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Published by: KatrinaDocs on Apr 17, 2009
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E x p e rtR e p o rt\ue000
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L o u is D . B ritsc hI I I \ue000
U . S.A rm y C o rp so f E ngineers, N ewO rle a n s D istric t
R o b in s o nv . U n ite d S ta te s , C iv il A c tio n N o . 0 6 -2 2 6 8 , E .D .L a.
D ecem ber18, 2008

I am a geologist at the U.S. Army Corps of Engineers, New Orleans District. For the past 24
years I have worked in the deltaic plain of coastal Louisiana conducting research and studies
focusing on the geomorphic development of the coast, land loss rates and causes, subsidence,
and the engineering properties and characteristics of depositional environments. I have been
actively involved in the planning and design of coastal restoration and protection projects as part
of the Coastal Wetlands Planning Protection and Restoration Act, Coast 2050, and the Louisiana
Coastal Area Study, all multi-agency projects with participation from numerous Federal, State,
and local agencies. I contributed land loss data and analysis, borrow source identification,
geologic history, and engineering geology data. I have published Corps technical reports, journal
articles, and proceedings, and made presentations at numerous technical conferences on the
subjects of land loss, subsidence, and geomorphic development of coastal Louisiana. As an
employee of the U.S. Army Corps of Engineers, I am receiving no additional compensation for
the preparation of this report. I have not testified as an expert witness at a trial or deposition in
the past.


This Expert Report discusses the geology of the area in the vicinity of the Mississippi River Gulf Outlet (MRGO) and the loss of land and habitats in the surrounding area. As detailed below, it is my opinion to a reasonable degree of scientific certainty that:

- The construction of the MRGO is only one of numerous factors which have contributed
to land loss, habitat change, and salinity change in the study area.
- Large-scale logging operations in the late 1800\u2019s and early 1900\u2019s removed the large,
old-growth baldcypress trees from the study area, prior to construction of the MRGO.

- The land loss rate trend for the study area (see Figure 2) is the same as that found in the Central Wetlands Unit (CWU) (see Figure 3), the Pontchartrain Basin as a whole, and in other basins along the Louisiana coast. Land loss rates and trends in the study area are not higher than in other areas of the Louisiana coast.

- Geomorphic and mapping data suggest that the trends of barrier island migration,
degradation, and loss were in place since the late 1800\u2019s, well before construction of the
MRGO, and continued after construction.

- The expert reports by Day and Shaffer (2008) and FitzGerald and others (2008) attempt
to show that most of the land loss, habitat change, saltwater intrusion, barrier island
degradation, etc. in the vicinity of the MRGO is due to construction and operation of the
MRGO. Data presented within the following sections clearly show that numerous other
processes and factors contributed to the changes within the study area, many which were
active prior to construction of the MRGO.

Regional Geologic Setting

The geomorphic development of coastal Louisiana is closely related to shifting Mississippi River
courses since the slowing of Holocene post-glacial sea level rise (Fisk, 1955; Frazier, 1967; and
Coleman and Gagliano, 1964). The Mississippi River has changed its course several times
during the last 7,000 years, leading to the development of the Mississippi River deltaic and
chenier plains. The deltaic plain is composed of several major delta complexes, two of which
(the Plaquemines/Modern and Atchafalaya) are still active. Dominant physiographic features of
the deltaic plain include abandoned courses and distributaries and their associated natural levees,
swamps, marsh, hundreds of lakes and bays, and barrier islands.

Recognition that the deltaic plain is formed by an orderly progression of events related to
shifting Mississippi River courses led to the identification and characterization of the \u201cdelta
cycle\u201d (Scruton, 1960; Frazier, 1967). The \u201cdelta cycle\u201d is a dynamic and cyclic process that
alternates between periods of progradation and a subsequent transgression of deltaic headlands as
deltas are abandoned and reworked by marine waters (Penland et al., 1988; Roberts, 1997).
Figure 1 illustrates the stages in the development of a major delta lobe through its regressive and
transgressive phases, from stream capture to submarine shoals. Many variables act to determine
the phase of the \u201cdelta cycle\u201d active at any one location. Time since initiation of stream capture
(the age of distributaries), sediment supply, rate of accommodation space creation (the area
available for deposition), relative sea level change, and rate of river discharge are some of the
variables responsible for development of the deltaic plain (Roberts, 1997).

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