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Comments to the U.S. Army Corps of Engineers,

New Orleans Division, in Relation to the Mid-Barataria Sediment Diversion (MBSD) Project

October 24^th, 2022

Grant S. McCall, Ph.D.

Executive Director and Chief Research Scientist

Center for Human-Environmental Research

Associate Professor

Dept. of Anthropology

Tulane University

mccall@cherscience.org

Russell D. Greaves, Ph.D.

Director

Office of Contract Archeology

University of New Mexico

Research Associate

Center for Human-Environmental Research

rustygreaves@yahoo.com

Our comments pertain to the social impacts of the Mid-Barataria Sediment Diversion (MBSD) project on the coast fishing communities in Lower Plaquemines Parish and its adjacent regions. As we perceive it, the primary failing of the final Environmental Impact Statement (EIS) concerns the potential negative impacts of the MBSD project on small-scale commercial fishing activities and, moreover, the knock-on consequences for community cohesiveness and resilience. The final draft of the EIS admits that there will be “major,” “permanent,” and “adverse” effects on the commercial fishing of brown shrimp (Farfantepenaeus aztecus) and oysters (Crassostrea virginica), and that these effects will have direct negative economic consequences for commercial fishers in Lower Plaquemines Parish, as well as broader indirect consequences for their communities.

The first and most important aspect of our comment focuses on the unrealistic expectations having to do with the responses of small-scale commercial fishers and fishing communities to the negative consequences of shifting salinity levels, pollutants, sediment loads, etc. The anticipated responses to these issues on the part of commercial fishers fall into three major categories: (1) mobility, i.e. making longer fishing trips in seeking target species; (2) flexibility, i.e. generating the capability of targeting alternative species; and (3) departure, i.e. exiting the fishing industry, moving into new industries, and/or physically leaving their current homes. Each of these expectations is, in our view, profoundly problematic reasons from both a social scientific and moral/ethical perspective.

The first adaptive strategy proposed by the MBSD EIS is the idea that fishers can cope with negative environmental consequences in the project area by traveling further offshore in pursuing target species. This strategic shift is at its most unrealistic as it pertains to the harvesting of oysters, which overwhelming takes place in private water-bottom oyster leases held by small-scale commercial fishers. In the Barataria Basin especially, virtually none of the harvested oysters come from the public oyster zones and virtually all oyster landings come from privately held water-bottom leases. Such water-bottom leases, that are granted by the Louisiana Department of Fish and Wildlife, have often been held by individuals and families for generations. The contents of their specific oyster fisheries and known and depended upon by oyster fishers. Local oyster fishers rely on extant and known infrastructure and established relationship for selling their catch. This is not necessarily easily restructured for them. In addition to the potential complexity of completely re-organizing the logistics on which their livelihood depends, oyster fishers and their families have deep temporal and cultural connections with those places in both practical and emotional terms. In many cases, families are closely tied to specific oyster leases in ways that would be impossible to re-establish through fishing activities elsewhere, either in public oyster areas or in alternative private leases. It would represent a tremendous economic hardship in an already-difficult industry, and it would be emotionally draining in relation to the potential loss of long-term family connections and attachments with particular places.

Next, as the mobility solution pertains to shrimpers, longer trip distances would further stress fishers who already exist on very thin economic return margins. Recently, a combination of high fuel costs (and other vessel operation expenses) and extremely low market prices have pushed small-scale commercial shrimpers to their limits. Many have already left the industry or are in the process of leaving. Longer fishing trip distances would obviously increase fuels costs significantly and add to the overall burden of vessel maintenance and operation. It also decreases return rates by necessitating more travel time from docks to shrimping areas, that obviously includes major opportunity costs in conducting other complementary forms of economic activity. In short, it makes a difficult lifestyle—one that has already pushed many beyond the breaking point—dramatically harder.

