City of Alma
314 Main Street North
Alma, Wisconsin 54610
June 22, 2017
Mr. Robert Edstrom
US Army Corps of Engineers
St. Paul District, Attention Project Management 180 5th Street East, Suite 700
St. Paul, MN 55101
Dear Mr. Edstrom:
I am writing to comment on the Draft Feasibility Report and Integrated Environmental Environmental Assessment for the Lower Pool 4 Dredged Material Management Plan.
The City of Alma is opposed to to those parts of the Plan referring to on-shore management of dredged material. The Environmental Assessment component of the report serves the function of Draft Environmental Assessment under the impact evaluation process of the federal National Environmental Policy Act (NEPA). It is the City’s position that its concerns require coordination between the City and the Corps. The City requests hereby that meetings, as required, be held to discuss the issues we present in this letter and participation by the City in appropriate revisions to the Plan and the determination of mitigation measures. It is our expectation that these meetings in addition to substantial resolution of the concerns raised therein will occur before the issuance of a Finding of No Significant Impact, which would conclude the NEPA environmental review process.
A. Socioeconomic Effects – Transportation
No mention of the traffic effects of the Plan on Beach Harbor Road in Alma is made in the Plan. This is a narrow City street not built to the standards of State Roads. Beach Harbor Road floods periodically, further weakening its structure to high loads. In 2014 the corps unloaded some 600,000 cu. yds. from Grand Encampment Island. All of it was carried across Beach Harbor Road, one dump truck at a time, 80,000 times.
The road was damaged and repairs made. Now the repairs need repairs. The Plan’s annual projections of trips may well finish off this road.
The proposed truck traffic through the center business district during the short tourist season is dangerous for increased pedestrian traffic from visitors. State Road 35 is narrow and congested with the comings and goings of on-street parking.
B. Socioeconomic Effects – Noise and Aesthetics
The proposed annual 11 day ritual of 10 hour days, five days a week, dump truck traffic through the commercial district will add noise during the short tourist season, making the businesses there less appealing to customers.
This same ritual will pass into and out of the Alma Marina Site. The 90 degree turn from Beach Harbor Road to the On-Shore Transfer Site at Alma Marina will create significantly disturbing noise for slip renters at the Alma Marina. This turn is a low speed transition from gravel to pavement and requires heavy braking and acceleration for each use. In addition, a double track crossing of the BNSF occurs nearby, with noise from the uneven surface, increasing the noise level at the Marina further.
C. Other Environmental Categories
Cultural Resources must include the National Historical District that includes most of the City center area the Plan’s truck traffic will pass. There are several individual properties listed as National Historic Properties along the route as well. These are all ignored in the Plan. Under Section 106 of the Historical Preservation Act, detailed regulatory and associated mitigation requirements need to be determined subsequent to the National Environmental Policy Act (NEPA) review which this Plan is part of.
D. Inadequate Notification
The businesses and residents along State Road 35 in Alma and on Beach Harbor Road in Alma are the most exposed to hardship under the Plan. They deserved early and direct notice of the Plan in the same way that the owners of the property to be acquired received it. They received none.
The use of Alma as Wisconsin terminal is assumed in the Plan. Given the supposed efficiency of barge hauling of bulk materials, it is obvious that basing the costs of hauling sand from dredge to disposal site by considering only ton mile costs for dump trucks ignores other, perhaps more economical, solutions. Alternative terminal sites in Pools 5, 5A, and 6 need to be evaluated. Hauling to the Flury West Site, for example, is possible from Pool 5. In this case, the truck portion of the trip becomes measured in feet, not miles, and the barge run increased by about 7 river miles. Other disposition sites close to potential offload sites may exist in these lower Pools, as well; but none have been explored in the Plan. They should be.
The City of Alma lacks staff and resources to fully analyze the voluminous Plan presented by the Corps in the time given by the Corps timetable. The points above are a start. I urge the the Corps to extend the time available comment to permit such analysis.
Very truly yours,
Mayor of Alma