Louisiana Coastal Wetlands Lawyer & Attorney : Erich P. Rapp : Kean Miller Law Firm : Serving New Orleans, Baton Rouge, Shreveport, Louisiana

Andrew C Revkin writing for the New York Times describes a variety of recent research suggesting that the worldwide sea level rise is greater and faster than previously realized. His recent article was published on June 19, 2008 in the Dot Earth blog and is entitled: Seas Rising and Warming Faster than Realized. He has linked his article to a number of other interesting and relevant publications.

The worldwide sea level rise is a very important aspect of coastal land loss in Louisiana. This is a global condition overlaying a problem associated with the management of the Mississippi River system that cannot be ignored. Global sea level rise further demonstrates the urgency with which action is needed in Louisiana on coastal land building.

Erich P Rapp.

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Mark Schleifstein of the New Orleans Times-Picayune writing on June 19, 2008 in an article entitled, Levee authority backs national '8/29 Commission' investigation reported that the Southeast Louisiana Flood Protection Authority had passed a resolution asking Congress to create a 8/29 Commission to investigate the government's handling of the aftermath of Hurricane Katrina. The resolution was proposed by John Barry, the author of Rising Tide.

Barry stated,

"I'm really asking that they take a comprehensive look at the entire Mississippi River system, the entire Mississippi valley, from New York state to Idaho," Barry said. "They should look, for instance, at the dams on the upper Missouri River in detail, because they have a real impact on the amount of sediment that's carried in the river, which has a real impact on the erosion of wetlands in Louisiana."

"If the nation understood the reality of the negative impacts on us in the metropolitan area of economic decisions upstream that were made in the national interest," it might lead to better decisions in flood control involving both protection from hurricanes and high rivers."

John Barry has said it exactly right. I am not aware of anyone speaking more closely to my own thinking on the causes and solutions related to the loss of Louisiana's coastal wetlands than John Barry. The idea of a 8/29 Commission is an excellent one. The scope he suggests addresses exactly the issues that I have been raising in this blog. The loss of coastal wetlands in Louisiana is a national problem caused by the management of the Mississippi River drainage basin by the federal government. 

I am not suggesting the federal government should not manage the Mississippi River drainage basin. I am just urging the federal government to acknowledge and take responsibility for their predominant role in causing coastal land loss in Louisiana.

Erich P Rapp. 

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As I have written many times before, the principal cause of coastal wetland loss is the reduction of sediment load in the Mississippi River. The reduction in sediment load has been caused primarily by the construction of locks and dams in the Mississippi River drainage basin, and the dams in the Missouri and Arkansas River systems are the most significant.

For the Corps of Engineers representatives working north of Louisiana, the reduction in the sediment load is a good thing. If your primary concern is navigation in the river system, a river with little sediment load is a good river. It means the Corps does not have to dredge the river bed as much.

In contrast for the Corps of Engineers in New Orleans tasked with coastal wetland restoration, a river with a limited sediment load makes their restoration job harder. Of course, the Corps in New Orleans is also given the task of maintaining navigation on the Southern course of the river. Thus, the Corps in New Orleans also prefers the smallest possible sediment load for management of their navigation responsibilities.

Which objective does the Corps serve? How do they decide which objective to serve and when? As far as I can determine, the Corps gives no consideration to the sediment load in the Mississippi River system needed for restoration and preservation of Louisiana's coastal wetlands when the Corps makes decisions about river management north of Louisiana. As a practical matter, the Corps cannot serve both objectives with no oversight and be expected to preserve and restore Louisiana's coast. The navigation interest extends for most of the river system course and the focus on preservation and restoration of coastal wetlands is an active part of decision making only in the Southernmost section of the river. Preservation and restoration of coastal wetlands loses and navigation wins in that internal competition at the Corps. As a practical matter, it cannot be any other way. 

The responsibilities for decision making need to be split and a neutral third party needs to be responsible for balancing the two interests.

A good recent news article expressing concern with the negative impact of sediment load on navigation can be found in the Baton Rouge Advocate on April 12, 2008. The article was written by John A Colvin and is entitled, Mississippi River sediment piling up.

Erich.

