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Andy Eline53 E. Gatesaeline@columbus.rr.comColumbusOH
  
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Andy Eline53 E. Gatesaeline@columbus.rr.comColumbusOH
  
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Andy Eline53 E. Gatesaeline@columbus.rr.comColumbusoh43206
  
As a business owner on the near west side of Cleveland, we use the Innerbelt almost daily to access customers and suppliers in the Midtown area, as well as the near east side of town. I think eliminating existing access ramps in the Trench is a terrible idea. It will certainly cause us to burn more gas and slow down ,if not kill the business we do in that neighborhood. I have traveled the Innerbelt and I90 east to I271 during morning and afternoon rush hour for years, and find the drive from Deadman's Curve to I271 much more dangerous ( and delayed by accidents ) than what I encounter in the Trench.Clevelanders are smart enough to drive that section of road safely. Don't change it.
Michael Resch3900 Trent Ave.mresch@valvepros.comClevelandOh.44109
  
The innerbelt trench project that will eliminate the Carnegie and Prospect exits will cause massive back-ups. This is an ill conceived design and does not take into consideration the economic impact that this will cause to the businesses in the area. The problems this design will cause on the surface streets will be extensive. I realize that the trench portion of the project is about 10 years away. If the trench project moves forward as currently designed, I expect to be moving our business out ot the Midtown area. My company employees 128 persons and we expect to at least double employment by the start of this project. I firmly believe that your projections that the Chester exit will be handle the volume are totally inaccurate.
Dan Neubert2900 Carnegie  Avedneubert@1-888-ohiocomp.comClevelandOhio44115
  
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GarryZeroqtoRkKzpRewalk4@ya.ruYUMDpVVgurfljaqYaGNsdlwjlLXQEcKMkkGCLtb
  
As a business owner who depends on getting our delivery people as well as our employees in and out of downtown as quickly as possible, this plan makes absolutely no sense. Having no entrance to Carnegie will force my west side drivers and employees to exit at E. 22nd, and the backup due to the lack of other exits will add time to what is otherwise an easy and quick trip to our building on Carnegie. From the east the approach will be a complete disaster with only Chester available. The backup alone will be unprecedented, but the attempt to navigate the north/south city streets to Carnegie will be horrible. It already takes 10 minutes to get from Carnegie to Chester on the north/south streets because of the timing of the lights and the two lane streets. Forcing everyone off on Chester, even with additional north/south access will cause enormous back ups. God forbid there would be an accident or breakdown or heavy snowfall on the ramp! There is no one I've spoken with who believes this plan has any chance of being beneficial to the city. Most people are incredulous. The Innerbelt was designed to bring people into the city of Cleveland, not funnel them through and out. This plan will assure that there is no reason to come to downtown or midtown by the freeways, and people will stay away in droves, including employees. The State should be more interested in encouraging development in downtown and midtown Cleveland rather than stifling it. I realize that the Innerbelt as it is now does not conform to today's standard of highway construction or safety. It wasn't built today, the city wasn't built today, and the people who work, visit, and live here have become accustomed to the convenience of the Innerbelt as it is. We do not see safety issues as we do not see accidents on the Innerbelt. In fact we see more accidents at the corners of Carnegie and 30th and 36th than on the Innerbelt. You cannot plan in a vacuum. You must consider that a city has grown up around the Innerbelt as it is and to restrict access to that city will most certainly have the opposite effect; the city will shrink and quickly die. Please reconsider the plan for the Innerbelt and do not restrict or remove the existing entrances and exits. Thank you for your understanding.
Robert Lash2111 East 36 Streetrob@moskeydental.comClevelandOhio44115
  
As a business owner in the MidTown neighborhood, I am firmly against the closure of the Prospect and Carnegie exits. The amount of traffic that flows through these exits and onto side streets is vital to the commercial success of the area. As a business owner, I rely on these exits for multiple purposes including deliveries, client and employee routing. Closing them would have devastating economic consequences to the neighborhoods surrounding East of Downtown.
Jason Therrien3635 Perkins Ave.jason@thundertech.comClevelandOhio44114
  
In reviewing the plans for the complete reconstruction of the I-77/I-71/I-90 Central Interchange in Cleveland, it is hard to imagine that you are going to completely eliminate access to the center of downtown from those coming in from the south. But apparently that is your plan. Why would I even go downtown any more when I have to exit at East 30th Street? I'm certain I'm not the only one who feels this way. I'm also certain there are other parts of the plan that will have a negative economic impact on the area. Can ODOT even consider anything other than the flow of traffic? And who is calling for this major project? What is the impetus behind this massive waste of money?
Rick Stunek9985 Barr Rdrstunek@forbeschocolate.comBrecksvilleOH44141
  
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Sillana2HuQCTgplpvrMsRen67v@yahoo.comRTyFIRkoqydgWBgzFEYuHxABQewRRoWuDdvaYTLHSwBAuWY
  
Testing the form, with the new anti-spam filter
Andy Eline1980 W. Broad St.andy.eline@dot.state.oh.usColumbusOH43223
  
This is test by Michael Williams
Michael WilliamsCollaboration Groupmwillia3@dot.state.oh.usColumbusOH43223
  
Central Viaduct Bridge: This is the opportunity to make an architectural statement with a landmark bridge. Redefine the skyline with this new bridge. Don't look for an easy way out with a bland, non-descript bridge. Define the future of Cleveland with a well designed bridge that will be recognizable around the world.
David Furyes1436 Wyandotte Avetifosi@ameritech.netLakewoodOhio44107
  
Before you start such an extensive project like this, you should take into account the effect on businesses in the area. As experienced with the Euclid Avenue project, you know how many businesses were adversely affected. Some long-standing businesses went out of business due the the lack of accessibility because of the construction project of RTA. We are in tough economic times--you need to take this part into account, and allow for business relocation/ and or compensation! I am just a citizen, but you need to take this message in serious consideration. I would like to hear your thoughts on this. Sincerely, Arlene Olson
arlene olson66 maple cliff Drivearlene_olson@jumo.comAvon LakeOH44012
  
