Neighbors for a Better Crossing urges public to comment before April 14 deadline

Neighbors for a Better Crossing, a coalition of Oregon and Washington residents and businesses, is calling on the National Marine Fisheries Service (NMFS) to deny the Interstate Bridge Replacement Project’s (IBR) request for authorization to potentially harm and harass marine mammals over a five-year period during its proposed $9 billion I-5 bridge replacement. The IBR plans to conduct necessary work, including pile driving (impact and vibratory) and rotary drilling, to construct a replacement bridge for the Interstate may incidentally expose marine mammals in the vicinity to elevated levels of underwater sound, thereby resulting in incidental “take,” by Level A and Level B harassment. Therefore, the IBR requests authorization to incidentally take marine mammals.

The Marine Mammal Protection Act (MMPA) states that the term “take” means to harass, hunt, capture, kill or attempt to harass, hunt, capture, or kill any marine mammal.

The MMPA defines “harassment” as: any act of pursuit, torment, or annoyance, which (i) has the potential to injure a marine mammal or marine mammal stock in the wild (Level A harassment); or (ii) has the potential to disturb a marine mammal or marine mammal stock in the wild by causing disruption of behavioral patterns, including, but not limited to, migration, breathing, nursing, breeding, feeding, or sheltering (Level B harassment).

In a letter to NMFS, Neighbors for a Better Crossing warned that the project’s pile driving, drilling, and demolition threaten fish habitat and migration, and the broader Columbia River ecosystem — while a proven, eco-friendly Immersed Tube Tunnel (ITT) could eliminate these risks entirely. 

Public Input Request

With NMFS considering IBR’s request, public input is critical.harmful proposal and demand an independent review of the ITT alternative

How to Take Action

Submit comments before the April 14, 2025, deadline:

• Email: ITP.hotchkin@noaa.gov
• Mail: Jolie Harrison, Chief, Permits and Conservation Division, Office of Protected Resources, National Marine Fisheries Service, 1315 East-West Highway, Silver Spring, MD 20910

Neighbors for a Better Crossing letter sent to NMFS on March 19, 2025

Neighbors for a Better Crossing is writing to strongly oppose the National Marine Fisheries Service’s (NMFS) consideration of the Incidental Take Regulations (ITR) requested by the Interstate Bridge Replacement Project (IBRP) for construction activities on the I-5 corridor between Portland, Oregon, and Vancouver, Washington, as detailed in the application received on July 18, 2024, and deemed complete on January 16, 2025. The proposed pile driving (impact and vibratory), rotary drilling, and demolition of the existing bridges threaten significant harm to marine mammals, fish migration patterns, and the broader Columbia River ecosystem — harm that could be entirely avoided by adopting a smarter, more sustainable alternative: an Immersed Tube Tunnel (ITT). We urge NMFS to deny this ITR request and advocate for a solution that protects marine life while meeting the project’s goals. 

The IBR’s plan to install and remove 1,560 steel pipe piles and 1,500 linear feet of steel sheet piles over 1,725 days within a five-year period (September 15, 2027–September 14, 2032) will expose marine mammals — such as fish habitat and sea lions — to elevated underwater noise, resulting in Level A and Level B harassment. This disturbance risks disrupting critical behaviors like foraging, migration and communication, while the demolition of the existing bridges could release hazardous waste, including heavy metals and concrete debris, into the Columbia River, further endangering fish habitats and water quality. These impacts are particularly concerning given the river’s ecological importance and the documented challenges of in-water construction, as evidenced by the nearby Abernathy Bridge project on I-205, where drilling delays and geological difficulties ballooned costs from $248 million to nearly $1 billion.  

The IBRP’s reliance on over 100 drill shafts — each costing $2.5–$3 million and facing the same challenging bedrock and boulders identified in the 2013 Columbia River Crossing test drilling — only amplifies these risks. Yet, this critical issue was omitted from the Supplemental Environmental Impact Statement (SEIS), despite IBR officials’ awareness since May 2024, raising serious questions about transparency and environmental oversight. For a project with a price tag that could exceed $9 billion, offering minimal congestion relief (just one additional lane per direction), the ecological cost to marine life is unjustifiable when a proven alternative exists.  

The Immersed Tube Tunnel (ITT), championed by Neighbors for a Better Crossing, offers a compelling solution that eliminates the need for in-river pilings, drilling, and demolition-related pollution. Used successfully in projects like the $3 billion Fraser River Tunnel in Vancouver, BC, an ITT involves prefabricating tunnel sections off-site, floating them into position, and installing them in a pre-dredged trench. This method avoids underwater noise from pile driving, minimizes sediment disruption, and prevents hazardous waste from entering the river—safeguarding marine mammals and fish habitats. Additionally, an ITT is faster to construct, potentially cutting build time in half, and is expandable to meet future traffic needs, unlike the proposed bridge. The U.S. Coast Guard’s 2023 rejection of the IBR’s reduced vessel clearance (from 178 feet to 116 feet) further supports a tunnel, which preserves river navigation without ecological compromise.  

Beyond environmental benefits, an ITT is more cost-effective, avoiding the drill shaft cost overruns that could burden Oregon and Washington taxpayers with over $2 billion each in bond debt, plus tolls of $2,350 annually for commuters. These savings could even eliminate the need for tolls, sparing communities and businesses along the I-5 corridor from economic hardship. Meanwhile, the existing I-5 bridge, listed on the National Register of Historic Places with over 70 years of service life remaining, could be repurposed for pedestrians, bikes, and transit — preserving history and generating revenue without demolition-related pollution.  

We urge NMFS to deny the IBRP’s ITR application and press for an independent review of the ITT alternative, as called for by Neighbors for a Better Crossing. The authorization of incidental take for marine mammals is unacceptable when a viable, environmentally friendly option like an ITT can achieve the project’s objectives — improving safety, mobility, and seismic resilience — without harming the Columbia River ecosystem. We further request that NMFS require a comprehensive environmental impact assessment, incorporating the ITT and its benefits to marine life, before any further approvals are granted.  

Thank you for your dedication to protecting our marine resources. We would appreciate a response detailing how NMFS will address these concerns and whether it will advocate for the ITT alternative.