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As the Corps of Engineers closes gates on the Bonnet Care spillway and the water level on the Mississippi River goes down, Louisiana has lost a once in a decade opportunity to divert an enormous amount of river sediment into the coastal wetlands of Louisiana. Times of high water on the Mississippi River are very important times in the coastal wetlands land building process. Unfortunately, we were not prepared to take advantage of this rare opportunity and the loss of coastal wetlands continues.

According to Chris Kirkham's Friday April 18, 2008 article in the New Orleans Times Picayune entitled, State may be spilling coast's rescue, the recent high water event on the Mississippi River brought 900,000 tons of river sediment through the state and into the Gulf of Mexico.

If the Corps of Engineers had been better prepared to divert a large portion of the sediment into the coastal wetlands, the condition of the coastal wetlands might have improved this spring. The Corps of Engineers needs to change the river management to take advantage of the next high water level event.

Erich. 

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On February 29, 2008, the Baton Rouge Advocate newspaper published a letter from Maura Wood, a senior program manager with the National Wildlife Federation, under the headline, Letter: Preventing disasters key issue. Woods indicates that the National Audubon Society and the Environmental Defense Fund also support the efforts of the National Wildlife Federation in this cause.

In this regard, Woods urges representatives of Louisiana in Washington, D.C. to be leaders in restoring coastal wetlands as a barrier protecting the people living in South Louisiana from hurricanes.  Ms. Woods calls for a sense of urgency in the use of the land building power of the Mississippi River to restore coastal wetlands in Louisiana.

It is good to see these national environmental organizations taking a special interest in this important issue.

Erich P Rapp.

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Garrett Graves, the new director of the Governor's Office of Coastal Affairs announced at a the February 24, 2008 meeting of the Coastal Protection and Restoration Authority that the Jindal administration planned a larger financial commitment from Louisiana for coastal restoration. Graves indicated that Louisiana could stop all other economic development initiatives if it were not prepared to do more to protect and restore the coast.

Graves also indicated that that the state was considering a number of larger scale projects that would be massive diversions from the Mississippi River. These projects include the artificial third delta and a large diversion in lower Plaquemines Parish.

The Jindal administration considers Louisiana under invested in coastal restoration and levee protection and seeks to change this condition. Of course, this change will also require a fundamental change in the way the Corps of Engineers moves forward with projects.

For more information on Graves comments at this meeting, see the Baton Rouge Advocate article published on February 25, 2008 entitled, Official: La to expand coastal commitment.

Erich P Rapp.   

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The Baton Rouge Advocate published a letter on March 5, 2008 under the headline, Letter: Wetlands require urgent action. Kerry St. Pe, the program director for the Barataria-Terrebonne National Estuary Program, wrote in the Baton Rouge paper that all stakeholders must join together to move quickly to restore coastal Louisiana.

St. Pe concludes that the state cannot afford delays that might be caused by strategies that could result in drawn-out disagreement. He emphasizes the adoption of proven technology on a large scale. In particularly, he suggests using existing sediment delivery technology such as dredges, pumps and pipelines need to be employed immediately. The land built through the sediment delivery processes must then be supported with small to medium size river diversions. These diversion will sustain the new land.  

St. Pe expresses concern about the disagreements arising from large scale river diversions. He views large scale diversions as potentially contentious and questions whether such diversion have long term benefits.

In sum, St. Pe thinks Louisiana should focus on the strategies where consensus exists.

Erich P Rapp. 

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The Corps of Engineers will soon begin work on the Lower Mississippi River Resource Assessment which was authorized in the Water Resource Development Act of 2000. The study will take two years and cost about $500,000. The study area includes the portion of the Mississippi River from Cairo, Illinois which is the confluence of the Ohio River with the Mississippi River to the mouth of the Mississippi River at the Gulf of Mexico. The study area includes 954 miles of the river and also includes 2.7 million acres of the river's natural floodplain (now protected from flooding by levees).

The study will consider aspects of the Mississippi River beyond navigation and flood control. The study will assess ways to enhance recreation, restore flood plain and restore aquatic habitat. The study will also consider some tributaries of the Mississippi River.

What Louisiana really needs is an assessment of the impact of management of the Mississippi River north of Louisiana on coastal wetlands in Louisiana. The scope of this study seems broad enough for such considerations, but will they be included?

