Section
6
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A Public Involvement Program has been developed and is being carried out as an integral part of this project. The purpose of this program is to establish and maintain communication with the public at-large and individuals and agencies concerned with this project and its potential impacts. To ensure open communication and agency and public input, the FDOT has provided an early notification package to state and federal agencies and other interested parties, defining the project and, in cursory terms, describing anticipated issues and impacts. In an effort to resolve all identified issues, the FDOT has conducted an extensive interagency coordination and scoping effort, and public participation process. This section details the FDOT’s program to fully identify, address, and resolve all project-related issues through the public involvement process.
ADVANCE NOTIFICATION (AN) PROCESS
The FDOT, through the Advance Notification (AN) Process, informed a number of federal, state, regional, and local agencies of the Bridge of Lions study. The FDOT initiated early project coordination on February 28, 1991 and April 9, 1996, by distribution of an Advance Notification package. This package was submitted twice due to the length of this study effort. Table 6-1 lists the agencies that received the packages. An asterisk (*) indicates those agencies that responded to the package. Summaries of comments received by the FDOT and the appropriate response are provided after the list. All comments received from agencies are contained in Exhibit D of the Appendix.
TABLE 6-1: |
|
| FEDERAL | |
| Environmental Protection Agency | U.S. Army Corps of Engineers |
| National Marine Fisheries Service - Habitat Conservation Division * | U.S. Fish and Wildlife Service |
| U.S. Dept. Of Interior - Castillo de San Marcos National Monument * | U.S. Dept. of Housing and Urban Development |
| National Park Service | Federal Emergency Management Agency - Natural Hazards Branch |
| U.S. Coast Guard - Seventh District | Soil Conservation Service |
| STATE | |
| Department of Environmental Protection * | Department of Community Affairs * |
| Florida Dept. of State, Division of Historic Resources * | Florida Inland Navigation District * |
| Department of Commerce ** | Department of Agriculture ** |
| Florida Game and Freshwater Fish Commission ** | |
| REGIONAL | |
| Northeast Florida Regional Planning Council * | St. Johns River Water Management District * |
| LOCAL | |
| St. Johns County Commission | St. Johns County Public Works |
| City of St. Augustine City Commission | City of St. Augustine Public Works |
| City of St. Augustine Beach City Commission | City of St. Augustine Beach Public Works |
| * =
Responses and comments received. ** = Responses received. No comment to the State Clearinghouse. |
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DIVISION OF HISTORICAL RESOURCES (MAY 23, 1996)
COMMENT:
Conditioned upon the FDOT avoiding, minimizing, or
mitigating project impacts to the identified significant historic sites, the proposed
project will be consistent with the historic preservation aspects of Florida’s
Coastal Management Program.
RESPONSE:
None required.
ST. JOHNS RIVER WATER MANAGEMENT DISTRICT (APRIL 26, 1996)
COMMENT:
The project is located in an area with the potential
for surface water quality problems. However, a stormwater plan and a stormwater utility
plan have been approved to assist in solving any potential problems. Early coordination
with the Jacksonville Service Center may help to eliminate problems in the permitting
process.
RESPONSE:
Early coordination with the Water Management District
will be initiated as part of the DEIS process and will be carried forward into the final
design phase.
DEPARTMENT OF ENVIRONMENTAL PROTECTION (DEP) (MAY 13, 1996)
COMMENT 1:
The DEP indicate that an Environmental Resource
Permit will be required prior to the start of construction. They also indicate the FDOT
should consider the following information when addressing potential impacts:
1) precautions to minimize the loss of submerged aquatic vegetation;
2) protective measures for manatees during construction demolition;
3) the construction time window and whether the project is located near a manatee aggregation or foraging area; and
4) potential for reduction in the navigation width of the area under the bridge, thereby reducing the waterway available to manatees and boaters.
RESPONSE:
1) Our study indicates there is a minimal amount of
submerged aquatic vegetation at the bridge site. Loss of submerged vegetation will be
minimal under all alternatives.
2 & 3) Manatee Precautions will be implemented during construction, see Exhibit B.
4) There will be no reduction in the available navigational width below the bridge under all alternatives. In fact, the replacement alternative will increase the navigation width of the bridge.
COMMENT 2:
The DEP also recommends inclusion of a lighting plan
for the proposed structure in any permit application.
RESPONSE:
Lighting plans will be included in permit applications.
Lighting impacts to turtle nesting beaches are not expected. Refer to page 4-22 of this
FEIS.
NATIONAL MARINE FISHERIES SERVICE (APRIL 24, 1996)
COMMENT:
Based upon their review of the available
information, the adverse impacts upon marine and anadromous fishery resources would be
minimal.
RESPONSE:
None required.
FLORIDA INLAND NAVIGATION DISTRICT (APRIL 17, 1996)
COMMENT:
This particular bridge, more so than almost any
other bridge on the Intracoastal Waterway, requires increased horizontal clearance for
safe navigation. Discussions with commercial waterway operators have revealed they would
recommend a reorientation of the fender system to provide better alignment with existing
cross currents at the bridge and the serpentine route of the ICW channel in this area. The
District would recommend that this reorientation be reviewed in the design phase of this
bridge replacement.
RESPONSE 1:
The preferred alternative is the Rehabilitation Option 1A, not the replacement options. However, the FDOT will coordinate with the District during the design phase of project development.
COMMENT 2:
The District will object to any proposal to reconstruct this bridge at any horizontal width less than 125 feet unless it is proven that a larger bridge cannot be constructed for physical or regulatory reasons. The District encourages the design pursuit of an alternative with a minimum 125 feet horizontal clearance and a minimum vertical clearance of 21 feet MHW.
RESPONSE 2:
Rehabilitation Option 1B and the two Replacement Options 2A and 2B will all have at least the minimum 125 feet horizontal clearance. Only the Replacement Options will meet the vertical clearance MHW. The two Rehabilitation Options, including the Preferred Option 1A, cannot meet this clearance requirement due to physical restraints.
NATIONAL PARK SERVICE (MARCH 22, 1991)
COMMENT:
They wish to be kept abreast of the project and any
potential impact to the Castillo de San Marcos National Monument.
RESPONSE:
The National Park Service will be given a copy of this
FEIS to review. In addition, the Park Service has been updated on the status of this
project.
NORTHEAST FLORIDA REGIONAL PLANNING COUNCIL (MAY 10, 1991)
COMMENT:
Based on the information contained in the
application and the responses of interested parties, the project is found to be consistent
with regional policies, plans and programs.
RESPONSE:
None required.
INTERAGENCY COORDINATION AND CONSULTATION
Provided below is a chronology of coordination meetings that have taken place on the project to meet the identified concerns.
Six meetings were held by the FDOT with the SHPO between March 1994 and September 1996. The following is a summary of events that took place.
March 10, 1994: This meeting was held to bring the SHPO up to-date with the study’s progress and to answer any questions the SHPO might have regarding the project alternatives.
January 20, 1995: This meeting introduced the temporary bridge concept and its potential archaeological involvement with the river bottom. Also discussed was a more extensive rehabilitation alternative. The SHPO felt the project team was making progress toward a compromise that would benefit the historical and business communities.
December 6, 1995: This coordination meeting was held in conjunction with the U.S. Coast Guard to discuss the project and issues of concern. Coast Guard navigational concerns were addressed along with their request to widen the bascule span. Also discussed was the need to identify the point at which repairs to the bridge become an adverse effect for Section 106.
February 1, 1996: This meeting was attended by officials of FHWA. The objective of this coordination meeting was to gain a clearer understanding of the required documentation necessary to obtain location design approval. It was agreed the next meeting would include the Advisory Council on Historic Preservation and the U.S. Coast Guard.
April 3 and 4, 1996: This meeting was held on-site with the FDOT, SHPO, FHWA, Advisory Council and the Coast Guard. The group was given an update of the archaeological investigation conducted for the project. The discussion focused on the merits of both alternatives and included question and answers from all parties involved. The project’s effect on the historic bridge and what mitigation measures would be required were also discussed.
September 13, 1996: This meeting was held to update the SHPO on the project’s status. Drawings of the four build alternatives were submitted for review as were photographs showing the view of the historic district from the existing bridge and from a height simulating the proposed replacement bridge. The SHPO was informed that a DEIS was being prepared and would be presented for comment in the near future.
DEPARTMENT OF INTERIOR/NATIONAL PARK SERVICE
On March 1, 1995, a meeting was held with the Superintendent of the Castillo de San Marcos at which the Bridge of Lions project was discussed.
MEETINGS WITH LOCAL GOVERNMENT
During the course of the study, numerous briefings were held with the St. Augustine City Commission. It was this body which initially request FDOT to conduct the study. The following dates indicate when the FDOT conducted presentations, provided documents, or answered questions: April 22, 1991, June 22, 1992, July 26, 1993, July 25, 1994, January 23, 1995, December 11, 1995, January 8, 1996, May 13, 1996, March 24, 1997, and April 14, 1997. These meetings provided the FDOT an opportunity to share information and receive feedback from the local elected body as well as the general public. The make-up of the Commission has changed during the study, therefore, periodic briefings were necessary. The Commission has been very interested in the status of the project and has issued two resolutions (See Exhibit A in the Appendix).
ST. AUGUSTINE BEACH CITY COMMISSION
A briefing was held with this elected body on June 3, 1996 to inform them of the status of the project and to receive input. This body issued a resolution favoring the Replacement Alternative (See Exhibit A in the Appendix).
Briefings were also held with the St. Johns County Commission on April 23, 1991 and June 23, 1992. This commission indicated that the project was more of a city issue than a county issue.
ST. JOHNS INTERGOVERNMENTAL COMMITTEE
The FDOT gave a presentation to this group elected and appointed officials. The presentation took place October 7, 1993.
CITY OF ST. AUGUSTINE TRAFFIC CONSULTANT
Meetings were held on February 8, 1994 and May 10, 1994 in order to coordinate the Bridge of Lions study with a traffic study being conducted by a consultant for the City of St. Augustine. This meeting served to coordinate the efforts of these two studies.
MAYOR’S TRANSPORTATION AND PARKING COMMITTEE
A meeting was held with this group on June 2, 1994 to discuss the Bridge of Lions and the future plans for traffic in St. Augustine. This group was briefed on the status of the project and informed that the four lane options were no longer considered as viable alternatives.
MEETINGS WITH LOCAL HISTORIC GROUPS
HISTORIC ST. AUGUSTINE PRESERVATION BOARD (Exhibit F)
A presentation was given to the Board on February 16, 1996 regarding the study’s progress. The Board gave their input to the FDOT. This group recommended the Rehabilitation Alternative as their preferred alternative.
HISTORIC COUNCIL OF ST. AUGUSTINE
A meeting was held with this group on March 25, 1994 to update them on the progress of the study and to receive their input.
ST. AUGUSTINE HISTORICAL SOCIETY "EXECUTIVE COMMITTEE"
On May 21, 1991, this group was informed of the FDOT’s study who, in turn, received input from this group early in the process.
