July 7, 1999 Mr.
Joel
Glenn,
P.E. REF: Draft
Environmental
Impact
Statement
for
Bridge
of
Lions
Dear Mr. Glenn: The National Trust for Historic Preservation appreciates the opportunity to provide written comments on the Draft Environmental Impact Statement (DEIS) for the Bridge of Lions in St. Augustine. You may recall that we wrote you on March 29 (copy attached) with initial comments on the DEIS; below are more detailed comments on the same. Summary Just as we stated in our March 29 letter and again at the public hearing held on June 7 at the St. Johns County Administration Building, the National Trust wants to unequivocally declare our position that this historic bridge should be preserved. Preservation does not have to come at the expense of safety or convenience. Sensitively rehabilitating the existing bridge can save money, time, and satisfy the overwhelming majority of local interests who wish to save this venerable bridge. We know the Florida State Historic Preservation Office (SHPO) and the Florida Department of State share this same position. The Florida Department of Transportation (FDOT), Federal Highways Administration (FHWA), and the United States Coast Guard (USCG) should defer to preservation concerns and dismiss alternative plans to demolish and build anew. In particular, with respect to the issues of navigational safety that have been raised, the USCG should exempt the Bridge of Lions from its "guidelines" for minimum width bascule opening and concentrate its efforts on pilot training, signage, maintaining the lay up dolphins, and working with the Army Corps of Engineers to ensure the maintenance of a safe shipping channel. In sum, the agencies involved should make a bona fide attempt to preserve the bridge as is before exploring replacement options. Background The National Trust is a private, independent, non-profit organization with more than 275,000 members nationwide, including nearly 15,000 in Florida. The National Trust was chartered by Congress in 1949, and for fifty years we have fought to save historic resources and the neighborhoods and landscapes they anchor. We help revitalize communities and we use education and advocacy to work with groups across the country—challenging citizens to create sensible plans for their communities. Often referred to as "Dixie’s handsomest span," the Bridge of Lions is one of St. Augustine’s most recognizable symbols and a key vantage point for viewing the nation’s oldest city. Indeed—to many—the bridge has become a national symbol for preservation. To lose this landmark would be to lose the city’s trademark entry. Saving it, however, would save an integral piece of St. Augustine’s 20th century history anddemonstrate that the city can march into the next century with its past intact. Compelled by the uniqueness of the resource and the very reasonable arguments for rehabilitating the bridge as opposed to replacing it, the National Trust included theBridge of Lions in "America’s 11 Most Endangered Historic Places" list in 1997. Listing came as a result of a highly competitive process which sought to highlight and raise thecountry’s awareness about unique and endangered historic resources. In selecting the Bridge of Lions, we responded to community pleas to help protect not only the bridge, which is individually listed on the National Register of Historic Places, but also the integrity of the adjacent St. Augustine National Historic Landmark District. In addition, we saw an opportunity to bring attention to transportation policies which unnecessarily threaten irreplaceable historic resources. As a result of the listing, the National Trust has seen a surge of interest in preserving the bridge. Newspapers from coast to coast have covered the story of the imperiled historic bridge in the nation’s oldest city. The press coverage alone demonstrates that decisions affecting this nationally recognized resource have more than just local impact. Indeed, since St. Augustine has long been considered a national and international tourist destination, it answers to a much larger audience when making decisions that affect its standing as an authentic tourist attraction. Therefore, repairs to the bridge must not be so narrowly viewed from the perspective of any one interest group, but rather a broad spectrum of people who value St. Augustine. From a broader policy standpoint, it behooves FDOT, FHWA, and the USCG to adopt repair measures that are more friendly to historic bridges. The fact is, bridges listed on or eligible for the National Register of Historic Places are special and they must be treated as such. If these agencies fail to address historic bridges as a category, the alternative—as witnessed at the June 7 public hearing—is a plethora of long and tedious public hearings, delays with environmental reviews, increased expenses, litigation, and frustration among the taxpaying public. In a positive move to contribute to the dialogue concerning the bridge rehabilitation vs. replacement, the National Trust recently awarded a grant to the 1000 Friends of Florida to conduct a policy development symposium. In the fall of 1999, nationally recognized bridge experts and professional facilitators will convene with preservationists and transportation officials to address the subject at a symposium in Orlando. Our investment in this meeting underscores our belief that developing a sensitive policy toward historic bridges would reduce contention over projects, save time and money through reduced litigation, and be more responsive to the public’s desires. The National Trust plans to be in Orlando and participate in the meeting, and we look forward to speaking with state and federal transportation officials. General Comments The National Trust appreciates the complexity of FDOT’s task in preparing this DEIS, but the magnitude of the issues and the importance of the resource warranted the completion of a clear, accurate, and comprehensive