Comment submitted by D. Izzo

The National Dredging Policy and the Action Agenda for Dredged Material Management ought to be revised, if it all possible in conjunction with a revision of the Economic and Environmental Principles and Guidelines for Water and Related Land Resources Implementation Studies of 1983 (Principles and Guidelines or P&G). The following concepts should be considered for incorporation in a revised policy and agenda: 1. The Federal Government should establish a clear policy that all dredged sediment will be used beneficially and not disposed of as ?spoil? by dumping offshore or placing in ?disposal areas.? This policy should be reflected in increased funding for dredging programs and a ban on offshore disposal. 2. The Federal Government should abandon its current policy of disposing of dredged material in the ?least cost? way and instead find ways to use dredged material efficiently and in an environmentally beneficial way. Consequently, the P&G methodology for economic analysis ought to be revised to reflect the life-cycle benefits of using dredged material for coastal protection, wetlands restoration and other uses. 3. The Federal Government should clarify unambiguously that the U.S. Army Corps of Engineers is the lead Agency for Federal navigation dredging with full oversight and complete decision-making authority. 4. The Federal Government should manage sediment regionally with the states and other concerned stakeholders on a watershed basis, using the principles of regional sediment management (i) developing regional sediment inventories and sediment budgets that consider inputs, movements, uses, and outputs throughout the system, and (ii) implementing measures to avoid, minimize, and mitigate any adverse impacts to hydrogeomorphic processes and affected sediment regimes associated with dredging projects. 5. The Federal Government should define the role of the States and other governmental entities (e.g., public port authorities) particularly in regard to watershed planning and regional sediment management, where they have an important part to play in planning dredging and beneficial use of dredged material in support of Federal navigation and conservation efforts. 6. The Federal Government should include within the National Dredging Policy the 25,000 miles (of rivers, lakes and canals) of inland navigable waterways that must be dredged to maintain the inland navigation system. 7. The Federal Government should revise the CWA and MPRSA as necessary to include current dredged material management strategies (e.g., Regional Sediment Management, Beneficial Uses, and Risk Based technology) following the American Society of Civil Engineers? Policies on Beneficial Use of Dredged Material (PS 513, April 27, 2006), and Regional Sediment Management (PS 522, April 24, 2007). 8. The Federal Government should require proponents of dredging activities that affect sediment resources to work collaboratively with regional stakeholders to mitigate any adverse impacts to hydrogeomorphic processes and affected sediment regimes as a condition of obtaining permits under the Clean Water Act. Dominic Izzo, P.E., F. ASCE Former Principal Deputy Assistant Secretary of the Army (Civil Works) 19 Coldsprings Court The Woodlands, Texas 77380-4609 Tel: 281-367-8690 E-mail: dizzo77@comcast.net