Cleveland needs a bridge that will put the city back on the map and that lets the rest of the country and world know that Cleveland is back. With a great innerbelt bridge and infrastructure, people and businesses will take more notice and invest in the city again. A superior bridge and innerbelt system can make Cleveland a national destination along with our new convention center and medical mart project. A Mediocre bridge will results in mediocre results, let's do something amazing with this project to prove our cities worth.
tonykajflkadjfla@aim.comohio44133
  
Closing the Carnegie and Prospect ramps will be detrimental to Midtown Cleveland. We have many clients come to the Kidney Foundation of Ohio office and closing the ramps will detour them from coming to our office and getting the help they need. If a clear cut route is not easy for them to access, many people will not come downtown.
Kelly Dowling2831 Prospect Avenuekdowling@kfohio.orgClevelandOhio44115
  
I think that the closing of the Carnegie and Prospects ramps will be to the detriment of the Mid-Town Corridor. We depend on these ramps to provide quick and easy access to not only our jobs, but to appointments in the ares. Shutting down these ramps will cause lost time due to further travel. I think that it is a very bad idea to close these ramps.
Brandi M. Leslie2831 Prospect Avenuebleslie@epilepsyinfo.orgClevelandOH44106
  
When will ODOT clean up all the trees and undergrowth along I-71 leading up to the innerbelt bridge? Theres garbage and trees and all kinds of overgrown mess along this stretch.
clevelandohio44113
  
Whatever design is chosen, please don't obstruct the view of the water and landscape from motorists. Without any mountains nearby, there are only a few expansive views motorists can enjoy -- and this is one of them. Cleveland's water views are a true value to the city, and they shouldn't be obfuscated by concrete walls or barely see-through screens. It would be a missed opportunity otherwise. From a psychological perspective, a bridge with a view presents an inviting, expansive city, whereas an enclosed, viewless bridge presents a city that is insular and antiquated. Choose a view! Thanks for listening. I'm a former Northeast Ohio resident, but travel to Cleveland often.
  
Building a new bridge of this magnitude is a once in a lifetime opportunity to leave an indelible mark on Cleveland. Please do everything you can to make sure it is aesthetically pleasing and a landmark that Northeast Ohio can be proud of. This particular bridge will be seen from every angle by both pedestrians as well as vehicle traffic. Cleveland has an eclectic mix of bridges that cross our beautiful river, so almost anything goes as long as it is unique. I like the idea of large sculptures or large steel arches to tie into our past. The key will be the attention to details and respecting how our community will interact with the bridge, both physically, visually and emotionally. Everyone traveling on I-90 east and west will use this new monument to the spirit of Cleveland. Let's make it something special.
Christopher Weigand8006 Summersweet Trailchrisweigand@roadrunner.comSagamore HillsOhio44067
  
Here are my thoughts and ideas about these 3 projects. Project #1: Opportunity Corridor: Problems: As every Clevelander knows who drives into downtown. I-90, 490, I-77, I-71 and The East/West Shore Way are a mad house during rush hour traffic. Not only are the downtown workers trying to go to and from work. But, we also have to contend with the out of state travelers and over the road truckers passing through our beautiful city. I think a Interstate Opportunity Corridor would serve the public better than a Boulevard. Here are some reasons why. 1. With The New Opportunity Boulevard. You have a lot of 490 traffic exiting at E 55th. I would think that that traffic would clog up a boulevard. ( Look at 55th and 490 now during rush hour. It's a traffic jam daily.). Plus a Opportunity Corridor Boulevard will end at University Circle. Thus, giving no access to points east. 2. Opening a Opportunity Corridor Boulevard does nothing to end the "Through Traffic" that travels through our downtown Interstate System. Choking it daily. Here is what I say we do with the Opportunity Corridor Project: I think by doing this. You will be solving other traffic flow problems into downtown. Extend I-490 along the old Northfolk Southern rail lines up behind University Circle. Then head north at the Old Conrail lines into Collinwood reconnecting at I-90 around the Eddy/ E. 152nd area. By creating a Interstate Opportunity Corridor up through University Circle and Collinwod back onto I-90. You would. 1. Be creating a downtown Cleveland bypass. That alone would alleviate "Through Traffic" along I-90, I-77, I-71 into downtown. 2. Be placing entrance/exit ramps at strategic points like University Circle. You would provide quicker emergency response times to the hospitals. 3. Be making it easier to access the museums and hospitals. Thus, creating new patients and foot traffic into the University Circle area. 4. Creating greater access to the east side cities. We all know. More foot traffic means more jobs. Which means more money in the depressed areas. Which means more future devolpement. (maybe that new medical mart?) Where do we get the land needed? The areas east of 55th along the tracks up through University Circle into Collinwood is very depressed right now. Crime ravages the neighborhoods daily. Foreclosures and abandoned property has made the areas blighted and unsafe. This is what I say we do to get the land needed. Instead of tearing down these foreclosed houses or having them go up in flames in different areas of the city. Why don't Cuyahoga County use their Land Bank to trade with people owning property needed for a Opportunity Interstate Corridor. Or, even have HUD involved on the land swaps. I'm sure alot of hard working families and senoirs would like to get out of the depressed and crime ridden areas of the east side for the greener pastures of the west. Of course, purchase or eminent domain those who do not want to play ball on the project. I really don't think a lot is needed to make this project work. Land is depressed and railway right a ways are already in the areas. If all else fails build a few tunnels and bridges. ------------------------------ Project #2: Replacement of the I-90 Bridge, I-71 and I-77 Ending at the new 490/90/Opportunity Corridor Who has seen the ugliness of the bridges of the i-90/I-71/I-490(s) into downtown from below? They are rusted and just plain out right an eyesore. I think they bring down the alour of the city How about when a accident on I-90 & I-71 east or west bound closes the lanes until emergency crews re-open the hiway. Or, How about trying to leave downtown during a blinding snow storm. This is what I say we do. Instead of I-90 running through downtown. 1. Have I-90 continue along the new I-490/I-71/I-77/Opportunity Corridor. (again alleviating downtown "Through Traffic" 2. Tear down the I-90 bridge(s) from the I-90/I-71Merge to dead man's curve. Fill in what's left over and reclaim the land for office buildings, parks or whatever. (no replacement bridge needed) 3. End I-71 and I-90 into the downtown area at the now present 490/I-90/I-71 merge. But, re-use the I-71/I-90 merge north to feed local traffic only onto Ontario street or other south western areas of the city. 4. Place strategic entrance/exit ramps to feed local traffic into the Steel Yard Commons/Tremont/West 14th and areas. 5. Extend East 9th and others south to the new 490/90/Opportunity Corridor and create entrance and exit ramps for said roads. (Sure we may have to drive a few more blocks. But, with traffic cops in downtown. Traffic flows in and out fine. It's the interstates that clog up.) 6. End I-77 at the new 490/90/Opportunity Corridor. Making I-77 north of 490/90 heavy vehicle traffic access into downtown.(18 wheelers, cranes & ect.). 7. Make everything else LOCAL traffic ONLY into downtown. No Need to go through downtown if "Through Traffic" can bypass the city using a new I-90/I-490/Opportunity Corridor. Leaving the other main routes open to local traffic. 8. Build new RTA Light Rail lines & Park & Ride lots around the SteelYard Commons Area. Hopefully, cutting down on the number of vehicles coming into downtown daily. Thus, bringing in more traffic to the Tremont and Steelyard Commons area. ---------------------- Project #3: West Shore Way Sewer Project and Boulevard. Ok, I just read in the past few weeks that. The city will be doing a study and replacement of sewer lines around the west Shore Way area. Effectlively closing lanes of the Shore Way. Why not start the Boulevard project as well? Why fix and pave everything after the sewer project is completed. Only, to rip it back up in a few years to make the Shore Way a boulevard? This is what I say we do: Wait till the new I-90/I-490/Opportunity Corridor is open then. 1. Do the Shore Way Sewer/Boulevard project's together. 2. End the west side Shore Way at west 3rd. Allowing for local traffic only to north western areas of downtown. 3. End the east side Shore Way at dead mans curve. Allowing for local traffic only to north eastern areas of downtown. ---------------- So, in closing. I think the Opportunity Project is the most important piece of the puzzle. Lets get it built and bypass downtown all together. Then the next piece of the puzzle, The I-90 bridge replacement and/or tear down. Then the next piece of the puzzle,- The Shore Way Sewer Project and Boulevard. After completion of all three projects, We will have 4 or 5 main arties ending into downtown. NOT passing through it. A New East and West Shore Way Boulevard. And a Opportunity Corridor bypassing downtown and giving access to University Circle Thank You, Chris Lebiedz (lee-bits) 216-341-5198
CHRIS LEBIEDZ3993 EAST 42ND STREETchristopherlebiedz@yahoo.comNEWBURGH HEIGHTSOHIO44105
  
