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Mr.
Joel
Glenn,
P.E., REF:
Bridge
of
Lions,
Draft
Environmental
Impact
Statement Dear Mr. Glenn, The following are comments prepared by local St. Augustine architects and members of the Jacksonville Chapter of the American Institute of Architects regarding the Draft Environmental Impact Statement. D.E.I.S. Comments: St. Augustine's unique architectural heritage and scenic beauty have not only made it an important tourist destination but have served to attract many visitors to return and become residents of this community. As architects, we are involved daily with construction projects and community efforts to maintain and preserve the historic architecture and urban design features of St. Augustine. Area architects have been involved with the Bridge of Lions project for over twenty years and have assisted organizations such as the Friends of St. Augustine Architecture and the Committee to Save the Bridge in efforts to preserve one of St. Augustine's most notable landmarks. An Architects' Resolution supporting the restoration of the Bridge of Lions was prepared in September of 1998. Primary concerns, which guided the Resolution as well as our current D.E.I.S. comments, may be summarized as follows: · The historical, architectural and engineering qualities of the Bridge of Lions should be preserved to the greatest extent possible in order to maintain its designation as a National Historic Structure and local architectural landmark · The pedestrian scale and scenic quality of the bayfront and city skyline should be preserved · Improvements and repairs to the Bridge of Lions to ensure pedestrian, vehicular and marine vessel safety · The protection of St. Augustine's tourist-based economy which is dependent on the authenticity, quality and preservation of its historical and cultural landmarks. This Architects' Resolution was supported and adopted by the Jacksonville Chapter and by the Florida Association of the A.I.A. In March of 1999, the Resolution was supported and adopted by the National Association of the American Institute of Architects at their annual convention. This endorsement for the restoration of the Bridge of Lions by the nation's most prestigious architectural association underscores the national interest and historical significance of this preservation project. A copy of this Resolution may be referenced in Appendix A of these comments. Local architects and representatives of the Jacksonville Chapter of the A.I.A. held a meeting with F.D.O.T. officials on March 25, 1999. The purpose of this meeting was to review questions concerning the Draft Environmental Impact Statement (D.E.I.S.) dated December 1998 prior to the architects submitting a formal response. Much of the meeting focused on the merits of the original 1990-1996 plans for the restoration of the Bridge and on specific issues such as Architectural/Aesthetics, Traffic/Safety, Navigational and Environmental. The questions and comments from this meeting may be referenced in Appendix B of these Comments. Note: The Restoration Option supported by the A.I.A. is most similar to the F.D.O.T. Rehabilitation Option 1A listed in the current D.E.I.S. This Option 1A was designated as a Restoration/Rehabilitation Option in previously published F.D.O.T. reports. The nomenclature of the various options is very important, as Option 1A Rehabilitation signifies the only preservation-oriented option currently being considered by F.D.O.T. We strongly recommend that this option include restoration in its title for the final E.I.S. Option 2A which proposes widening the horizontal clearance span to 151 feet should be reclassified as a Remodeling versus Rehabilitation Option, as it does not meet the Secretary of Interior Standards for Rehabilitation of Historic Structures and would cause the Bridge of Lions to loose its National Register designation. As late as 1995, reports published by F.D.O.T. used Alternate 1A to describe the present Option 1B which increase the horizontal span to 151 feet. This situation adds to the confusing nature of the present options nomenclature. The use of more descriptive nomenclature would eliminate this confusion. Also, the No-Build Option listed in the D.E.I.S. should be re-designated as Maintenance-Only Option and include funding to preserve the existing construction through necessary repairs and painting in order to extend the use and appearance of the Bridge. Any lesser scope of work for this Option would appear irresponsible. Subsequent to the March 25th meeting, F.D.O.T. made available various project documents for review by local architects at their St. Augustine branch offices. We appreciate these opportunities to have met with F.D.O.T. and the professional and cooperative manner of their staff. Due to the volunteer effort and limited review of the current D.E.I.S. and previous project documents, some of the following Comments may appear superfluous. We offer the following critique of the D.E.I.S. both as individual architects and as an organization dedicated to enhancing the quality of life and safeguarding the public interest. ARCHITECTURAL/AESTHETIC
ISSUES The historical and architectural significance of the Bridge of Lions has been understated and given minimal analysis in the D.E.I.S. We suggest adding the following documentation to best illustrate the architectural/aesthetic value of a Restoration/Rehabilitation Option. · Historical photographs · Reproductions of original construction plans, particularly the original Architectural details. Ref. sheets No. X8, X9, X13, C 206-13 & C 206-15 · The 1982 Nomination to the National Register of Historic Places · The 1997 nomination to the National Trust's "Eleven Most Endangered Structures" list. · Letters in support of restoration by prominent local, state and national civic and cultural organizations · The 1998 National A.I.A. Resolution in support of Restoration of the Bridge of Lions In addition, the specific information relating to the historic and architectural significance of the Bridge of Lions should be analyzed within the report as follows: ·
