Restored Bridge of Lions Has Dozens of Malfunctions

[NthDegree]

Chis,

Your 90% conjecture (and I will call it conjecture since it is yours to prove) is irrelevant. The issue is as I stated above: character, integrity and avoidance of adverse effects on the historic bridge. The acronym agencies agreed under the federal law.  So its not your standard, or your interpretation to make.  If you disagree, take it up with them, not me. 

Oh and I forgot to include HABS/HAER in the agencies involved who agreed to the rehabilitation.       



 



     

[ChriswUfGator]

Chis,

Your 90% conjecture (and I will call it conjecture since it is yours to prove) is irrelevant. The issue is as I stated above: character, integrity and avoidance of adverse effects on the historic bridge. The acronym agencies agreed under the federal law.  So its not your standard, or your interpretation to make.  If you disagree, take it up with them, not me.  

Oh and I forgot to include HABS/HAER in the agencies involved who agreed to the rehabilitation.            

The percentage is irrelevant, under the guidelines no historic material at all should been replaced where it was repairable. And as FDOT acknowledged from the outset, the old bridge was indeed repairable, and for half the cost of the new one. Game over.

For the second time, the standards you claim were met, were not met. You, not me, originally brought up the ACHP and the national register. You can keep throwing however many additional agencies into this that you want, the only preservation agency that really had anything to do with the design was ACHP, and as I already pointed out they had no authority to enforce the guidelines and no design input other than a non-binding comment period. Moreover, the preservation guidelines that you brought up but refused to post (now I see why) were clearly not followed, where they call for no historic building material to be replaced at all where it was repairable, which FDOT acknowledged from the outset was the case.

So, I've already posted 16 USC 470 ss. 106 for you, which did not contain anything close to the language you claimed it contained. I've also posted the Secretary of the Interior's preservation guidelines for properties on the national register, which you brought up but refused to post, probably because they completely contradict your position. If there is anything else you'd like to discuss, post the applicable standards, USC, state statute, or agency publication or guidelines involved and we can go from there.

Out of the agencies you've rattled off while avoiding acknowledging that the standards you originally brought up completely contradict you, only two (USCG and ACHP) really had anything to do with the design of this project, and one had no authority, and the other only sets the standards for how wide drawbridge spans must be to accomodate boat traffic. Which has nothing to do with historic preservation.

So as I said, if there is some other standard you'd like to discuss, post it. Otherwise, at least according to the standards you originally brought up, your argument is out of gas. Just because the thing got built does not mean the preservation guidelines were followed. And they clearly weren't. And I guess I can use your logic and say the Secretary of the Interior and USDOI agrees with me, since they publish the standards. Notwithstanding the fact that, like every agency you've listed except two, they had little or nothing to do with the design of this project. And actually, since Federal generally trumps state, and a cabinet department certainly trumps advisory boards and nonprofits, I guess that means I win in the acronym-dropping battle?

Seriously, if you have some standard or agency guideline you'd like to discuss, then post it. Continuing to claim an alphabet soup of agencies agreed with you, without posting anything supporting that, and after you've already made similar claims about 16 USC 470 ss. 106 and the USDOI preservation guidelines which completely exploded and wound up contradicting you, just looks foolish. Pardon me if I don't take your word for it after that.

[ChriswUfGator]

And then there is always Section 4(f), which came into play and gave teeth to ACHP's "advisory" recommendations ... http://www.doi.gov/oepc/handbook.html

Having finished reading through all of that DOJ advisory on ss. 4(f), and reading up on it generally, there were no uniform guidelines for the preservation of historic bridges under 4(f) until 2008 (written 2007, effective 2008), nearly two years after the original Bridge of Lions had already been destroyed. Prior to that, the USDOT and DOI were split on whether 4(f) even applied to most bridges.

http://onlinepubs.trb.org/onlinepubs/archive/NotesDocs/25-25(19)_FR.pdf

Under the current guidelines, it appears questionable whether this project would have been approved. In order to replace rather than renovate a registered landmark bridge, the applying party must now show the bridge's design geometry is incurably deficient to handle projected traffic flow, or that any damage or defects are irreparable. The BOL, while in need of repair, was never argued to represent an incurably deficient design, nor by DOT's own admission was any damage or decay irreparable.

