Connect the Dots
The GNOTS permit isn't just about barges. It's about who those barges serve.
What GNOTS Reserve Filed
On March 9, 2026, the US Army Corps of Engineers published a public notice for GNOTS Reserve, Inc. (Permit No. MVN-2026-00154-EDM): a 9-tier by 8-barge mooring facility at Mississippi River Mile 120.5 in Luling, Saint Charles Parish. That's 72 barges covering 14.1 acres of river, and the comment window closes April 7.
GNOTS Reserve was founded in 1967 and already operates one of the largest fleeting operations in the country. The question is: why here, why now, and who does it really serve?
The GNOTS–IMTT Connection
The circled area shows the proposed 72-barge mooring at River Mile 120.5, immediately downriver from the Hale Boggs Memorial Bridge, next to IMTT's newly purchased Luling property.
The proposed barge mooring sits directly adjacent to IMTT's newly purchased 597-acre Luling property. Right now, IMTT has land in Luling but no convenient river access. GNOTS's barge fleet changes that, creating the connection between the Mississippi River and IMTT's property that would allow loading and unloading of petroleum and chemical cargo.
IMTT purchases 597 acres in Luling under a holding company, without alerting the community. IMTT CFO Matthew Rosenboom later admitted they "did not intend to use subterfuge," but residents weren't notified.
GNOTS expands its commodity authorization to include tank barges, exactly what a petroleum terminal like IMTT would need. The timing lines up directly with IMTT's Luling acquisition and rezoning push.
GNOTS files permit MVN-2026-00154-EDM for a 72-barge mooring facility at Mile 120.5, in front of IMTT's Luling property. The Corps gives the public 28 days to comment. No public hearing scheduled.
IMTT told residents at their August 2024 town hall that they plan to connect the St. Rose terminal to a potential Luling terminal through a pipeline under the river. The GNOTS barge fleet is the missing piece: it provides the river access that would make the Luling terminal operational.
What the Corps Is Not Analyzing
The USACE's own preliminary determination claims "no effect" on Essential Fish Habitat or endangered species, and "no impacts to wetland areas." But the permit was reviewed without a cumulative impact analysis, without accounting for what IMTT intends to build next, and without a public hearing.
The Corps is required to consider the welfare of the people, but only if those people speak up before April 7.
Health & Safety
A community already carrying a toxic burden, with no fire protection for what comes next
IMTT has had several fires at its St. Rose terminal in recent years. Fire Chief Barry Minnich of the Luling Fire Department stood up at IMTT's 2024 town hall and said the department is not equipped to handle an IMTT terminal, and does not support this project.
"How is Luling's fire department supposed to protect the community from a terminal that's paying only 20% of its taxes for the first ten years?" —Luling Fire Chief Barry Minnich
- Nine volunteer fire departments in St. Charles Parish
- IMTT plans to claim an 80% industrial tax exemption for 10 years, paying just 20% of their share while LFD bears the risk
- A fenceline homeowner at the town hall was told his insurance would increase ~$2,300/year due to industrial proximity
IMTT CFO Matthew Rosenboom was asked directly at the town hall if he would want to live in St. Charles Parish. He said no.
Environmental Impact
Five endangered species, a coastal restoration project, and 14 acres of river floor
What the Corps Called "No Effect"
The USACE's preliminary determination says this project has no effect on Essential Fish Habitat and no impact on wetlands. Scientists and local advocates disagree — and the Corps' own review process didn't include a cumulative impact analysis or a public hearing.
- Pallid sturgeon, one of the most endangered fish in North America, spawn in the natural bank habitat that deadman piles and riprap would destroy
- West Indian manatees are increasingly showing up in Louisiana waters; barge collisions are their leading cause of death
- Eastern black rail, confirmed in only three Louisiana parishes including ours, nests in nearby marsh
- Research shows 82% of plant life dies under mooring structures, a dead zone bigger than 10 football fields on the river floor
The Davis Pond Freshwater Diversion sits right here near Luling, channeling river water into the Barataria Basin to restore Louisiana's vanishing coast. It is one of the most significant coastal restoration projects in the state.
Any fuel spill or bilge discharge from 72 barges could poison the water feeding that restoration. This is the coast we're counting on to protect our communities from future hurricanes and preserve our fishing grounds for future generations.
The Corps permit does not analyze the cumulative risk to Davis Pond restoration from a potential spill at this scale.
At their August 2024 Luling town hall, IMTT admitted that their required wetland mitigation plantings at another site had failed multiple times. The employees responsible had moved on and left no documentation. IMTT had to purchase mitigation credits to close the gap.
This is the company that community members and local advocates believe would operate the terminal the GNOTS fleet appears positioned to serve — based on property adjacency, GNOTS's 2024 expansion into tank barge authorization, and IMTT's own statements at the August 2024 Luling town hall. The Corps permit does not account for IMTT's track record or what comes next on those 597 acres.
Online
Go to the USACE comment portal
rrs.usace.army.mil/rrs, click Accept on the terms page
Find the permit
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2026-00154, then click the comment balloon next to the listingPaste your comment and submit
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By Email
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[email protected]
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Public Comment: MVN-2026-00154-EDMPaste and personalize the template below
A simple comment requesting a public hearing is enough.