The news coverage of this river assessment includes an article in the February 4, 2008 Memphis Commercial Appeal entitled River Resource Assessment will last two years and coast up to $500,000.

Erich.

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On February 17, 2008, Torbjorn E. Tornqvist of Tulane University and other researchers published a letter in the journal Nature Geoscience entitled Mississippi Delta subsidence primarily caused by compaction of Holocene strata. The research findings suggest that the Mississippi delta is sinking as much as one fifth of an inch per year, but that the sinking is mostly limited to the upper layers of sediment while the land beneath is more stable.

This research suggests that the high rate of subsidence is largely the result of compaction of the shallow sediment deposits from the last 10,000 years in the upper few hundred feet near the surface of the earth. These findings suggest that flood control structures that penetrate through the shallow sediment deposits and rest on the more stable foundation below would not subsidence as quickly.

News articles reporting on this research include: Science Daily in an article entitled Post-Katrina Rebuilding? Mississippi Delta Both Spongy and Stable published on February 22, 2008; and New York Times in an article in a section entitled Observatory with the article title Support for a Theory As to Why Land Sinks Along the Gulf Coast by Henry Fountain published on February 19, 2008.

Erich P Rapp

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A recent article in the Geophysical Research Letters entitled, Post-glacial sediment load and subsidence in coastal Louisiana by Erik R. Ivins, Roy K Dokka, and Ronald G. Blom concluded that heavy sediment deposited in the Mississippi River delta at the end of the last ice age has caused coastal Louisiana in the Mississippi River delta to sink. This process is expected to continue for hundreds of years. The process will likely cause the area in question to subside over three feet in the next two hundred years.

The sinking of this land will likely be compounded by a general sea level rise from global warming. These factors will make the area more vulnerable to hurricanes and tropical storms. Of course, the hurricanes and tropical storms will then themselves do further damage to the coastal wetlands.

News Accounts related to this research paper can also be found at;

Associated Press: Sediment Make New Orleans Sink - February 1, 2008

Environmental News Service: Ancient Glacial Sediments Drag Down Louisiana's Sinking Coast - February 10, 2008 

Erich P Rapp

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Although efforts to stem coastal wetland loss in Louisiana are already grossly underfunded, the Corps of Engineers is seeking reimbursement for a part of the cost of dredging the Mississippi River to maintain the navigation channel from the budget for coastal restoration projects authorized and funded pursuant to the Breaux Act. See the editorial in the New Orleans Time Picayune on Monday February 18, 2008 and the related article in the New Orleans Times Picayune on Thursday February 14, 2008.

The Mississippi River Commission, which is related to and controlled by the Corps of Engineers, is taking the position that the State of Louisiana and the Corps of Engineers must pay for any increase in dredging costs that result from any coastal restoration project in Louisiana that diverts water and sediment from the Mississippi River.

Officials for the State of Louisiana believe that the transfer of this cost to the Breaux Act coastal restoration projects will effectively shut down the restoration projects.

Interestingly, Garret Graves, the Chairman of the Louisiana Coastal Protection and Restoration Authority and member of the Breaux Act task force suggested that perhaps the Corps should be responsible for the damage to the Louisiana coastal wetlands that resulted from the Corps management of the Mississippi River.

Melanie Goodman, the Corps' Breaux Act program manager replied that actions related to navigation "a century ago" which are damaging the coastal wetlands in Louisiana are in the past and not subject to reimbursement.

Of course, this entire blog is dedicated to the idea that the Corps is making decisions and undertaking actions everyday that adversely impact the Louisiana coastal wetlands and that the continuing series of interconnected decisions dating back many years is, in fact the responsibility of the Corps of Engineers and the federal government.

The Corps' two part defense is that it did not know they were damaging the coastal wetlands of Louisiana many years ago when they built dams and levees on the Mississippi River and its tributaries. This is, of course, not true. The Corps has known since the 19th century that the coast of Louisiana was subsiding and that the sediment from the Mississippi River offset the subsidence.