Here are my thoughts and ideas about these 3 projects. Project #1: Opportunity Corridor: Problems: As every Clevelander knows who drives into downtown. I-90, 490, I-77, I-71 and The East/West Shore Way are a mad house during rush hour traffic. Not only are the downtown workers trying to go to and from work. But, we also have to contend with the out of state travelers and over the road truckers passing through our beautiful city. I think a Interstate Opportunity Corridor would serve the public better than a Boulevard. Here are some reasons why. 1. With The New Opportunity Boulevard. You have a lot of 490 traffic exiting at E 55th. I would think that that traffic would clog up a boulevard. ( Look at 55th and 490 now during rush hour. It's a traffic jam daily.). Plus a Opportunity Corridor Boulevard will end at University Circle. Thus, giving no access to points east. 2. Opening a Opportunity Corridor Boulevard does nothing to end the "Through Traffic" that travels through our downtown Interstate System. Choking it daily. Here is what I say we do with the Opportunity Corridor Project: I think by doing this. You will be solving other traffic flow problems into downtown. Extend I-490 along the old Northfolk Southern rail lines up behind University Circle. Then head north at the Old Conrail lines into Collinwood reconnecting at I-90 around the Eddy/ E. 152nd area. By creating a Interstate Opportunity Corridor up through University Circle and Collinwod back onto I-90. You would. 1. Be creating a downtown Cleveland bypass. That alone would alleviate "Through Traffic" along I-90, I-77, I-71 into downtown. 2. Be placing entrance/exit ramps at strategic points like University Circle. You would provide quicker emergency response times to the hospitals. 3. Be making it easier to access the museums and hospitals. Thus, creating new patients and foot traffic into the University Circle area. 4. Creating greater access to the east side cities. We all know. More foot traffic means more jobs. Which means more money in the depressed areas. Which means more future devolpement. (maybe that new medical mart?) Where do we get the land needed? The areas east of 55th along the tracks up through University Circle into Collinwood is very depressed right now. Crime ravages the neighborhoods daily. Foreclosures and abandoned property has made the areas blighted and unsafe. This is what I say we do to get the land needed. Instead of tearing down these foreclosed houses or having them go up in flames in different areas of the city. Why don't Cuyahoga County use their Land Bank to trade with people owning property needed for a Opportunity Interstate Corridor. Or, even have HUD involved on the land swaps. I'm sure alot of hard working families and senoirs would like to get out of the depressed and crime ridden areas of the east side for the greener pastures of the west. Of course, purchase or eminent domain those who do not want to play ball on the project. I really don't think a lot is needed to make this project work. Land is depressed and railway right a ways are already in the areas. If all else fails build a few tunnels and bridges. ------------------------------ Project #2: Replacement of the I-90 Bridge, I-71 and I-77 Ending at the new 490/90/Opportunity Corridor Who has seen the ugliness of the bridges of the i-90/I-71/I-490(s) into downtown from below? They are rusted and just plain out right an eyesore. I think they bring down the alour of the city How about when a accident on I-90 & I-71 east or west bound closes the lanes until emergency crews re-open the hiway. Or, How about trying to leave downtown during a blinding snow storm. This is what I say we do. Instead of I-90 running through downtown. 1. Have I-90 continue along the new I-490/I-71/I-77/Opportunity Corridor. (again alleviating downtown "Through Traffic" 2. Tear down the I-90 bridge(s) from the I-90/I-71Merge to dead man's curve. Fill in what's left over and reclaim the land for office buildings, parks or whatever. (no replacement bridge needed) 3. End I-71 and I-90 into the downtown area at the now present 490/I-90/I-71 merge. But, re-use the I-71/I-90 merge north to feed local traffic only onto Ontario street or other south western areas of the city. 4. Place strategic entrance/exit ramps to feed local traffic into the Steel Yard Commons/Tremont/West 14th and areas. 5. Extend East 9th and others south to the new 490/90/Opportunity Corridor and create entrance and exit ramps for said roads. (Sure we may have to drive a few more blocks. But, with traffic cops in downtown. Traffic flows in and out fine. It's the interstates that clog up.) 6. End I-77 at the new 490/90/Opportunity Corridor. Making I-77 north of 490/90 heavy vehicle traffic access into downtown.(18 wheelers, cranes & ect.). 7. Make everything else LOCAL traffic ONLY into downtown. No Need to go through downtown if "Through Traffic" can bypass the city using a new I-90/I-490/Opportunity Corridor. Leaving the other main routes open to local traffic. 8. Build new RTA Light Rail lines & Park & Ride lots around the SteelYard Commons Area. Hopefully, cutting down on the number of vehicles coming into downtown daily. Thus, bringing in more traffic to the Tremont and Steelyard Commons area. ---------------------- Project #3: West Shore Way Sewer Project and Boulevard. Ok, I just read in the past few weeks that. The city will be doing a study and replacement of sewer lines around the west Shore Way area. Effectlively closing lanes of the Shore Way. Why not start the Boulevard project as well? Why fix and pave everything after the sewer project is completed. Only, to rip it back up in a few years to make the Shore Way a boulevard? This is what I say we do: Wait till the new I-90/I-490/Opportunity Corridor is open then. 1. Do the Shore Way Sewer/Boulevard project's together. 2. End the west side Shore Way at west 3rd. Allowing for local traffic only to north western areas of downtown. 3. End the east side Shore Way at dead mans curve. Allowing for local traffic only to north eastern areas of downtown. ---------------- So, in closing. I think the Opportunity Project is the most important piece of the puzzle. Lets get it built and bypass downtown all together. Then the next piece of the puzzle, The I-90 bridge replacement and/or tear down. Then the next piece of the puzzle,- The Shore Way Sewer Project and Boulevard. After completion of all three projects, We will have 4 or 5 main arties ending into downtown. NOT passing through it. A New East and West Shore Way Boulevard. And a Opportunity Corridor bypassing downtown and giving access to University Circle Thank You, Chris Lebiedz (lee-bits) 216-341-5198
CHRIS LEBIEDZ3993 EAST 42ND STREETchristopherlebiedz@yahoo.comNEWBURGH HEIGHTSOHIO44105
  