Indicate
the
total
number
of
bridges
crossing
the
Intercoastal
Waterway
designated
as
National
Register
Structures:
· Identify the specific historical, architectural and engineering features of the Bridge of Lions which distinguish its unique character and led to its designation as a National Historic Structure. · Identify aspects of the original design which have been removed or remodeled by D.O.T. over time and which will be restored as part of a Restoration/Rehabilitation option. · Provide a Restoration Assessment of current architectural features that are damaged and in need of immediate repair in order to stabilize any further deterioration of the original construction. Note: Several of the bascule towers are missing clay tiles and have spalling concrete that exposes steel reinforcement along the eave/cornice. It is extremely important that this project be staffed to provide the Historical and Architectural Assessments for a Restoration/Rehabilitation Option, which is commensurate with the stature of the Bridge of Lions. Note: We recommend that a Historic Preservation Specialist and/or qualified restoration professional be engaged to consult and oversee these assessments and specify the necessary repair/restoration work which is required to properly maintain the present structure and guide the Restoration/Rehabilitation Option. SPECIFIC COMMENTS: · On page 4-17, the analysis of Visual Impacts/Aesthetics declares that "the pedestrian's view of the surrounding historic St. Augustine from the proposed new bridge (i.e. replacement options 2A and 2B) will not be substantially altered" and on page 4-23 that "the view of the Bridge from Castillo de San Marcos (or the Bay front) will not be significantly altered." We believe these statements are misguided and misrepresent the "visual impact" of the pedestrian view from the Historic District and Avenida Menendez for the following reasons: 1. Figure 4-6 compares the "view" of the existing bridge from its crest only, thereby negating the increased Bridge height of Option 2A and 2B, blocking the city's skyline along the easterly approach. Also, the increased road width of options 2A and 2B are not accounted for in this representation. Refer to existing easterly bridge approach photograph in Appendix C. 2. Figure 4-10 and 4-11 shows "views" to the Bayfront and Bridge from the Historic District but were photographed well above "pedestrian" ground level and negate the visual impact to the pedestrian which would be caused by the increased Bulk and Height of the replacement options. Note: It appears these "views" were photographed from a second story level and do not depict what the pedestrian view would be from the sidewalk or the Bayfront Promenade. Refer to existing Bayfront photograph in Appendix C. 3. The inset photograph format for analyzing these views is inadequate for showing the visual impact due to the fact that the smaller existing photographs are too small to read and larger seemingly computer-generated overlays are drawn incorrectly. Note: A fairer assessment of the "Visual Impact" could be provided by showing the existing "pedestrian views" compared to a same size overlays of the replacement Bridge Options 2A and 2B. · On page 5-8, it states that based upon the visual changes discussed in Chapter 4, "It was determined that Replacement Options 2A & 2B will not have an adverse effect on the St. Augustine Historic District." We disagree with this finding based on the faulty "view" analysis indicated above and the following observations concerning the proposed 2A & 2B "Ornate Design" options as described on pages 2-28, 2-32 and 2-35. 1. The 25% increase in height and 35% increase in width of the proposed bridge roadway represents a 50% overall increase in the bulk of the new bridge. A 50% bulk increase cannot be considered an insignificant amount. 2. The fact that an "authentic" National Historic structure adjacent to the Historic District would be demolished and replaced is by itself a threat to the significance of the St. Augustine National Historic District. Historic districts may be strengthened or weakened by compatible or incompatible developments. The loss of this historic bridge that serves as a major pedestrian and vehicular entrance to the historic district and as a compatible landmark along the bayfront, would surely have an adverse effect on our Historic District. · On page 2-28, the "ornate design" concept proposed within the Replacement Option is misguided in that it wrongly assumes that by attaching replicated light fixtures and railings from the original design to the 50% larger new bridge it becomes "architecturally compatible" and "stylistically" consistent with the community setting. Note: This is a naive assessment of architectural aesthetics in that it ignores an analysis of the scale, proportion, balance, rhythm and congruity issues which are required to establish not only the merits of any new bridge design but its compatibility with the architectural context of the Historic District. · Figures 2-9, 2-10, 2-12 and 2-14 provide plan and side elevation views of the proposed options. While a model or three-dimensional perspective would better analyze the aesthetic merits of each option, the following design weakness of Options 1B, 2A and 2B should be addressed prior to a final recommendation. 