Mr. Barry Dragon, March 16, 2015 Commander, Seventh Coast Guard District (dob) Brickell Plaza 909 S.E. 1st Ave. Miami, FL 33130-3050 Commander, On behalf of the Florida Council of Yacht Clubs representing thousands of power and sail captains I would like to register our strong objections to the implementation of the AAF project for many reasons, some of which, come under your cognizance. As you know, several railway bridges over rivers in Central and Southern Florida are or will be directly impacted by the frequency of the passenger train traffic as well as by the much longer freight trains carrying containers that are expected in the future as a result of the expansion of the Panama Canal. Further, at the St. Lucie inlet, the USCG station is up stream from the existing railroad bridge which means that if a navigational or medical emergency occurs down stream from the bridge while a two mile long container train is crossing it, the life saving and rescue mission of your agency will be severely compromised. Specifically, we would like to address some of the deficiencies in the Draft Environmental Impact Study (DEIS) submitted by All Aboard Florida, Inc that come within areas of mutual interest to the USCG and to our members. 1) Section 4.1.3 Navigation: The adverse effects of 32 additional train crossings on the St Lucie River single-tracked trestle bridge built in 1925 are not clearly or fully recognized, stated, or considered in the DEIS. a)the DEIS shows an average daily vessel count of 157 vessels passing through the draw span at Mile Post 260.93 along the St. Lucie River. Actual counts of vessels by the Martin County Engineering Department show a count of 243 vessels per day. b) The Martin Metropolitan Planning Organization (MPO) reports that there are no publicly reported inspection records for the trestle bridge over the St. Lucie River, indicating that neither the FRA nor the FDOT has any public record of the condition of this 90 year old bridge. c) The existing bridge and trackage in its original 1925 configuration with a proposed 32 additional trains crossing the span each day for a potential of over 50 freight and passenger trains per day has not been adequately considered in the DEIS. A comprehensive study of the need to replace the bridge or construct a tunnel under the St. Lucie River should be considered and required by the FRA and USCG.
d) Stacking: The All Aboard Florida AMEC model video presentation indicates that boats will stack in a single file manner while waiting for the bridge. However, the tidal currents do not flow in a perpendicular manner to the bridge. The channel through which boats must pass to go under the railroad bridge runs in a diagonal path to the river and as a result when boats are attempting to wait for the bridge when it is down, simply adjusting the throttle from forward to reverse will not control the boat because of the sheering effect of the current. The current pulls the boats in a diagonal direction which cannot be controlled by the throttle. If there are multiple boats in a stacking position it will be impossible to respond to the current properly. In addition, when there is a northeast wind which is the prevailing wind in the area, with an outgoing current, the operators of the vessels will have a very difficult time engaging the current as it cannot readily be observed. e) Navigation: The Okeechobee Waterway is regularly used as a barge and transport channel for the marine industry. Included in this most frequently, is the movement of construction barges. According to the Ferrara Group, (a $4,000,000 per year industrial marine construction business located on the South Fork of the St. Lucie River). They regularly move marine barges under the US1 Roosevelt Bridge, through the State Road 707 Bridge, and the FECR trestle bridge. Unfortunately, the boats that push these barges are somewhat difficult to operate and slow to react, and are not able to stack at the bridge while waiting for the trestle to go up or down. In addition, when it has been determined the trestle bridge is going to be lowered, a tug boat is required to begin its stopping procedure as far away as Frasier Creek, to be able to stop prior to impacting the bridge. Once the bridge re-opens it can take in excess of 30 minutes for the barge to resume navigable speed and clear the trestle bridge. Therefore, if the gaps between openings are less than 30 minutes it will be impossible for these barges to navigate the opening. f) Open Span Width: The width of the trestle bridge opening is very narrow (40 feet). The model video contemplates boats passing in both directions in an expeditious manner. This will be impossible as large fishing boats cannot pass in both directions at the same time. This will become very complicated when multiple boats are staging on either side of the opening during closures. If a barge is attempting to navigate the opening during a limited time, all other boats will have to wait. But they can t just stack and wait for the barge to pass as they will be in the way. It is imperative that this opening is widened. g) The FRA and FDOT should require a double-tracked trestle, and a much wider clear span opening as broad based safety and convenience measures for marine and vehicular uses. h) The DEIS does not take into account the designation of the St. Lucie River as an Emerging Strategic Intermodal System (SIS) facility. i) The DEIS does not take into account the federal designation of the St. Lucie River channel in the area of the trestle bridge at Mile Post 260.93 as the Okeechobee Waterway, which regardless of the SIS designation, is nonetheless the cross-florida navigable link for vessels going from the Gulf of Mexico to the Atlantic Intracoastal