report. Unfortunately, the report falls short of these expectations. We, therefore, have a number of questions and concerns which we address below. It concerns us that the DEIS fails to maintain objectivity. The report is predisposed towards replacement and uses biased photography, incomplete analysis, and persuasive language to build is case. In fact, the DEIS would have readers believe that this effort (which took eight years to complete and was much delayed) yielded an exhaustive and complete report on rehabilitation and replacement options. In spite of its long preparation time, the report uses stale information, skewed numbers, and still fails to make a defensible case for replacement. Furthermore, after consultation with staff at the Advisory Council on Historic Preservation, we understand that compliance with Section 106 of the National Historic Preservation has not been completed. We urge the FDOT and the other involved parties to uphold their Federal responsibilities and conduct a thorough Section 106 review. Specific Comments 1. The section on the no-build alternative (S-2) makes two statements without providing important definitions or substantiation: a) the report states that "a no-build alternative provides nothing except routine maintenance and repair," and b) "[the no-build alternative] would not bring the bridge up to current navigational standards." With respect to statement a), it is unclear exactly how much more maintenance and repair the bridge needs. Repair might include, for example, the rehabilitation of key structural components of the bridge. If this is all that is required, why would FDOT and the USCG push for more expensive solutions? Routine maintenance and repair may well be all it takes to preserve the safety and functional ability of structures over the course of many decades. FDOT states that "…it has been determined there is a need to provide more than routine maintenance to the Bridge of Lions," (S-1). On the next page, however, the report adds the word repair to this determination. Two questions arise, then, 1) "Does the bridge need simply routine maintenance or does it need routine maintenance and repair for an expanded life span?" and, 2) " Why is it unreasonable to expect FDOT to continue to provide routine maintenance and repair?" If routine maintenance and repair were exercised in a timely and judicious fashion throughout the bridge’s life, then less radical rehabilitation options would continue to be legitimate options. With respect to statement b) about navigational standards, more questions arise: "Exactly what are the current navigational standards?" "Where can a copy of these standards be found?" "Are they standards, guidelines, requirements, preferences, or what?" "Do they have the force of law?" Until these questions are answered, we cannot fully address what it is FDOT is proposing because their recommendations may be based on suppositions. As we understand it, the USCG establishes guidelines for horizontal clearance. Indeed, it is interesting to note that the vast majority of the bridges along the Atlantic Intracoastal Waterway do not comply with the clearance guidelines (FEIS at 1-13). The USCG, may have "desired navigational clearances" or "preferences" for opening widths, but they are advisory more than regulatory. If we simply follow the USCG’s rationale, then an entire bridge must be replaced so barge pilots can avoid striking bascule piers. For a project this large, this complex, and this expensive, surely there is more to this issue than the width of the bascule opening. Or is there? Since the major sticking point in the rehabilitate vs. replace debate seems to hinge on the horizontal clearance of the navigational path, then isn’t preference for replacement a case of "the tail wagging the dog?" Perhaps greater emphasis should be placed on developing other, less radical rehabilitation, options than are presented in the DEIS. (Please refer to the attached letter from the National Trust to FDOT, dated March 29, 1999.) 2. It is important to keep in mind that the bridge has been and continues to be both safe and functional. Using FDOT’s own measuring stick, the existing bridge is safe and it works. FDOT has maintained the bridge and it meets vehicular and navigational needs for the area. The conjured need for a wider navigational opening is not supported and is being used by the USCG and FDOT to divert attention toward replacement options. With respect to vehicular traffic, the existing bridge is safe and adequate. FDOT admits that "a four lane structure was not in the best interest of the Department or the community," (Page 2-4). Therefore, replacement alternatives that introduce "dead lanes" will only frame up a scheme by which additional traffic lanes can eventually be added. Increasing capacity instead of addressing the overall traffic and transportation plan in St. Augustine is an irresponsible, "band-aid" approach. Instead, FDOT would do well to use the money saved on rehabilitating the bridge (as opposed to demolishing it and rebuilding a modern replica) to initiate a comprehensive study of St. Augustine’s transportation needs—paying particular attention to the National Historic Landmark District, and the interests of the numerous businesses engaged in heritage tourism (St. Ausgustine’s and Florida’s number one industry). 