National
Trust
for
Historic
Preservation March 29, 1999 Mr.
Joel
Glenn,
P.E. REF:
Bridge
of
Lions,
Draft
Environmental
Impact
Statement Dear Mr. Glenn, We understand that the period for submitting comments on the Draft Enviromental Impact Statement (DEIS) for the Bridge of Lions has been extended to July 7, 1999. Please be assured that the National Trust for Historic Preservation will send more detailed written comments to you by the July 7 deadline. In the interim, however, we would like to suggest some additional issues that should be evaluated by the Florida Department of Transportation (FDOT). In our view, additional rehabilitation options need to be developed. Options 1A and 1B are a good starting point, but we believe that more creative approaches may be available. Option 1B, which would double the width of the horizontal clearance for navigation, represents one extreme on the spectrum of possible approaches to rehabilitation, with so much reconstruction and modification that the bridge would lose its listing on the National Register of Historic Places. While Option 1A would retain the bridge's National Register status, it nonetheless involves fairly radical and perhaps unnecessary removal of historic materials. There may be additional ways to both preserve the integrity of the bridge and better accommodate intracoastal traffic. We strongly recommend that FDOT develop one or two additional Rehabilitation Options, evaluating an approach that would be less radical than Option 1A, but would involve more rehaibilitation than the No Build Option. FDOT may also wish to develop an additional alternative that would represent a mid-way point between Options 1A and 1B. These additional alternatives should be evaluated in a supplement draft EIS. The public meeting now scheduled for June 7 might be a good opportunity to present some initial information about these refined options.Since none of the action alternatives would avoid the use of the historic bridge, Section 4(f)(2) will require selection of the least harmful alternative that is feasible and prudent, in order to ensure that the project includes "all possible planning to minimize harm" to the bridge.1 As a result, the focus of the review process as it moves forward should be heavily weighted toward rehibilitation rather than replacement. The two rehabilitation options included in the Draft EIS do not provide a sufficient array of rehibilitation alternatives to ensure that the requirement of all possible planning to minimize harm will be satisfied. We urge you to consult closely with the Florida State Historic Preservation Office in order to develop additional options to more fully explore the potential for rehabilitation in a way that would minimize harm to this important historic landmark. We appreciate the opportunity to comment on this project, and we appreciate FDOT's extension of the comment period. If you would like additional information from the National Trust, please call me or Daniel Carey, Assistant Director of the National Trust's Southern Office in Charleston, South Carolina, at (843) 722-8552. Sincerely,  Elizabeth
S.
Merritt
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