Under the current rules, the original Bridge of Lions would probably not have been replaced. Whether you could get around this by calling a replacement a rehabilitation or not is questionable, but that would seem unlikely under the guidelines where the original pier designs were unique, and where there is now a stated preference for the repair of historic materials vs. replacement except in the case of design insufficiencies or incurable defects, neither of which was ever alleged to be the case here.

I suppose it's a moot point, since these requirements didn't yet exist when the B.O.L. replacement happened. Also, since at this point I have to conclude that you and/or Dan must have some personal involvement in the project, given your defense of it in the face of all evidence to the contrary,  I'll say again: I LIKE THE NEW BRIDGE! I think it is quite a feat to have a new bridge that looks like an original 1920s Florida drawbridge. I wish they built every bridge like that.

I was never banging a preservation drum, this whole thing was your giant side-track to my original point, which was only that replacing a repairable bridge cost the taxpayers an extra $36mm by DOT's own admission, and the only possible justification for the additional expenditure would be if the finished product was more reliable and required less maintenance than it otherwise would have. My issue was that, despite going the extra mile, the new bridge has proven less reliable than the old one. We don't seem to be getting the benefit out of the extra investment, which makes one wonder whether we wasted $36mm.

[NthDegree]

Chris,

To the heart of the issue between us, as I understand it. Your position is that the bridge was "replaced" rather than "repaired."  My position is that neither of your stated terms apply (replaced, repaired) as per the standards and terms that all local, state and federal agencies use (acronym agencies).  Further, the Standards of Rehabilitation were applied in total and correctly. 

I have excerpted from the Final Environmental Impact Statement below (link provided). FDOT, FHWA, ACHP, SHPO and SOB all committed to the MOA.  All done according to law.         



http://www.partnershipborderstudy.com/bol_old/index.html

Section 7. Final Bridge of Lions Environmental Impact Statement

RECOMMENDATION

COMMITMENTS

The Florida Department of Transportation is committed to minimizing construction impacts to the historic Bridge of Lions, the lion statues, and the Bridge of Lions Park, as indicated in the Memorandum of Agreement (MOA) among FHWA, FDOT, The Advisory Council on Historic Preservation, and the SHPO. Steps to ensure this will be taken throughout the construction phase, and delineated in detail during the final design phase of this project. Such steps may include the following:

Recordation of the Structure: The FHWA and FDOT shall ensure that the appropriate recordation measures are carried out and accepted by the SHPO prior to any demolition, alteration, or rehabilitation activity affecting the Bridge of Lions or the marble lion statues. Plans, photograph documentation and written narrative must be consistent with the Level 2 documentation standards of the Historic American Building Survey (HABS) and Historic American Engineering Record (HAER).

Conservation of the Lion Statues: FHWA/FDOT will develop a restoration plan of the Lion statues in consultation with the SHPO. The plan will include a technical plan and information regarding the professional qualifications of the conservator, and stipulations for removal of the two Lion statues will prior to construction.

Archaeological Monitoring: FHWA/FDOT will ensure that particular care is taken during construction to avoid affecting any archeological remains that may be associated with the Trolley Station Archaeological Site (8SJ3312). Suitable arrangements for monitoring will be made in consultation with the SHPO prior to construction. Monitoring will be conducted by an archaeologist meeting the Secretary of Interior’s Professional Qualifications Standards for Archaeology ad will include recording and reporting major features or artifact concentrations uncovered and the recovery/duration of a sample of uncovered remains where practical. In the event that archaeological resources are discovered, the contractor will cease construction in the immediate area and proceed with consultation under 800.13 (b)(3).

Project and Design Review: FHWA/FDOT shall ensure that the project design for rehabilitation of the Bridge of Lions and all associated new construction are compatible with the historic and architectural qualities of the structure and are consistent with the Secretary of Interior’s Standards for Rehabilitation (36 CFR Section 67.7, Revised 1990), and that the design plans and documents for the project are developed in consultation and with and submitted to the SHPO for review and comment.