The additional implication from the Corps' claim about the past is that the Corps is not taking new actions today that adversely impact on the coast of Louisiana. This is also not true. The Corps makes management decisions about the Mississippi River and its tributaries such as the Missouri River and the Ohio River, everyday that deny or reduce sediment transport to the coast of Louisiana. In many ways, an analytical disconnect exists between management of the more northern portions of the Mississippi River drainage basin and the coast of Louisiana. The analysis of Corps projects in the Missouri River or the upper Mississippi River or the Ohio River almost never consider the impact of these projects on sediment transport to the coast of Louisiana, and those decisions and actions continue day after day and year after year up to the present and likely far into the future. The Corps' suggestion that the damage they have caused to Louisiana's coast is the result of actions far in the past is simply not true. It is also the result of events planned and executed in the present.

Erich P. Rapp.

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Mark Schleifstein reported in the Monday January 28, 2008 Times Picayune that the Corps of Engineers may propose the buy out of certain low lying properties as part of their comprehensive plan to protect south Louisiana from a catastrophic hurricane.

The areas in question would include the southernmost parts of Slidell, Mandeville, and Lacombe on the north shore of Lake Pontchartrain; Delacroix and Reggio in St. Bernard Parish; Ruddock in St. John the Baptist Parish; Lafitte and Barataria in Jefferson Parish; and a number of communities on both sides of the Mississippi River in Plaquemines Parish.

In part, I applaud the Corps willingness to accept some financial responsibility for the loss of land on the Louisiana coast and the economic damage that this loss of land has caused to land owners in the region. Of course, the scope of the acceptance of responsibility is a function of the price that the Corps is willing to pay for that which they buy.

The move also presents some reasons for concern. The offer to purchase low lying land on the coast of Louisiana suggests a conceptual move by the Corps from a restoration and preservation of coastal land strategy to a retreat from the subsiding land strategy.

This trend needs to be monitored closely.

Erich.

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On January 10-11, 2008, a two day conference on the Atchafalaya River was held in Baton Rouge. Over 150 faculty members from Louisiana universities, representatives of various state and federal agencies and interested individuals attended the conference. The purpose of the meeting was to review what people know about the river and its surrounding environment, to report on recent and ongoing research related to the river, and to identify information gaps that have a negative impact on decision making by land and water managers and government policy makers. The program included 30 presentations on research being conducted in relation to the Atchafalaya River and the surrounding basin

The Atchafalaya River is a 140 mile long distributary channel of the MIssissippi River. The delta at the Gulf end of the river is the only actively building delta in the Gulf of Mexico. The Atchafalaya transports 100% of the Red River sediment and 25% of the Mississippi River sediment. Because the gates at the Old River Control structure which joins the Mississippi River and the Atchafalaya River do not trap sediment in the way that other locks and dams do, the Atchafalaya River delta is allowed to continue a building process from the deposit of sediment.  Over time not only is the river delta building but the Atchafalaya basin itself is also naturally filling in and evolving from open water to cypress swamp to bottomland forest.

The delta building process that continues for now in the Atchafalaya is the same process that has ceased to function in the Mississippi River delta. This failure of this process has been the principal cause of the loss of coastal wetlands in Louisiana which, of course, is the subject of this blog. The study of the ongoing delta building process in the Atchafalaya river and basin is thus worthwhile to better understanding events in the Mississippi River delta.   

Erich.

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The situation in the Mississippi River where more sediment than ever is going into the river and less sediment than ever is reaching the coastal wetlands in Louisiana as described in the recent National Research Council report on the Mississippi River is not unique to the Mississippi River.

The problem is an international problem. On May 21, 2005, Science News Online published a report concerning river sediment entitled, Muddy Waters: More sediment is entering rivers, but less makes it to the sea. In turn, this Science news article was directly related to the publication of the scientific research paper entitled, Impact of Humans on the Flux of Terrestrial Sediment to the Global Coastal Ocean. This research article was published in the April 15, 2005 issue of Science Magazine in Volume 308 at page 376.

The conclusion of the Science news article and the research paper cited above are that humans have simultaneously increased the sediment transport by global rivers through soil erosion by approximately 2.3 billion metric tons per year, yet reduced the flux of sediment reaching the world's coasts by approximately 1.4 billion metric tons per year because of retention within reservoirs. Further over 100 billion metric tons of sediment and 1 to 3 billion metric tons of carbon are now sequestered in reservoirs constructed in the last 50 years.  Further still, coastal retreat is directly influenced by the reduction of river-supplied sediment.