Waterway, or the Atlantic Ocean. Sec. 33 CFR 117.317 Okeechobee Waterway currently designates the railroad bridge at Stuart as not constantly tended and normally in the fully open position. 33 CFR 117.8 Permanent changes to drawbridge operation, requires that anyone seeking to change the operation of a drawbridge must first submit letter of request to the Coast Guard s District Commander supporting or justifying the requested change. If the District Commander decides that a change is warranted, he or she will begin rule making to implement the change. The DEIS provides no indication that a request to permanently change drawbridge operations at Stuart has been submitted to the Coast Guard nor is there any discussion of whether such a request is likely to be granted. j) The navigation report indicates a wait time of approximately 17.6 minutes of wait time for boats during train crossings at the St. Lucie River Crossing, while glossing over the actual impact of boating and boating businesses in the area, where at time several boats are stacked up waiting for trains to cross. The study describes the impact as minimal." It is difficult to believe that an additional 32 trains plus 20 freight trains plus more additional freight coming up from Miami crossing the New River would not have any impact. The New River bridge would be closed 6.5 hours per day: 30 times a day for an average of 13 minutes vs. 10 times a day currently for an average of 19 minutes. The Loxahatchee River Bridge currently is used by about 20 trains a day and the bridge is down and blocking marine traffic for about 20 minutes each time. The Loxahatchee span would be closed 8.4 hours per day: 42 times a day for an average of 12 minutes vs. 10 times a day for an average of 19 minutes. The proposed additional AAF passenger train traffic will add at least one additional bridge lowering each hour two additional lowerings unless the northbound and southbound trains cross at the exact same time, which is unlikely. That s 40 to 60 minutes each hour with the bridge being down, blocking all boat traffic, including emergency boats operated by the U.S. Coast Guard, the Jupiter Police, the Tequesta Police and the Florida Fish and Wildlife Conservation Commission. Safe vessel transits are often limited by the narrow passage to one direction at a time, and the need for a slow to modest speed (no more than 10 to 15 knots). The length of the openings must allow passage for all vessels waiting on both sides to cross. With 88,000 transits per year and up to 450 per day, including large commercial vessels, waiting lines can be long. Less than 15 minutes would often be insufficient for vessels on both sides of the bridge to organize, accelerate, and individually pass under the bridge. Note that it is too narrow for safe two way traffic for many vessels. Waiting for the bridge to open degrades the boating experience significantly, and can drive potential waterway users to just stay home. As mentioned earlier, vessels loitering
and trying to position themselves for when the bridge opens, unnecessarily wastes fuel, emits increased air emissions due to the additional fuel burn and typically low engine speed, and run greater risk of collision, grounding and being forced into the bridge by strong currents. 2) Section 7.2.2. - Navigation: This paragraph is in the Mitigation section of the DEIS, and claims to resolve the issues common to the three (3) vertical swing bridge crossings (New River, Loxahatchee River, and St. Lucie River). The first six of the mitigation methods proposed involves notice of bridge closings through 1) scheduling, 2) internet app, 3) countdown horns, 4) contact with first responders, 5) coordination with local authorities during peak boating times, and 6) coordination of schedules through the USCG. At the New River, AAF proposes to place a bridge tender as a means of solving conflicts and interference with commercial boat traffic. All seven (7) of these mitigation measures are minimal, and almost ineffective, and don't reflect or compensate for the actual interference and damage that 32 additional trains will place on the commercial and recreational boating community. Additional measures should be studied and proposed, including but not limited to replacement of the 1925 trestle bridge over the St. Lucie River with a double-tracked, wide clear span bridge or a tunnel crossing under the St. Lucie River. In addition, All Aboard Florida will significantly impact boaters who must cross under railway tracks and use drawbridge access to open water, as well as businesses dependent on those boaters, therefore impacting the economy, recreation and quality of life. Reports from a significant number of boaters indicate that they would no longer use these recreational areas and would not make their usual stops here. These rivers are unique waterways. The St. Lucie River is composed of the federal Okeechobee Waterway, which is an Emerging Strategic Intermodal System (SIS) (east and west), and which serves as a connector with the Atlantic Intracoastal Waterway (north and south), and the Atlantic Ocean. There is no other location on the east coast of Florida with this type of navigable water access. As a result, it is not reasonable to add 32 trains per day, without significant mitigation of the impacts this will cause to the recreational and commercial boating communities. In conclusion, we look forward to communicating with you in the future as the project develops and more facts are made public that might allow us to understand its impact on navigation and allow us to comment on issues of navigational safety. Likewise, we would very much appreciate your keeping us and the public informed on any facts that your own investigations reveal that might affect the viability of the AAF project from this same viewpoint. Sincerely,
Thomas Smith Commodore Florida Council of Yacht Clubs