January 25, 2011 VIA E-MAIL AND U.S. MAIL Jeffrey M. Hall, Colonel U.S. Army Corps of Engineers 100 West Oglethorpe Avenue Savannah, Georgia 31401
[email protected] Re: Notice of Availability of a Draft Tier II Environmental Impact Statement and Draft General Reevaluation Report for Savannah Harbor Federal Navigation Project, Chatham County, GA and Jasper County, SC; S.C. Coastal Conservation League et al. v. Westphal, C/A No. 9-00-0798-23 (D.S.C. 2001) Dear Colonel Hall: On November 15, 2010, the Savannah District of the U.S. Army Corps of Engineers (the “Corps” or “Savannah District”) issued a Joint Public Notice (the “JPN”) providing Notice of Availability of a Draft Tier II Environmental Impact Statement (“DEIS”) and Draft General Reevaluation Report (“Draft GRR” or “GRR”) pursuant to the authority provided by Section 102(b)(9) of the 1999 Water Resources Development Act for the Savannah Harbor Federal Navigation Project, Chatham County, Georgia and Jasper County, South Carolina (hereinafter referred to as the “Project,” the “Proposal,” or “SHEP”). On behalf of the South Carolina Coastal Conservation League, the South Carolina Wildlife Federation, the Center for a Sustainable Coast, the National Wildlife Federation, and the Savannah Riverkeeper (the “Conservation Groups”), the Southern Environmental Law Center (“SELC”) submits this comment letter to express our substantial concerns about this proposed Project.1 As described in more detail below, this proposal raises serious problems regarding compliance with the National Environmental Policy Act (“NEPA”), 42 U.S.C. §§ 4321 et seq. (2010); the federal Clean Water Act (“CWA”), 33 U.S.C.