1. Option 1B maintains the pedestrian scale and rhythm of the piers and lampposts up to the center span. Here the rhythm is awkwardly broken with a half columniation before engaging the increased (151 feet) bascule span. There doesn't appear to be any design rationale for this awkward resolution of an increased bascule span (i.e. why was 151 feet chosen versus 125 feet or 90 feet for the bascule span?). 2. Options 2A and 2B both disregard the pedestrian scale afforded by the original Bridge of Lions design. The number of piers, pedestals or lampposts which establish the quaint pedestrian character of the current bridge have been reduced by almost half (24 vs. 42). This substantial loss of repetitive vertical elements not only weakens these replacement bridge designs, it significantly detracts from the processional experience in crossing the river and entering the historic town center. Note: The paucity of Option 2A & 2B would only become more apparent due to the 23 foot increase in the roadbed width. The combination of increased roadbed height and width along with the wider spaced pole lighting and pedestals eliminates the human scale and proportion relationships that so successfully tie the current Bridge of Lions to the city's Historic Districts. · The increased roadway width of options 2A and 2B appears to require a greater horizontal displacement of the Lion statues that currently compliment and announce the west side approach to the Bridge of Lions. This is another objectionable circumstance that would further reduce the aesthetic appeal and cultural significance of the bridge itself. TRAFFIC/SAFETY
ISSUES We believe adequate regulatory and technical means can be incorporated into a Restoration/Rehabilitation Option to provide for pedestrian, vehicular and marine vessel safety. Traffic congestion in downtown St. Augustine is getting worse, not only because of increased tourism, but also by the fact that St. Johns County is experiencing an explosion of growth. The Draft Environmental Impact Statement does not address this increase in traffic and its effect on the Bridge and the Historic District. Improvements and a realignment of the east approach to the Bridge should greatly improve vehicular traffic safety. We also believe improvements can be made to the west approach to the Bridge that would increase traffic flow and assure pedestrian safety. SPECIFIC COMMENTS: · Has a comprehensive traffic study been conducted in conjunction with the Restoration or Replacement Option for the Bridge of Lions? What effect do each of these options have on future traffic? The FDOT should cite these studies and results. · What will the effect of the Restoration or Replacement option be on the potential for increased traffic flow into the St. Augustine National Historic Landmark District? · The construction of the second SR 312 bridge and the expansion to four lanes of SR 312, which will be completed later this year, needs to be addressed in the final D.E.I.S. · The D.E.I.S. has addressed some improvements and a minor realignment of the east approach to the bridge, but we would recommend that the FDOT consider extending the right-of-way to allow a pedestrian park to occur in place of the displaced business along the north side of Anastasia Boulevard. This would eliminate the risk of accident due to multiple business driveways accessing A1A at the foot of the Bridge in Davis Shores. This straight approach to the bridge would be safer and also more aesthetically appealing. Refer to sketch in Appendix C. · The west approach to the Bridge is a traffic congestion nightmare due to three separate lanes of cars approaching the bridge from three separate directions while three lanes of cars exit the bridge in three different directions. The D.E.I.S. does not mention this problem and offers no solution in either the Restored or Replacement Options. · The FDOT has indicated very minor changes to the west approach to the Bridge. The report should indicate changes that would ease the backup of cars at the traffic light on the west end or indicate some road changes that would allow through traffic to the north to flow more smoothly. The northbound traffic lane requires roadway changes in order for traffic to flow more smoothly. · Traffic signal changes and possibly rush hour or afternoon beach traffic solutions should be addressed, including signalization and manual control at certain times. · Since marine traffic has changed from primarily commercial to primarily recreational and since the main traffic obstacle to the traffic flow is the Bridge opening for marine traffic, the D.E.I.S. should address a more stringent opening schedule (i.e. every two hours and not at all during certain high traffic times of the day). · The D.E.I.S. suggests a particular crash test barrier be used to separate vehicular and pedestrian traffic. Due to the fact that this greatly affects the aesthetics of the Bridge, it should be better illustrated. Has an analysis of a more historically compatible, less intrusive design for the barrier been studied? · The D.E.I.S. should cite the law or guidelines that require pedestrian separation. It would seem that the guidelines should be based upon speed limits, which are currently very low and would not increase with either option. · Speed limits for the Restoration Option and the Replacement Option should be analyzed for their effect on vehicular and pedestrian safety. · The D.E.I.S. does not address the safety issue of the increase in height of the Bridge. In particular, it does not address how the increased slope affects vehicle and bicycle stopping distance at the west end of the bridge. · The D.E.I.S. does not illustrate the pedestrian routes and crossings for each of the options. The report does not indicate how the increased slope of the Replacement Options would affect the safety of the pedestrians at the east and west end crossings. · The Americans with Disabilities Act (ADA) needs to be fully addressed in the D.E.I.S. The existing bridge meets the current ramping slope requirements however, due to the increased height of the Replacement Options, the east end appears not to comply. EVACUATION
