After six months with little new information since the unveiling of the refined MVVA plan and accompanying traveling exhibits this past winter, the official environmental review process required by the National Environmental Policy Act (NEPA) is set to begin. The National Park Service has announced it will begin a formal Environmental Assessment (EA) in September on the proposed plan and is seeking public comments though the end of this month to help guide the EA. As the NPS explains, this “public scoping” is intended to bring to its attention any issues that it may have missed and may need to address in the actual Assessment. If the EA concludes that there will be no adverse impacts from the plan, then that essentially concludes the review process. But if potentially adverse impacts are identified, an in-depth and potentially lengthy Environmental Impact Statement (EIS) must be conducted. The NPS release also indicated that a concurrent EA will be conducted by MODOT regarding I-70 and Memorial Drive, including the impacts of additional highway ramps. The timeline for this process is as yet unknown.
The NPS release seems to raise significant questions about where the project stands. All elements on the Illinois side (and apparently the proposed gondola) will not be part of the Assessment, suggesting that these elements either have been eliminated or are indefinitely postponed. City to River previously raised concerns about the apparent postponement or scaling back of key elements such as the Underpass Park and Beer Garden on the South grounds as well as the new appearance of additional highway infrastructure to the depressed lanes. With this new uncertainty the overall vision is, if anything, now a deeper mystery.
But back to the public scoping for the Environmental Assessment. Is something missing in the proposed EA that needs to be addressed? City to River firmly believes the answer is yes. Replacing the redundant I-70 and Memorial Drive with an attractive boulevard is a legitimate proposal that needs to be studied as part of the official process. Typically an Environmental Assessment looks at all viable alternatives for a proposed action. In that case, the environmental review normally would examine a range of alternatives to improve connections between downtown and the Arch grounds and nearby riverfront. However, this process is bears little semblance to normality. The rigorous NPS EA has been carefully limited to avoid the issue of connectivity entirely.
A year ago City to River was told by numerous parties that a boulevard could not be completed by 2015, the 50th Anniversary of the Arch. Thus, a potentially superior alternative to the more limited lid (and substantial elimination of Memorial Dr.) was left unstudied. This begs the question: should an environmental review of a 40-50 year infrastructure investment only consider alternatives that could be completed by an arbitrary deadline just a few years from now? In a grim irony many elements of the MVVA plan are now being scheduled beyond 2015.
The people of Saint Louis deserve the best project that can be completed in a reasonable amount of time. It is vital for the city’s identity and future. The National Park Service, MVVA and each of the other design finalists, and countless others have identified the overwhelming merits of removing the orphaned interstate. It would be extremely rare, if not unheard of, for such a widely admired proposal to not receive a thorough analysis.
City to River believes a boulevard could be completed by the end of the decade at the latest. We have also shown how the boulevard plan could be compatible with the existing proposal of the one-block lid seamlessly bridging The Old Court House and Ely Luther Park with the rest of the Arch grounds.
City to River encourages its supporters to submit a public scoping comment to the National Park Service by the end of the month. Comments should focus on the big issues of connectivity regardless of the self-imposed constraints of the process. With no public plan for the transportation infrastructure and no forseeable MoDOT Environmental Assessment process, the NPS EA is the only venue for public input. At minimum, the Environmental Assessment must address how the preferred plan may impact the future possibility of a boulevard. A full-blown follow-up study of the boulevard concept (which extends further north than the Arch study) can be separate from the immediate process. But it must begin.
Saint Louis will not be truly reconnected with its riverfront until the unnecessary barriers of a de-designated I-70 are removed. The sooner a full examination of the boulevard from the New Mississippi River Bridge to Choteau’s Landing can begin, the sooner we can fully achieve the admirable goals stated in the competition.