MEETINGS WITH CIVIC AND OTHER INTERESTED PARTIES
The FDOT has conducted numerous meetings with many organizations in St. Augustine. These meetings generally consisted of presentations by the Department concerning the project and input from the members. The following is a listing of with whom and when the Department met. These groups generally hold varied views concerning the project. Although many individuals held strong views concerning the project, no clear consensus emerged.
| 1. | St. Johns County Committee of 100 ( May 20, 1991, September 16, 1993, April 13, 1995). |
| 2. | Sertoma Club of St. Augustine (June 26, 1991, September 21, 1993). |
| 3. | St. Augustine Boat Club (July 9, 1991). |
| 4. | St. Augustine Kiwanis Club (November 14,1991). |
| 5. | St. Augustine Rotary Club (August 23, 1993). |
| 6. | Matanzas Bay Club (August 24, 1993). |
| 7. | Sunrise Rotary Club (September 1, 1993). |
| 8. | National Guard Officers Wives Club (October 12, 1993). |
| 9. | Pilot Club of St. Augustine (October 20, 1993) |
| 10. | Grace United Methodist Church Retirees (October 21, 1993). |
| 11. | St. Anastasia Catholic Church Knights of Columbus (October 27, 1993). |
| 12. | Navy League (February 17, 1994). |
| 13. | Anastasia Island Merchants (October 25, 1994). |
| 14. | Executive Committee/Senior Staff, St. Augustine/St. Johns County Chamber of Commerce (November 1, 1994). |
| 15. | St. Augustine Port, Waterway & Beaches Commission (September 21, 1995). |
Since May 1991, six public meetings have been held for this project. All meetings were advertised in local newspapers and a mailing list was utilized to inform interested parties of all public meetings. All meetings were held in St. Augustine and averaged approximately 100 participants. The following is a summary of these meetings.
May 23, 1991: The FDOT presented an overview of the project’s history and a statement of issues and concerns regarding the historic structure.
June 29, 1992: This meeting was held to address the traffic analysis and the two-lane versus four-lane options (see FEIS Section 2).
July 29, 1993: At this meeting, findings and alternatives from the Rehabilitation Report were presented.
July 28, 1994: At this meeting, two narrowed alternatives were presented: a rehabilitation alternative using one-lane for maintenance of traffic during construction; and a new two-lane structure.
March 6, 1995: The FDOT presented the temporary bridge concept for maintenance of traffic during construction. A more extensive rehabilitation alternative was also presented.
June 10, 1996: At this meeting, the four build alternatives discussed in this FEIS were presented and the Coast Guard navigational concerns were discussed.
A formal public hearing was held in St. Augustine on June 7, 1999 from 7:00 p.m. to 11:35 p.m. at the St. Johns County Administration Building Auditorium, located at 4015 Lewis Speedway, St. Augustine, Florida. The hearing was held to inform the public of the information contained within the Draft Environmental Impact Statement and to give the public an opportunity to express their views regarding specific location, design, socio-economic effects, and environmental impacts associated with the project. Mr. Joel Glenn, District Environmental Management Engineer for the Florida Department of Transportation, District II office, presided at the hearing in conjunction with Mr. Nick E. Mpras Chief of the Office of Bridge Administration for the U.S. Coast Guard. The U.S. Coast Guard, the FDOT and its consultants were on hand at the meeting room two hours prior to the formal proceedings to informally discuss the project with the general public. Approximately 360 people were in attendance.
Following introductory remarks by Mr. Mpras of the U.S. Coast Guard, Mr. Glenn gave the opening remarks for the FDOT prior to their formal audio-visual presentation. The presentation summarized the need for the bridge replacement/rehabilitation project, and the relative merits of the alternatives based on their level of safety improvement and socio-economic and environmental impacts. Included in the presentation was a description of the right-of-way acquisition procedures with particular reference to State and Federal relocation assistance programs. Following the presentation, the next portion of the hearing was devoted to comments and questions from the public.
Specific questions and comments raised at the public hearing were answered at the hearing when possible, in this Final Environmental Impact Statement, through correspondence, or during informal discussions with concerned individuals. Forty-three (43) speakers gave formal statements, three (3) attendees made informal statements to the court reporter for inclusion in the public record, and seven (7) written statements were received during the hearing. A total of 199 letters, facsimiles, and exhibits were received after the public hearing and within the time period allotted for comments. In addition to the responses received after the public hearing, the FDOT received a total of 313 letters, facsimiles, and exhibits prior to the hearing between the dates of January 1, 1999 and June 6, 1999.
COMMENTS FROM ELECTED AND APPOINTED OFFICIALS
The following summarizes the comments made by elected officials and appointed agency officials at the public hearing. Comments are indicated in italics with the appropriate FDOT response noted below.
Comment 1. Katherine Harris, Secretary of State –
- As Secretary of State and Chief Historic Preservation Officer for the State of Florida, I’m delighted to see such a large turnout in support of saving the Bridge of Lions. It is the opinion of the Department of State that rehabilitation of the bridge is the only viable option that recognizes the importance of the bridge’s historical legacy. While substantial work is necessary, the crucial historic properties of the bridge would change little from its rehabilitation. Replacement bridge materials can retain the historical character of the bridge through composition, design, color, texture, and workmanship.
Our office was notified that a private professional engineer was asked to review the Coast Guard position in this matter. He could not substantiate the Coast Guard’s central claim of a threat to vehicular or waterway traffic. Before a plan is selected, we urge that a full, complete, current and accurate study be performed. It should consider all relevant issues and should fairly address these viewpoints.
The Rehabilitation Option 1A has been selected as the preferred alternative. Comment has been noted and included in the official project record. Response 1:
Comment 2. Len Weeks, Mayor of St. Augustine -
I’m here today to speak for myself and for what I believe to be the overwhelming majority of citizens in our community who support the restoration of the Bridge of Lions. St. Augustine is a unique community based on historic architecture, charm and ambience. I have no doubt that with modern technology, with the engineering that’s out there today, that you can restore this bridge and give us a bridge that’s safe for both pedestrians, for vehicles and for boats. I see no overwhelming public benefit that would be served by the demolition of the Bridge of Lions. I do, however, see tremendous benefits to the City, State and Nation if it is restored and still meets the District’s safety standards. I would appreciate the State of Florida and the federal government agencies taking a close hard look at this bridge to ensure that every guideline has been met, and to give proper discussion and investigation into the options of restoring and rehabilitating the Bridge of Lions so that we can save and protect this piece of St. Augustine’s history for future generations.
Response 2:
- The Rehabilitation Option 1A has been selected as the preferred alternative. Comment has been noted and included in the official project record.
Comment 3. Daniel Carey, Assistant Director of the southern office of the National Trust for Historic Preservation –
- Compelled by the uniqueness of the resource and the very reasonable arguments for rehabilitating the bridge as opposed to replacing it, the National Trust listed in 1997 the bridge on our 11 Most Endangered Places. In selecting the Bridge of Lions, we responded to community pleas to help protect not only the bridge but also the integrity of the National Historic Landmark District. In addition, the National Trust saw an opportunity to bring attention to insensitive transportation policies which unnecessarily threaten irreplaceable historic resources.
Response 3:
- (Excerpt of FEIS Section 2) The Department considered the following as important factors in developing the Rehabilitation Alternative: 1) historic integrity; 2) safety; and 3) cost-effectiveness. The Rehabilitation Alternative described in this EIS is the culmination of a rigorous examination of numerous rehabilitation concepts, varying in degrees of rehabilitation from enhanced maintenance, to restoration, to extensive rehabilitation. The goal of the study was to develop an alternative that would enable the existing bridge to remain on the National Register of Historic Places, and restore some elements of the original bridge that have been lost through the years. The Preferred Rehabilitation Option 1A will meet both the rehabilitation goals. The Department believes that a total restoration (i.e., returning the bridge to its original status) is not feasible due to safety and cost effectiveness concerns.
Comment 4. Mary Ann Naber, Advisory Council on Historic Preservation -
- I have come here from Washington to witness to the fact that this bridge is of national significance and has received national attention. The Advisory Council on Historic Preservation is an independent federal agency that was created by Congress in 1966 to advise the President and Congress on matters involving historic preservation and also to oversee implementation of a Section 106 process which was dictated by the NEPA passed in 1966. I’m here to remind you that we will be a full participant in consultation on this project to consider means to, first, avoid all possible harm to the existing Bridge of Lions and the adjacent national historic landmark, historic district; and secondly, to consider any possible means to minimize harm to those two properties as well as others. The DEIS does not comport with 106 in any way. There are findings within the document that have no SHPO concurrency. There are broad determinations made as to the effects of the various proposed alternatives on the properties that have been identified that have not received SHPO concurrence or concurrence form any of the other consulting parties. I’m here to remind you that under Section 106 that concurrence is required from the SHPO before you reach the next step of the process, and I would expect to see a separate cultural resources assessment subsequent to the DEIS and before publication of the FEIS, if not a supplemental [DEIS] published.
There are a number of additional flaws within the DEIS. The effect to the national historic landmark district of St. Augustine has been consistently underplayed. Both the National Historic Preservation Act and regulations implementing Section 106 of that Act gives special recognition to national historic landmark properties.
And the consideration of the Replacement Options 2A and 2B neglect to consider the effect of the larger scale bridge on the national historic landmark district as a structure which would be out of scale with the prevailing scale, human scale, pedestrian scale within that district and one of the reasons that the district is so attractive to the heritage tourism and the kind of pedestrian traffic that we’ve heard about so much this evening.
This DEIS also fails to consider construction impacts, both direct impacts such as additional pile driving for any of the new bridge alternatives, as well as indirect impacts to the economy within that area both during construction and as a result of the construction of the new facility. I do not see that either the Coast Guard and FHWA has yet exhausted consideration of restoration in a manner that would be prudent and feasible.
A Cultural Resource Assessments Review was requested from the Department of State Division of Historical Resources by the FDOT. In a letter to FHWA dated June 19,1997, the State Historic Preservation Officer reviewed the results of the above referenced surveys and found them to be complete and sufficient. SHPO also reviewed the referenced reports and concur with the conclusions and recommendation contained in them. This letter is contained in the EIS as Appendix H.
Response 4:
- The Rehabilitation Option 1A has been selected as the preferred alternative. A Memorandum of Agreement concerning this project was signed by the Advisory Council, see Exhibit K in the Appendix.
Comment 5. Commissioner John Reardon , St. Johns County Commission -
- St. Augustine and St. Johns County rely on tourism as its Number 1 economic industry. Historic preservation is the major attractor. Eradicating one of the premier landmarks and icons that symbolize St. Augustine would be a further eroding away of our charm, our ambience and our tourism market. At a time when barge traffic is intentionally bypassing our channel, I don’t want to see use attract more. Restoring the bridge with an extended fender system for guidance of larger watercraft should be the answer and should be developed. Please respect the desires of the majority of the population of St. Johns County in protecting our community from the homogenization of our important local landmarks and character.
Response 5:
- The Rehabilitation Option 1A has been selected as the preferred alternative. Comment has been noted and included in the official project record.
Comment 6. Dr. Rick Gleeson, Commissioner for the St. Augustine Port, Waterway and Beach District -
- I represent the district on the management advisory group for the Guana, Tolomato, Matanzas National Estuarine Reserve. I would like to clarify at this point that the resolution that the Port Authority, the district, has in the EIS encourages protection of the bridge by the use of fenders of a modern design. We do not, and I emphasize do not, endorse replacement of the bridge.
Response 6:
- The Rehabilitation Option 1A has been selected as the preferred alternative. Comment has been noted and included in the official project record.
