Letter
of Comment Presented at the First Grand Island Public Meeting on the Peace
Bridge Expansion Project
November
14, 2002
Mr. Jake Lamb
Parsons Engineering
37 Franklin Street
Buffalo, New York 14202
Dear
Mr. Lamb:
I
welcome the opportunity to present you with these comments because I believe
that the Buffalo and Fort Erie Public Bridge Authority has been mislead.
You have been asked to consider alternatives that are motivated by either
political self-interest or the single purpose agendas of some special interest
groups. These misguided citizens
believe that the construction of a signature bridge should take precedence over
the need to protect and preserve our natural environment.
In reality the proposed alternative alignments discussed herein establish
a gateway to Grand Island and not the City of Buffalo thus defeating the purpose
of a signature bridge.
Before
I begin, I want you to know that these comments represent my personal views both
as a resident of Grand Island where I have lived for 30 years and as a
professional scientist intimately familiar with the workings of the Niagara
River ecosystem. My views do not represent those of any group, organization, government
body or government agency.
General
Comments
I
disagree with the whole concept of this evaluation exercise.
The original twin span proposal if built would have been constructed
using revenue generated from the business activity of the Buffalo and Fort Erie
Public Bridge Authority. Little or no public funding would be needed. The signature
span driven by the personal agendas of a small group of malcontents would end up
costing taxpayers millions of dollars. I
take exception to this blatant attempt to squander tax dollars on the long shot
chance that a signature bridge will somehow cure the economic woes of the City
of Buffalo. I submit to you that
much more than a bridge is needed to cure problems in this city that are really
a function of poor government leadership and bureaucratic apathy.
The
Buffalo and Fort Erie Public Bridge Authority should return to the original twin
span alignment and complete the construction of the second span as soon as
possible. If this continued special
interest group rhetoric does not end soon we will be left with a “pretty
bridge” and a ruined urban and regional economy that is a byproduct of missed
economic opportunity. The City of
Buffalo and this small group of special interests will once again prove their
uncanny ability to snatch defeat from the jaws of victory.
The
array of alternatives grouped into categories dubbed “Crossings South of Grand
Island” and “Crossings at Grand Island” represent the most insidiously
disastrous options for bridge alignment yet to evolve from your Bi-National
Integrated Environmental process. The
crossings south of Grand Island would have severe impacts on a State designated
Significant Habitat Area consisting of Strawberry Island, Motor Island (formerly
Frog Island) and more than 400 acres of submerged aquatic plant beds.
This area is nationally recognized as one of the most important spawning
and nursery areas in North America for the Muskellunge.
It also retains international significance and has been formally
designated part of an Important Bird Area of International significance by the
National Audubon Society.
The
suggestion that a signature bridge should be built on or near Grand Island is
inconsistent with the espoused theory that such a span should serve as gateway
to the City of Buffalo. These alternatives merely define a gateway to Grand
Island. The mere suggestion is at
the very least completely redundant. Our
gateway bridge, the South Grand Island Bridge, has been in place of decades.
This majestic span is a Grand Island hallmark.
To suggest or even imply that we need another signature bridge clearly
demonstrates how ill conceived these alternatives really are.
Comments
on Crossings South of Grand Island
The
Upper Niagara River ecosystem is a tenuous integration of open water, vegetated
shallows, wetlands and riparian uplands. The synergy arising from the
integration of this diverse collection of habitats adds immense value to the
Niagara River ecosystem. Segmenting this ecosystem with a multi-lane signature
bridge will significantly degrade value of this natural resource causing a
substantial decrease in species diversity and a corresponding decline in water
quality.
The
proponents of the “Crossings South of Grand Island” alternatives have
indicated repeatedly in the media that a span crossing the Niagara River between
Strawberry Island and Motor Island would have no environmental impact that could
not be mitigated. In fact, a local
State Assemblyman commented that bridge related impacts could be mitigated away
by constructing bird watching and fishing stations on the bridge deck.
The entire notion would be laughable if it were not for the seriousness
with which those suggestions were made. Imagine
taking your son or daughter on a bridge fishing trip where nearly all of the
line on your fishing reel is needed just to reach the water surface and a day of
fishing could result in acute hearing loss from the noise of passing traffic.
The bird watching stations would add a new dimension to this popular
hobby. Instead of looking at birds
in their native habitat observers would get to see great blue herons on their
way to the Motor Island rookery collide with bridge cables and fall to the
pavement where they would be flattened by passing traffic.
Clearly, the suggestion of such a mitigation plan is an insult to anyone
who has any respect for the environment.
In
general, alternatives SG-1 and SG-2 will adversely impact the ecology of the
upper Niagara River and will undo the efforts by Federal and State agencies to
preserve and enhance habitat during the last decade. The State of New York, local businesses, fishing and
environmental groups and the US Army Corps of Engineers working together as a
team have invested nearly two million dollars in the restoration of Strawberry
Island, the preservation of the great blue heron rookery on Motor Island and the
planned recovery of wetlands along the east side of Beaver Island Park.