Your plan to get rid of the Carnegie and Prospect Innerbelt exits/entrances is terrible. There are many owner occupied businesses and non profits that rely on easy access from the freeway. Getting off at E22 is difficult due to the extra lights and traffic. Going to Chester is worse due to the traffic and lights to get to Carnegie. Your plan will encourage businesses to move away from Cleveland. Business is based on how easy is it to get to the location. You will make it hard.
Rick Greiner31765 Burlwood Drrgreiner@sbcglobal.netSolonOH44139
  
The Innerbelt bridge need people work on now not later.. Put some people to work.. many birdge companys out thier are going under.. most bridge builder need work and they are union.. The steel mills and ford are done in this town..we soon we be a town were people travel threw not vist it.. Man up Odot and get on the state from reasearch to do bridge work... Get the goverment to pay for it.. tell them it going to fall down.. it is going to fall down if you do get on the job and get the job going..
rev will523 san't clairrevwill75@yahoo.comclevelandohio44070
  
Why not make a 2 level bridge, the upper level as a bypass over downtown and would funnel travic that just needs to travel from east to west side, or visa versa, without needing access to downtown exits. This would alleviate a lot of innerbelt congestion. We have a 271 bypass for the same reason & it does help.
Wendy Dalton5828 Clearview Drivewdrnc@cox.netParma HtsOhio44130
  
I have two Idea suggestions for the INNER belt Bridge design for your consideration. #1) for the Inner Belt Bridge my Design envisions the outer shoulder lane planted with vegetation. According to what I have read in the PD, that would entail going from 5 lanes of traffic to 4 or with the dual bridge completion 8 lanes of traffic instead of 10. Framing the roadbed with a garden landscape above the flats creates an elevated park that is an original concept for the bridge design to work with the chosen structural plan and provides Cleveland with a signature bridge design. Also the elevated park concept could introduce a pedestrian or bicycle lane aspect? But the main point is an opportunity to incorporate an elevated green space over the flats. Idea #2 Envisions an observation tower engineered at the center point of the completed bridge. The observation tower bridges over the bridge and thus creates a new icon of city center located in the flats. The observation tower creates a new nexus that invites a residential development possibilities on either side of the river. This concept creates a unifying symbol to "Bridge" the east/west identity divide...this concept could also become "the Sculptural Component"... a structure at the center point rising over the bridge, the mid-point joining the East and West.
Daniel Rothenfeld13401 Lakeshore Blvd#4wonderfeld@yahoo.comBratenahlOhio44110
  
Please make sure you add some of the design esthetics, is there any hope of some decking? Also I have some concern that the two bridges do not match in some respects. We seem to have to many varying design elements going on with the sound barriers and the colors on bridges. Can ODOT get some consistency and then maintain it across all areas? Any chance of working in irrigation systems for adjacent landscaping? As for some of the negativity, just shake your head do good job for us.
Michael Hirz16300 Van Aken mjhirz@ameritech.netShaker Heightsoh44120
  
Removal of the exit on I90 East to Carnegie Ave. is a serious mistake. It is one of the most vital arteries connecting to University Circle and the Heights areas. I along with a majority of motorists heading to those areas will be forced to exit on E22nd and go through 2 additional lights to get to Carnegie eastbound. This is ridiculous!!! The planners obviously do not live in the area or commute to University Circle or the Cleveland Clinic!!! If there are too many exits, eliminate the E 22nd exit instead. It is a much less traveled side street. Please take this suggestion seriously; you will be adding hours of commute time annual to those of us that travel to University Circle daily, as more congested interestions at E22nd (less safety). The Carnegie exit has always been one of the better planned exits that merges off slowly and always has been safe (unlike some that have sharp turns and short merge times). Please reconsider for us Clevelanders!!! Thanks. Your reply would be appreciated as well.
Patrick Paoletta1705 Cumberland Rd.patrick.paoletta@firstmerit.comCleveland HeightsOH44118
  