Comment 7. David Roach Executive Director, Florida Inland Navigation District -
- As a public official I can appreciate the position that you are in regarding this decision. There are reasonable concerns on both sides of this issue that need to be considered with respect and caution. However we urge you to make a decision at the earliest instant and move forward expeditiously in improving this structure for the safety of the public. The Navigation District is the local sponsor of the Atlantic Intracoastal Waterway project in Florida. Our records reflect that we have been concerned with bridges crossing the waterway since we purchased the waterway in 1927. Of course this was the same year that the current Bridge of Lions was constructed. Currently the existing bridge has a horizontal opening for vessels of 76 feet while the ICW channel is 125 feet in width, a 39% restriction in the channel width. When the bridge was constructed in 1927 the waterway was only 50 [feet] in width. After we purchased the waterway, our partner in the project, the U.S. Army Corps of Engineers, expanded the waterway to 75 feet in width. Since that time, we have increased the width of the waterway to 125 feet. The existing bridge is the narrowest of some 91 bridges crossing the waterway and by far the most struck bridge by vessels. Why is this bridge the most dangerous for commercial and pleasure vessels? It’s a combination of factors unique to the area of which only one factor can really be altered. These factors are the narrow bridge opening, extreme currents form the presence of the inlet, cross winds, and dog legs in the channel both north and south of the bridge. The combination of these conditions create the danger, lack of control and ultimately the bridge collision. The only one of these factors that can be altered is the width of the bridge opening.
While the dolphin moorings have helped they are not the sole solution to this problem. Currently boats have to wait their turn to use these moorings and therefore, it may take them two tide cycles or over 6 hours to transit the area. As we know, time is money. This type of wait is a restriction to commerce. The U.S. Army Corps of Engineers, the State of Florida, and the St. Augustine Port Waterway and Beach District will be initiating a $59 million dredging project of the ICW in the St. Augustine and Matanzas areas and in Salt Run. This project will take 300 days to accomplish and will require 900,000 gallons of fuel to be brought to the area by barge to fuel the dredge. Additionally, over 30,000 feet of dredge pipe and other construction equipment barges, the dredge, and booster pumps will be brought to the area on the waterway.
You will hear tonight that commerce on the waterway has declined. I will suggest to you that the commerce on the waterway runs in cycles. I would also like to submit for the record a spreadsheet that compiles waterborne commerce tonnage statistics over the last 80 years. This information clearly shows the cyclic nature of the commercial tonnage moving on the waterway.
I would also like to enter into the record the Corps of Engineers layout and design manual for waterways. This document states that bridges should completely span the waterway channel for safety. The existing bridge does not meet the Coast Guard regulations for bridge clearances in Florida, and while some other bridges don’t currently meet these standards, none of them have the dangerous conditions that I previously mentioned or the number of bridge collisions that this bridge has.
While preserving our nation’s historical heritage is important, it should not come at the expense of public safety. The District recommends that you reconstruct this bridge to meet the safety needs or transportation today and 65 years into the future. We would recommend that you preserve the historic towers on the bridge and use them in the construction of the new bridge.
Response 7:
- The Rehabilitation Option 1A has been selected as the preferred alternative. Comment has been noted and included in the official project record. The issue concerning the navigational clearance of the bridge was fully considered during the selection of the preferred alternative.
Comment 8. Howard Davis, City of St. Augustine Historical Architectural Review Board -
- We’re an appointed board whose responsibility is to review all the construction that takes place within the historic preservation districts in the city of St. Augustine. The Bridge of Lions abuts Historic Preservation District 3. Your DEIS did not address the most important approach, and that is a true restoration of the existing bridge and not what’s been called the rehabilitation. We would like to see a different approach to replacing what are only seven bad spans. The statements tonight about having to replace 95 percent of the bridge, someone in your organization fostered that statement publicly, and it has been used over and over again. Today’s technology can provide you methods by which to replace steel spans, without even removing the road decks. We would like to see an in-depth restoration report as part of the Final EIS.
Response 8:
- The Rehabilitation Option 1A has been selected as the preferred alternative. Section 2 has been modified to discuss why a complete restoration alternative was considered infeasible. Comment has been noted and included in the official project record.
The following summarizes the substantive comments made by members of the general public at the public hearing. Several speakers presented similar comments and are therefore combined into one comment. Comments are indicated in italics with the appropriate FDOT response noted below.
Comment 1.
- Restore, rehabilitate the present safe two-lane bridge. There are seven bridges south of St. Augustine that are no more than 81 feet in width. With the historic significance of our bridge that has just needed a lot of maintenance, why not widen all of the other non-historic bridges first, and then reconsider the Bridge of Lions.
Response 1:
- The Rehabilitation Option 1A has been selected as the preferred alternative. Comment has been noted and included in the official project record.
Comment 2.
- I am here to strongly support Option 2A. I cannot argue with and can only accept the Coast Guard’s position that we need a wider channel. A bridge deck with two travel lanes, two emergency lanes, and appropriate sidewalks is certainly appropriate and necessary for the safety of the people crossing the bridge. After reading the Draft EIS and listening to your presentation tonight, I am confident that the FDOT has available as its resources architects, designers, and engineers that can design a superstructure on the bridge that can do just as good a job of blending into the St. Augustine skyline as the engineers did that built this bridge 70 years ago.
Response 2:
- The Rehabilitation Option 1A has been selected as the preferred alternative. Comment has been noted and included in the official project record.
Comment 3.
- The Save Our Bridge committee was formed to promote the restoration of the Bridge of Lions. We are submitting a petition indicating support of Option 1A.
Response 3:
- The Rehabilitation Option 1A has been selected as the preferred alternative. Comment has been noted and included in the official project record along with the petition.
Comment 4.
- In a very real sense, the Bridge of Lions is a traffic calming device, buffering the historic district from the abrupt change in traffic movement coming from Anastasia Island. The Save Our Bridge committee recognizes this function as a basis of maintaining the existing bridge geometry. Rather than improve the eastern approaches to the bridge, an array of solutions consistent with FDOT standards could be instituted that would gradually reduce speeds as motorists approach the bridge, while informing and training them with signage, warning signals, and other devices. Of the 45 crash incidents reported to the St. Augustine Police Department, perhaps 2 could be related to the geometry of the bridge itself.
The Coast Guard cannot demonstrate that a wider bridge opening will decrease the incidents of collision of vessels with the bridge. In fact, reviewing the point of passage or the past-the-point data that the Corps of Engineers keeps, there’s been no petroleum movement through the Bridge of Lions for the last two years.
Response 4:
- The Rehabilitation Option 1A has been selected as the preferred alternative. As indicated in Section 2, Option 1A will incorporate a northerly horizontal alignment shift of Anastasia Boulevard to improve the existing alignment better. This alignment is deficient under current standards in that the curve is too sharp, thus increasing the potential for traffic crashes. Proposed alignment modifications will make the roadway curve approaching the bridge less sharp and thus safer for vehicular traffic. Section 1 has been updated to include more accurate reporting of tonnage movement through the Bridge of Lions.
Comment 5.
- A number of cities in Volusia County and Volusia County itself passed resolutions in support of the restoration of this bridge. A change in the historic character of the bridge will shape public perception which equals a loss of tourists, a measurable loss in local dollars that contribute to the economy. I encourage the FDOT to fully study the measurable impact the replacement this bridge will have on the local economy.
Response 5:
- The Rehabilitation Option 1A has been selected as the preferred alternative. Comment has been noted and included in the official project record.
Comment 6.
I think we need a new bridge. The most important thing is the safety issue.
Response 6:
- The Rehabilitation Option 1A has been selected as the preferred alternative. Under Option 1A, the bridge will be brought up to current safety standards through replacement of corroded portions of the superstructure, improvements to the fender system, and the replacement of the mechanical and electrical systems, Design deficiencies such as the substandard horizontal alignment at the eastern end of the bridge on Anastasia Boulevard will be remedied, as will the substandard travel lane widths and safety railings on the bridge. Comment has been noted and included in the official project record.
Comment 7.
- A four lane bridge would be good because of the street configuration nearby the bridge on both ends.
Response 7:
- The Rehabilitation Option 1A has been selected as the preferred alternative. The reasons not selecting a four-lane bridge are thoroughly documented in Section 2 of the FEIS. Comment has been noted and included in the official project record.
Comment 8.
- My comment concerns the Draft Environmental Impact Statement and its failure to assess the social and economic impact to the areas of potential effect by definition and in accordance with the NEPA 106 Review Process. The social and economic relationship of the bridge to the St. Augustine town plan, historic district, and the surrounding area has not been addressed in this draft. Scientific methodology is available to quantify the social and economic impacts historic preservation has on small communities. The destruction or alteration of this key structure in a city that promotes itself on the basis of historical authenticity could cause irreparable harm to the character of the historic district, their property values, ability to provide jobs, increase personal income, and ability to trap tourism. This must be acknowledged and fully studied in the draft EIS in accordance with the law.
Response 8:
- The Rehabilitation Option 1A has been selected as the preferred alternative. The FEIS has been modified to reflect the FDOT’s recommendation. In selecting Option 1A, there will be no adverse economic impacts to the St. Augustine business community.
Comment 9.
- The Jacksonville chapter of the American Institute of Architects oppose the 2A and 2B options and take exception to the claims that the view will not change and that the new bridge will be aesthetically compatible. These options disregard the pedestrian scale afforded by the original Bridge of Lions design. The 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.
Response 9:
- The Rehabilitation Option 1A has been selected as the preferred alternative. Comment has been noted and included in the official project record.
Comment 10.
- My solution is to build a four to six-lane tunnel under the Matanzas River. If such a tunnel were built, the FDOT could take the land on the east side of the tunnel at the end of the bridge by eminent domain and have the tunnel emerge on the west side of the river on the waterfront.. Then the City must eliminate on-street parking in the center of the city and turn the present two-lane streets into four-lane streets. There should also be a large central highway across the city right over to US 1. For traffic going north, the city might consider an elevated four-lane expressway along the river but which would not interfere with the views from the Castillo de San Marcos and along the other places there. It could be joined to the tunnel and the Vilano Bridge and U.S. 1.
Comment 11.
- Nine years ago, my son was killed on the Bridge of Lions, and everyone says there’s very few accidents. Yes, there are very few accidents, but for me it was one too many. It was a week before Christmas nine years ago, and a drunk driver did not navigate the curve in the road, and the guardrails did not hold, and the vehicle went into the water. My son drowned in that river, and the bridge contributed to that death. I want a safe, new bridge. Save the lions, but build a new bridge please.
Response 11:
- The Rehabilitation Option 1A has been selected as the preferred alternative. Comment has been noted and included in the official project record.
Comment 12.
- For the last 12 years, I was the manager of the 7th Coast Guard District bridge program, but I’m now retired. The reason I’m here is because I fully respect those who would like to retain the historic bridge; I totally agree with that. Unfortunately, this is a transportation issue. I am particularly concerned that it may take a major waterway incident involving the Bridge of Lions, if it is rebuilt and retained with its current clearances, with possible loss of life, to awaken this beautiful historic city to the risk of retaining a bridge with serious navigational deficiencies. Federal Highway and FDOT require increases in roadway and sidewalk widths to ensure today’s highway traffic meets minimum safety requirements. The 1927 bridge with Model A roadsters does not meet AASHTO’s standards today and must be widened to ensure safety of residents and visitors as they go across the bridge. Likewise, the waterway traffic has increased in size significantly since the Bridge of Lions was constructed. The bending waterway with cross currents at the face of the bridge creates a formula for disaster. Retention of the existing structure will inevitably result in disaster down the road.