3. The National Trust is concerned that the rehabilitation options—as presented—are too limiting, too radical, and too expensive. Rehabilitation can be nearly as flexible as demolition and new construction, and, in the hands of experts, can be a long-lasting, economically viable option that meets service needs. First, there are more than two rehabilitation options which should be considered. For example, Option 1B does not acknowledge that the installation of permanent dolphins and a new fender system that would all but eliminate the navigational concerns of the USCG without demolishing and redesigning key features of the bridge. Option 1B assumes that the horizontal opening must be 151 feet. The current system of dolphins and fenders (with the existing and correctly measured 79 foot opening) works well. In the end, a rehabilitation plan (under the supervision and direction of an engineer experienced with historic bridges), a dolphin and fender system as is currently in place, and additional training, enforcement and posted warnings by the USCG would retain the integrity of the bridge while preserving its function and safety. This option, not considered by FDOT, would make an excellent Option 1C. Also, we question the need for replacing 90% of the existing bridge. What preservation engineers and experts were consulted with respect to this radical rehabilitation plan? The list of preparers (Section 7) is light on historic preservation experts. With the exception of archaeologists, no independent, outside historic preservation experts appear to have been consulted. The current condition of the bridge and its projected life span are key questions for which the parties must have answers. Because only insiders were used to examine the bridge, we know no more about these questions after reading the DEIS. FDOT should contact preservation engineers to check their hypotheses about the bridge’s capacity and longevity. 4. With respect to rehabilitation options, the DEIS speculates (with incomplete data) about the costs of preservation, and in doing so presents a subtle bias in favor of demolition and new construction. In the end, the numbers may not be as close in terms of comparative expenses of rehab vs. new. Likewise, the life expectancies for the rehabilitation options may not be as short as FDOT portrays in the report. It is clear that further study is necessary to more completely explore rehabilitation options which will satisfy both safety and historic interests. In addition, we argue that the rehabilitation option can, among other things, take advantage of Federal funds (via TEA-21 enhancement grants) and therefore greatly reduce costs to FDOT and the taxpayers. Generous TEA-21 enhancement grants—for projects such as historic preservation—are available to FDOT. Accessing these enhancement funds is as simple as submitting a proposal to the Metropolitan Planning Organization (St. Johns County). The recently rehabilitated Venetian Causeway in Miami presents a clear cut example of how FDOT can work with the local preservation community to develop sensitive alternatives to a stock replacement plan and still meet transportation and navigational needs. It is our understanding that the Venetian Causeway was an ISTEA enhancement project that FDOT is proudly touting around the state. Why can’t this success story be duplicated in St. Augustine? 5. Last, with respect to the projected costs of rehabilitation vs. new construction, we have examined the numbers presented in the DEIS and we have recommendations for a more equitable and accurate presentation of the costs. Currently, FDOT is willing to spend up to $25 million for a replacement bridge (option 2B). The rehabilitation option (1A) costs about $18 million. Why is it unreasonable to ask that the difference ($7 million) be dedicated to trust fund to maintain the rehabilitated bridge? The extra $7 million could be set aside and earn interest, in effect endowing the future maintenance and repair of the bridge. Part of FDOT’s premise for replacing the historic bridge is their claim that the cost of maintaining the historic bridge will far outrun the cost of maintaining a modern bridge. Even stipulating that FDOT is correct, the $7 million difference between old and new is practically a "wash" in that the money saved in the 1A option could be used to maintain the bridge for another 50-75 years. In fact, according to FDOT’s Table 2-2 forecast, the greatest possible difference between maintaining the historic bridge vs. maintaining a new bridge for 75 years is $24 million. At a conservative 5% return, $7 million yields $350,000 annually. Spending $350,000 each year for 75 years totals approximately $26 million. Therefore, the real difference between the 75 year forecast for rehabilitation vs. new construction is only $ 2 million. FDOT’s own numbers demonstrate that the rehabilitation option is more fiscally prudent in both the short term and the long term. *The previous information was rendered using FDOT’s own figures taken from Tables 2-1 and 2-2 in the DEIS (pages 2-36 and 2-37). Conclusion The inadequacy of the DEIS and the overwhelming support for the preservation of the Bridge of Lions leads to one conclusion: FDOT must eliminate replacement options and focus more intently on developing more sensitive rehabilitation options. Therefore, we urge FDOT to revise the DEIS and respond to our comments made in this letter. Furthermore, we hope—in light of the facts and the public sentiment—that a revised DEIS will reflect a significant change in FDOT’s approach to resolving this bridge issue. The National Trust has an abiding interest in not only advocating for the preservation of the Bridge of Lions but in helping to find solutions that would allow for the preservation of the historic bridge. Towards that end, the National Trust has awarded a planning grant to a local non-profit organization in St. Augustine to secure the services of an engineer who can consider rehabilitation options and costs. The grant will help underwrite a study of the bridge which would present new and improve information for FDOT to consider. A professional engineer with vast experience with historic bridges has already been contacted. Before any decisions are made, this study should be allowed to proceed and the information should be considered as part of the overall discussion. We thank you for your attention to these concerns. Please fell free to contact Daniel Cary or me if we can help clarify any of the points raised in this letter.
Sincerely, John
B.
Hildreth |