City to River Comment on National Park Service Environmental Assessment

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.

One Response to “City to River Comment on National Park Service Environmental Assessment”

  1. Pat Eckelkamp says:

    Highway removal/at-grade boulevard is the only way to go.

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