Response 12:
- The Rehabilitation Option 1A has been selected as the preferred alternative. Comment has been noted and included in the official project record.
Major comments made by Federal agencies in response to the DEIS fell within two categories: 1) meeting the recommended vertical and horizontal navigational guide clearances; and 2) minimizing impacts to Section 4(f) resources. State of Florida agencies expressed concern with 1) minimizing impacts to Section 4(f) resources; 2) avoiding impacts to the West Indian Manatees; and 3) the necessity to widen the horizontal navigational channel. Responses to specific concerns of each agency are contained in this section.
RESPONSE TO COMMENTS RECEIVED BEFORE/AFTER PUBLIC HEARING
A total of 199 letters, facsimiles, and exhibits were received after the public hearing and within the time period allotted for comments. In addition to the responses received after the public hearing, the FDOT received a total of 313 letters, facsimiles, and exhibits prior to the hearing between the dates of January 1, 1999 and June 6, 1999. The following summarizes the substantive comments, indicated in italics, with the appropriate FDOT response noted below. Several comments are similar in content and are therefore combined in this summary. A summary of all comments received on the DEIS are contained in Exhibit J in the Appendix.
A. FEDERAL AGENCY COMMENTS
Comment 1. National Marine Fisheries Service:
Based on our initial assessment, we anticipate that any adverse effects that might occur on marine and anadromous fishery resources would be minimal and, therefore, do not have any comments to provide at this time.
Response 1: This comment has been included in the FEIS. No further response required.
Comment 2. U.S. Public Heath Service, Department of Health and Human Services: We recommend that during the NEPA process the sponsors ensure that the topics listed below are considered along with other necessary topics/concerns, and be addressed if appropriate for the proposed project. Mitigation measures/plans which are protective of the environment and public health should be described in the EIS wherever warranted for adverse impacts.
A. Areas of Potential Public Health Concern:
I. Water Quality/Quantity
II. Air Quality III. Wetlands And Flood Plains
IV. Hazardous Materials/Waste
V. Non-Hazardous Solid Waste/Other Materials
VI. Radiation
VII. Noise
VIII. Occupational Health And Safety
IX. Land Use
Response 2: The following is FDOT’s response to each comment on the health concern list. In general, Section IV of the FEIS contains the estimation of project impact to each of the agency’s concerns and proposed mitigation, where applicable. II. Air Quality - The preferred alternative is not expected to have any influence on ambient air quality in the area . The project will not result in increasing the number of, or speeds of, vehicles crossing the bridge. This project is in conformance with the State Implementation Plan because it will not cause violations of the National Ambient Air Quality Standards. III. Wetlands and Flood Plains - The preferred Option 1A Alternative will have no short term or long term impact to wetlands. The preferred alternative will retain the existing pier configurations; therefore, no encroachment to the base floodplain will result. This alternative will have no involvement with the floodplains of the Matanzas River/Intracoastal Waterway. IV. Hazardous Materials/Waste & V. Non-Hazardous Solid Waste/ Other Materials - A contamination screening for the project revealed no significant contamination sites within the study area. At this time, the preferred alternative has a low potential for involvement with any contamination-related issues. VI. Radiation - Construction impacts from the project will be controlled in accordance with FDOT’s Standard Specification for Road and Bridge Construction and by using Best Management Practices. VII. Noise - It has been determined that the preferred alternative will not result in any significant impacts related to traffic noise. Noise control measures during construction will include those contained in FDOT’s Standard Specification for Road and Bridge Construction. VIII. Occupational Health and Safety - All construction-related activities will be performed in accordance with FDOT’s Standard Specification for Road and Bridge Construction and by using Best Management Practices. IX. Land Use and Housing - The project will not impact land use because there will be no change in roadway capacity (number of travel lanes) of the bridge, nor any deviation from the future land use plans of St. Augustine and Anastasia Island. There is a sufficient supply of properties available in the project area to accommodate potential business and residential displacement. No significant short term or long term negative impacts should occur as a result of project development. Comment 3. U.S. Department of the Interior, Office of the Secretary - We concur that there is no prudent and feasible alternative to the proposed project however, we do not believe that all possible planning has been done to minimize harm to Section 4(f) resources. If prudent and feasible, the bridge should be preserved. Options requiring a temporary bridge are unacceptable to the Castillo de San Marcos National Monument. We strongly oppose any option that requires a temporary bridge and recommend continued cooperation and coordination with the State Historic Preservation Officer and the St. Augustine City Commission for the selection of the preferred alternative. Response 3: In choosing Rehabilitation Option 1A as the preferred alternative, the project fulfills the Section 4(f) requirements. The temporary bridge is necessary to maintain traffic during the construction phase of the project and will have no adverse impacts to the fort as discussed in Section 4 of this FEIS. The traffic flow pattern during construction will be virtually identical to existing conditions. (Refer to the maintenance of traffic discussion in Section 2 of the FEIS and the FHWA/SHPO letter in Exhibit H indicating no effect on Section 4(f) resources) Comment 4: U.S. Environmental Protection Agency - Based on the information provided, impacts of concern to this agency appear to be relatively minor. We are concerned, however, that construction activities might degrade water quality in the vicinity of the bridge. All best management construction practices should be implemented and strictly monitored to minimize damage to the aquatic environment. We rate this document EC-1, the Draft EIS adequately describes impacts to the environment. Response 4: All construction-related activities will be performed in accordance with FDOT’s Standard Specification for Road and Bridge Construction and by using Best Management Practices. Comment 5: Natural Resource Conservation Service - We support Replacement Option 2A as being the most desirable alternative. Response 5: The Rehabilitation Option 1A has been selected as the preferred alternative. No further response is required. Comment 6: U.S. Army Corps of Engineers - The current Bridge of Lions is a restriction to navigation. Our Navigation Safety Standards call for bridge approaches to be straight for at least 1,100 feet on either side. We suggest that the design of the new bridge should attempt to reflect this approach alignment. If a bascule bridge is to be constructed, it should have at least 21 feet of vertical clearance when closed. The U.S. Army Corps of Engineers strongly concurs with the positions taken by the U.S. Coast Guard and the Florida Inland Navigation District. Response 6: The Rehabilitation Option 1A has been selected as the preferred alternative. The existing approach to the bridge will be maintained as is. The bridge’s existing bascule span, and its existing minimum midspan vertical clearance will remain at 7.3 meters (24 feet) at mean high water. Comment 7: Florida Inland Navigation District - This particular bridge requires increased horizontal clearance for safe navigation. The District recommends a minimum horizontal clearance of 125 feet to provide safe navigation and to reduce the number of bridge strikes. The District also would recommend that a reorientation of the fendering system be reviewed in the design phase. For the reasons noted the District will object to any proposal to reconstruct this bridge at any horizontal width less than 125 feet unless it is proven that a larger bridge can not be constructed for physical or regulatory reasons. We encourage the Department to pursue a design alternative with a minimum of 125 feet horizontal clearance and a minimum vertical clearance of 21 feet mean high water. Response 7: Refer to the response for Federal Agency Comment #6. Comment 8: National Park Service - We urge Federal Highway and other decision making organizations to seriously and forthrightly consider the preservation alternative.
Response 8: The Rehabilitation Option 1A has been selected as the preferred alternative. No further response is required. It is the Department of State (DOS)’s opinion that rehabilitation of the bridge is the only viable option. The features that are essential to maintain the historic character and integrity of the Bridge of Lions landmark will remain practically unchanged [under the rehabilitation alternative. Based on the information contained in the Draft EIS and agency comments the state has determined that, at this stage, the allocation of federal funds for the project is consistent with the Florida Coastal Management Program (FCMP). Response 1: The Rehabilitation Option 1A has been selected as the preferred alternative. The FEIS has been edited to include a specific manatee protection plan in the chance that explosives may be required during construction. Comment 2. Department of State - It is our opinion that rehabilitation of the Bridge of Lions is the only viable option that will preserve those features that were originally recognized and qualified the structure for listing in the National Register of Historic Places in 1982. Although a substantial rehabilitation of the entire structure is needed, these [historic] qualities will remain practically unchanged. The only noticeable change would occur in the increased width of the travel lanes and the addition of a safety barrier between the travel lanes and the sidewalk. All replacement bridge materials should retain the historic character of the structure in their composition, design, color, texture, and workmanship. The Bridge of Lions is an integral feature on the waterfront of the Matanzas River directly opposite St. Augustine’s historic town plaza and is the eastern entry into the Historic District. It is our opinion that the Bridge of Lions’ inclusion in the Historic District was an omission and will recommend that it be added to the landmark district when the National Park Service reviews this district. This project could have significant adverse effects on the Historic District. The potential adverse indirect effects of the project on St. Augustine’s historic properties have not been fully explored. It is our understanding that the U.S. Coast Guard horizontal guide clearances are advisory, rather than mandatory. It is the opinion of this office that there may be feasible and prudent alternatives to increasing the horizontal width of the bridge opening. These alternatives have not been addressed in the draft EIS. The Florida Department of Transportation has not shown that the rehabilitation of the Bridge of Lions is not a prudent or feasible alternative. In addition, this office has been notified by a group of concerned citizens that an independent professional engineer has been asked to review the draft environmental document. We have been informed that these preliminary investigations of the bridge engineering indicate that the U.S. Coast Guard position regarding bridge safety cannot be substantiated. It is our recommendation that the Florida Department of Transportation wait for the results of this study, because they may contradict the information presented in the draft environmental document. Finally, we would like answers to the following questions and would ask that the FDOT consider the following recommendations that address some specific and general issues regarding the Bridge of Lions project and this draft document. The data a documentation in this draft document are not sufficient in our opinion to complete a review of the alternatives that have been presented. A. Traffic Issues
I. Water Quality/Quantity - The water quality analysis conducted for the project expects the water quality of the preferred alternative to be similar to that currently experienced under the No-Build Alternative. The St. Johns River Water Management District requires the FDOT to obtain an Environmental Resource Permit. Said permit will be obtained during the final design of the project. As such, the proposed stormwater facility design will include, at a minimum, the water quality requirements for water quality impacts, as required by the St. Johns River Water Management District Rule 40C-4 and 40C-42. Therefore, no further mitigation for water quality impacts will be needed.
B. FLORIDA STATE CLEARINGHOUSE COMMENTS
Comment 1. Department of Community Affairs - The Department of Environmental Protection (DEP) notes that an Environmental Resource Permit may be required from the St. Johns River Water Management District. In addition, this water body is known to have West Indian Manatees present requiring a manatee watch program during construction.
1. How might the widening of the SR 312 bridge...affect traffic in St. Augustine? What were the U.S. Coast Guard clearance recommendations for that structure and its openings?
2. What traffic studies have been completed for this project? Reference them and the results and recommendations.
3. The potential for increased traffic flow through the St. Augustine Landmark Historic District area does not appear to have been analyzed and the potential for associated adverse effects have not been sufficiently addressed.
4. Have economic impact studies related to increased traffic congestion in the Historic District been completed? If not, they may be necessary to address the impact on the economy of the district resulting from significant changes to the Bridge of Lions.