Project Review: FHWA/FDOT shall ensure that design documents and other appropriate representations for the rehabilitation of the bridge are provided to the SHPO for the review at the completion of 30%, 60%, 90% and 100% stages of the construction plans and documents.
top.gif (238 bytes)

 

RECOMMENDATION

As a result of the public hearing, environmental studies, and interagency coordination, the alternative recommended for Location/Design Concept Approval is Rehabilitation Option 1A. Option 1A will renovate major portions of the bridge in an attempt to minimize impacts to the historic nature of the structure. By maintaining the existing “charted” horizontal navigational clearance of 23.2 meters (76 feet), the existing bascule piers will be retained, thus allowing the bridge to remain listed on the National Register of Historic Places.

In addition to rehabilitating the Bridge of Lions, improvements will also be made to the bridge approaches. The bridge’s east approach will incorporate a northerly shift in the substandard horizontal alignment of Anastasia Boulevard. This modification would make the roadway curve approaching the bridge less sharp and thus safer for vehicular traffic. The intersection reconfiguration would involve creating intersections at St. Augustine Boulevard and Anastasia Boulevard, at St. Augustine Boulevard and Oglethorpe Boulevard, and require the permanent closure of access to Flagler Boulevard from Anastasia Boulevard. This improvement will increase safety, simplify traffic operations, and reduce motorist delay.

The use of a temporary bridge is required for the Preferred Option 1A to maintain traffic during construction. The temporary bridge's east approach will require temporary closure of access to St. Augustine Boulevard, Oglethorpe Boulevard, and Flagler Boulevard due to the tight horizontal alignment in relation to the existing streets.
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I appreciate all the work you have done to research the law on this. Its how issues like this are settled.  Knowing the process is time consuming but, it is the agreed upon law that binds us.     

[NthDegree]

Thanks for the link to Joe Pullaro's study.  He really keyed in on some of the difficulties associated with the decision making process for rehabilitation on historic bridges.  He would know. He was a consultant on the BOL for the FDOT.   

[ChriswUfGator]

Ah, I just noticed this post;

Ok, so I already stated that replacing a historical item with a copy that happens to use a few bits and pieces isn't my idea of preservation. You obviously have a different opinion.

actually it is the Interior Department that has a different opinion...and since they set the national standards on historic structures, I'm going with them

Gee-willikers, Tufsu! I'm so glad I have you here to educate me on this whole Dept. of Interior historic registry thingy, I'd never even heard of it before you were nice enough to clue me in. I mean, I might never have understood the criteria for listing or the guidelines for preservation, if it weren't for you taking the time to educate poor little ignorant me! You'll just have to forgive my awful ignorance, after all, what would I possibly know about this anyway?



 

[ChriswUfGator]

Chris,

To the heart of the issue between us, as I understand it. Your position is that the bridge was "replaced" rather than "repaired."  My position is that neither of your stated terms apply (replaced, repaired) as per the standards and terms that all local, state and federal agencies use (acronym agencies).  Further, the Standards of Rehabilitation were applied in total and correctly. 

I have excerpted from the Final Environmental Impact Statement below (link provided). FDOT, FHWA, ACHP, SHPO and SOB all committed to the MOA.  All done according to law.         



http://www.partnershipborderstudy.com/bol_old/index.html

Section 7. Final Bridge of Lions Environmental Impact Statement

RECOMMENDATION

COMMITMENTS

The Florida Department of Transportation is committed to minimizing construction impacts to the historic Bridge of Lions, the lion statues, and the Bridge of Lions Park, as indicated in the Memorandum of Agreement (MOA) among FHWA, FDOT, The Advisory Council on Historic Preservation, and the SHPO. Steps to ensure this will be taken throughout the construction phase, and delineated in detail during the final design phase of this project. Such steps may include the following:

Recordation of the Structure: The FHWA and FDOT shall ensure that the appropriate recordation measures are carried out and accepted by the SHPO prior to any demolition, alteration, or rehabilitation activity affecting the Bridge of Lions or the marble lion statues. Plans, photograph documentation and written narrative must be consistent with the Level 2 documentation standards of the Historic American Building Survey (HABS) and Historic American Engineering Record (HAER).

Conservation of the Lion Statues: FHWA/FDOT will develop a restoration plan of the Lion statues in consultation with the SHPO. The plan will include a technical plan and information regarding the professional qualifications of the conservator, and stipulations for removal of the two Lion statues will prior to construction.

