January 17, 2023
Ms. Samantha Belcik
U.S. Army Corps of Engineers, Chicago District
ChicagoShoreline@usace.army.mil
231 S. LaSalle Street, Suite 1500
Chicago, IL 60604-1437
Re: Comments on Chicago Shoreline Coastal Storm Risk Management
Dear Ms. Belcik:
As a member of Friends of the Parks (“FOTP”), I was informed that the U.S. Army Corp of Engineers (ACOE) is seeking comments on the National Environmental Policy Act document and General Reevaluation Report related to Chicago Shoreline Coastal Storm Risk Management.
I am a lover and supporter of Chicago’s parks. Chicago’s park system is incredible and one of the city’s unique features. The vast public lakefront parkland, which stretches for a full 26 miles along Chicago’s 30-mile shoreline, serves as the gem of that system and offers protection to our communities from the impact of climate change on Lake Michigan.
Climate change places our lakefront at risk. Intense storm winds and high waves pummel Chicago shoreline communities. Fluctuating lake water levels and more extreme weather events cause lakefront erosion, beach and park loss, flood risks to neighborhoods, sewer back-ups, and damage to roads, paths, homes, and businesses. The National Oceanic and Atmospheric Administration, Environmental Law and Policy Center, and leading scientists from universities in the Midwest predict the trend won’t end anytime soon.
In February 2020, Chicago declared a climate change emergency in response to severe storms, years of rising water levels, and lakeshore erosion. The storms of 2020 caused an estimated $37 million in damages to beaches and parks. The city lakefront watched as four beaches in Roger Park washed away and closed, enough sand was lost at Rainbow Beach to expose the infill, and other parks and beaches across the city suffered a battering of lake waves and the loss of sand and erosion at alarming rates.
The dual culprits for the damages were the storm and the failure of structural protections (revetments, metal girders, groins, and rock barriers), some of which were installed by the ACOE. In Rogers Park, beaches protected by structural barriers were washed away when revetments failed. Structural or hard armoring interrupts sand movement, alters wave dynamics, and pushes water to unprotected areas. Covering the entire lakefront with structural protections would be costly in installation and maintenance or replacement. Given previous failures of structural measures, ACOE must rethink the Great Lakes shoreline’s built environment and resiliency.
As we prepare for storms of the future, particular attention needs to be given to areas of greatest risk:
- communities facing the most severe flooding
- areas with industrial facilities on the shoreline that could contaminate our drinking water.
The Environmental Law and Policy Center’s 2022 report, Rising Waters: Climate Change Impacts and Toxic Risks to Lake Michigan's Shoreline Communities, named the communities most at risk along the shoreline: Chicago’s North Side neighborhoods of Rogers Park, Edgewater and Uptown and South Side neighborhoods of South Shore and the Southeast Side. The North and South Shore communities risk flooding and widespread damage to homes and businesses as far as half a mile inland. Southeast Chicago contains industrial facilities with hazardous waste.
Of particular concern to me as a resident is the Chicago Area Waterway Confined Disposal Facility (CDF) which sits at the confluence of the Calumet River and Lake Michigan, on a prime lakefront parcel. It is directly upstream from Calumet Beach and adjacent to both Calumet Park and Steelworkers Park. The Chicago district of ACOE has operated this dredging disposal facility since 1984, almost 40 years.
Lake Michigan provides the drinking water for three states, and providing for clean water should be a top priority of any Shoreline Coastal Storm Risk Management plan. Higher water levels threaten industrial facilities with hazardous and toxic materials built long ago along the shoreline, when water levels were lower. At particular risk is the CDF site in Chicago’s Southeast Side.
The site contains one million tons of contaminated or toxic dredge. The dredge contains numerous toxins and pollutants, such as mercury, arsenic, lead, and polychlorinated biphenyls. The sediment placed is stored in the CDF because it is considered too toxic to be dumped in the lake.
The CDF was scheduled to be closed in 2022 and turned into public parkland. The ACOE has proposed, instead, constructing a 25-foot mountain of toxic dredge atop the existing dump. The ACOE predicts that it will run the site for another 20 years. The CDF lingers as a remnant of previous eras' zoning and environmental policies and it needs to be removed to meet changing realities.
As water levels rise, the in-water facility is at greater risk of leaching water into the river or the lake. The ACOE's documents reveal that the container's liner is ripped, leaching toxins into the water supply. To attempt to remedy the problem, ACOE has placed sandbags at critical spots within the facility. The rip demonstrates that the site requires continuous maintenance and that its very existence poses an immediate threat to safe drinking water.
As storm surges and wave action increases, the aging facility is at risk of causing more pollution. Stronger, larger waves have risen as high as 20 feet in recent years, and a revetment built by the ACOE to protect Northerly Island and Rogers Park beach have failed. Recent violent storms washed away the sand used to plug the rip in the CDF liner. The Chicago Reporter noted that the U.S. Environmental Protection Agency critiqued the ACOE for not addressing climate change factors in the design of its proposed expansion. The structure has a dirt wall to hold in the toxic dredge. The plan omitted evidence about the ability of current walls and new walls of an expanded CDF to stand up to rising water, storm surges, and stronger waves.
Turning the CDF into a park as promised would be a nature-based solution to deal with the continually eroding lakeshore at risk of climate change damage and is a critical component to complete our Last Four Miles plan. Leaving this facility on the shoreline creates a risk of flooding and contamination of the homes and businesses by the toxins stored in the CDF. Any Chicago Shoreline Coastal Storm Risk Management plan should address reducing the risk of pollution and contamination.
One solution to this is Friends of the Park's Last Four Miles proposal to expand lakefront access to the two miles on the northern and two miles on the southern end of the lakefront without public paths, beaches, or parks. The CDF is one of the last critical parcel of lands on the South Side to complete Chicago’s public lakefront. The communities most at risk of flooding are the same communities without public lakefront parks.
Given the recent failure of structural protections and the great risk to our community from flooding, erosion, extreme storms and the impacts of climate change, a new method is needed. Communities lose money on repairs, rebuilds, and damages each time protections fail and need to be replaced. By selecting more sustainable solutions to begin with, we can save time and money.
We know now that our public parkland and natural areas are not only aesthetically beautiful but also can be on the front line of fighting climate change. Building parks is a cost-effective way to protect the Drive, bicycle paths, walkways, businesses, and residents. It will also protect habitats and animals we share the space with. By investing in parks, beaches, natural ecosystems, and other nature-based solutions, we can begin to build a lakefront that will help reduce the causes and impacts of climate change.
New parks and beaches suggested in the Last Four Miles initiative will contribute to Chicago’s long term environmental sustainability. The five hundred acres of new ecologically sustainable parks and beaches proposed would improve the air and water quality of Chicago and benefit Lake Michigan’s ecosystem. The new parks and beaches would provide shoreline protection from storms and erosion. The new parkland would create aquatic and wildlife habitats and support birds on the Mississippi migratory bird flyway.
Chicagoans have tirelessly fought to expand the amenity of our public lakefront. Lincoln Park, Grant Park, Burnham Park, Jackson Park, Rainbow Beach, and Calumet Park—all were created by the people of Chicago. A vast public parkland stretches for a full 26 miles along Chicago’s 30-mile shoreline as the result of the dedicated work of our predecessors.
Today the visionary legacy of Chicago’s founders has nearly been completed. Chicago’s lakefront park system creates a linear park expanse that is unrivaled in the Great Lakes Basin. When other waterfront communities neglected their shoreline, Chicagoans dedicated themselves to creating a beautiful public lakefront. The result is a legacy—an inheritance— upon which we can build.
Thank you for receiving my feedback.
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