B. Navigation Issues
1. Have economic impact studies related to limitations on tows...transitioning the bridge been completed? If not, they may be necessary to address the impact on the economy of the commercial mariner businesses resulting from significant changes to the way they transit the Bridge of Lions.
2. Provide an explanation of the Truman-Hobbes Act and its applicability to the Bridge of Lions.
3. Would not the bridge construction contractor and the U.S. Coast Guard coordinate the impact of construction closings on navigation, more so that the bridge designers? Please see the Construction Impacts section.
4. Why is a ship hitting the bridge fenders an issue? Have mariners been injured during any of the reported fender impacts? If so, provide documentation to that effect. Fenders are designed to protect the bridge piers that flank the official transit channel.
5. How many “bigger” ships actually transit the Bridge of Lions?
6. Is the traffic transitioning the Bridge...actually decreasing rather than increasing? Provide documentation to address this question.
7. Is the [Intracoastal Waterway] channel... actually dredged 125 feet wide its entire length? If not, why not, and when will it be dredged to widen it? If the channel is not 125 feet at this transit site, and will not be widened by the U.S. Army Corps of Engineers, why does the U.S. Coast Guard require that bridge rehabilitation project provide a 125-foot clearance?
8. Have other U.S. Coast Guard districts seen similar reported increases in commercial tonnage, fuel transits, and ship dimension increases? If so, how have other districts interpreted the recommended Guide Clearances for Bridges Across Navigable Waters of the United States (1984) and addressed historic bridges?
C. Section 106 of the National Historic Preservation Act and Section 4(f) of the National Transportation Act
1. The [EIS] should include brief but thorough explanations of these laws. The sections should be of similar format. We note that there is no Section 106 section. We have been told by outside reviewers that the Section 4(f) evaluation is confusing. For these two sections it is important to remember who the potential audience may be, and , therefore, include more definition of terms and simplified explanations of the two processes.
2. Include a summary of the participants, and the process steps, which have been completed, and those yet to be completed in the 106 section. The brief 106 explanation on Pages S-7 is not sufficient.
3. The City of St. Augustine has been very careful over the years to enact local ordinances such as Division 3, Section 28-87, St. Augustine Code, to protect the historic resources for the community. Although not directly relevant under Section 106 and Section 4(f), the City has recognized the necessity to protect those resources and this should be a consideration for this project.
D. Tables and Figures
1. Review all tables and matrices for completeness to ensure that all options or the necessary information is included. Most reviewers of the document may not be as close to the project and the subject matter as the document preparers. Our staff found many of the Figures and Tables incomplete and confusing.
2. The graphic illustrations for the proposed options (i.e. Figures 2-9 and 2-10) and the view changes (i.e. Figure 4-10) are not effective in showing what is intended to illustrated. They would be much more effective if they include mylar overlays, or a combination of photographs with mylar overlays.
3. What are the sources for the graphics data, i.e. Figure 1-6 and Table 1-3?
4. Provide graphics to illustrate the discussions of possible motorist delays on Pages 4-42-43.
5. Table 4-5 should be inserted after the section on Natural and Physical Impacts before Construction Impacts on Page 4-42.
6. We recommend that all categories of impact should be included in tables such as 4-6.
E. Miscellaneous
1. Include copies of the National Register nominations for the Bridge of Lions and the St. Augustine Town Plan Historic District as exhibits in this document.
2. The potential effects to the Historic District if significant alterations or replacement of the [bridge] is undertaken have not been adequately addressed and evaluated in this document.
3. Would a significant rehabilitation like Option 1B or the replacement of the Bridge of Lions be consistent with the local comprehensive plans (City and County)?
4. The FDOT closed the Bridge of Lions on September 2, 1996 to waterborne traffic...and temporary repairs to the bridge were made.’ The repairs were not to the bridge or its piers, but to the bridge fender system that protect the channel piers (Page 4-15). This section should be corrected.
5. Provide an analysis of the routine [FDOT] bridge maintenance vs. the development of an intensive historic bridge specific maintenance program to be implemented after the rehabilitation of the Bridge of Lions.
6. The list of affected parties during construction on Page 4-12 does not include businesses in the historic downtown area.
7. Are air quality, water quality and excavation/debris removal of less importance during construction than Motorist Delays, Noise, Navigation (see Other Construction Issues - Page 4-44)? If so, explain why?
8. Page 6-8, Historic St. Augustine Preservation Board - Briefly explain that the Board no longer exists (the City has assumed many of its responsibilities). Exhibit F should be G. Which alternative did the board prefer in 1996?
Response 2: Regarding the potential effects to the landmark Historic District: The loss of the bridge may affect the view and qualities of the historic district. However, the decision to rehabilitate the existing structure should alleviate most of the concern regarding views. The Department is committed to designing the rehabilitation such that those portions of the bridge which must be replicated will reflect the original design and convey as much of the original visual character of the initial construction as possible. In addition, certain items from the original bridge which have been removed or lost over the years will be replicated and reconstructed during the rehabilitation, thus restoring most, if not all, of the original character of the bridge and enhancing views both of and from the structure.
Regarding increased volume of through-traffic through downtown and created congestion: None of the alternatives presented in either the EIS documents will affect traffic patterns. Regardless of the alternative presented therein, only two lanes of traffic will be carried on the bridge with no associated increased traffic flow from Anastasia Island into the historic area. As such, the Department strongly believes that the preferred Rehabilitation Option 1A will not increase traffic in the areas that are stated, nor will any impacts to tourism be realized.
Regarding the potential adverse indirect efforts of the project on St. Augustine’s historic properties not being fully explored: Again, the indirect impacts referred to in comments are directly related to an assumption that a replacement bridge would create an increase in traffic into the historic district. The project is not expected to have a direct or indirect effect on traffic into this area as none of the alternatives presented in the EIS add capacity to the bridge. The selection of Rehabilitation Option 1A as the preferred alternative will not impact the bridges current Level of Service of “E” or the level of service in the district.
Regarding the Florida Department of Transportation not proving that the rehabilitation of the Bridge of Lions is not a prudent or feasible alternative: The Department, through the NEPA and the Section 106 process has strived to review information on all interests relating to the bridge. As the agency responsible for marine safety, the U.S. Coast Guard has indicated that the existing horizontal clearance for navigation is unacceptable to marine interests. Consequently, the Department is compelled to consider these concerns. The Draft EIS does not make a conclusion that rehabilitation is not prudent or feasible. However, based upon comments received at the Public Hearing, and through consultation with SHPO, the Final EIS recommends Rehabilitation Option 1A as the most prudent and preferred alternative for construction.
Regarding the Department of State’s recommendation that the Florida Department of Transportation wait for the results of a separate engineering study (performed by a group of concerned citizens), because it may contradict the information presented in the draft environmental document: The Department extended the deadline for comments to the Draft document until July 7, 1999. After reviewing all of the comments from agencies and the public, the Department selected Rehabilitation Option 1A as the preferred alternative.
Regarding the comment that the data and documentation in the Draft EIS are not sufficient to complete a review of the alternatives that have been presented: The Department has evaluated the bridge for many years. The information presented in the Draft document is a summary of all of the studies and coordination that were completed at the time of publication. With the addition of comments and concerns received during the DEIS review period added to the information presented in the DEIS, the Department is confident that the information existed to complete an informed decision regarding construction alternatives. Outdated data is updated as part of the FEIS.
Traffic Issue 1: A traffic count and study conducted in February 1999 identified approximately 28,400 vehicles crossing the Bridge of Lions daily. It is expected that the S.R. 312 bridge will alleviate some of the congestion over the Bridge of Lions, but until construction is completed and traffic patterns have stabilized, studies to determine this effect cannot be conducted.
With respect to the U.S. Coast Guard requirements, the S.R. 312 bridge is a fixed bridge with a vertical clearance of 65 feet at the main channel span. The horizontal clearance is 100 feet. At the time the design of the bridge and the permit application was reviewed by the U.S. Coast Guard, the horizontal clearance guideline at this location was 90 feet.
Traffic Issue 2: A traffic analysis was conducted in 1996 during the development of the Bridge of Lions Preliminary Engineering Report. The traffic study analyzed both approaches to the existing bridge and the downtown street grid. Additionally, detailed traffic analyses were undertaken at the intersections of King Street and Avenida Menendez and Cathedral Place and U.S. 1 Alternate. An analysis of alternate corridors both north and south of the Bridge of Lions were also reviewed. All of these studies were coordinated with the City of St. Augustine.
The traffic studies conclude that sufficient traffic exists across the Bridge of Lions to warrant a four lane structure, but that significant improvements to the street grid west of the bridge would be required to fully realize the added capacity. The improvements to the street grid would impact the historic section of downtown St. Augustine, and coupled with the expansion of the bridge, would be contrary to the City of St. Augustine’s efforts to relieve congestion in the area. The studies also concluded that if the bridge is widened, improved traffic service would be realized on the bridge only, and that if additional capacity is not provided on the local delivery system, traffic congestion and safety problems will continue.
The DEIS discussed traffic in two separate sections of the document. Although the discussions were not detailed, the document attempted to present the reasoning for recommending a two lane bridge as a replacement option rather than the four lane structure required to handle the current traffic load.
Traffic Issue 3: Regardless of the selected alternative for construction, the capacity of the bridge will not change as no lanes will be added. This statement includes the No Build option presented in the document.
The Final EIS recommends Rehabilitation Option 1A as the preferred alternative. For this alternative, the existing two lane bridge will be rehabilitated. Because there will not be a capacity improvement to the structure, it is highly unlikely that increased traffic flow through the St. Augustine landmark Historic District from the bridge will be realized. Based on the selected option, it would appear that additional presentations regarding increased traffic flow in this area are not warranted.
Traffic Issue 4: Economic impact studies related to increased traffic congestion in the Historic District have not been completed. None of the options presented in the DEIS will increase capacity on the structure, therefore no increase in traffic flow into downtown St. Augustine will occur. The bridge will be rehabilitated under the preferred alternative presented in the Final document, with no impacts to the tourist economy nor increased traffic in the Historic District beyond the normal growth pattern expected. As such, economic impact studies as suggested should not be necessary.
Navigation Issue 1: Economic impact studies related to the limitations on tows (tugs with a barge flotilla) transiting the bridge have not been completed. Additionally, the Department does not have the resources to conduct such a study because of the implications on a national level. The preferred alternative is for the bridge to be rehabilitated and additional navigation clearance not added beneath the structure. Therefore, it is not expected that these changes will affect the current marine transit of the Bridge of Lions. The U.S. Coast Guard may have information regarding this issue.
Navigation Issue 2: With respect to the Bridge of Lions, the U.S. Coast Guard can invoke the Truman B Hobbes Act in order to provide for a congressional review of the implications of not replacing the bridge. Specifically, the Act would, in this case, provide the U.S. Coast Guard an additional avenue to require the horizontal clearance for marine navigation to be expanded from the current charted width of 76 feet.
Navigation Issue 3: During the design phase of the project, detailed plans relating to navigational issues will be addressed. It is hoped that any conflicts would be resolved prior to construction and a Marine Maintenance of Traffic Plan developed during design and implemented during construction. Any contractor that is awarded the construction, however, can submit their own Maintenance of Traffic Plan for both vehicular and marine traffic for Department consideration prior to the beginning of construction. If there is added value or cost savings to be realized under the contractor’s proposal, the Department can approve that plan and allow construction to proceed in a manner different from that shown in the plans.
