July 6, 2020

Ms. Elaine K. Holley
Norfolk District US Army Corps of Engineers

Dear Ms. Holley:

The Hanover County Unit of the National Association for the Advancement of Colored People would like to use this opportunity to express our concerns regarding the proposed Wegmans Distribution Project (Corps Project # 2012-02369) and it’s uneven impact on the Brown Grove community. We have been following this matter and believe there are several issues that need resolution prior to the issuance of any permit that would allow the project to advance. Specifically, we are concerned with the following:

  • The lack of engagement with Brown Grove residents and the surrounding communities to negotiate ways to reduce the negative impacts of the proposed Distribution Center.

  • An unjustified conclusion by the Army Corps of Engineers the project does not require an Environmental Impact Statement review

  • No environmental justice review has been conducted to study the cumulative impacts of industrial encroachment on the Brown Grove community

  • A general lack of respect regarding long documented public statements there are unmarked grave sites on the property by Brown Grove residents

While much can be stated about these concerns, the Hanover County NAACP generally supports the comments others have made regarding these topics. We feel the process has been rushed and legitimate concerns expressed by Brown Grove and other nearby communities have been largely dismissed by Wegmans and others supportive of this development. This is exemplified by the continued insistence that no surveys for human remains be conducted beyond simple visual observations.

Ample evidence exists that would lead one to reasonably conclude alternative scenario analyses allowed under the National Environmental Policy Act (NEPA) of 1970 is required to fully understand the impacts the proposed Wegmans project would have to surrounding communities. While the Corps stated in the permit public announcement that no Environmental Impact Statement (EIR) review was necessary, little information was provided to support this decision.

We respectfully request this reasoning be made public to ensure full transparency of the decision-making process.

We encourage the Corps to have an environmental justice study conducted for this project, where Brown Grove community members can be engaged along with other nearby residents. Brown Grove – established after the Civil War by freed men and women – has a long-documented history of industrial encroachment. Thus, the proposed federal action needs to account for this proposed action and consider real world alternative actions.

We are also aware the Hanover County Comprehensive Plan has a future expansion of New Ashcake Road going through Brown Grove close to the current footprint of Egypt Road, which boarders the western portion of the proposed distribution center. Such a project needs to be considered along with the distribution center and the other industrial encroachment issues Brown Grove has suffered. A 3rd party conducted environmental justice study that allows collaboration with local stakeholders would provide for a greater understanding of the project and its negative impacts.

The Brown Grove School is located on the proposed project site. While minor archaeological surveys have been conducted, the Hanover County NAACP is concerned with the recent conclusion the school offers little historical research value. We understand from Brown Grove residents the structure was also used as part of the original community church. This would have been understood by all had residents been approached prior to the archaeological site work having been conducted. An area like this could also have unmarked grave sites.

It is our view the Brown Grove School represents a significant historical resource that requires further investigation. Brown Grove community members should be consulted regarding the school and an effort made to both preserve the structural remains and record the school’s history.

The Hanover County Unit of the NAACP Virginia disagrees with the US Army Corps of Engineer’s current recommendation to proceed with issuing a permit for this project. It is our view this effort has been rushed. Key steps in gathering basic information regarding this project has been skipped. The affected communities have been largely excluded. As a result, the issuance of any permit for this project will result in continued environmental injustice directed towards Brown Grove. This is an unacceptable inequality that requires resolution.

No permit issuance should unfairly target this minority community who has been already suffered from unchecked industrial sites being located in their literal “backyards”. Wegmans would be another such project.

The Hanover County Unit of the NAACP respectfully requests the Army Corps to defer any permit issuance until both a formal Environmental Impact Statement review and Environmental Justice study are conducted. Given the long disenfranchisement of Brown Grove, we request there be sufficient effort made to ensure members of this community and others are proactively engaged in such efforts.

Please reach out should you have any questions or concerns regarding these comments.

Respectfully,

Robert N. Barnette Jr. President, Hanover County NAACP
Chris French Environmental Committee Chair, Hanover County NAACP