ISSUES The evacuation routes discussed in the D.E.I.S. do not seem to take into consideration the current widening to four lanes of the S.R. 312 bridge which is due to be completed this summer. St. Johns County is preparing a new evacuation plan at this time and the results should be made a part of the D.E.I.S. SPECIFIC COMMENTS: · The current county evacuation plan includes the Bridge of Lions. The D.E.I.S. mentions no problem with the existing bridge as a means of evacuation. Why would the restored bridge Option 1A decrease evacuation time as stated in the D.E.I.S. considering it would still be a two-lane drawbridge? · A few years ago, with a hurricane bearing down on St. Augustine, Anastasia Island was evacuated. The D.E.I.S. should document any evacuation problems that occurred during previous evacuation instances. · The D.E.I.S. should incorporate a study that evaluates the effect the opening of the widened S.R. 312 bridge will have on the evacuation plan for Anastasia Island. The combination of the two lane Bridge of Lions, the four lanes at S.R. 312 and two lanes at the S.R. 206 bridge seems adequate for the timely evacuation of Anastasia Island. NAVIGATIONAL
ISSUES We believe that a restored Bridge of Lions with the existing opening width is adequate to meet the navigational needs of recreational and commercial marine traffic along the Intercoastal Waterway in St. Johns County. SPECIFIC COMMENTS: · The D.E.I.S. fails to show the true commercial barge traffic that actually goes through our bridge. The recent study by T.J. Tremmel clearly shows a 13% decline in barge traffic. It also indicates a trend for commercial barge traffic using the ocean not the Intercoastal Waterway, leaving I.C.W. for recreational use in the future. · D.E.I.S. states the current bridge opening is 76 feet. The Le Buono design shows the bridge opening to be 79 feet 6 inches fender to fender. The D.E.I.S. should be corrected to show the true opening width. · The D.E.I.S. states the Bridge is a navigational problem and has to be widened to 125 feet. Is the channel going to be dredged to a 125' width and when would this take place? What permitting would be required? If the span in the replacement option is to be 125 feet, are we encouraging additional commercial traffic to use the Matanzas Bay through St. Augustine? Will we be inviting super barges and with them the possibility of an oil spill endangering the Bayfront and the Historic area? · Are ships passing through the Bridge expected to be larger in the future? If so, what studies can be cited that show this trend? · What marine traffic studies have been prepared and is it possible to decrease the openings per day of the bridge? Automobile traffic has reached alarming numbers and the opening schedule for bridges on the I.C.W. should be coordinated with the local traffic needs of the area. The D.E.I.S. should address this problem and offer a solution to relieve rush hour traffic congestion caused by excessive bridge opening. ENVIRONMENTAL
ISSUES The environmental issues discussed in the D.E.I.S. revolve around the amount of wetlands disturbed by construction. An environmental study should be expanded to include the effects of the bridge construction on the National Historic District and the colonial buildings as well as the other historic structures. SPECIFIC COMMENTS · The D.E.I.S. should evaluate the vibrational impact of driving pilings and sheet piles for the proposed Replacement Bridge Option on the colonial era structures and other historic buildings in the downtown area. · The D.E.I.S. should evaluate the effect of large truck traffic hauling materials for the Bridge construction and compare the tonnage of materials required for each option? · If the Replacement Option is approved, how will the existing Bridge be demolished and dismantled and what vibrations will be transmitted to the Colonial town? · Previous reports listed the Restoration Option as having the least environmental impact. The current D.E.I.S. does not provide an adequate comparison of the various Options' environmental impact. A reasonable comparison would include an analysis of the noise, vibration, air pollution, waste disposal and construction duration of each Option. It would appear the complete demolition of the existing Bridge and rebuilding of the new structure would severely impact the immediate environment in comparison to the repair and rehabilitation of the existing Bridge of Lions. SUMMARY While the D.E.I.S. documents the four build Options 1A, 1B, 2A, 2B in some detail, Section 4 of the report is deficient in its stated intent to form the "scientific and analytical basis for comparing these alternatives." We are particularly concerned by the lack of a professional Architectural/Aesthetic critique as well as the analysis of the Natural and Physical impacts of each Option. The concerns and recommendations expressed in these Comments are a composite of our professional group and we trust they will be given reasonable consideration by F.D.O.T. We appreciate the openness of your staff in meeting with our group. We look forward to possible future workshops in which to discuss and explore additional means of improving the traffic flow across the Bridge of Lions while preserving the Historical and Architectural significance of this landmark structure.
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