Navigation Issue 4: Ships hitting the bridge fenders are an issue as each impact requires additional funds to be spent repairing the fenders. In addition, the Department could require closing of either the waterway or the roadway (or both) to effect repairs to the fenders or bridge piers after such impacts, depending on the damages. These closures are costly to mariners and motorists both in time and money. To the Department’s knowledge, no mariners have been injured in any of the reported fender impacts. Although fenders are designed to protect bridge piers, most fender systems will not protect a bridge from a significant strike from a large vessel.
Navigation Issue 5: A detailed analysis of available data related to marine traffic through the Bridge of Lions is attached to this document as Exhibit M. In addition, the U.S. Coast Guard and the U.S. Army Corps of Engineers report that some barges passing through this location are as long as 300 feet and up to 60 feet wide.
Navigation Issue 6: Data from the U.S. Army Corps of Engineers, the U.S. Coast Guard and the Florida Department of Transportation indicate that overall traffic through the Bridge of Lions is increasing, primarily due to a heavier use of the Matanzas River by pleasure craft. The actual number of commercial vessels and tows is decreasing. See Exhibit M of the Final EIS.
Navigation Issue 7: The channel of the Intracoastal Waterway is not dredged to 125 feet in width for the entire length of the waterway.
Section 106 Issue 1: There is no Section 106 chapter in the Draft document. However, in Chapter 3 under Cultural Environment, we attempted to describe all resources that are covered by Section 106. Chapter 4 discusses the potential impacts to these resources. The guidelines we used in preparing NEPA documents do not specify a formal Chapter titles Section 106. Your suggestion of an explanation process is taken and will be included in the Final document. The Section 4(f) section of the document did contain a brief statement of the law. We attempted to make reasonable discussion describing 4(f) impacts to each resource. We attempted to use charts to increase the understanding of the issues. All of your suggestions have been taken into consideration in the preparation of the Final document.
Section 106 Issue 2: A more detailed explanation of the process and the activities completed is included in the Final document.
Section 106 Issue 3: The Department has considered the comments regarding the City of St. Augustine and has reviewed the City’s Comprehensive Plan. This information is included in our evaluation.
Tables/Figures Comment 1: The use of tables, figures and matrices was implemented to hopefully avoid confusion and present data in an unbiased manner. Some information in the matrices could be considered subjective although the Department attempted to present only factual information. A complete review of all displays will be completed for the purpose of clarifying any confusing issues.
Tables/Figures Comment 2: Figures 2-9 and 2-10 are intended to be depictions of a conceptual horizontal and vertical layout. The colors are intended to highlight general areas of construction activity or inactivity in both the vertical and horizontal views. It is not felt that overlays would enhance the presentation of the information desired to be conveyed to the reader. Figure 4-10 is no longer an issue as the bridge is proposed to be rehabilitated and will remain in its current form for the final document.
Tables/Figures Comment 3: The information presented in the DEIS Figure 1-6 was derived from the U.S. Army Corps of Engineers publication Army Corps of Engineers publication “Waterborne Commerce of the United States, 1994. This information has been updated using the 1996 and 1997 publications. The information in Table 1-3 was derived from Florida Department of Transportation Bridge Tender Logs. Please note that both Figure 1-6 and Table 1-3 have been updated in the FEIS.
Tables/Figures Comment 4: A more detailed Maintenance of Traffic Concept and Signing and Pavement Marking Concept are included in the FEIS.
Tables/Figures Comment 5: Table 4-5 is a summary of the Natural Impacts Section. The chart may be confusing because the Maintenance of Traffic section is a sub-section of Construction Impacts.
Tables/Figures Comment 6: Table 4-6 is a summary of all impacts. To avoid confusion, only those items directly affected were shown in this table.
Miscellaneous Comment 1: Inclusion of the items will be considered for the Final document.
Miscellaneous Comment 2: As the preferred option is to rehabilitate the existing bridge with no additional capacity features, no adverse effects to the Historic District, other than those associated with the actual construction period, are expected. Additional evaluation is not warranted based on the selection of rehabilitation as the preferred alternative.
Miscellaneous Comment 3: All alternatives carried forward to the DEIS phase comply with the City and County Comprehensive Plans. The City’s Comprehensive Plan states that the they (the City) will continue to monitor FDOT maintenance and repair projects as well as any plans for rehabilitation or replacement. In addition, the background section of the Traffic Circulation Element states that any roadway expansion to the Bridge of Lions would not be recommended due to the impact of said expansion on the adjacent transportation system within the Historic District.
Miscellaneous Comment 4: The fenders are considered an integral part of the bridge. Any repair required to the fender system is considered a repair to the bridge.
Miscellaneous Comment 5: Because of the intensive rehabilitation effort, maintenance will be very similar to that of a new bridge.
Miscellaneous Comment 6: Under the preferred Rehabilitation Option 1A alternative for construction, a temporary bridge will be used to handle traffic. Because traffic flow from the bridge to the historic area will not be interrupted, only minor impacts related to travel delays during construction are anticipated.
Miscellaneous Comment 7: The heading format of the document does not indicate importance, it is a method of subdividing topics.
Comment 3: Department of Environmental Protection - Based upon the information submitted, the proposed activities are consistent with the Department’s authorities in the Florida Coastal Management Program, provided the necessary permits are obtained prior to construction and the necessary protections for wildlife are implemented during construction. An Environmental Resource Permit may be required from the St. Johns River Water Management District. Also, since this water body is known to have West Indian Manatees present, the method of bascule pier replacement is of great concern. The plan states on page 4-40 that explosives are not expected to be used during the project, but if they are, a plan will be developed to the satisfaction of all concerned agencies. Ultimately, if blasting is proposed for the removal of the old bridge, a manatee watch program most likely will be required. Early coordination with the Department’s Bureau of Protected Species management is recommended.
Response 3: Under the recommended Rehabilitation Option 1A, the bascule pier will not be replaced. However, the FEIS has been edited to include a specific manatee protection plan in the chance that explosives may be required.
Comment 4: David Roach, Executive Director, Florida Inland Navigation District - I was unable to complete my comments at the public meeting within the five-minute time frame that was allowed. Therefore, I am submitting a copy of my speech and the information that I reference in the speech to you for the public record.
As a public official I can appreciate the position that you are in regarding this decision. There are reasonable concerns on both sides of this issue that need to be considered with respect and caution. However we urge you to make a decision at the earliest instant and move forward expeditiously in improving this structure for the safety of the public.
The Navigation District is the local sponsor of the Atlantic Intracoastal Waterway project in Florida. Our records reflect that we have been concerned with bridges crossing the waterway since we purchased the waterway in 1927. Of course this was the same year that the current Bridge of Lions was constructed. Currently the existing bridge has a horizontal opening for vessels of 76 feet while the ICW channel is 125 feet in width, a 39% restriction in the channel width. When the bridge was constructed in 1927 the waterway was only 50 feet in width. After we purchased the waterway, our partner in the project, the U.S. Army Corps of Engineers, expanded the waterway to 75 feet in width. Since that time, we have increased the width of the waterway to 125 feet. The existing bridge is the narrowest of some 91 bridges crossing the waterway and by far the most struck bridge by vessels. Why is this bridge the most dangerous for commercial and pleasure vessels? It’s a combination of factors unique to the area of which only one factor can really be altered. These factors are the narrow bridge opening, extreme currents form the presence of the inlet, cross winds, and dog legs in the channel both north and south of the bridge. The combination of these conditions create the danger, lack of control and ultimately the bridge collision. The only one of these factors that can be altered is the width of the bridge opening.
While the dolphin moorings have helped they are not the sole solution to this problem. Currently boats have to wait their turn to use these moorings and therefore, it may take them two tide cycles or over 6 hours to transit the area. As we know, time is money.
This type of wait is a restriction to commerce. The U.S. Army Corps of Engineers, the State of Florida, and the St. Augustine Port Waterway and Beach District will be initiating a $59 million dredging project of the ICW in the St. Augustine and Matanzas areas and in Salt Run. This project will take 300 days to accomplish and will require 900,000 gallons of fuel to be brought to the area by barge to fuel the dredge. Additionally, over 30,000 feet of dredge pipe and other construction equipment barges, the dredge, and booster pumps will be brought to the area on the waterway.
You will hear tonight that commerce on the waterway has declined. I will suggest to you that the commerce on the waterway runs in cycles. I would also like to submit for the record a spread sheet that compiles waterborne commerce tonnage statistics over the last 80 years. This information clearly shows the cyclic nature of the commercial tonnage moving on the waterway.
I would also like to enter into the record the Corps of Engineers layout and design manual for waterways. This document states that bridges should completely span the waterway channel for safety. The existing bridge does not meet the Coast Guard regulations for bridge clearances in Florida, and while some other bridges don’t currently meet these standards, none of them have the dangerous conditions that I previously mentioned or the number of bridge collisions that this bridge has.
While preserving our nation’s historical heritage is important, it should not come at the expense of public safety. The District recommends that you reconstruct this bridge to meet the safety needs or transportation today and 65 years into the future. We would recommend that you preserve the historic towers on the bridge and use them in the construction of the new bridge.
Response 4: The Rehabilitation Option 1A has been selected as the preferred alternative. Comment has been noted and included in the official project record. The issue concerning the navigational clearance of the bridge was fully considered during the selection of the preferred alternative.
C. ELECTED OFFICIALS COMMENTS
Comment 1. Representative John L. Mica, U.S. Congress -
My understanding is that the reconstruction of the Bridge of Lions would significantly alter this historic landmark. To avoid significant alteration of the bridge, I urge you to move forward with a plan of restoration instead of replacement.
Response 1:
The Rehabilitation Option 1A has been selected as the preferred alternative. No further response is required.
Comment 2. Wm. B. Harriss, St. Augustine City Manager -
The St. Augustine City Commission, at its regular meeting voted to support the Replacement 2A Option. The Minutes of the February 8, 1999 meeting reflect an extremely divided audience with much heated discussion. In view of the importance of the Bridge of Lions to our entire community, we ask that a copy of the Minutes be included in the review process.
Response 2:
The Minutes of this important meeting have been reviewed by Department staff. The issues raised at the City Commission meeting were similar in nature to those raised at the subsequent Public Hearing held for the Bridge of Lions PD&E Project. The Public Hearing transcript, in its entirety, is included in this FEIS as part of the official public record.
Comment 3. Paula B. Owens, St. Augustine City Clerk -
In reference to the letter from Wm. B. Harriss I am enclosing a copy of the Minutes of the February 8th meeting for inclusion in the Bridge of Lions review process.
Response 3:
No response required.
Comment 4. Patricia Northey, Chair of Volusia County Council -
Please allow me to lend my support to the Save our Bridge Committee’s efforts to preserve St. Augustine’s historic Bridge of Lions. I urge the Department of Transportation to pursue a restoration option for the Bridge of Lions.
Response 4:
The Rehabilitation Option 1A has been selected as the preferred alternative. No further response is required.
Comment 5. Barbara M. Davis, Chair of Volusia County MPO -
On behalf of the Board of the Volusia County MPO, I am writing you this letter to express the Board’s support of preserving the existing bridge.
Response 5:
- The Rehabilitation Option 1A has been selected as the preferred alternative. No further response is required.