Archaeological Monitoring: FHWA/FDOT will ensure that particular care is taken during construction to avoid affecting any archeological remains that may be associated with the Trolley Station Archaeological Site (8SJ3312). Suitable arrangements for monitoring will be made in consultation with the SHPO prior to construction. Monitoring will be conducted by an archaeologist meeting the Secretary of Interior’s Professional Qualifications Standards for Archaeology ad will include recording and reporting major features or artifact concentrations uncovered and the recovery/duration of a sample of uncovered remains where practical. In the event that archaeological resources are discovered, the contractor will cease construction in the immediate area and proceed with consultation under 800.13 (b)(3).

Project and Design Review: FHWA/FDOT shall ensure that the project design for rehabilitation of the Bridge of Lions and all associated new construction are compatible with the historic and architectural qualities of the structure and are consistent with the Secretary of Interior’s Standards for Rehabilitation (36 CFR Section 67.7, Revised 1990), and that the design plans and documents for the project are developed in consultation and with and submitted to the SHPO for review and comment.

Project Review: FHWA/FDOT shall ensure that design documents and other appropriate representations for the rehabilitation of the bridge are provided to the SHPO for the review at the completion of 30%, 60%, 90% and 100% stages of the construction plans and documents.
top.gif (238 bytes)

 

RECOMMENDATION

As a result of the public hearing, environmental studies, and interagency coordination, the alternative recommended for Location/Design Concept Approval is Rehabilitation Option 1A. Option 1A will renovate major portions of the bridge in an attempt to minimize impacts to the historic nature of the structure. By maintaining the existing “charted” horizontal navigational clearance of 23.2 meters (76 feet), the existing bascule piers will be retained, thus allowing the bridge to remain listed on the National Register of Historic Places.

In addition to rehabilitating the Bridge of Lions, improvements will also be made to the bridge approaches. The bridge’s east approach will incorporate a northerly shift in the substandard horizontal alignment of Anastasia Boulevard. This modification would make the roadway curve approaching the bridge less sharp and thus safer for vehicular traffic. The intersection reconfiguration would involve creating intersections at St. Augustine Boulevard and Anastasia Boulevard, at St. Augustine Boulevard and Oglethorpe Boulevard, and require the permanent closure of access to Flagler Boulevard from Anastasia Boulevard. This improvement will increase safety, simplify traffic operations, and reduce motorist delay.

The use of a temporary bridge is required for the Preferred Option 1A to maintain traffic during construction. The temporary bridge's east approach will require temporary closure of access to St. Augustine Boulevard, Oglethorpe Boulevard, and Flagler Boulevard due to the tight horizontal alignment in relation to the existing streets.
~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~

I appreciate all the work you have done to research the law on this. Its how issues like this are settled.  Knowing the process is time consuming but, it is the agreed upon law that binds us.     

Thank you for posting that, I appreciate it.

I have never said the project was illegal, just that it did not appear to comply with the preservation guidelines in replacing much of the original structure when the original bridge could have been repaired economically. It would be hard to say anything was done improperly, as the regulations concerning the preservation of historic bridges had only been adopted two years after the original bridge was already taken down, so there was no guideline to violate. I suppose the other thing that caught my attention here is that I feel the word "rehabilitation" in this case really meant "replacement" of virtually everything except the towers, lions, and apparently some of the steel arches, although those look slightly different than the originals to me, I guess they could be original but modified.

Anyway, given the choice, my personal preference is to repair what is there rather than build a copy, however nice a copy it may be. And this one, I completely agree, is a very nice one. It was just a bit mind-boggling to me, not being involved with this project, that doing what we did wound up being double the cost of fixing the original. Usually when you make the decision to gut a historic structure and start from scratch, it's because repairing the original is cost-prohibitive. But in this case, it was the reverse, keeping the original was cheaper by half. That combined with the seemingly endless series of reliability issues with the new machinery, had me thinking this might have been a waste of money.

I think we agree on the facts, we just disagree on the interpretation. I would have preferred the cheaper option to the taxpayer, and retaining an original historic structure (in that order), and you view this as an investment that will pay off with reduced maintenance costs and an extended future lifespan. So far that hasn't been the case, but I suppose they'll eventually get the kinks worked out and it will be fine. In any event, what's done is done, and I like the new brdge much much much better than what DOT originally proposed in the 1980s, which was a generic 4-lane concrete eyesore.