The accumulation of sediment behind dams in accompanying reservoirs (particularly in the Missouri and Arkansas Rivers) as well as the accumulation of sediment behind locks in accompanying slack water navigation pools in other parts of the Mississippi River drainage system are contributing directly to the loss of coastal wetlands in Louisiana to the open sea.

Erich P Rapp.

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Dr. J. David Rogers, Professor of Geological Engineering at the University of Missouri-Rolla will make a presentation on coastal land loss in Louisiana at the annual meeting of the Geological Society of America which is being held in Denver, Colorado from October 28 to 31, 2007. The presentation will be held on October 31st at 10:30 AM in Room 505 of the Colorado Convention Center. The presentation is entitled, Geological Factors Promoting Subsidence and Coastal Land Loss in the Mississippi River Delta and the Great Debate about what to do about it.

Erich P Rapp.

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On October 16, 2007, the National Research Council issued a press release concerning the publication of their upcoming report entitled, Mississippi River Water Quality and the Clean Water Act: Progress, Challenges and Opportunities. A pre-publication copy of the report is also available online as a .pdf file. 

Again, the National Research Council has emphasized an important theme related to coastal wetland loss in Louisiana. The report strongly suggests that the Mississippi River system including the major tributaries need to be analyzed and administered as a whole and not in parts. Decisions are often made in relation to segments of the system without regard to the impact of those decisions on other parts of the river. The report specifically mentions the lack of sufficient sediment in the Mississippi River reaching the wetlands along the river in Louisiana as an example of this management issue. Inevitably decisions made far to the north of Louisiana along the Mississippi River determine the sediment transport of the river as it reaches the wetlands in Louisiana.

The people in Louisiana and the rest of the Mississippi River basin need to remember this truth when they take action in relation to the Mississippi River.

Erich P. Rapp 

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Almost all of the coastal area of Louisiana is no more than a few feet above sea level. This condition leaves many people in South Louisiana concerned about global sea level rise as well as the subsidence experienced in the Mississippi River delta region. If anyone ever doubted that the federal government and the Corps of Engineers were also quietly worried above the problem, the article on October 2, 2007 in the Los Angeles Times entitled Coastal buyout talk roils lives in Mississippi should remove all doubt.

The Corps of Engineers appears to have begun undertaking a voluntary project which looks a lot like a "pilot" project to assess the feasibility of a larger scale retreat from low lying coastal regions. Susan I. Rees of the Corps is directing a project aimed at buying out 17,000 coastal homes in Mississippi near Bay St. Louis with a proposed budget of $10 billion.  

Although the Corps states that it is not considering expansion of this buyout program, the implication for the bulk of Louisiana south of Interstate 10 is painfully clear.

Has the federal government and the Corps of Engineers quietly come to the conclusion that low lying coastal areas cannot be saved from inundation resulting from global sea level rise?  What does this mean for the coastal wetlands of Louisiana?

Erich P Rapp.

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As discussed in earlier entries, the coastal wetlands of Louisiana have been built and in the past maintained by sediment transported in the Mississippi River and deposited in the coastal wetlands. This natural process creates a relationship between the riparian lands in the upstream course of the river and the delta of the river. The existence of the wetlands depends on this relationship and the law protects it.

Louisiana law provides for predial servitudes. These servitudes concern the legal relationship between different "estates" or tracts of land or real property with different owners. In a predial servitude, a "dominant" estate has a right in relation to a "servient" estate. For example, one who builds a wall near a property boundary has an obligation as a servient estate to keep the wall in good repair so as to prevent damage to the neighboring "dominant" estate. This is a legal  servitude found in a Louisiana civil code article. Louisiana law recognizes legal servitudes, i.e., predial servitudes imposed by statute and conventional servitudes, i.e., predial servitudes created by contractual agreement between the owners of the separate estates. 

Louisiana law also recognizes a natural servitude. A natural servitude arises from the natural relationship between different estates. The statutes creating natural servitudes are found at Louisiana Civil Code arts. 654 to 658. These articles give the courts the power to examine the facts about how two estates or tracts of land relate to each other, and these articles allow the courts to find the existence of a servitude even though no contract or statute provides a specific description of the servitude.