- Comment 6. Commissioner Nancy Liebman, City of Miami Beach -
- I write this letter of support for the Historic Bridge of Lions. In my community of Miami Beach, we convinced the Florida Department of Transportation to restore the landmark Venetian Causeway Bridges. I hope you will make every effort to find community value for saving the Bridge of Lions.
- Response 6:
- The Rehabilitation Option 1A has been selected as the preferred alternative. No further response is required.
- Comment 7. Representative Corrine Brown - U.S. Congress -
Because of its historic significance I must support the preservation of the Bridge of Lions. It is an asset to the aesthetics of St. Augustine and the Third Congressional District.
- Response 7:
- The Rehabilitation Option 1A has been selected as the preferred alternative. No further response is required.
- Comment 8. Commissioner James E. Byrant, St. Johns County Board of County Commissioners -
- The St. Johns Board of County Commissioners has not taken a position on the Bridge of Lions. I, as District 5 County Commissioner which includes the City of St. Augustine, am supportive of the St. Augustine City Commission majority decision in favor of replacement.
- Response 8:
- The Rehabilitation Option 1A has been selected as the preferred alternative. No further response is required.
- Comment 9. David G. Conn, Attorney for St. Augustine Port, Waterway and Beach Commission -
- Accompanying this correspondence is the resolution adopted by the St. Augustine Port, Waterway and Beach Commission on July 6, 1999, pertaining to the Bridge of Lions. It is understood that this will become part of the official comments and the proceedings under consideration by the Florida Department of Transportation.
Excerpts from the Resolution: “the St. Augustine Port, Waterway and Beach Commission has responsibilities pertaining to navigation in the waters under and about the Bridge of Lions. Now therefore, be it resolved...that the Commission...endorses rehabilitation/ restoration of the Bridge...[and] strongly urges all authorities and governmental entities having responsibility for planning improvements to the Bridge of Lions, and /or deciding upon the navigational requirements for same, that all prudent and feasible solutions (e.g. navigational regulations, protective fender designs and/or guide walls) be fully assess, developed and implemented.”
- Response 9:
- The Rehabilitation Option 1A has been selected as the preferred alternative. No further response is required.
Comment 10. City of Lake Helen - Resolution No. 98-19:
- The City Commission of the City of Lake Helen hereby expresses its support of the efforts to save the Bridge of Lions and Rehabilitation Option 1A and does hereby direct the City Clerk to forward copies of this Resolution to the Florida Department of Transportation.
- Response 10:
- The Rehabilitation Option 1A has been selected as the preferred alternative. No further response is required.
- Comment 11. AIA Scenic Highway Committee - St. Johns County Board of County Commissioners -
- The AIA Scenic Highway Committee would like to show its unanimous support of efforts being made to restore the Bridge of Lions. Our committee was appointed by the County Commission to study and make recommendations concerning possible state and federal designation of AIA as a Scenic Highway. We have identified this bridge as an important resource in seeking eligibility for designation as a state and federal scenic highway.
- Response 11:
- The Rehabilitation Option 1A has been selected as the preferred alternative. No further response is required.
- Comment 12.
- City of New Smyrna Beach - Planning staff at the City of New Smyrna Beach believe that replacing this bridge with a historically discordant and ponderous structure would destroy a vital part of the charm and the past of St. Augustine. We encourage the U.S. Department of Transportation and the Florida DOT to consider restoration, rather than demolition of this treasured landmark.
- Response 12:
- Comment has been noted and included in the official project record.
D. PRIVATE CITIZEN AND ORGANIZATION COMMENTS
The following is a summary of comments received by private citizens and organizations. A formal response from the FDOT is not required in most cases either because it has been answered previously in this section, or because the comment is moot since the Rehabilitation Option 1A has been selected as the recommended alternative.
Comment 1. Save Our Bridge Committee - After reviewing the DEIS several documents that were sent to the FDOT are not included. Enclosed are notarized copies of resolutions from the City of Lake Helen and the City of Deltona endorsing Rehabilitation Option 1A. Also enclosed is a copy of a letter from the AIA Scenic Highway Committee endorsing the efforts by the Save Our Bridge Committee. These important documents should be included in the final copy of the EIS.
Response 1: A summary of these resolutions are included in the FEIS as part of the local agency comments and response section.
Comment 2. Historical Preservation Board - City of Palatka - You have not made a case for a new bridge as the only alternative for safe passage.
Response 2: Comment has been noted and included in the official project record.
Comment 3. Citizens for a Safe New Bridge of Lions - This group is made up of former City officials and other influential persons as a counter to the restoration group. We favor a new bridge as described in your recent DEIS study under Replacement Option 2A. We would like to suggest that the DOT add only 2 feet more to each side of your plan 2A and make it a full 4 12 foot lanes. We firmly believe that a new 2-lane would be inadequate and unable to handle even today’s traffic, much less that projected in the near future.
Response 3: As summarized in Section 2 of the EIS, a four-lane bridge option was studied. It was determined that, at this time, a four-lane structure was not in the best interest of the Department or the community. Despite the four lane bridge concept being adequate for the projected traffic volumes crossing the bridge, it would only provide marginal traffic operational improvements until the adjoining street system within the Historic District is upgraded. Implementation therefore, would lead to persistent congestion on the major downtown St. Augustine streets connecting with the Bridge of Lions, unless these streets were widened from their current configuration. Street widening in the District is not included in the City’s Comprehensive Plan Traffic Circulation Element.
Comment 4. T. J. Tremmel - This Comment for the record is in response to the Draft EIS 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 EIS.
1) Channel width and guide clearances. – The navigational clearances currently in effect on the Jacksonville to Miami segment of the Atlantic Intracoastal Waterway were put into effect arbitrarily. Furthermore, the guide clearances for the Atlantic Intracoastal Waterway are not consistent and a The 125’ channel width recommendation is exaggerated when compared to the basis of need. The 125’ channel width is not funded or established in actuality, and the width and depth of the channel are not maintained to the stated arbitrary recommendations. Guide clearances should be reviewed and possible revised back to fit the reality of the channel width and navigational needs in this segment of the ICWW.
2) Ship impacts – The analysis of ship impacts does not suggest that an increased horizontal bridge span will solve the complex navigational conditions at the Bridge. 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. Available records indicate that at least 15 of the reported 38 ship impacts occurring over a 16 year period were related to operator error. None of these impacts caused damage to the Bridge itself; all damage occurred to the fender system. According to FDOT sources, the drawspan of the Bridge has a history of excellent performance and continues to perform better than most drawspans currently operating.
3) Solutions: The Draft EIS 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 marine safety issues is a bridge replacement. Several solutions include a guide wall system or extended fender system, installation of bridge enhancements, improvement of aids, publication of conditions at the Bridge, and establishment of 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.
Response 4: Mr. Tremmel’s Comment Report has been included in its entirety in the Public Record. The selection of Rehabilitation Option 1A renders most of the questions raised in the Comment Report moot. In response to Part 1), the FEIS has been revised to replace the reference to mandatory clearances with the term “guide clearances”. In response to Part 2), the ship impact section has been updated to reflect the most current data. In response to Part 3) recommendations have been noted and are included in the Public Record.
Comment 5: Florida Trust for Historic Preservation - As a statewide organization of professionals and individuals knowledgeable in the economic, social, environmental and cultural benefits of historic preservation, the Florida Trust for Historic Preservation strongly urges that the FDOT seek to facilitate a full restoration of the Bridge of Lions, referred to as Rehabilitation Option 1A.
Response 5: Comment has been noted and included in the official project record.
Comment 6: Florida Architect’s Political Action Committee - An Architect’s Resolution supporting the restoration of the Bridge of Lions was “adopted by the National Association of the American Institute of Architects in March 1999”. This endorsement for the restoration of the Bridge of Lions...underscores the national interest and historical significance of this preservation project. Other comments raised by the PAC regarding the EIS documentation are summarized below:
1. The nomenclature of the various options [in the EIS] is very important. As Option 1A Rehabilitation signifies the only preservation-oriented option currently being considered...we strongly recommend that this option include restoration in its title for the final EIS.
2. As late as 1995, reports published by the FDOT used other nomenclature to describe the alternatives/options. This situation adds to the confusing nature of the present options nomenclature. The use of more descriptive nomenclature would eliminate this confusion.
3. The No-Build Option should be re-designated as Maintenance-Only Option and include funding to extend the use and appearance of the Bridge. Any lesser scope of work for this Option would appear irresponsible.
4. The historical and architectural significance of the bridge has been understated in the EIS. We suggest adding the following documentation: 1) Historical photographs; 2) Reproductions of original construction plans, particularly the original Architectural details; 3)The 1982 Nomination to the National Register of Historic Places; 4) The 1997 nomination to the National Trust’s “Eleven Most Endangered Structures” list; 5) Letters in support of restoration by prominent organizations; and 6) The 1998 National AIA Resolution.
5. Indicate the total number of bridges crossing the Intracoastal Waterway designated as National Register Structure.
6. Identify the specific historical, architectural, and engineering features of the bridge which distinguish its unique character and let to its designation.
7. Identify aspects of the original design which have been removed or remodeled by FDOT and which will be restored as part of the Restoration/Rehabilitation option.
8. 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.
9. 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.
10. We believe the visual impact statements are misguided and misrepresent visual impact.
11. The ornate design concept proposed within the Replacement Option is misguided in that it wrongly assumes it will be consistent with the community setting.
12. The PAC questions the graphical renderings provided in Section 2.
13. Traffic and Safety Issues: Has a comprehensive traffic study been conducted in conjunction with the project? What will the effect of the project be on the Historic District? The construction of the second S.R. 312 bridge and the expansion to four lanes of S.R. 312 needs to be addressed. We would recommend 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.
14. The PAC provides comments regarding traffic signals at both approaches to the bridge.
Response 6: FDOT’s response can be located in the modified Section 2 of the FEIS. The FDOT has met with members of the Florida Architect’s Political Action Committee. These meetings were held in St. Augustine on March 26, 1999 and July 21, 1999.
Comment 7: Between January 29, 1999 and June 4, 1999, the FDOT received 202 post cards from Save our Bridge proponents, endorsing the Rehabilitation Option 1A. These advocates emphasize the importance of the historic structure and challenge the need for a new bridge.
Response 7: Comment has been noted and included in the official project record.
Comment 8: Correspondence was also received endorsing the Replacement Alternative. These replacements proponents emphasize the need for improved safety conditions for both vehicles and pedestrians. Several renounce the historical nature of the bridge. Others are concerned with the bridge’s ability to handle emergency traffic as in the case of hurricane evacuation.
Response 8: Comment has been noted and included in the official project record.
Comment 9: One comment was received proposing a four-lane tunnel built under the Matanzas River.
Response 9: Comment has been noted and included in the official project record.
Comment 10: Comments were received from ship captains providing recommendations to improve navigational safety. These recommendations included Guide Walls that are designed to help a tug and barge, or any vessel with a difficult handling situation, make a safe passage during times of strong tide and wind conditions. Another safeguard recommendation pertains to wind regulations prohibiting vessels from navigating through the bridge if the wind exceeds 25 knots.
Response 10: Comment has been noted and included in the official project record.
Comment 11: One captain contradicted the U.S. Coast Guard’s contention that a widened horizontal span would allow safer navigation of commercial vessel as not a valid reason for tearing down a historical landmark. Tugs and barges have been navigating through the Bridge of Lions for many years with very few incidents. On past incidents that involved tug/barge combinations making contact with the fendering system operator error is the main contributing factor. Other captains dispute the claim that fuel is transited through the Bridge of Lions. The captains also state that since the installation of lay-up dolphins there have been no bridge collisions.
