Healthy Port Communities Coalition to Army Corp of Engineers Seeking Clarification Regarding on Future P11 Dredge Placement Plans
Colonel David W. Dake
District Engineer
U.S. Army Corps of Engineers, Galveston District
Houston Ship Channel Improvement Project
2000 Fort Point Rd.
Galveston, TX 77550
P.O. Box 1229
Via email: swgpao@usace.army.mil
Dear Colonel Dake,
On behalf of the Healthy Port Communities Coalition (HPCC), we hope this email finds you well. On December 16th, 2025, HPCC sent you a letter regarding the Houston Ship Channel Improvement Project (Project 11) – Life Safety Risk Assessment and Comprehensive Review of Upland Dredged Material Placement Areas (DMPAs). In the letter, our coalition highlighted significant concerns surrounding the DMPAs, supported by an independent technical analysis conducted by William B. Empson, PE, PMP, a retired USACE engineer. We requested that you provide clarification of the current U.S. Army Corps of Engineers (USACE) plans and meet with our coalition to discuss these issues in detail.
We are emailing you today to follow-up on that letter and request a meeting with our Coalition members. We have received confirmation from Representative Sylvia Garcia and Port Houston that USACE now plans to barge the dredge spoils offshore and not reopen the Glendale and Filterbed DMPAs. HPCC supports this decision and acknowledges the time, hard work, and difficult discussions undertaken to resolve this issue. Barging the dredge spoils from these specific sites prioritizes the health and safety of residents in the Pleasantville and Port Houston/Denver Harbor neighborhoods. We would greatly appreciate meeting with you to obtain clarification on the details of this new plan for the Glendale and Filterbed DMPAs. In addition, HPCC would also like to discuss the significant life safety risks associated with the East and West Clinton, Rosa Allen, and House Tract placement areas, which are immediately adjacent to residential neighborhoods in, Clinton Park, Galena Park, and Pasadena.
We also have an immediate concern over the rapidly approaching contract award for the expansion of the House Tract placement area. The USACE is scheduled to begin soliciting bids for this $10 to $25 million expansion (Solicitation No. W912HY26BA004) on July 20, 2026, with the award in late October 2026. Because this facility is located immediately adjacent to residential homes, we urgently request that the Corps fulfill its regulatory obligation to conduct a formal life-safety risk assessment prior to finalizing this contract.
Based on the analysis of our technical expert, the current approach is utilizing outdated analyses and inherently risky construction methods to support upland placement areas that are located immediately adjacent to homes. Continuing to dispose of dredge spoils in these placement areas is inconsistent with USACE standards and best practices. Our organizations and the communities we represent urge the USACE to find solutions that do not use, reopen or raise berms near residential communities.
Furthermore, our expert raises serious concerns that are relevant to the ongoing operations at the other DMPAs in the Greater Houston area. As our organizations have maintained, our desire is to work with both Port Houston and the U.S. Army Corps of Engineers to find solutions and approaches that support safety for the residents living in neighborhoods adjacent to these sites. As we outlined in our December 16, 2025, letter, barging the other spoils to Galveston Bay or the Gulf is a viable alternative that we support.
Our structural concerns include the following:
- The Project 11 design processes have not incorporated risk-informed decision-making or formal life-safety risk assessments as required by USACE federal policy.
- The slope stability analyses of the placement areas are outdated, and do not include static liquefaction evaluations.
- The proposed method for raising dikes, known as “upstream raising,” is high-risk and has been banned in Brazil because of frequent fatal failures of similar structures.
- The dredge spoils in the existing placement areas contain hazardous chemicals, yet Port Houston & USACE have refused to conduct comprehensive toxicity tests. The previously mentioned construction method proposes using these toxic dredge spoils for new berm construction.
- There are significant gaps regarding the effects of sea-level rise and land subsidence, and their impacts on dike stability and flood risk. Furthermore, the design does not address management of potentially toxic stormwater discharge.
- The proposed upland placement areas qualify as dams under USACE dam safety criteria, and therefore, should be designed, constructed, and operated in accordance with these standards.
Our coalition has had a longstanding relationship with the Corps, particularly as it relates to the Project 11 expansion, and has had consistent communication with Colonel Blackmon through correspondence and meetings, as exemplified in Colonel Blackmon’s October 30th, 2024 letter (attached). We are eager to continue this relationship under your leadership and look forward to hearing back from you.
Thank you for your time and consideration on this matter.
Sincerely,
Sarah Cinco
Healthy Port Communities Coalition Organizer
Representing:
Achieving Community Tasks Successfully
Air Alliance Houston
Bayou City Waterkeeper
Coalition of Community Organizations
Environmental Community Advocates of Galena Park
East Harris County Empowerment Council
Healthy Gulf
Public Citizen
Attachment: William B. Empson, PE. Project 11 Memorandum for Healthy Ports Community Coalition. Empson Consulting, LLC. December 9, 2025.
Attachment: USACE Healthy Port Follow-Up Letter 30 OCT 24
cc: Charlie Jenkins; Maria Aguirre; Ric Campo; The Honorable Ted Cruz; The Honorable John Cornyn; The Honorable Sylvia Garcia; The Honorable Dan Crenshaw; The Honorable Christian Menefee; The Honorable Carol Alvarado; The Honorable Molly Cook; The Honorable Ana Hernandez; The Honorable Mary Ann Perez; The Honorable Lina Hidalgo; The Honorable Adrian Garcia; The Honorable Rodney Ellis; The Honorable John Whitmire; The Honorable Tarsha Jackson; The Honorable Joaquin Martinez; The Honorable Oscar Mireles; The Honorable Leticia Plummer; The Honorable Christina Morales; The Honorable Penny Morales Shaw; The Honorable Harold Dutton; The Honorable Carol Alvarado; The Honorable Boris Miles