The second approach proposed by the MBSD has to do with the generation of increasing flexibility in terms of fishing activities, strategies, and gear/tactics. In a nutshell, the idea is the fishers can offset potential negative effects on target species by shifting their focus to alternative species. A key example in this regard is an anticipated shift from the targeting of brown shrimp, that are likely to be significantly harmed by the MBSD project, to the targeting of white shrimp, which are likely to be less affected. Above all, what is missed here is that it is not a zero-sum game: shrimpers currently depend on both species, which have non-overlapping seasonality. Shrimpers can’t simply catch more white shrimp to make up for the loss of the brown shrimp season. Furthermore, we find it highly unlikely that those currently involved in the commercial shrimp and oyster industries, who already mix various fishing opportunities with other forms of economic activity in quite complex ways, could easily augment lost income by targeting finfish or other seafood species. If those opportunities were viable, people would already be doing them.

Finally, the most unrealistic expectation of the MBSD EIS is that small-scale commercial fishers could exit the industry and easily transition into alternative forms of quality employment. In fact, the EIS document admits this numerous times, repeating some variant of the following: “Low income and minority populations may be less likely to adapt to changing environmental conditions because switching to other industries due to age, educational or training background, cultural or language barriers is difficult” (Appendix H, p. 139). Such barriers in terms of literacy, language, immigration status, education level, age, and cultural background also deterred a core segment of the small-scale commercial fishing community from participating in the MBSD environmental review process and certain cultural/ethnic/linguistic communities have basically given up on achieving any form of government support at the state and federal levels. The expectation that impacted commercial fishers would, for example, enter the formal educational system to retrain into an alternative industry is as absurd as it is unfair.

Additionally, in our research, we have noted that the vast majority of small-scale commercial fishers already alternate their involvement in a diversity of other forms of economic activity at various time scales: for example, a small-scale commercial shrimper who also works as a roofer or handman. Alternative sources of economic income allow small-scale commercial fishers to cope with dynamics of economic risk posed by fluctuations in fuel prices and other operating costs, market prices, variable abundances of target species (i.e. good vs. bad seasons), and disaster events. Once again, however, combining small-scale fishing and alternative economic activities is not a zero-sum game. Fishers frequently need both kinds of economic opportunities to survive, particularly in the context of sharply declining fishing profit margins. While small-scale fishers can periodically participate in alternative forms of economic activity, they cannot continuously expand their participation in other industries as a permanent solution to the disruptions caused by the MBSD project.

In a more general sense, we feel that, in severely undermining small-scale commercial fishing activities in the Barataria Basin, the MBSD project will have profoundly negative consequences for coastal communities in the region, especially in Lower Plaquemines Parish. Our research (McCall and Greaves 2022) has shown that Lower Plaquemines Parish communities are comprised of complex and crucial networks of social support that assist individuals and families in coping with disruptions at various scales of both time and severity. On the one hand, such disruptions include personal events, such as the loss of a job, an illness/injury, a death in the family, etc. During such times, networks of social support provide a wide range of help, including money, employment, food, childcare, home repairs, mechanical assistance, emotional support, and other forms too numerous to list here. In addition, such networks of social support were fundamental in dealing with large-scale stressor events, such Hurricane Katrina and the B.P. oil spill. More recently, such social networks played a major instrumental role in the region’s response to and recovery from Hurricane Ida—often filling gaps in terms of the shortcomings of government responses at the state and federal levels.

In our view, the greatest failure of the MBSD EIS from the perspective of social science is its characterization of Lower Plaquemines Parish as lacking “connectedness” and having low scores on indices having to do with social wellbeing at the community level. The apparent implication of this is that the negative consequences for coastal fishers will have a muted impact on overall community wellbeing and resilience since there isn’t much to lose on those fronts to begin with. Based primarily on publications by Dillard et al. (2013) and Buck et al. (2015), the EIS measures social connectedness using (among other things), “charitable giving, access to telephone services, participation in democracy (voter turnout), tenure in community, [and] number of religious organizations per 1,000” (p. 3-189). This approach was obviously designed to cull information from publicly available internet sources, such as census and corporate data, voting records, and so on. Given the life-and-death seriousness of this set of issues, we believe that deeper ethnographic research was warranted in evaluating project impacts to coastal community social systems. In reaching the wrong conclusion in this dimension, the MBSD EIS is making a serious and consequential mistake.

