Comment to the Administrative Action

Draft Environmental Impact Statement

Prepared by Thomas J. Tremmel

For Save Our Bridge Committee

July 4, 1999

U.S. Department of Transportation
Federal Highway Administration
Florida Department of Transportation
in cooperation with
U.S. Coast Guard

F.P. ID Number: 210255-1
State Project Number: 78040-1508
Work Program Number: 2116970
Federal Aid Project Number: BRF-491-2(14)

Bridge of Lions (S.R. A1A) over the Matanzas River
St. Augustine, St. Johns County, Florida.






If no solutions are sought, no solutions are found.





This Comment for the record is in response to the Draft Environmental Impact Statement (the Draft) for the St. Augustine Bridge of Lions and will deal with 1) Channel Widths and Guide Clearances of the Jacksonville to Miami segment of the Intracoastal Waterway; 2) the history and analysis of ship impacts including causes, circumstance, and expense of impacts at the Bridge; and 3) prudent and feasible alternative solutions to navigational safety issues without widening the horizontal span. The Comment is made in response to the statements and data brought forward in the Draft Statement and Public Forums.


On June 7, 1999, the Florida Department of Transportation (FDOT) and the United States Coast Guard (USCG) conducted a Public Forum for the Bridge of Lions. Corrected and additional commercial vessel traffic data provided by Comment/Tremmel, 3/17/99 were accepted to the Draft as of the date of this Forum.

This data proves that the Jacksonville to Miami segment of the Intracoastal Waterway is experiencing a significant decline in commercial shipping activity. Through the Bridge of Lions there has been a large decline in commercial shipping activity with only 9,000 cargo tons passing through in the last year of record—1997. With these facts established, the cost benefit as related to the commercial shipping industry becomes an uncontestable point: the cargo tonnage and number of shippers do not support a compelling cost benefit to remove the Bridge of Lions.

The Environmental Impact Statement must identify all alternatives that could minimize harm to the historic structure before considering replacing the Bridge an option. The Draft attempts to make a case that there are no alternatives to the navigational safety issue because of the amount of traffic through the Bridge and the number of impacts on the Bridge. This attempt has been made without performing the requisite research or analysis as to whether or not there are prudent or feasible alternative solutions to protect the historic property.

Part One: Channel Width and Guide Clearances

Page S-1, Paragraph 3 in the Introduction of the Draft states that: "The river is part of the Atlantic Intracoastal Waterway; as such, strict navigational clearances are required."

There is little basis for this statement. As established in USCG Public Notice 18-96 (see Appendix D): "Guide Clearances are not intended to be regulatory in nature, but rather to identify minimum clearances that will normally receive favorable consideration by the Coast Guard under the bridge permitting process as providing for the reasonable needs of navigation. The circumstances of a particular case may require greater or lesser clearances for a particular location. Deviations from these Guide Clearances will be considered on a case-by-case basis during the bridge permitting process." The wording of this Notice is inherently flexible and far from strict.

Furthermore, the Guide Clearances for the Atlantic Intracoastal Waterway are not consistent and are influenced by many different factors. The Florida segment of the Intracoastal Waterway (ICWW) from Jacksonville to Miami has the widest Guide Clearances (125’) of the entire waterway. The greatest single factor that recently influenced the increase in the channel width requirements from 90’ for this segment of the ICWW is political rather than based on proven need.

The Florida Inland Navigational District (FIND) is a special taxing district that draws its funding from ad valorem taxes in counties through which the Intracoastal Waterway flows. It is FIND’s mandate to maintain the channel of the Intracoastal Waterway in concert with its federal "sponsor"—the United States Army Corps of Engineers (USACE). FIND recommended and requested the USACE to widen the channel in width in their jurisdiction. The USACE accommodated the request and the U.S. Coast Guard matched the Guide Clearances directly to the USACE accommodation by publishing Public Notice 18-96.

FIND and the USACE have not been funded by Congress to widen or maintain this channel to125’—one of the reasons being diminishing barge traffic.

The agencies in collaboration have not been able to maintain the channel at 90’ for decades in this segment of the ICWW. Guide Clearances should be reviewed and possibly revised back to fit the reality of the channel width and navigational needs in this segment of the ICWW.

