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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; www.niagaraheritage.org) 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.
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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.
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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.
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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.
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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.
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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.
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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.
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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?
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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.
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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.
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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.
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The passenger boarding
area is an excessive blot of paving in the lower gorge, unsightly, artificial,
contrary to a natural park.
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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.
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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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