Response 11: Comment has been noted and included in the official project record.
Comment 12: Comments regarding architectural and/or aesthetic treatments to either a replacement or rehabilitated bridge were received. The suggestion was made to maintain or replicate the post and chains along the sidewalks.
Response 12: Comment has been noted and included in the official project record.
Comment 13: Comments challenging the U.S. Coast Guard’s 125 horizontal clearance requirement and their position that the wider channel will reduce vessel collisions with the bridge, were also received.
Response 13: Comment has been noted and included in the official project record.
Comment 14: One comment was received that puts blame for congestion, not on the bridge, but with the traffic signals. It was recommended that FDOT synchronize the signals in the Historic District.
Response 14: The City of St. Augustine is responsible for maintaining the roadways and signals within the Historic District.
Comment 15: Comments recommending a new bridge on a more northerly alignment were also received.
Response 15: Comment has been noted and included in the official project record.
Comment 16: Several people requested to put on the project’s mailing list.
Response 16: Everyone who requested to be put on the project’s official mailing list will be added.
Comment 17: Jacksonville Historic Preservation Commission - On behalf of the Jacksonville Historic Preservation Committee, I am submitting this letter of support for the preservation of the Bridge of Lions. It is the position of the Commission that the bridge represents a landmark of statewide and regional significance.
Response 17: Comment has been noted and included in the official project record.
Comment 18: Palatka Historical Preservation Board - At their regular meeting on March 4, 1999, the Board voted unanimously in support of the preservation of the Bridge of Lions. We join Floridians along Florida’s First Coast and throughout the State in opposing the removal of the bridge and urge you to reconsider the removal of this landmark.
Response 18: The Rehabilitation Option 1A has been selected as the preferred alternative. No further response is required.
Comment 19: Punta Gorda Historic Preservation Commission - This letter is sent in support of restoration of the St. Augustine Bridge of Lions, a national treasure presently threatened by replacement.
Response 19: Comment has been noted and included in the official project record.
Comment 20: Robert J. Bitterli, Chair - St. Petersburg Planning and Historic Preservation Commission As Chairman of St. Petersburg’s Planning and Historic Preservation Commission, I am familiar with the issues which affect these types of decisions, as well, with the Florida Department of Transportation’s ability to make allowances for Florida’s irreplaceable historic resources. I encourage your favorable decision to restore the Bridge of Lions and thank you in advance for understanding the importance of maintaining a sense of place for all of Florida’s citizens.
Response 20: Comment has been noted and included in the official project record
Comment 21: David Nolan - With regard to your Final Environmental Impact Statement on the Bridge of Lions, I want to make sure that you include the role played by the bridge in the civil rights movement of the 1960's. It was one of two bridges that played a significant role in that movement. Dr. Martin Luther King crossed the Bridge of Lions in St. Augustine, Florida, and it was the demonstrations he led here that led to the passage of the landmark Civil Rights Act of 1964 that outlawed so many of the practices of racial segregation that were a blot on our twentieth century soul. The only place in Florida where Dr. King was arrested in a civil rights demonstration was right at the foot of the Bridge of Lions, at the Monson Motel.
Response 21: Comment has been noted and included in the official project record
Comment 22: Thomas A. Oldfield, PE, C. Eng., MimechE, AFR Aeas. - I would like to take this opportunity of sending my thoughts on a potential solution i.e. Bow Thruster Steering on barges to improve steering and minimize the angle of attack when passing through a barge. The longer and wider the barges, the greater the angle of attack required to control the large bow. This effect automatically make bridge collisions inevitable under certain conditions, and at least a hard grind down the Bridge fenders. Specifically, when passing under the Bridge of Lions, the available width is 79.5 ft. between the fenders, but due to curvature it is actually rated at 76 ft., thus leaving 16 ft. max. clearance to angle the barge. By the same token, a 50 ft. wide x 100 ft barge would have 26 ft. clearance to angle the barge, and the tug has to deal with a reduced bow couple. A Bow Thruster can be attached to the Bow of a barge. The pump and control can be built onto the Tug. I offer these comments in the hope that the Tug Operators will co-operate in a study that will be aimed at developing the Predicted Cost Benefit. My primary objective is to retain the historic Bridge of Lions in St. Augustine in its present form.
Response 22: Comment has been noted and included in the official project record
Comment 23: Dade Heritage Trust - Dade Heritage Trust, Miami-Dade’s largest historic preservation nonprofit organization, joins the Florida Trust and the National Trust for Historic Preservation in urging the Florida Department of Transportation to restore, not replace, the Bridge of Lions in St. Augustine. Ancient bridges are still in use in cities around the world. Surely Florida has the technical skill and financial resources to restore and preserve a 73-year old landmark that enriches our state with its beauty.
Response 23: The Rehabilitation Option 1A has been selected as the preferred alternative. Comment has been noted and included in the official project record.
Comment 24: John. W. McCulley, McCulley Marine Services, Inc. - Our company operates Tugs and Barges on the Intracoastal Waterway mostly from Jacksonville to Tampa. We are much in favor of reconstructing the bridge and increasing the span width to 125 feet or more. If the current ran through the bridge in line with the span, there would be no problem wit a 90 foot width, however the current runs at 45 degree angle with the span and tries to push the barge into the fender system. Just to the south of the bridge there is a crowded anchorage of mostly sailboats. A southbound tug and barge must not only avoid the current forcing him down on the fender system, but also then make a hard left turn to avoid a collision with the anchored sailboats. We often use the mooring dolphins on the north and south side of the bridge to wait out the tide so as to make a slack water passage through the bridge. This delay costs our customers and us both time and money.
Response 24: Comment has been noted and included in the official project record.
Comment 25: City of Longwood Historic Preservation Board - The Bridge of Lions has been described as the most outstanding twentieth century structure in St. Augustine, Florida. We believe that this ornate landmark has captured the character of our nation’s oldest city and should be restored for future generations to enjoy.
Response 25: Comment has been noted and included in the official project record.
Comment 26: Dredging Contractors of America - The Dredging Contractors of America strongly supports a replacement bridge in St. Augustine in order to bring the channel dimensions up to commercial standards existing elsewhere on the Atlantic Intracoastal Waterway.
Response 26: Comment has been noted and included in the official project record.
Comment 27: Punch Jones Interiors - We question the validity of the realignment of Anastasia Island approach) for two reasons: 1) Currently, the curve requires that traffic slow down both on the approach to and the departure from the bridge. This would appear to be an asset rather than a liability. We are, at present, unaware of any accidents regarding the curve that were not alcohol related, indicating to us that drinking and driving was the problem not the curve itself. 2) The Usina and the 312 bridges involve curves equal to, or worse than, the one located on Anastasia Blvd. It seems to use to be both unreasonable and irresponsible to remove a number of businesses from the tax base. The building, which houses our business, was built approximately five to seven years after the bridge. In order to save our building, we feel strongly that the problems regarding the bridge and the roadway leading tot he bridge should be treated as two separate issues.
Response 27: Comment has been noted and included in the official project record.
Comment 28: Society for Industrial Archeology - At its 1999 Annual Meeting held in Savannah, Georgia, the Society...passed the enclosed resolution in support of the preservation and restoration of the renowned Bridge of Lions in St. Augustine, Florida.
Response 28: Comment has been noted and included in the official project record.
Comment 29: Jane Owen - Any options under consideration for the bridge, other than Replacement Options 2A and 2B, would violate the intent of the Americans With Disabilities Act. In order to permit a bicyclist to pass, a pedestrian has to face the water and hug the railing. Wheelchairs can’t perform such maneuvers and risk being bumped from behind by impatient bicyclists. While concrete barriers between traffic lanes and sidewalks would be required by law for any kind of bridge modification, they would do nothing to protect pedestrians from bicyclists, only be more restrictive.
Response 29: Comment has been noted and included in the official project record
Comment 30: National Trust for Historic Preservation - Southern Office - 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 navigation standards. With respect to statement a), it is unclear exactly how much more than 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. 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 b) exactly what are the current navigation standards? Do they have the force of law? The USCG may have desired navigational clearances but they are advisory more than regulatory.
2) It is important to keep in mind that the bridge has been and continues to be both safe and functional. FDOT would do well to use the money saved on rehabilitating the bridge to initiate a comprehensive study of St. Augustine’s transportation needs.
3) The National Trust is concerned that the rehabilitation options 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. 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 hypothesis about the bridge’s capacity and longevity.
4) With respect to rehabilitation options, the DEIS speculates .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.
5) 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 costs.
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. 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.
Response 30: In response to Question 1): Refer to Section 1 which identifies the results of extensive bridge inspections. The inspection revealed advanced corrosion damage in portions of the superstructure requiring the replacement of a minimum of seven spans nearest the bridge ends and implementation of weight restrictions on the bridge. Replacement of these spans is not routine maintenance. The magnitude of deficiencies require extensive repair and are addressed only in the two viable alternatives: Rehabilitation and Replacement.
In response to Question 2): The FDOT has selected Rehabilitation Option 1A as the preferred alternative.
In response to Question 3: Qualified bridge engineers and inspectors were used to determine the condition of the existing bridge. As shown on the photographs provided within the DEIS, the bridge’s condition continues to deteriorate to the point where significant repairs are required to ensure the continued public safety.
In response to Questions 4 and 5: AASHTO-approved estimating techniques were used to determine both cost and life expectancy for all project alternatives. At this point in project development, these methods are considered by the transportation engineering industry to be the most accurate.
Overall response: The LoBuono Armstrong engineering team, with a combined experience of 55 years between the two senior project engineers, are amply qualified to perform the required engineering services for this project.
INTERAGENCY MEETINGS DURING THE DEIS CIRCULATION PERIOD
The following is a summary of various meetings held concerning this project, while the DEIS was circulated.
May 18, 1999 This meeting reviewed the comments received on the DEIS to-date and discussed the upcoming Public Hearing. This meeting was attended by FDOT, SHPO, FHWA, and the U.S. Coast Guard.
June 7, 1999 This meeting was held between the FDOT, FHWA, and the U.S. Coast Guard to discuss the procedures of the Public Hearing to be held that night.
June 8, 1999 This meeting was held the day after the Public Hearing. The meeting was attended by the FDOT, FHWA, SHPO, U.S. Coast Guard, and the Advisory Council on Historic Preservation. A variety of topics were discussed at this meeting, including: navigation, Section 106/Section 4(f) issues, and future consultations concerning this project.
August 24, 1999 This meeting was called by FDOT to review the comments received on the DEIS as well as the Public Hearing. In attendance were the FHWA, SHPO, and the U.S. Coast Guard. This meeting also received further input from the SHPO and the Coast Guard as the FDOT was in the process of identifying a preferred alternative.
September 2, 1999 The FDOT held a press conference in St. Augustine and announced Rehabilitation Option 1A as the Preferred Alternative.
September 23, 1999 A Section 106 Consultation meeting was held in Tallahassee and attended by officials from FDOT, FHWA, SHPO, and the “Save Our Bridge” committee. A variety of topics were discussed including the preparation of a Memorandum of Agreement (MOA), as well as further research on the ballast pile site. The subject of the Lion Statues was also discussed.