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City to River Comment on National Park Service Environmental Assessment

Monday, August 29th, 2011

In our last post City to River called attention to the current National Park Service Environmental Assessment comment period. Comments are due tomorrow August 30, 2011 by midnight. We ask all our supporters to submit comments to the National Parks Service on the current process and proposal, and especially on the effect of a widened highway on the Arch Grounds.


City to River’s official comment for the Environmental Assessment is as follows:



Question 1: Do the purpose, need, and objectives reflect what you think the NPS needs to accomplish with this project? If not, what else do you think needs to be accomplished?

City to River does not believe that the purpose, need and objectives reflect what the NPS needs to accomplish with the revitalization project. Specifically, the proposed closure of Memorial Drive and addition of longer Interstate highway ramps do not preserve the integrity of the Arch grounds. These changes represent unacceptable impacts on the cultural landscape of the City of St. Louis. Any additional highway infrastructure creates a larger barrier to visitors and further harms the visitor experience, doing nothing to promote extended visitation to the Arch, the city or the river.

The visitor experience will also be harmed by proposed changes to Memorial Drive and I-70. The proposed solution does not reduce impacts from adjacent transportation systems, but in fact, makes them worse. Pedestrians utilizing the popular Washington Avenue entrance will not only have I-70 looming above, they will contend with fast-moving and increased traffic entering and existing I-70. This significantly worsens an already bad pedestrian experience.

Removing the street grid by closing Memorial Drive and Washington Avenue also harms connectivity by making the visiting experience less predictable and more confusing. Downtown streets become a maze to be navigated in order to find the Arch grounds.

The re-routing of I-70 from the Poplar Street Bridge to the new Mississippi River Bridge makes possible an at-grade boulevard between the two. The boulevard should be studied as an alternative to promote connectivity, protect and enhance the cultural landscape of the city and Arch grounds, enhance the visitor experience and encourage extended visitation. We believe that this is the best way to accomplish what the NPS set out to accomplish with this project.



Question 2: What concerns do you have about the potential impacts of the project to revitalize the park? How do you think these concerns could be addressed?

The current proposal to close a large portion of Memorial Drive as part of the lid concept has led to the proposed addition of more Interstate highway infrastructure on-site. This is the total antithesis of increasing connectivity, a primary goal of this multi-hundred million dollar effort. Additional highway infrastructure is an adverse impact that should only be considered as a last resort and only if there is no other option. Alternatives to the current proposal have not been adequately considered and there is no public comprehensive traffic study informing this proposal. Whatever is built represents a substantial investment in time and money, such that a further reconsidering of connections to the Arch grounds will be unlikely for several decades. An at-grade boulevard, potentially with a one block depression under a lid, is a feasible alternative to additional infrastructure and provides far superior connections along the entire length of the Arch grounds and to Laclede’s Landing and North Riverfront. Therefore, the highway removal alternative endorsed by all five competition finalist design teams, including the winning MVVA team, should (at the very minimum) be studied before “improvements” are made that would preclude this option for decades to come.

The MVVA team stated in their winning proposal “…the benefits of removing the highway altogether are clear…”. The design team also kept Memorial Drive open and did not place additional infrastructure between the city and the Arch grounds. There has been no explanation to-date regarding why the proposal now calls for the opposite of what the winning design team chose and the opposite of what dozens of St. Louis community stakeholders have proposed; the removal of the most significant barrier to Arch grounds connectivity.

Communities across the nation as diverse as San Francisco, Milwaukee, New Haven, Syracuse and New Orleans are examining and implementing new proposals to remove outdated highway infrastructure and return streets and boulevards to central cities. Many of these real-life case studies have shown that removing highways from urban cores cause property values to increase substantially and significant redevelopment and revitalization of the area to occur. We are not the only ones to identify this opportunity for St. Louis: the Congress for New Urbanism has placed I-70 in downtown St. Louis on their list of “Freeways Without Futures”.

There is no reason to believe that St. Louis will have a different experience than other cities that have benefited from highway removal; in fact, a leading real estate consultant has identified $1.2 billion in development potential over the next 20-25 years as a result of replacing the former I-70 segment with an at-grade boulevard. The benefits of transforming downtown St. Louis and its riverfront into a connected, walkable and vibrant community is clear. Failure to fully study this opportunity means that the best solution to address the stated goals of the NPS will be wholly ignored without even a modicum of consideration. City to River strongly encourages the NPS not to close the door on this opportunity without giving it the serious consideration it is due.



Please submit any additional comments in the box provided. You can enter up to 35,000 characters in the comment field (approximately equivalent to a 10 page letter). If you wish to send us more detailed comments, you may submit them in hard copy by clicking on Print Form in the left navigation.

A boulevard in place of the Interstate highway would provide for additional development opportunities, fulfilling not only the desire for improved connections, but very explicitly creating attractors adjacent to the Arch grounds that would promoted extended visitation to the Arch, city and river.

According to a recent study conducted by Development Strategies, removal of the former Interstate 70 and its replacement with the new Memorial Drive creates up to 500,000 square feet of new developable land. This includes land facing the Arch as well as land adjacent to the boulevard reclaimed from highway right-of-way. The newly available property will support the creation of nearly $1.2 billion in additional real estate market value over the next 20-25 years.

