FfOR wrote to:
1) the RDC in April 2008 requesting discussion of the proposed Cobblestone Landing project
2) the Corps of Engineers in May 2009 requesting a public hearing on the project.
We have not yet received responses. Several people have asked for more information about those letters, so we have posted their text here for you to read.
April 21, 2008
Mr. John Conroy
Riverfront Development Corporation
22 N. Front Street, Suite
Memphis, TN 38103
Thank you for the invitation to discuss the preliminary concept design plan for the Cobblestone Landing on February 14. We also appreciate your providing printed copies of the power point presentation and have carefully reviewed it along with the December 1995 Garrow Cultural CRM Plan, Part 2 in which you participated.
As you know, Friends for Our Riverfront (FfOR) supports the goal of stabilization, restoration, and increased public use of the Cobblestone Landing. It is both the city’s historic and current riverboat landing and one of our most significant landmarks. Its location in the center of the waterfront’s lower level and adjacent to the historic core of downtown, makes the restoration and continued use of this area a key component in revitalizing the waterfront and downtown.
FfOR does not believe the currently proposed concept plan presents solutions and designs that will accomplish our mutual goal. The plan instead changes the use of the cobblestones by shoring the water’s edge in such a way as to prevent future use by boats, preventing vehicular access, relocating the Memphis Queen Lines, and proposing construction of Ron Terry Plaza on a section of the Cobblestones, all of which will have a cumulative adverse impact on the site.
We are glad that this plan is just in the preliminary phase and would very much like to work with you to formulate a concept design plan that will achieve the end goal of a restored landing and an active waterfront. We hope that the following comments can move us in that direction and would like to have the opportunity to meet with you and discuss them.
1) Working dock. The Cobblestone Landing has been in continuous use since the mid-1800s and should continue to be a working dock. The preliminary concept plan, however, makes no provision for continued boat use of the area. This is contrary to all recommendations and promises by the City since 1987 and will have an adverse effect on the Memphis Queen Riverboat, which is an historic property individually listed on the National Register and which has been docked there since the late 1940s. Design issues such as the addition and width of sidewalks, whether to include stepped areas at the base of the Cobblestones, etc. should be secondary to making sure the restored Cobblestone Landing accommodates boat use.
2) Stabilization of Landing. Stabilization and protection from further erosion is imperative. According to the Garrow Report cobblestones in this area originally extended to –3 on the river gauge. Restoration to +10 or +12 feet should be possible. An adequate vertical toe-wall should be constructed below this point to stabilize the western edge and prevent further erosion. The slope at the base of the Cobblestones should be consistent with that above water, and the material used should not negatively effect or prevent boat use of the area. Erosion resulting from water run-off along Riverside Drive also should be addressed. The wall was not correctly designed and is causing harm to the resource.
3)Materials. Historic cobbles should be re-laid whenever possible and every effort made to collect them from the harbor and city storage facilities. Any new material necessary for repair and in-fill to damaged sections of the landing should be natural limestone, not concrete, and should be clearly identifiable as added at this point in time.
4) Pedestrian Access. Once restored, the cobblestones should be at a consistent slope to encourage use of the area. If additional walkways are necessary they should be added above grade and the use of wood should be considered first. As a National Register listed structure, ADA accessibility can be modified and should be at the North and South ends of the Landing. A wooden floating dock should be provided for boats and for access to the boats. Temporary wooden platforms could be considered as gathering points.
5) Plaza. The design for Ron Terry Plaza should be reconsidered in light of the space already lost on the Cobblestone Landing (Garrow Report, page 17, item 6). The Plaza design, its bulk and height, are also inconsistent with the horizontality of the landing.
6) Vehicles. Beginning with mule drawn carts, vehicular access is historically accurate and should be allowed. It is a negative effect to turn the area into a barren rockscape. A lack of maintenance and erosion has harmed the resource, not vehicles.
7) Utilities. Decisions about appropriate lighting, the location of utilities, etc. should be carefully considered in terms of historicity and attractiveness.
8) Maintenance. On-going low-tech maintenance such as river water to clean the cobblestones after flooding should be planned and budgeted. Note the recommendation of weekly cleaning when the river is falling (Garrow Report, p.23). Removal of silt will lessen the amount of unwanted vegetation on the cobblestones.
