16_CUVA_WRD-Letter_MM20_SOF_memo_Aug2024.docx
DOCX document 106 KB Posted
- Attached to
- CUVA 224822
- Solicitation number
- 140P2026R0093
About this file
This is a memorandum from the National Park Service Water Resources Division to the Cuyahoga Valley National Park (CUVA) Superintendent dated August 28, 2024, regarding concerns about the proposed riverbank stabilization project at Towpath MM20 along the Cuyahoga River in Ohio. The memo expresses significant environmental and safety concerns about the project design, noting that the proposed channel realignment may shorten channel length and reduce channel width, potentially increasing slope, flow velocities, or flood stage. The Water Resources Division identifies potential negative impacts including bed degradation, downstream bank erosion, and substrate grain size changes. Key issues cited include incomplete hydraulic analysis relying on estimated bathymetry without calibration or validation, making it impossible to adequately evaluate impacts to flood risk and visitor safety as required by Executive Orders 11988 and 13690 and Director's Order 77-2.
The memo additionally raises concerns that the Cuyahoga River segment is listed on the Nationwide Rivers Inventory with recognized values in fish, recreation, and scenic resources. The extensive proposed armoring is deemed incompatible with potential Wild and Scenic River designation. The Water Resources Division strongly encourages reevaluating alternatives, including relocating the towpath rather than implementing the proposed design, citing NPS Management Policies Section 4.6.6 which prioritizes avoiding impacts on watershed features and allowing natural fluvial processes to proceed unimpeded. The memo requests that if the project proceeds with armoring, justification be provided in the Wetlands and Floodplain Statements of Findings for not relocating approximately 500 feet of the towpath. Related federal contract solicitation 140P2026R0093 (CUVA 224822) has been issued for this stabilization work.
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Text version
United States Department of the Interior
NATIONAL PARK SERVICE
Water Resources Division 1201 Oak Ridge Drive, Suite 250 Fort Collins, CO 80525
VIA ELECTRONIC MAIL, NO HARD COPY TO FOLLOW
August 28, 2024 Memorandum
| To: | Lisa Petit, Superintendent, Cuyahoga Valley National Park |
| Through: | Mike Ward, Deputy Regional Director for Parks and Programs |
| From: | Forrest “Ed” Harvey, Chief, Water Resources Division |
| Subject: | Stabilize Riverbank at Towpath MM20 South along the Cuyahoga River Cuyahoga Valley National Park, Ohio |
The purpose of this memo is to highlight concerns about potential impacts to natural resources and public safety resulting from the proposed project at Towpath MM20 along the Cuyahoga River in CUVA. This project is part of a series of bank stabilization projects being undertaken at CUVA to address concerns related to bank erosion. Wetlands Statements of Findings (WSOF) and Floodplain Statements of Findings (FSOF) have been approved for projects occurring at several other sites. Details for the MM20 site, however, are concerning due to several aspects of the proposed design presented in the draft WSOF and FSOF. Specifically, the proposed channel realignment appears to shorten channel length and reduce channel width, potentially resulting in increased slope, flow velocities or flood stage, or a combination of the three. Potential impacts include bed degradation, adjustments in channel planform (e.g. bank erosion) downstream from the project site, and changes in substrate grain size distribution. Although a hydraulic analysis was performed to compare existing and proposed conditions, it relied on estimated channel bathymetry and appears not to have undergone calibration nor validation. Thus, it is not possible thoroughly evaluate impacts to flood risk and visitor safety, as is required by Executive Order (E.O.) 11988, E.O. 13690, and Director’s Order 77-2.
Moreover, this site is listed on the Nationwide Rivers Inventory (NRI), which is currently undergoing an update at the direction of NPS leadership. NPS and other federal agencies are required to manage NRI rivers in a way so as not to preclude Wild and Scenic River designation or affect river values. For the CUVA NRI segment, the rivers values are fish, recreation, and scenic. The proposed armoring project could adversely affect these values and the extensive hardening is incompatible with WSR designation.
We strongly encourage the project team to reevaluate alternatives, including relocating the towpath and discontinue efforts under the proposed design. As described in NPS Management Policies (2006), Section 4.6.6. Watershed and Stream Processes, “the Service will protect watershed and stream features primarily by avoiding impacts on watershed and riparian vegetation and by allowing natural fluvial processes to proceed unimpeded. When conflicts between infrastructure (such as bridges and pipeline crossings) and stream processes are unavoidable, NPS managers will first consider relocating or redesigning facilities rather than manipulating streams.” If the consensus is to continue with the armoring project, please provide justification for not relocating approximately 500 feet of the towpath in the WSOF and FSOF.
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MWR: Herbert Frost, Nancy Finley, James Lange, Hector Santiago DSC: Vicki Freese-Supler, Jason Longshore, NRSS WRD: Kevin Noon, Susannah Erwin image1.png image2.jpeg image3.jpeg
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