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January 7, 2001

Thomas B. Lyons

Director, Environmental Management

Office of Parks, Recreation and Historic Preservation

Agency Building One, 19th Floor, Empire State Plaza

Albany, New York 12238


DEIS comments re Niagara Gorge Access Project


Recent actions of the NYSOPRHP, including its endorsement of reservation-based fireworks and the DEIS itself, with its unacceptable “preferred alternative” selection, stand in opposition to Olmsted’s philosophy, the natural Niagara Reservation that he imagined and, together with Vaux, soundly planned.  This is deeply disappointing since the NYSOPRHP has been citing the vision of Olmsted as the guiding principle on which the rehabilitation of the Niagara Reservation will be based.


Indeed, the 29 November 2000-completed DEIS includes a reproduction of the entire Olmsted-Vaux plan for the Reservation, and uses that part of it which says the best view of the Falls is from Canada as a justification for the original construction and continued existence of the observation tower, which provides “views important to the community.”  This use of Olmsted’s remark is a serious misreading, however.  His comment about the view from Canada was objective description, not a plea for an observation tower in partial redress of a geographical reality.  He went on to describe the natural environment features that should be preserved and restored on the Niagara Reservation.  A mirror-sided observation tower was not one of these features.  The following paraphrase is what the Olmsted plan (p.13) said about this: “Attempting to build something that will improve the view from the American side, if it is built on a large scale, will be grandiose, useless, and wasteful.”  (Olmsted Plan Condensed;  The present tower, moreover, on 27 December 2000, was used as a staging site for an elaborate fireworks display, supported by NYSOPRHP, an event enthusiastically heralded by local media outlets.  There was no mention of Olmsted’s disdain for such events, which he placed in the following category: “grotesque performances by mountebanks, with fireworks and music.”  This discharge of fireworks from an observation tower that shouldn’t have been built in the first place is a classic example of adding insult to injury.


Some months ago Governor Pataki visited the Niagara Reservation and announced that the Observation Tower was an eyesore, implied that it was an affront to the natural parks philosophy of Olmsted and Vaux, and said that it had to go.  An elevator shaft/tunnel was mentioned as the alternative.  The current DEIS indicates that this would be cost prohibitive, and even more destructive to the gorge face than the present tower.  The “preferred alternative” is to rehab the existing tower and elevator shaft so that it is a mirror-sheathed structure extending into the gorge, capable of delivering “at least” 2,400 people per hour to the Maid of the Mist tour boats.  We find this proposal to be seriously flawed.

  •  There is no information in the DEIS about what the economic share of increased tour boating would be to NYSOPRHP.  The general public is asked to accept a loss of its natural heritage, to sell it off in a sense, but not told the selling price.  This is also a concern of the 1999 Scoping Meeting not responded to by the 2000 DEIS.

  •  Elevator maintenance responsibility is another subject still open to negotiations, apparently.  Linked to profit sharing and the private-public structure of this proposal, it should be settled and part of the DEIS for comment before the process continues.  This is also a Scoping Meeting concern not responded to by the DEIS.  

  • The Reservation does not “need” yet another gift shop, detracting from the natural atmosphere of the surroundings and taking potential business away from the private sector in the city.  Olmsted spoke to this issue using a restaurant as an example.  

  • The “views important to the community” provided by the tower and elevator shaft appear to be those which result in photographs used in promotional literature.  It seems to us that if 40 years haven’t produced enough of these, that a concentrated effort over the next year would do so.  Seasonal, times of day, and varying light, wind, and other conditions could provide ample opportunity for thousands of photographs.  Helicopters, ever present, provide other and similar vantage points.  This is not a legitimate reason for tower retention.

  • In a 16 April 2000 Buffalo News article, Commissioner Castro was quoted as saying “No new buildings” in reference to the Niagara Reservation.  Her declaration should apply to the proposed gift shop, ticket booth and office facilities for tour operations at “park level,” and to public restrooms and other spaces within the gorge.  For a tour lasting well under an hour, public restrooms on top should be sufficient.  

  • The proposed reflective surface of the structure would be extremely offensive aesthetically, more appropriate to Manhattan or some other contemporary urban setting than the Niagara Gorge.

  • It is well known that foliage and sky reflected in picture windows cause the injury and death of countless birds that fly into such surfaces; what indication is there that the tower surface will be safe for birds?  

  •  The rationale for this surface, that it will reflect the natural scenery and “blend in,” is a stretch.  It will also, from certain angles, reflect the glare of the sun, perhaps blindingly.  For thousands of people who view it from levels below the gorge edge, from trails and other vantage points, it will reflect the hodgepodge of buildings on the Canadian gorge rim.

  •  We take as a given that elevators will transport tourists to Maid of the Mist boat rides.  The number, however, 2,400 per hour (emphasis ours) is excessive, twice the number present boats can handle, even when their carrying capacity is doubled from what it currently, which is intended.

  •  We suspect elevator carrying capacity will be used as a rationale for adding more boats.  At what number of boats, or size of boats, does their presence in the pool below the falls become an aesthetic offense? Some of us feel that four is already too many.  Elevator capacity points the Reservation firmly in the direction of amusement park rather than an Olmsted natural environment.  This direction toward amusement park is sufficiently clear that one of the comments of the scoping process was to consider opening the pool below the falls to public “boater access (kayaks, canoes and inflatables).”  The comment on page 85 of the DEIS, under “VII.D.8. Growth Inducing Aspects,” where it says, “It is not expected any significant local growth will occur as the result of the implementation of this project,” seems shortsighted, less than forthcoming.  In addition, this 18 February 1999 Scoping Meeting general concern is inadequately responded to by the 29 November DEIS.

  •  The passenger boarding area is an excessive blot of paving in the lower gorge, unsightly, artificial, contrary to a natural park.

  •  The tunnel alternative should be revisited, with the attitude that it is possible, though expensive, to accomplish this alternative without the outlandish damage to the gorge wall shown in the computer-generated drawing.  Certainly there are drilling techniques that would permit, without use of explosives, the vertical shaft and horizontal tunnel to be completed with no or minimal damage to either the gorge wall or the shale slope.  If the Olmsted vision is the ideal, then the NYSOPRHP should strive to achieve it.  The tunnel alternative might cost $100 million, but the gorge wall would retain its natural character for the next century or more.  That’s a million a year to have done it right, not $20 million to keep an eyesore.

  • If the Olmsted vision is the philosophical base on which the preservation and renewal of the Niagara Reservation rests, then NYSOPRHP deserves to drape itself in the Olmsted and Vaux cloak; if the DEIS is to be an example of this direction, then the Plan needs to be read more carefully.  It is not a great piece of literature that is open to multi-leveled interpretation; it is a straightforward plan that needs to be adhered to as much is humanly possible to avoid the further Disneyfication of the Reservation.  The current DEIS for the “Niagara Gorge Access Project” does not do this.


Respectfully submitted,


Bob Baxter, Conservation Chair

Niagara Heritage Partnership



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Niagara Heritage Partnership

MPO Box 1495

Niagara Falls, New York 14302-1723