Low Sodium Diet for the innerbelt? I know we are 'Ohio Proud' to be using the massive amounts of salt that are being used, wouldn't it be better to putting moneys into a self contained steam deck heating system rather than apparence features such as tacky figurines? Just imagine on all the future repairs that could be saved, instead of putting it on a 'high sodium' diet every winter. I wonder how these costly figurines will look in 10 years standing proudly over crumbling concrete & rust... (Very appropriate for Cleveland?). By the time they get the second phase (replacing the existing bridge) of this finished, it will soon be time to start repairing (or rebuilding) the one they have yet to build... bad enough we have some of the worst roads in the country. (3 sets of ball joints, 3 wheel bearings, 2 pairs of shocks in 4 years?... yeah it keeps the economy rolling?) I currently live near Ohio 2, the salt runoff is leeching into my basement via the walls, floor & through the garage floor, destroying the concrete. Something that eats concrete like this really can't be good for the environment either.
Craig Rommeldesertfox3@netzero.netMentorOhio44060
  
The following comments were drafted by the NOACA Transportation/Water Quality Advisory Council (TRANSWAC)and approved for submission by The NOACA Transportation Advisory Committee (TAC). NOACA Transportation/Water Quality Advisory Council (TRANSWAC) Comments Concerning the Draft Innerbelt Environmental Impact Statement May 7, 2009 General Issues Given the significant amount of storm water from the proposed Innerbelt project that will discharge to Cleveland’s highly valued lakefront or to the Cuyahoga River, water resource impacts should be thoroughly explored in the Innerbelt Environmental Impact Statement (EIS) process. According to one ODOT estimate provided to the TRANSWAC committee, 33% of the drainage of the Innerbelt project (some 111 acres) goes directly to Lake Erie. A study prepared by TRANSWAC provides a literature review and summarizes local data to show the potential that storm water discharges from the project could violate Lake Erie water quality standards and add pollutant loads to the Cuyahoga River. The EIS should address the issues raised by the TRANSWAC report and its referenced technical documents and provide a full discussion of the current and potential water quality impacts of discharges from the Innerbelt facility. Particularly, ODOT and FHWA as lead agencies are encouraged to collaborate with the various cooperating and participating agencies of the EIS process to evaluate the issues which TRANSWAC has raised and to determine appropriate responses to mitigate water quality impacts. ODOT should collaborate with Ohio EPA to clearly explain the respective roles of storm water permits and water quality standards water quality in assuring project compliance with all water quality requirements of Ohio law. A commitment should be made to conduct an equivalent supplemental EIS review process in an extended time frame if the above processes cannot be completed with out causing a delay in the issuance of a final Environmental Impact Statement. Evidence exists that the existing Innerbelt discharge may have deleterious effects on the receiving waters of Lake Erie and the Cuyahoga River. Yet, current Ohio EPA storm water permits and the draft EIS would suggest that ODOT need only provide treatment for additional impermeable surfaces or newly separated storm water. As the Innerbelt project represents a total reconstruction, the EIS should consider the costs and benefits of providing storm water treatment for the entire project. Because of the potential water quality concerns, the need to be proactive in fully protecting Cleveland’s waterfront resource, and the unique opportunity that is attendant with a major reconstruction of drainage facilities, storm water management options should not be limited to ODOT’s standard list of Best Management Practices. (ODOT notes that their list of storm water quality Best Management Practices represents their process, which is meant to keep ODOT in compliance with existing Ohio EPA regulations. This BMP list includes: exfiltration trenches, extended detention and retention basins, bioretention cells, infiltration trenches, infiltration basins, constructed wetlands, manufactured systems, and vegetated biofilters.) The EIS should discuss the costs and benefits of the full range of storm water management options and establish a framework for the selection of options. This evaluation should include consideration of treatment of Innerbelt discharges in the Northeast Ohio Regional Sewer District’s central treatment facilities. The NOACA/TRANSWAC role as a participating agency should be clarified. The EIS should discuss the work of the TRANSWAC along side of other consulting committees in Chapter 5. The EIS should note and respond to issues of past TRANSWAC and TRANSWAC member comments provided in response to the Level 1 Ecological Survey, EIS scoping, and the Innerbelt Storm Water Best Management Report. Specific Comments 1) The issue of potential violations of Lake Erie water quality standards should be thoroughly discussed. Lacking more specific or more representative data, the data and findings previously provided by the TRANSWAC committee should be incorporated into this discussion. The EIS should describe the existing water quality issues of the near shore areas of Lake Erie and the expected impact of current and new discharges of Innerbelt storm water to Lake Erie near shore areas. ODOT should request that Ohio EPA and other agencies with water quality management responsibilities review this supplemental information to determine whether the final project discharges will comply with all water quality requirements of Ohio law. 2) The EIS should clearly state the estimated the amount and percentage of the Innerbelt runoff which currently discharges to Lake Erie, the Cuyahoga River, and the centralized treatment facilities of NEORSD. As available, the same estimates should be provided for Innerbelt drainage system after reconstruction. 3) The EIS should evaluate the potential to treat its Innerbelt direct storm water discharges as a move toward achievement of the TMDL targets set for the Cuyahoga River and current water quality standards. 4) The EIS should clearly explain the process for determining the current regulatory requirements for storm water discharges from the Innerbelt. This discussion should include an explanation of how requirements are determined where application of ODOT’s best management practices would still result in a violation of Ohio water quality standards. 5) The EIS should evaluate a wide range of options for treatment of storm water from the Innerbelt. This evaluation should include treatment of some or all of the Innerbelt discharge in NEORSD’s central treatment facility. This option should be considered as an alternative to the separation strategy that ODOT has discussed in the draft EIS. Other options beyond BMPs should also be considered. 6) The public record should acknowledge TRANSWAC’s request to ODOT and NEORSD to consider alternative ways to evaluate the cost and benefits of centralized treatment lacking a rate structure for treatment by NEORSD. 7) The EIS should acknowledge NEORSD’s letter of June 22, 2007 and consider the approach and data provided in that letter in assessing the costs and benefits of centralized treatment in NEORSD facilities. 8) The EIS should show pollutant loading changes that would occur as a result of the separation strategy proposed in the draft EIS. The EIS should estimate the additional storm water load that would be added to Lake Erie and to the Cuyahoga River. The potential for violations of water quality standards as a result of increased loads should be considered. To the extent that reductions in combined sewer loads are used as a justification for separation, planned improvements through NEORSD’s Long Term Control Plan should be considered. Additionally, consideration should be given to the cost effectiveness of sizing NEORSD facilities to accommodate ODOT’s loads. Example calculations on the impact of separation were provided to ODOT as part of TRANSWAC comments on ODOT’s Innerbelt BMP report. The calculations show that separation could result in greater loads to receiving waters. 9) The EIS should address the issue of the need to provide right of way space for the installation of Best Management Practices where applicable. 10) The EIS should address the issue that the project, as a total reconstruction of the Innerbelt, should consider options to provide treatment for 100% of the pavement of the project rather then simply providing treatment for newly paved or newly separated storm water. 11) The EIS should provide a responsiveness summary to indicate how it addressed comments made as a result of comments received on the Level 1 Ecological Survey and also on the Innerbelt Storm Water Best Management Practice report. 12) The EIS should discuss the development of project specific procurement specification for water quality issues and storm water management. Also, consideration should be given to the development of special allocations and contingency funds specific to water quality and storm water management issues. 13) The project’s Purpose and Need statement should be revised to make it clear that the Innerbelt project should consider and is expected to result in improved management of Innerbelt air quality and water quality environmental issues. 14) In its comments of March 20, 2006 TRANSWAC asked that the Innerbelt project consider designing elements of the drainage system to provide for hazardous spill containment and for precise measurement of storm water loads. The draft EIS does not discuss the containment of hazardous spills nor is there any pledge made to provide monitoring chambers to allow for precise measurement of future storm water loads. 15) FHWA and ODOT should meet with stakeholders and agencies interested in water quality and storm water management issues to solicit assistance and to consult on a schedule to address draft EIS deficiencies. These meetings should also discuss comprehensive EIS commitments to protect water quality and consider supplemental EIS processes to compensate for issues that can not be fully addressed in the next EIS document.
Andy Vidra1299 Superior Avenueavidra@hotmail.comClevelandOH44114
  