Therefore, the Draft statement quoted in the Introduction might be rewritten to read "The river is part of the Atlantic Intracoastal Waterway; as such, arbitrary navigational clearances are in effect."

Part Two: Ship Impacts

Source documents for this Comment were obtained through the Freedom of Information Act requests and include USCG Marine Casualty Investigation Reports (Appendix B) and the FDOT Reports of Bridge Accidents Caused by Water-Borne Traffic (Appendix C).

Page 1-19, Table 1-3 in the Draft lists 30 "Ship Impacts" with "Causes (if stated)." Seventeen of the 30 have no cause stated. Eight more ship impacts were added to the Draft at the time of the Public Forum bringing the total to 38 "impacts" on the Bridge from December 1982 to November 1998. Analysis of source documents bring into focus a clearer picture of ship impacts than presented in the Draft as related to the navigational safety of the Bridge of Lions (see Appendix A—Ship Impact Analysis and Draft Statement Corrections).

A summary of the "Analysis and Corrections" (Appendix A) would include the following observations:

  • The 38 ship impacts occurred over a 16 year period.
  • Available records indicate that at least 15 impacts with determined "Causes" were related to operator error.
  • One no-damage impact and one damage impact can be correlated to one Bridge malfunction.
  • Twenty out of 38 impacts have unknown causes.
  • Available records indicate 18 impacts were barge-related with 10 of these impacts causing damage to the fender system.
  • Every barge impact over the sixteen-year history has been to the fender system rather than the Bridge.
  • Available records indicate that none of the 38 impacts have damaged the Bridge itself. Of the 17 impacts that caused damage, all damage was to the fender system.
  • Available records indicate the most repeated "Cause" is operator error. Recreational boats cutting through drawspan against the right-of-way protocol of another vessel is the single greatest cause of impact.
  • A 125’ span does not allow two boats to pass through the span in opposite directions. Therefore, widening the span can not compensate for the most common operator error at this Bridge.

Page 1-19, Paragraph 1 under Ship Impacts in the Draft states that: "The causes of these accidents vary from mechanical malfunctions with the drawspan to the navigational restrictions in the channel, especially the limited horizontal clearance between the spans." Over the sixteen-year history, available records indicate one Bridge malfunction in relation to ship impacts. Two trawlers on the day of the malfunction had minor trouble navigating through the Bridge (see 5 and 6 in Appendix A). According to FDOT sources, the drawspan of the Bridge of Lions has a history of excellent performance and continues to perform better than most drawspans currently operating.

Page 4-15 under Horizontal Clearance in the Draft states: "Under the No-Build Alternative and Option 1A, the increasing frequency of barge impacts to the bridge structure can be expected to continue." This statement has no basis considering at the least, a current three-year decline of barge traffic actually passing through the Bridge. With diminishing barge traffic, impacts to the Bridge with its current span and fender system would logically decrease.

The Bridge of Lions has been the most scrutinized bridge in the 7th Coast Guard District with the number of ship impacts used to further the case for replacing the historic structure. By analyzing the substance of the impacts rather than the number of impacts, it could be said that available records indicate that the number, nature, and cost of ship impacts on the Bridge of Lions fender system do not present a compelling record to support widening the horizontal span at the cost of the historic structure. Prudent and feasible navigational safety aids applied to the present conditions could greatly reduce ship impacts to the fenders while retaining the important historical components of the Bridge.

Part Three: Solutions

Page S-5, Paragraph 1 in Areas of Controversy the Draft states: "The FDOT Study’s main concern is to resolve outstanding safety issues. However, no matter which alternative is selected, every effort will be made to consider community and historic interests." The Draft exhibits a minimal effort in consideration of St. Augustine’s historic interests as there is no exploration of solutions to resolve the safety issues and protect historic interests concurrently. The only solution explored and presented for resolution of the marine safety issues is a bridge replacement.

As established, the three government entities charged with the responsibility of making the decision for this Bridge have not explored "prudent and feasible alternatives" to a replacement as required by the historic laws that govern this process. This dereliction of responsibility is slowing said process dramatically. Therefore, we, the people, are taking it as our responsibility to motivate the responsible agencies toward their required mission and mandate so that a pragmatic Record of Decision can be reached in a timely manner. The following is an informational discussion of a combination of measures that might result in a prudent and feasible solution that would serve both navigational safety and the historic mandates at the same time.