[NthDegree]

The steel arched girders are rehabilitated, or to use your term, repaired .

Early on the FDOT had said they were going to be replaced, which prompted the original claims that the rehab-ed bridge was going to be "90%" new materials.  Later they determined that the spans could be rehab-ed. 

They were trucked in segments to Plant City, restored and returned.  It was quite a sight to behold, those spans being trucked away. 

http://www.thebridgeoflions.org/art46.html 

     


 

[ChriswUfGator]

Here is what I was referring to; 36 CFR 67.7;

http://law.justia.com/cfr/title36/36-1.0.1.1.32.0.1.7.html

(2) The historic character of a property shall be retained and preserved. The removal of historic materials or alteration of features and spaces that characterize a property shall be avoided.

and;

(3) Each property shall be recognized as a physical record of its time, place, and use. Changes that create a false sense of historical development, such as adding conjectural features or architectural elements from other buildings, shall not be undertaken.

And;

(6) Deteriorated historic features shall be repaired rather than replaced.

And;

(9) New additions, exterior alterations, or related new construction shall not destroy historic materials that characterize the property.

And most importantly;

(d) In certain limited cases, it may be necessary to dismantle and rebuild portions of a certified historic structure to stabilize and repair weakened structural members and systems. In such cases, the Secretary will consider such extreme intervention as part of a certified rehabilitation if:
(1) The necessity for dismantling is justified in supporting documentation;
(2) Significant architectural features and overall design are retained; and
(3) Adequate historic materials are retained to maintain the architectural and historic integrity of the overall structure.

Here, we had a registered landmark that was economically repairable, but instead was demolished and certain sections were salvaged and reincorporated into the new structure. The prerequisite for any rehabilitation work of this nature is that repair, rather than a rehabilitation that replaces significant portions of the original structure must be economically infeasible, or in the case of a bridge after 2008, the structure must be a deficient design. Neither was the case here, where the cost of repair was half that of replacement.

So, given the scope of the work, wherein  nearly the entire structure was replaced, I was understandably having a difficult time figuring out how the guidelines coukd have possibly been followed, where they mandate that repair be economically infeasible before undertaking this scope of work on a registered landmark, and where repair was not only feasible, but was ackniwledged by DOT to be half the cost of replacing most of the structure, as is what happened.

Surely you can read the language in 36 CFR 67.7 and see the same issues I do. I get that the engineers and architects believe it complied, and I get that the ACHP signed off on it. But when you know the history and the scope of the work, and then compare that to the guidelines, there really seems to be a discrepancy in what happened here.

[ChriswUfGator]

The steel arched girders are rehabilitated, or to use your term, repaired .

Early on the FDOT had said they were going to be replaced, which prompted the original claims that the rehab-ed bridge was going to be "90%" new materials.  Later they determined that the spans could be rehab-ed. 

They were trucked in segments to Plant City, restored and returned.  It was quite a sight to behold, those spans being trucked away. 

http://www.thebridgeoflions.org/art46.html 

I don't favor the word "rehabilitated" because it is intentionally generic enough to encompass everything from replacing rusted rivets or repainting something to a complete demolition and replacement. The drafters of 36 CFR and 16 USC 470 really took the easy way out by selecting that term, instead of using commonly defined words. It would have been better for everyone had the line been a little brighter, But that certainly isn't your fault.

Regarding the arches, that's great they saved those, is it just me or did they lengthen those stanchions that stick off to the sides on the arches where the light poles were mounted?

[NthDegree]

Hope this helps answer some of your questions Chris.

http://www.youtube.com/watch?v=wX5YQn-PXjs&feature=player_embedded

[ChriswUfGator]

Hope this helps answer some of your questions Chris.

http://www.youtube.com/watch?v=wX5YQn-PXjs&feature=player_embedded

Well the time-lapse segment beginning around 2:00 certainly shows exactly how much of the historic material they left, doesn't it.

[tufsu1]

please do not question the attorney when it comes to engineering

[Non-RedNeck Westsider]

please do not question the attorney when it comes to engineering

or transit   

[Dashing Dan]

It all looks okay to me. 

They built a new bridge beneath the old one. 

The new bridge does the work and the old one is what people see.