This entire investment and all of the ecological values that have accrued
to date will be lost if a signature bridge is constructed between Strawberry and
Motor Islands.
The
entire Niagara River corridor is designated an Important Bird Area of
International Significance by the National Audubon Society.
This designation is not easily earned and is a testimony to the overall
value of this ecosystem particularly in the area around Strawberry Island.
What this means is that certain bird species with global ranges must come
to the Niagara River corridor to complete their respective life cycles.
The proposed alternative alignments would compromise this process in a
way that could affect the global population dynamics of some of these avian
species.
Constructing
a bridge between Strawberry Island and Motor Island at a point where the broad
expanse of the Niagara River divides into two distinct channels multiplies the
impact of an accidental hazardous materials release or an oil spill resulting
from a vehicle accident. Instead of flowing down a single channel these
pollutants will contaminate both the east and west channels making it difficult
if not impossible to employ effective containment measures.
The loss of fish and wildlife resources in such an event will be
catastrophic, but the effects are even more far reaching as potable water
intakes are either contaminated or shut down to avoid potential contamination.
Beaches and marinas downstream of the incident along with shoreline
property will also be adversely affected.
A
bridge spanning the widest part of the Upper Niagara River will require the
installation of a number of support piers.
Placement of the piers in shallow water areas will be preferred as
opposed to the deeper swifter waters of the river. Placement of piers in the
shallow area between Strawberry Island and Motor Island will consume a large
portion of the existing submerged aquatic plant beds and construction activities
associated with their installation will destabilize the remaining submerged
flora. These plant beds serve as
valuable spawning and nursery areas for a variety of fish species many of which
are of recreational importance.
Placement
of installation of multiple bridge support piers will directly impact the flow,
capacity and volume of the Niagara River. These changes could redirect current
patterns accelerating the erosion of Strawberry Island as well as the Grand
Island shoreline. This erosion
process will eventually lead to the destabilization of the submerged aquatic
plant beds between Strawberry Island and Motor Island allowing bottom sediment
to migrate into the adjacent Federal navigation channel increasing the need for
maintenance dredging.
The
increased traffic associated with a multi-lane span traversing the river between
Strawberry Island and Motor Island will introduce a substantial air pollution
load to an area that is not currently exposed to such emissions. The release of
nitrogen oxides, heavy metals and other compounds associated with automobile and
truck exhaust will be continuous increasing the potential for entrainment in the
water column during heavy rainfall or aerodynamic downwash events. In addition,
the release of road surface drainage along the length of the span will add trace
levels of oil, grease and other pollutants. Once entrained in the water column
these contaminants will stimulate excessive algal growth especially in the slack
current vegetated shallows depleting dissolved oxygen levels and establishing a
detrital layer that will slowly chemically contaminate river bottom sediments.
I should point out that the shallow water sediments in and around
Strawberry Island are one of the few areas within the entire Niagara River
corridor that have not been chemically altered despite more than a century of
industrialization.
The
historic value of Strawberry Island will be compromised by the proposed bridge
alternatives. At the time of
colonization Strawberry Island was nearly two miles long extending from the foot
of present day Hertel Avenue downstream to Motor Island.
The shallow water area between what remains of Strawberry Island and
Motor Island was originally part of the historically larger island. This area
was used as a staging area for British troops preparing to invade Black Rock
during the War of 1812. Since no
surveys have been conducted it is likely that artifacts from this campaign may
still exist in what is now shallow river bottom.
Construction of a signature bridge at this location will compromise these
potential cultural resource values.
Bird
collisions with a cable stay bridge design will be substantial since the
proposed alignment will act as a giant mist net frustrating the seasonal
migration of bird species traversing the Niagara River corridor.
A bridge at this location will decimate the heron population on Motor
Island particularly during the nesting season when activity is highest.
Scientific studies have shown that the potential for bird collisions
increases substantially with this type of bridge design.
The construction of a bridge in the area near Strawberry Island will
adversely impact the heron rookery on Motor Island that is now a nature preserve
managed by the New York State Department of Environmental Conservation.
In addition, the presence of this bridge will have a negative impact on
populations of the canvasback and American widgeon known to overwinter in
this area of the Niagara River in record numbers.
The
tranquil setting of calm water and picturesque sunsets will be replaced with the
unnatural superstructure of a signature bridge and a substantial increase in
ambient noise levels. The natural
viewshed for the new State funded Beaver Island Casino will be marred by the
looming structure of a bridge putting this entire investment at risk. In fact,
the construction of a bridge on an alignment between Strawberry Island and Motor
Island will result in the degradation or taking of park land, recreation lands,
wildlife and waterfowl refuges and historic sites.