On March 5, 1999 Captain Norman Dean of St. Augustine submitted a Comment to the FDOT in response to the Draft. Captain Dean explains and shows a solution for the safe and easy passage of barges through the Bridge of Lions called a "guide wall system" or "extended fender system" (See Appendix D; Norman Dean Comment). Captain Dean states that "This guide wall will help tug and barge or any vessel with a difficult handling situation make a safe passage during times of strong tide and wind conditions…guide walls are longer and meant to be contacted by the vessel if necessary."

The present fender system on the Bridge of Lions is slightly extended and built to be sacrificial to protect the bascule piers of the Bridge. A guide wall system can be built with present day technology and materials to be permanent rather than sacrificial. While maintenance may be required, the companies that design and build these systems have stated maintenance cycles of 15 to 20 years. These systems have been used and tested in a variety of maritime situations that have called for vessel impact solutions including ferry landings, locks, ports, and bridges throughout the U.S. and internationally.

The guide wall (or extended fender) system first helps align a vessel with horizontal span before passing through the span. Secondly, this type of system limits the angle at which a vessel can contact the fenders. By limiting the angle, the energy required to safely deflect the vessel is dramatically reduced. If the perpendicular velocity at which the vessel approaches the fender and passes through the horizontal span is substantially limited, then the thickness and size of the fender protecting the span can also be reduced, resulting in a slightly increased span clearance. The guide wall system could replace the current temporary system of barges using "lay-up dolphins" with a permanent solution. Unlike lay-up dolphins, where a barge has to stop and start momentum to use, the guide wall system can keep a vessel moving through the span without delay.

In relation to guide walls and extended fender systems, the USCG Aids to Navigation & Waterways Staff directed the research of this Comment to the Trellex Morse Fender System division. Trellex Morse is an International Company whose fender systems are used throughout the world. Trellex Morse has taken a preliminary look at the Bridge of Lions and feels that a suitable, cost-effective fender system can be designed for this Bridge that would address the navigational safety concerns. Many other companies also design and build these types of systems including Bridgestone, Seibu, Summitomo, Shibata, and Seaward.

Many bridges throughout the United States and the world have specific bridge regulations and enhancements that match and mitigate the particular navigational problems and adverse conditions. Bridge regulations could enhance navigational safety in concert with a guide wall system or as stand-alone solutions. The FDOT, USCG, and FIND (Florida Inland Navigational District) could install enhancements, improve aids, publish conditions at the Bridge, and establish bridge regulations for all commercial tows that fit the local conditions at the Bridge of Lions. Many of these actions have already been recommended by the Captain of the Port of the United States Coast Guard (see Appendix Pages B-12 through B-15 or see Draft; Appendix F; Pages F-2 through F-4).


The navigational clearances currently in effect on the Jacksonville to Miami segment of the Atlantic Intracoastal Waterway were put into effect arbitrarily. The 125’ channel width recommendation is exaggerated when compared to the basis of need. The channel width of 125’ is not funded or established in actuality, and the width and depth of the channel are not maintained to the stated arbitrary recommendations.

The analysis of ship impacts does not suggest that an increased horizontal bridge span will solve the complex navigational conditions at the Bridge of Lions. With the span increased, wider vessels could navigate the Bridge; this would still require navigational aids and bridge regulations because of wind, current, tide factors, and alignment of the channel.

There is no gain for the City of St. Augustine or the American people by widening the horizontal span of the Bridge of Lions. If larger vessels fill a wider span without local conditions being addressed, we will have the same problems with navigational safety at an exponentially larger scale. Additionally, an increased horizontal span will not compensate for the operator errors of bad judgement by recreational boaters. A case can be made that an increased span could cause more accidents through the span as reckless boaters have more room to attempt to squeeze through on the right-of-way of the opposite direction.

There are solutions to addressing navigational safety concerns while retaining the historic significance of the Bridge of Lions. The brief discussion of solutions touched upon in this Comment is hopefully a beginning point for the responsible agencies to fulfill their requirements as regulated by the legal process of conducting an Environmental Impact Statement. Prudent and feasible alternatives exist and should have been explored and presented in the Draft Statement. Prudent and feasible alternatives still must be considered before decisions can be made.

T.J. Tremmel

St. Augustine, Florida