This submittal is an addendum to the comments submitted by the NOACA TRANSWAC. Accounting of Key Public Participation Dates and Products Relevant to Water Quality Protection and Stormwater Management Issues for the Cleveland Innerbelt Project –Includes Communication Efforts by TRANSWAC and TRANSWAC members Item Date Description Location in the Draft EIS.* 1 03/14/2003 NEORSD meeting with C. Hebebrand, ODOT; NEORSD identified water quality as a Innerbelt project concern and encouraged long range coordinated efforts via management of Innerbelt stormwater. Not referenced 2 04/03/2003 Email from Craig Hebebrand to L. Stumpe, NEORSD (assurance that the current goals of the Innerbelt project where inclusive of the goal “protect and enhance water quality”) Not referenced; copy of correspondence not provided in EIS appendices. 3 02/09/2004 Erwin Odeal, NEORSD, letter to ODOT (request that ODOT Innerbelt planning comprehensively consider stormwater management issues) Referenced in App. E; copy of correspondence not provided in EIS appendices. 4 03/20/2006 Key TRANSWAC Report identifying water quality concerns and identifying 11 issues that should be addressed in the planning process Referenced in App. E; copy of correspondence not provided in EIS appendices. 5 04/21/2006 ODOT statement on Innerbelt stormwater issues Referenced in App. E; copy of correspondence not provided in EIS appendices. 6 8/16/2006 Letter from D. Lastovka ODOT to F. Greenland NEORSD; Project assumptions identified. Question asked about ongoing fee for treatment under the option that ODOT would direct a first flush to NEORSD for treatment. Noted in Chapter 5, Referenced in App. E and copy of letter provided in EIS appendices 7 10/16/2006 Letter from F. Greenland, NEORSD to D. Lastovka, ODOT; stating that the District has not yet made a determination about the basic fee structure for the stormwater management program that NEORSD is developing Noted in Chapter 5, Referenced in App. E and copy of letter provided in EIS appendices 8 11/20/2006 Letter from D. Lastovka, ODOT to F. Greenland, NEORSD; ODOT expresses intent to investigate separation strategy where hydraulically appropriate. Noted in Chapter 5, Referenced in App. E and copy of letter provided in EIS appendices 9 01/12/2007 ODOT response to TRANSWAC’s 03/20/06 report Referenced in App. E copy of correspondence not provided in EIS appendices. 10 03/05/2007 L. Stumpe as TRANSWAC work group chair, comments on EIS scoping issues. Comments identify that ODOT’s formal response of 01/12/2007 do not address the issues of the 03/20/2006 repot by TRANSWAC for purposes of the EIS. Referenced as a public comment in Chapter 5; copy of cover letter correspondence is provided in EIS app. F. Comments and attachments requested to be made part of record are not included. 11 04/08/2007 L. Stumpe, Chair, Innerbelt TRANSWAC work group comments on Level I Ecological Survey Report. Particular note is made that the report fails to address Lake Erie impacts. Not referenced; copy of correspondence not provided in EIS appendices. 12 04/10/2007 NOACA/ TRANSWAC request to ODOT to include various analysis of stormwater management as a part of the EIS. Request for cost/benefit analysis of centralized treatment of first flush in NEORSD centralized facilities. Not referenced; copy of correspondence not provided in EIS appendices. 13 5/27/2007 Recap of 4/26/07 meeting between NEORSD and ODOT concerning collection system details. Not referenced; copy of correspondence not provided in EIS appendices. 14 5/29/2007 Letter from D. Lastovka, ODOT, to F. Greenland, NEORSD; recap of discussions of 4/26/07 meeting including information about specific CSO discharges Noted in Chapter 5, Referenced in App E and copy of letter provided in EIS appendices 15 06/22/2007 NEORSD letter to ODOT suggesting approach and cost data to assist in evaluation of cost and benefits of centralized treatment for first flush treatment option Not referenced; copy of correspondence not provided in EIS appendices. 16 07/25/2008 TRANSWAC comments on ODOT’s stormwater management BMP report Not referenced; copy of correspondence not provided in EIS appendices. * Presents or absence base upon a review of EIS compact disk provided by ODOT. Files of in participation appendices that cover correspondence dates were searched. (Appendices E&F) ** Table author --L Stumpe: 5/11/09
Andy Vidra614 Superior Avenueavidra@mpo.noaca.orgClevelandOH44114
  
