from this new mountain of dredge may endanger birds migrating along the Lake Michigan Flyway and destroy the habitat for the aquatic and terrestrial wildlife that live and breed on the Lake Michigan shore.

We implore you to intervene by pulling the City of Chicago and Chicago Park District out of their roles as cost-share partners on this project.

It is imperative that you step up to craft an appropriate resolution to this matter that does not call for the 10th Ward to continue to carry our region’s pollution burdens. Alternative processes and locations must be chosen to protect all of our public health.

We look forward to hearing a different message than what was in the newspaper when we hear from First Deputy Policy Director Elise Zelechowski per her commitment to communicate with us later today.

Sincerely,

Your name
Your ward/district/municipality of residence

CC:
First Deputy Policy Director Elise Zelechowski
CDOT Commissioner Gia Biaggi
Alderman Susan Sadlowski-Garza
Chief Equity Officer Candace Moore


Email (General)


Subject Line: Stop the Expansion of the CDF

To:
Emails below

CC:
info@fotp.org

Email Text:

Dear Your State Rep and/or Your State Senator,

On this 50th anniversary of global Earth Day, I write to ask you to bring your leadership to an issue of concern to all Chicagoans, Illinoisans, and, in fact, everyone who gets their drinking water from the Great Lakes. If the Army Corps of Engineers gets its way, they will expand and extend the life of a pollution dump on the shore of Lake Michigan and the confluence of the Calumet River, in an environmental justice community no less. They need to be stopped.

In early 2019 the Chicago District of the Army Corps of Engineers (“Corps”) published a Draft Dredge Management Plan and Environmental Impact Study 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.

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 in May–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.

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.

The Corps has provided no evidence that the Pollution Control Board’s stringent Lake Michigan Basin water quality standards are being maintained in the vicinity of the CDF or will be met following this expansion. In fact, the Corps initially provided no water quality data to support its DDMP/EIS and simply relied on the cynical assumption that the Southeast Side of Chicago and its lakefront waters are already contaminated.

This new 25-foot high hill of toxic waste will be permanently perched on the shore and subject to storm surge and rising Lake Michigan waters. What could go wrong? Well, for example:

  1. Lake water flowing in and out of the CDF and waves crashing over its surface, as well as its exposed drainage, storage and drying operations, are likely to release the PCB’s, mercury, lead and other toxic contaminants in the dredge into Lake Michigan – contaminating the City’s drinking water and endangering residents using local beaches and harbors.
  2. In a worst case, a structural failure of the CDF could be environmentally catastrophic for Lake Michigan and our region.
  3. Day-to-day operations at the expanded CDF include air drying of toxic sediment which is likely to result in the release of airborne toxics, including volatilized PCBs, into the local community and adjacent parks, exacerbating air pollution in a community already highly impacted by air pollution, which we have now learned is a likely factor in COVID-19 related mortality rates.
  4. Airborne and waterborne releases from this new mountain of dredge may endanger birds migrating along the Lake Michigan Flyway and destroy the habitat for the aquatic and terrestrial wildlife that live and breed on the Lake Michigan shore.

I implore you to intervene with:

  • the City of Chicago and Chicago Park District, which should pull out of their roles as cost-share partners on this project;
  • the State of Illinois, through the Illinois Environmental Protection Agency, which should not sign off on this project; and/or
  • federal elected officials who should intervene via the US Environmental Protection Agency and directly with the US Army Corps of Engineers to stop the Corps from finalizing an Environmental Impact Statement which ignores the adverse environmental impacts of continuing, expanding and extending this dangerous operation on the Southeast Side lakefront.

It is imperative that leaders like you step up to craft an appropriate resolution to this matter that does not call for the 10th Ward to continue to carry our region’s pollution burdens. Alternative processes and locations must be chosen to protect all of our public health.

Sincerely,

Your name

Your ward/district/municipality of residence

CC:
Mayor Lori Lightfoot
First Deputy Policy Director Elise Zelechowski
CDOT Commissioner Gia Biagi
Lieutenant Governor Juliana Stratton
Alderman Susan Sadlowski-Garza
Illinois Environmental Protection Agency, Director General,  John J. Kim
Illinois Environmental Protection Agency, Barb Lieberoff
Environmental Protection Agency, Environmental Justice Coordinator, Chris Pressnall
Congresswoman Robin Kelly
Senator Richard Durbin
Senator Tammy Duckworth
Friends of the Parks


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
First Deputy Commissioner and Acting Chief Sustainability Officer, Elise Zelechowski: elise.zelechowski@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

Federal
Congresswoman Robin Kelly: https://robinkelly.house.gov/contact
Congressional Representatives (Illinois):    https://www.govtrack.us/congress/members/IL#representatives 
Senator R. Durbin: https://www.durbin.senate.gov/contact/email
Senator T. Duckworth: https://www.duckworth.senate.gov/connect/email-tammy