Gulf Restoration Network, the Louisiana Audubon Council, and the Sierra Club, Delta Chapter (collectively “Citizens”), represented by the Tulane Environmental Law Clinic, strongly object to the permit application in the name of Allstate Financial Company for a Clean Water Act Section 404 permit and 401 water quality certification to fill 24 acres of wetlands in St. Tammany Parish to create a multipurpose development. Citizens request that the United States Army Corps of Engineers (“Corps”) and Louisiana Department of Environmental Quality (LDEQ) complete an Environmental Impact Statement (EIS) on the significant effect of this filling of 24 acres of wetlands, particularly when considered in light of the past, present, and reasonably foreseeable future impacts of similar development in this area. The Corps must conduct a cumulative impacts analysis and the Corps must make that analysis available for public comment if the public is to meaningfully participate in these proceedings. Similarly, if the Corps does not perform an EIS, it must make its Environmental Assessment (EA) and its Finding of No Significant Impact (FONSI) available for public comment.