Such an opportunity for new development will not happen with the existing configuration of I-70, nor would this redevelopment be catalyzed by the current lid proposal. The greatest potential for development lies in the areas along the elevated sections of I-70. This massive infusion of ideally located new development property presents the greatest opportunity for economic revival that St. Louis has seen in decades.

Below is a breakdown of the potential value of new development adjacent to the boulevard. These figures do not include the increase in value of properties more than a few blocks away, such as the Ballpark Village site, or existing buildings currently adjacent to the Arch.

Chouteau’s Landing District $133,000,000
Broadway and Spruce Lot developed $126,000,000
New Parcels facing Memorial & the Arch $ 69,000,000
Surface lots on Broadway near Convention Center $ 21,000,000
New Parcels east of Jones Dome $ 22,000,000
Laclede’s Landing Parcels @ Eads Bridge $107,000,000
North Riverfront fronting Memorial $136,000,000
Bottle District & off boulevard North Riverfront $543,000,000
Total Real Estate Value $1,156,000,000

All five finalist design teams in the Framing a Modern Masterpiece competition identified replacing I-70 with an at-grade boulevard as the best solution to meet the challenge set forth by NPS and City Arch River:

“Not only would our design not be in the way of a boulevard, but we designed so that it purposely works with a boulevard.”

“We predict fanfare should the elevated highway that cuts off Laclede’s Landing be removed.” -– Behnisch

“…the benefits of removing the highway altogether are clear…”

“Full Circle’s grand loop of transportation facilities could be easily integrated into its [City to River’s] design.” — Weiss-Manfredi

“City to River articulates an enormous number of benefits arising from such a scheme…”
– SOM-Hargreaves-BIG


In addition, the following have endorsed further study of City to River’s plan to replace I-70 adjacent to the Arch grounds with an at-grade boulevard:

Chivvis Development – developers of Chouteau’s Landing, just south of the Arch
Citizens for Modern Transit – local transit advocacy organization
Coldwell Banker Commercial – leading area commercial real estate firm
Drury Hotels – Drury Plaza, Drury Inn – Convention Center – major Midwest and downtown hotel operator
Environmental Operations – developers of former St. Louis Centre mall and One City Centre office tower
Gentry’s Landing – high-rise riverfront apartment community
Hilliker Corporation – leading area commercial real estate firm
Laclede’s Landing Merchant’s Association – organization representing Laclede’s Landing businesses
Laclede’s Landing Redevelopment Corporation – organization representing Laclede’s Landing property owners
Landmarks Association of St. Louis – St. Louis’ leading historic preservation organization
Lodging Hospitality Management – owner/operator of Ballpark Hilton
LoftWorks – Craig Heller – developers of Syndicate Trust, The 411, City Grocers, and several other Downtown buildings
Mansion House – high-rise riverfront apartment community
City of St. Louis Mayor’s Vanguard Cabinet – Planning and Land Use Committee
North Riverside Holdings – Tim Tucker and Mark Schulte – owners of Cotton Belt building on North Riverfront
Open Space Council – committed to conserving, protecting and sustaining land and water resources throughout the St. Louis region
Spinnaker St. Louis – Amos Harris – developers of Laurel project in former downtown Dillard’s building
St. Louis Convention & Visitors Commission – lead St. Louis convention agency
St. Louis Chapter of American Institute of Architects – local chapter of national organization
William Kerr Foundation – committed to projects designed to improve education, enrich the environment and promote health and accessibility with offices on North Riverfront.

Make Your Voice Heard: NPS Seeks Comment for Environmental Review Process

Wednesday, August 17th, 2011

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.

Letter from Superintendant

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.

City to River Discusses Riverfront Connectivity with National Expert

Wednesday, August 3rd, 2011

Several members of City to River were recently invited to discuss issues of riverfront connectivity on a tour of St. Louis with Dan Burden. Burden, named one of Time Magazine’s Six Most Important Civic Innovators in 2001, has consulted for thousands of cities and spends 350 days annually on the road.

Missed Connections
Despite his experience in a wide range of American cities, the total disconnection of St. Louis from the Mississippi River and the lack of life along the river took Burden aback. While circling the Jefferson National Expansion Memorial on a warm Sunday afternoon he noted that there were no visible users in the entire south third of the park. To Burden it was clearly an issue of creating multiple comfortable connections between downtown and the arch grounds to encourage Cardinals fans to walk to the South end of the park and loft-dwellers to walk to the North end. Burden drew a direct comparison between our situation and that of Cincinnati:

View Larger Map

Mending the Gap
In Cincinnati, the riverfront is also isolated by a major interstate, but thousands of users are periodically drawn to see the Reds and the Bengals at their stadiums. However, the downtown riverfront contains few amenities outside of professional sports. For Burden, that means that St. Louis has great potential; whereas Cincinnati has the people but not the full-time amenity, we have the amenity of an outstanding park and international icon, but we lack the people. With the burgeoning population downtown, all we have to do is connect the dots. City to River believes that the most efficient way to consistently bring people to the arch grounds is to make them a part of downtown.

Burden saw a strategy for reconnection in the nearby St. Louis Riverfront Trail. Praising the artistic vision evident in floodwall murals and in Bob Cassily’s Rootwad Park, Burden suggested that any rethinking of connection between the city and the river must start by creating unique and livable places for people. City to River is in agreement with Mr. Burden and we continue to advocate for the most cost effective solution: the replacement of the soon-to-be redundant elevated and depressed highway lanes with a pedestrian-friendly boulevard from Poplar Street to Cass Ave.