Our research has shown that small-scale commercial fishing is the glue that holds together such important social systems of support and reciprocity. In a broad sense, fishing provides a living for a large swath of coastal community populations, which is particularly concentrated among low-income and minority communities. If this form of economic production is lost, it will seriously harm a key segment of these communities, undermining the ability of those involved in the fishing industry to provide support to others in the community while needing further support themselves. As fishers slip further into poverty and/or leave the area, this will have wide-ranging consequences for both the overall health and resilience of coastal communities. Many residents feel that they may be forced to leave their homes and that their communities may cease to exist altogether by virtue of the impacts of this project—and we fear that they may be right. In one of the riskiest places on Earth, the social consequences of the MBSD project would seem to make it even riskier.

The final aspect of our comment has to do with process. On the one hand, the MBSD project is likely to have existential consequences for coastal communities in the Barataria basin. On the other hand, as likely the most important coastal restoration project in U.S. history (and with a price tag in the billions of dollars), the success of the MBSD project is most directly threatened by an overwhelming lack of public support, particularly among coastal communities and commercial fishers. Clearly, the review process and public engagement with the MBSD project has failed.

There are multiple overlapping reasons for this, though a few things stand out as particularly important. For one thing, the major barriers to access on the part of coastal community members, as well as public hearing and meeting fatigue, have led to a near total failure in incorporating community feedback and traditional knowledge in the consideration and design of the project. For example, we have heard repeatedly that the project might have at least provided some benefits in terms of navigation between the river and Barataria Bay (as has happened unintentionally with the recent Mississippi River crevasse at Neptune Pass on the East Bank). For another thing, it is clear that the environmental impact review process has not invested the effort necessary to relate the potential impacts of the project to the lived experiences of the affected community members. Meaningful public engagement must be more than a long series of public meetings and comment periods for environmental impact statements. In this sense, it seems to us that both the attendant social scientific research done in relation to the project impacts and the mechanisms of public engagement were superficial.

Furthermore, relative to the multi-billion-dollar budget of the MBSD project, the expense of doing the kind of research and public engagement that seem warranted by such an expansive project footprint would be negligible. On top of that, it is also evident that a great deal of social scientific research was, in fact, done (see Appendix H)—much of which is generally consistent with the points made in our comment—and then it was basically ignored. In our view, the fight against coastal land loss and environmental degradation depends on having healthy and resilient coastal communities. If the MBSD project somehow succeeds in its environmental goals but drives out coastal fishing communities, it will be a Pyrrhic victory and, if the project fails at such a high cost, it threatens all future coastal restoration activities. For these reasons, the review process for projects like the MBSD must do much better in understanding, relating to, and engaging with coastal communities or the future of coastal restoration efforts is bleak.

References

Buck, K., M. Dillard, and K. Rose. 2015. Coastal Community Well-Being Data, National Centers for Coast Ocean Science, In Gulf of Mexico Data Atlas [Internet]. Stennis Space Center (MS): National Centers for Environmental Information; 2015. [8 screens]. Available online at: https://gulfatlas.noaa.gov/. Accessed January, 2018

Dillard, M.K., T.L. Goedeke, S. Lovelace, and A. Orthmeyer. 2013. Monitoring Wellbeing and Changing Environmental Conditions in Coastal Communities: Development of an Assessment Method. NOAA Technical Memorandum NOS NCCOS 174. Silver Spring, MD. 176 pp.

McCall, G.S., and Greaves, R.D. 2022. Creating a Diversion: Why the Mid-Barataria Sediment Diversion (MBSD) Project Is Unpopular Among Coastal Communities in Southeast Louisiana. Marine Technology Society Journal 56(3): 67-83.