May 18, 2009 Craig Hebebrand ODOT District 12 5500 Transportation Blvd. Garfield Heights, OH 44125 RE: Comments of Meagan Mauter on Draft EIS for the Cleveland Innerbelt Dear Craig: Thank you for the opportunity to provide comments on the draft Environmental Impact Statement (EIS) for the Innerbelt project. I have sought to investigate areas in which the subject EIS does not conform with the language of the NEPA statues. There are three key areas where the draft EIS conflicts with NEPA regulations. First, the draft EIS insufficiently addresses the impacts of the Innerbelt project on stormwater quality. Second, the draft EIS fails to investigate alternatives of stormwater management or present options for mitigating water quality impacts due to stormwater runoff. Finally, the draft EIS misrepresents or fails to document the extensive debate around issues of stormwater management and water quality protection that have already been raised during the project development phase. Because the draft EIS product seem to be in such substantial deviation from the NEPA statues I have sought clarification from both the Council on Environmental Quality and the Federal Department of Transportation. I have had the opportunity to review the draft EIS for the Cleveland Innerbelt project and particularly to focus on the issues of water quality protection and stormwater management. In this process I have reviewed the comments which were approved by the NOACA Transportation Advisory Committee. These comments cover a variety of Issues that should have been addressed in the draft EIS and certainly should be addressed in the final EIS. I have adopted and incorporated , sometimes with modification, many of the NOACA comments as my own. The third section of these comments includes a statement that I delivered to the NOACA Transportation Advisory Committee on 5/15/2009. This statement advocates for the adoption of the NOACA comments mentioned above by the TAC committee, as well as proposing environmental mediation as an avenue for ensuring the conclusion of the EIS process in a timely manner. I am asking that these comments be incorporated into the public record for this project. The final section of these comments is adapted from the section of the Council on Environmental Quality’s “Citizens Guide to NEPA” that addresses protocol for environmental mediation. I strongly encourage ODOT to adopt the environmental mediation process for this Innerbelt project and meet the environmental commitments outlined at the conclusion of these comments. Non-Compliance with NEPA regulations 1) The draft EIS fails to adequately address the impacts of stormwater discharge to near-shore areas of Lake Erie. NEPA regulations Sec. 1502.15 require discussion of the effected environment. Sec. 1502.15 Affected environment. The environmental impact statement shall succinctly describe the environment of the area(s) to be affected or created by the alternatives under consideration. The descriptions shall be no longer than is necessary to understand the effects of the alternatives. Data and analyses in a statement shall be commensurate with the importance of the impact, with less important material summarized, consolidated, or simply referenced. Agencies shall avoid useless bulk in statements and shall concentrate effort and attention on important issues. Verbose descriptions of the affected environment are themselves no measure of the adequacy of an environmental impact statement. Further, Section 1502.16 require analysis of the environmental consequences of the proposed action should the proposal be implemented. The discussion will include the environmental impacts of the alternatives including the proposed action, any adverse environmental effects which cannot be avoided should the proposal be implemented, the relationship between short-term uses of man's environment and the maintenance and enhancement of long-term productivity, and any irreversible or irretrievable commitments of resources which would be involved in the proposal should it be implemented. Section 1502.16 lists eight mandatory areas of discussion, including point (h) (h) Means to mitigate adverse environmental impacts (if not fully covered under Sec. 1502.14(f)). 2) The draft EIS fails to investigate alternatives of stormwater management or present options for mitigating water quality impacts due to stormwater runoff. In addition to the NEPA statues cited above, The Council on Environmental Quality has provided additional guidance that suggests that alternative for mitigation for environmental impacts should be discussed in the EIS. Specifically in a document entitled “NEPA’s Forty Most Asked Questions” a response is provide for the question of the scope of mitigation measures that must be discussed in an EIS. The answer quoted is as follows: “The mitigation measures discussed in an EIS must cover the range of impacts of the proposal. The measures must include such things as design alternatives that would decrease pollution emissions, construction impacts, esthetic intrusions, as well as relocation assistance, possible land use controls that could be enacted, and other possible efforts. Mitigation measures must be considered even for impacts that by themselves would not be considered “significant.” Once the proposal itself if considered as a whole to have significant effects, all of its specific effects on the environment (whether or not “significant”) must be considered, and mitigation measures must be developed where it is feasible to do so.” Sections 1502.14(f), 1502.16(h) and 1508.14 of the Environmental Quality Improvement Act of 1970 are cited in support of the answer. The deficiencies of discussion around stormwater management are detailed in subsequent sections of these draft EIS comments. 3) The draft EIS misrepresents or fails to document the extensive debate around issues of stormwater management and water quality protection that have already been raised during the project development phase. The requirements for such reporting are included in Sec. 102 [42 USC 4332] of Title I of the NEPA act. Prior to making any detailed statement, the responsible Federal official shall consult with and obtain the comments of any Federal agency which has jurisdiction by law or special expertise with respect to any environmental impact involved. Copies of such statement and the comments and views of the appropriate Federal, State, and local agencies, which are authorized to develop and enforce environmental standards, shall be made available to the President, the Council on Environmental Quality and to the public as provided by section 552 of title 5, United States Code, and shall accompany the proposal through the existing agency review processes; … if there is any disagreement on such impacts, [the responsible officials are required to] prepare a written assessment of such impacts and views for incorporation into such detailed statement. By not documenting local concerns around the impact of this Innerbelt project to stormwater quality and stormwater management issues, the draft EIS may have limited the discussion and consideration of design alternatives by other cooperating agencies on the State and Federal levels. Furthermore, inadequate documentation may have inhibited the ability of the local public to become aware of environmental issues and design alternatives surrounding stormwater management. I expect reporting requirements on the Final EIS to comply with regulations for