Rear Admiral Scott A. Buschman, Commander
United States Coast Guard District Seven
Bridge Administration Branch
Brickell Plaza Federal Building
909 SE First Avenue
Miami, Florida 33131-3050
RE: Obstruction of Navigable Waterways - St. Lucie River
Dear Rear Admiral Buschman:
Martin County has important new information to share about the number of vessels transiting the St. Lucie River at the Florida East Coast Railway Bascule Bridge. The bottom line is that the new data indicates there is far more vessel traffic than projected in the Draft Environmental Impact Statement (DEIS) for the All Aboard Florida (AAF) Passenger Rail Project. This new data indicates the expected increase in bridge closures is an even more serious problem, due to the larger number of vessels.
On November 13, 2014, the Coast Guard held a public meeting at the Blake Library in Stuart, Florida to provide an opportunity for oral and written comments regarding current and future operations of the Florida East Coast Railroad Bridge across the St. Lucie River. The meeting was directed by Gene Stratton, Bridge Management Specialist of the Seventh Coast Guard District.
On November 19, 2014, the Martin County Board of County Commissioners submitted comments on Docket USCG-2014-0937. The comments included 81 days of boat count data from June 12, 2014 to August 31, 2014 at the St. Lucie River Railroad Bridge and a commitment to continue to collect data for a one year period. Martin County also committed to make the count data available to the Coast Guard for evaluation of the St. Lucie River Railroad Bridge's current navigation issues, and for future Rulemaking.
Further, in their November 2014 letter, the Martin County Board of County Commissioners also urged the Coast Guard to immediately initiate the Rulemaking Process on the St. Lucie River Railroad Bridge to establish predictable hourly opening times with minimum safe vessel transit times. The proposed AAF Passenger Rail Project will create additional impacts on a bridge that is already an unreasonable obstruction to navigation. A similar request was made by the community group Citizens Against Rail Expansion in Florida (CARE FL), following the research and analysis performed for CARE by retired U.S. Coast Guard Captain and U.S. federal Senior Executive Service maritime navigation authority, Mr. Dana Goward.
With respect to vessel traffic at the St. Lucie River Railroad Bridge, the attached report from Taylor Engineering, Inc. includes eleven (11) months of data collected from June 12, 2014, to April 30, 2015. Peak travel hours are from 10 AM to 5 PM, however substantial additional boat traffic is seen between 6 AM and 8 PM daily. Boat counts in the report reflect traffic during daylight hours only and therefore under count the total boat traffic.
The Navigation Discipline Report included in the DEIS utilized vessel traffic data extracted from "peak vessel traffic season"-a two·week video assessment of the St. Lucie River Bridge, from January 3, 2014, to January 17, 2014. Page 4·21 of the DEIS states:
"The vessel traffic data show an average of 102 vessel crossings per day <Min=28; Max=263) from Monday to Friday, compared to about 315 vessels (Min=157; Max=413) per day on a weekend. Sundays had the most vessel activity, with a range of 296 to 395 vessel counts."
Table 4.1.3-2, Daily Vessel Traffic at the St. Lucie, Loxahatchee, and New River Bridges, January 2014 on Page 4·22 of the DEIS. states :
''Vessel traffic was assessed during January daylight hours, from 6:00 am to 6:30 pm."
Table 4.3·6 on Page 4·22 of the Navigation Discipline Report for the AAF Passenger Rail Project from Orlando to Miami, Florida in Appendix 4.1.3-C of the DEIS states:
"Vessel traffic was assessed primarily during daylight hours (from 6:00am to 6:30pm), but casual observations were also recorded later at night."
The DEIS is misleading in terms of 1) what the "peak vessel traffic season" is for Martin County, 2) what the average daily boat count is in those "peak" months, and 3) what the average boat count is on weekends. First, the DEIS collected data in January 2014, which indicates that the winter months are the "peak vessel traffic season," while the data collected by Taylor Engineering shows that the "peak vessel traffic season" for Martin County is the spring and summer months, with April boat counts 83% higher than January counts. Second, the DEIS shows the average daily boat count, from January 3, 2014 to January 17, 2014, to be 121 boats per day, while data collected from Taylor Engineering shows the average daylight boat count in the month of April 2015 to be 280.9 boats per day. Third, the DEIS shows that Sunday has the highest daily count, with an average ranging between 296 and 395 boats. Taylor Engineering shows the highest daily count to occur on Sunday as well, but with an average of 420.3 boats per day, with the highest actual count on a Sunday of 880 boats. This is a significant fact, assuming that the highest number of riders on the passenger rail would likely be the weekends. This information is yet another indication that the flawed DEIS does not provide an accurate depiction of the negative impacts that AAF will have on Martin County.
Martin County will continue to collect boat count data and share it with the Coast Guard through August 2015. Please keep us informed on any actions the Coast Guard initiates on correcting the current navigation issues at the St. Lucie River Railroad Bridge.
Teri Rauth, P.E.
Deputy Director of Engineering
Enclosures: Vessel Traffic Data, Taylor Engineering, Inc.
CC: Martin County Board of County Commissioners
Michael Durham, Martin County Attorney
Stephen M. Ryan, Martin County Legal Counsel
John Winkle, Federal Railroad Administration
Osvaldo Collazo, U.S. Army Corps of Engineer
Barry Dragon, USCG Chief, Bridge Branch