9) Consultation. The Landing is one of our city’s oldest significant public spaces, and the public, especially riverfront users, should be involved in the actual formation of a concept upon which a design is based. A qualified architectural historian should also be involved in the process.
10) Landmark status. The historic structure/landscape is already listed on the National Register. As the last remaining intact wharf on the Mississippi River, its nomination for an upgrade to a National Historic Landmark designation, similar to Beale Street National Historic Landmark, should be pursued.
Thank you for your consideration, John. Please let me know when there is a convenient time for you to meet and discuss these comments in more detail.
President, Friends for Our Riverfront
May 6, 2009
Mr. Mitch Elcan
U. S. Army Corps of Engineers
167 N. Main Street, Room B-202
Memphis, TN 38103-1894
Re: Public Notice No: MVM-2009-093(jme)
Dear Mr. Elcan,
I am writing on behalf of Friends for Our Riverfront (FFOR), a 501(c)(3) organization, to request a public hearing on a permit request by the Riverfront Development Corporation (RDC) for a project misleadingly described as a “restoration” of the Memphis Cobblestone Landing.
FfOR supports the goal of preservation, restoration, and increased public use of the Cobblestone Landing. Used by Indians, French, Spanish, British, and early Americans, the river landing at Memphis was paved with cobblestones beginning in the 1850s. It has been in continuous use as a public boat landing for more than 150 years and is eligible to be a National Historic Landmark. Its location, in the center of the waterfront’s lower level and adjacent to the historic core of downtown, makes the restoration and continued use of this area a key component in revitalizing the waterfront and downtown.
Any changes to the landing must be consistent with its continued use as a public landing and its future as a National Historic Landmark.
Although the RDC project description defines the project as “restoration of Historic Cobblestone Landing,” as currently designed the project will use federal transportation funds to destroy the landing as a navigable site. Altering the landing’s slope and using riprap, a sidewalk, and steps to stabilize the bank not only ignores changing water levels but will negate future docking of watercraft. See, United States v. Schmitt, 999 F.Supp. 317, 370 (E.D.N .Y. 1998), aff’d 28 Fed.Appx. 63 (2nd Cir. 2002), holding that riprap constituted an obstruction to navigation in violation of the Rivers and Harbors Appropriation Act of 1899, 33 U.S.C. 403.
There are also serious concerns about the project’s negative impact of adding east-west sidewalks and its failure to plan for sustainable maintenance and corrections to current stormwater run-off problems necessary to improve water quality.
Currently listed on the National Register as part of the Cotton Row Historic District, any proposed alterations are subject to 4(f) review and are subject to the Rivers and Harbors Appropriation Act of 1899, the Clean Water Act, the National Historic Preservation Act, and the National Environmental Policy Act. A full Environmental Impact Statement is demanded before any permit is issued.
In 1995, as a result of the disturbance of the cobblestones without required federal permits, the City of Memphis, the Memphis District of the U. S. Corps of Engineers, the Tennessee State Historic Preservation Officer, and the national Advisory Council on Historic Preservation signed a Memorandum of Agreement. In it the City committed to prepare an assessment of the landing as a historic resource and “a preservation plan as a guide for the continued viability of the site.” The subsequent “Cultural Resource Assessment and Preservation Plan of January 1966” described the Cobblestone Landing as “perhaps the one historic resource in Memphis that best exemplifies the scope of the City’s history.” Since then the condition of the Cobblestone Landing has continued to be neglected and allowed to deteriorate by the City and by the RDC under contract with the City.
There has been no open public review of this project, and the views of the public should be essential to informed Federal decision making.
Because of the obvious adverse impact the current RDC proposal will have on the continued use of this historic site as a landing, FfOR urges the Corps of Engineers to open the process and receive public comment and input to develop an alternative design that will respect and preserve the use and historic significance of the Cobblestone Landing.
President, Friends for Our Riverfront
cc: Gary Fottrell, Federal Highways Administration, TN Division
Gerald F. Nicely, TN Dept. of Transportation
Jim Fyke, TN Dept. of Environment and Conservation
Patrick McIntyre, TN Historical Commission
Dick Tune, TN State Historic Preservation Officer
Dan Brown, TN Preservation Trust
John Eddins, Advisory Council on Historic Preservation