These civil code articles create a natural servitude between the riparian landowners upstream on the Mississippi River and the coastal wetlands of Louisiana. In this natural servitude, the coastal wetlands are a dominant estate and the riparian lands upstream in the Mississippi River drainage basin (including the river's tributaries) from the coastal wetlands are servient estates.

The historic basis for the natural servitude is found in the Napoleonic Code and was ultimately derived from Roman law. Interestingly, this natural servitude bears a striking resemblance to riparian water rights recognized in the majority of the other states. The law of riparian water rights provides that riparian landowners can use the waters of a river, but cannot change any characteristic of the flow of the river to such an extent as to be detrimental to the interests of the riparian owners downstream. 

Also of note, the concept of a riparian water right entered the common law of the United States in a decision written by Justice Story in 1827 in the case of Tyler v. Wilkinson and subsequently referenced by Chancellor Kent in his commentaries on American law in 1828. Justice Story is said to have based his decision on Roman law.  The decision of Story as cited by Kent was widely relied upon by courts in the United States and England in giving form to riparian water rights.

The protection of all characteristics of the flow of a river including the quality of its sediment transport and the relationship of the sediment transport to the riparian land has a long basis in legal history of the common and civil law. In fact, this legal tradition dates back to the very beginning of law as recognized in western civilization, i..e, Roman law.

The existence of a natural servitude raises issues of choice of law between states, interstate legal conflict, federal immunity and countless other related issues. Nevertheless, a long legal history rooted in the very beginning of law, as we know it, which is now common to most of the states and the federal government of the United States has formed a basis for protecting the sediment transport in the Mississippi River that creates and maintains the coastal wetlands of Louisiana.

Of course, this entry barely touches the surface of the many legal issues that impact on a property damage claim based upon such a natural servitude. More later.

Erich Rapp.

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The Lake Pontchartrain Basin Foundation and the Coalition to Restore Coastal Louisiana have recently released a draft report entitled, Comprehensive Recommendations Supporting the Use of the Multiple Defense Strategy to Sustain Coastal Louisiana. Part II of the report is at this link. The LPBF and the Coalition are now seeking comments on the Draft Report. The deadline for providing comments is September 30, 2007.

Erich P Rapp.

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The National Wildlife Federation has recently released its "Hurricane Katrina Report Card."  The report grades Congress and the President in four areas: 1) Addressing Global Warming, 2) Reforming the U.S. Army Corps of Engineers, 3) Fixing FEMA, and 4) Restoring the Louisiana Coastal Wetlands.

With regard to Louisiana's coastal wetlands, the report gives Congress a "B." The report card praises Congress for: 1) directing the Corps to prepare a plan for closing the Mississippi River Gulf Outlet, 2) drafting a Water Resource Development Act (WRDA) that would authorize the first phase of a long-term plan for restoring Louisiana's deteriorating coastal wetlands and de-authorize the Mississippi River Gulf Outlet, and 3) allocating revenue from new offshore oil and gas leases to coastal states which will provide Louisiana with a dedicated revenue stream to fund coastal wetland restoration.

Congress is criticized for including the Morganza to the Gulf levee plan in the pending WRDA which will potentially damage the coastal wetlands. Further, Congress is criticized for delaying significant revenue from new offshore oil and gas leases from reaching Louisiana until 2017.  

The President is given a "D-" for his efforts regarding the restoration of the Louisiana coastal wetlands. The President is praised for objecting to the Morganza to the Gulf levee project. The President is criticized for his failure to demonstrate any sense of urgency, leadership, interest or commitment to Louisiana coastal wetland restoration in general and  to large scale diversion of sediment laden water from the Mississippi River into the wetlands that are essential to the restoration effort in particular.

It is also noted that the President blocked funding in 2003 of a long term comprehensive coastal restoration plan. Further, the report card notes that an early draft of the Corps' anticipated December 2007 report on hurricane protection will showed a disturbing preference for levees over a coastal restoration plan. This early draft also is noted for failing to consider how structural hurricane protection could destroy existing wetlands and thwart wetland restoration efforts.

Erich P. Rapp.

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