Specific impacts warranting full consideration under Section 4 (f) of the
Federal Department of Transportation Act of 1966 include the following:
a.
Loss of the public boat launch at the foot of Sheridan Drive in Tonawanda and
the degradation of Aqua Lane Park and the Erie County Riverwalk.
b.
Loss or destruction of the State designated significant habitat area between
Strawberry Island and Motor Island that is part of Beaver Island State Park.
c.
Degradation of Strawberry Island a part of Beaver Island State Park and the
heron rookery on Motor Island that is under the legal protection of the New York
State Department of Environmental Conservation.
d.
Beaver Island Park, its beaches, trails and a public marina will be subjected to
the negative aesthetic impacts associated with the visual intrusion of the
bridge structure and the associated noise generated by bridge traffic.
e.
Aesthetic impacts adversely affecting River Lea at Beaver Island Park a property
that is potentially eligible for listing in the National Register of Historic
Places.
f.
Loss of recreational duck hunting currently permitted within Beaver Island State
Park and on Strawberry Island.
Alternatives
SG-1, SG-2 and SG-3 cannot be built without first razing and relocating the Town
of Tonawanda Water Treatment Plant. This
would include partial excavation and reconstruction of the water intake tunnel
that extends more than a half mile into the Niagara.
The relocation of this plant and the associated intake will merely
increase the magnitude of adverse environmental impact associated with the
construction of bridges along the proposed alternative alignments.
The costs associated with this project will have to be borne by the rate
payers who make use of the drinking water provided by this facility.
Comments
on Crossings at Grand Island
Alternative
GI-2 is fundamentally flawed. The
assumption made by the proponent of this alternative is that the South Grand
Island Bridges will be adequate for the increased traffic flow to and from
Canada. This is utter nonsense.
If this alternative becomes reality the endless traffic jams that exist
at the existing Peace Bridge will merely be shifted to Grand Island.
Localized air pollution will increase and the pounding heavy truck
traffic will insure that the South Grand Island Bridges will require continuous
extensive maintenance and repair.
The
quality of life on Grand Island will decline significantly with either
alternative. Island neighborhoods already segmented by the New York State
Thruway Authority will become even more isolated. Traffic flowing onto the
island will bypass the Grand Island business district causing further economic
decline. The bridges, their limited
access highways and associated plazas will generate pollutants that will degrade
water quality, disrupt wildlife movement and irreversibly consume hundreds of
acres of woodlands, wetlands and stream habitat.
The
destruction of wetlands associated with either alternative will alter or destroy
the natural systems that attenuate flood flows and assimilate the pollutants
contained in surface water runoff. Artificial
flood and stormwater management systems would have to be built to replace these
natural functions imposing a significant capital cost upon the Grand Island Town
Government. The cost of these
infrastructure improvements will be passed on to residents in the form of
increased property taxes and reduced government services.
Park
land and scenic area impacts subject to review under Section 4 (f) of the
Federal Department of Transportation Act of 1966 will be lost or adversely
impacted by both alternatives. Alternative
GI-1 will impact several marinas, a yacht club, the Beaver Island Parkway
bicycle trail and several wetland preservation areas that lie along the proposed
alignment of the highway and associated plaza.
Alternative GI-2 will adversely impact the Spaulding Boathouse located in
the banks of the West River. This
structure is listed in the National Register of Historic Places and is afforded
special protection under Section 106 of the National Historic Preservation Act.
Both alternatives will impact the scenic State parkway corridor that runs along
the west side of Grand Island.
Finally, it is clearly apparent that the original twin span alignment adjacent to the Peace Bridge is the best alternative with the least amount of environmental impact. It will fully address the needs of the community for efficient management of traffic flow between the United States and Canada and more importantly will not require public funds for construction. That being said, there is another option for the location of the inbound truck plaza. Instead of establishing a plaza adjacent to the Scajaquada Expressway (Route 198) consider moving it to the largely abandoned rail corridor that extends northward from the International Railroad Bridge to the Town of Tonawanda. This linear corridor contains sufficient space for a truck plaza and a dedicated limited access highway that could significantly improve traffic flow and eliminate the hazards associated with the serpentine layout of Route 198. An added benefit this corridor is that it can be easily linked to either Route 190 or 290.
In
summary, the five alternatives proposed for Grand Island and the waters south of
Grand Island will have substantive and far reaching adverse environmental
impacts that cannot be neutralized by mitigation. Besides excessive cost, all of these alternatives represent a
needless intrusion into our community and the environment that defines the
quality of life on Grand Island. You
need to reject these alternatives and move on.
If you choose to pursue any one of these alternatives I can assure you
that I and my fellow islanders will make it our life mission to insure that a
signature bridge is never built on or adjacent to Grand Island.
Sincerely,
Paul G. Leuchner