documenting public comments as outlined in CEQ NEPA Regulations, 40 C.F.R. §§ 1501.4(b), 1506.6(b) and CEQ NEPA Regulations, 40 C.F.R. §§ 1506.6, 1508.10. NOACA Comments, Adopted As My Own: Given the significant amount of storm water from the proposed Innerbelt project that will discharge to Cleveland’s highly valued lakefront or to the Cuyahoga River, water resource impacts should be thoroughly explored in the Innerbelt Environmental Impact Statement (EIS) process. According to one ODOT estimate provided to the TRANSWAC committee, 33% of the drainage of the Innerbelt project (some 111 acres) goes directly to Lake Erie. A study prepared by TRANSWAC provides a literature review and summarizes local data to show the potential that storm water discharges from the project could violate Lake Erie water quality standards and add pollutant loads to the Cuyahoga River. The EIS should address the issues raised by the TRANSWAC report and its referenced technical documents and provide a full discussion of the current and potential water quality impacts of discharges from the Innerbelt facility. Particularly, ODOT and FHWA as lead agencies are encouraged to collaborate with the various cooperating and participating agencies of the EIS process to evaluate the issues which TRANSWAC has raised and to determine appropriate responses to mitigate water quality impacts. ODOT should collaborate with Ohio EPA to clearly explain the respective roles of storm water permits and water quality standards water quality in assuring project compliance with all water quality requirements of Ohio law. A commitment should be made to conduct an equivalent supplemental EIS review process in an extended time frame if the above processes cannot be completed with out causing a delay in the issuance of a final Environmental Impact Statement. Evidence exists that the existing Innerbelt discharge may have deleterious effects on the receiving waters of Lake Erie and the Cuyahoga River. Yet, current Ohio EPA storm water permits and the draft EIS would suggest that ODOT need only provide treatment for additional impermeable surfaces or newly separated storm water. As the Innerbelt project represents a total reconstruction, the EIS should consider the costs and benefits of providing storm water treatment for the entire project. Because of the potential water quality concerns, the need to be proactive in fully protecting Cleveland’s waterfront resource, and the unique opportunity that is attendant with a major reconstruction of drainage facilities, storm water management options should not be limited to ODOT’s standard list of Best Management Practices. (ODOT notes that their list of storm water quality Best Management Practices represents their process, which is meant to keep ODOT in compliance with existing Ohio EPA regulations. This BMP list includes: exfiltration trenches, extended detention and retention basins, bioretention cells, infiltration trenches, infiltration basins, constructed wetlands, manufactured systems, and vegetated biofilters.) The EIS should discuss the costs and benefits of the full range of storm water management options and establish a framework for the selection of options. This evaluation should include consideration of treatment of Innerbelt discharges in the Northeast Ohio Regional Sewer District’s central treatment facilities. The NOACA/TRANSWAC role as a participating agency should be clarified. The EIS should discuss the work of the TRANSWAC along side of other consulting committees in Chapter 5. The EIS should note and respond to issues of past TRANSWAC and TRANSWAC member comments provided in response to the Level 1 Ecological Survey, EIS scoping, and the Innerbelt Storm Water Best Management Report. Specific Comments 1) The issue of potential violations of Lake Erie water quality standards should be thoroughly discussed. Lacking more specific or more representative data, the data and findings previously provided by the TRANSWAC committee should be incorporated into this discussion. The EIS should describe the existing water quality issues of the near shore areas of Lake Erie and the expected impact of current and new discharges of Innerbelt storm water to Lake Erie near shore areas. ODOT should request that Ohio EPA and other agencies with water quality management responsibilities review this supplemental information to determine whether the final project discharges will comply with all water quality requirements of Ohio law. 2) The EIS should clearly state the estimated the amount and percentage of the Innerbelt runoff which currently discharges to Lake Erie, the Cuyahoga River, and the centralized treatment facilities of NEORSD. As available, the same estimates should be provided for Innerbelt drainage system after reconstruction. 3) The EIS should evaluate the potential to treat its Innerbelt direct storm water discharges as a move toward achievement of the TMDL targets set for the Cuyahoga River and current water quality standards. 4) The EIS should clearly explain the process for determining the current regulatory requirements for storm water discharges from the Innerbelt. This discussion should include an explanation of how requirements are determined where application of ODOT’s best management practices would still result in a violation of Ohio water quality standards. 5) The EIS should evaluate a wide range of options for treatment of storm water from the Innerbelt. This evaluation should include treatment of some or all of the Innerbelt discharge in NEORSD’s central treatment facility. This option should be considered as an alternative to the separation strategy that ODOT has discussed in the draft EIS. Other options beyond BMPs should also be considered. 6) The public record should acknowledge TRANSWAC’s request to ODOT and NEORSD to consider alternative ways to evaluate the cost and benefits of centralized treatment lacking a rate structure for treatment by NEORSD. 7) The EIS should acknowledge NEORSD’s letter of June 22, 2007 and consider the approach and data provided in that letter in assessing the costs and benefits of centralized treatment in NEORSD facilities. 8) The EIS should show pollutant loading changes that would occur as a result of the separation strategy proposed in the draft EIS. The EIS should estimate the additional storm water load that would be added to Lake Erie and to the Cuyahoga River. The potential for violations of water quality standards as a result of increased loads should be considered. To the extent that reductions in combined sewer loads are used as a justification for separation, planned improvements through NEORSD’s Long Term Control Plan should be considered. Additionally, consideration should be given to the cost effectiveness of sizing NEORSD facilities to accommodate ODOT’s loads. Example calculations on the impact of separation were provided to ODOT as part of TRANSWAC comments on ODOT’s Innerbelt BMP report. The calculations show that separation could result in greater loads to receiving waters. 9) The EIS should address the issue of the need to provide right of way space for the installation of Best Management Practices where applicable. 10) The EIS should address the issue that the project, as a total reconstruction of the Innerbelt, should consider options to provide treatment for 100% of the pavement of the project rather then simply providing treatment for newly paved or newly separated storm water. 11) The EIS should provide a responsiveness summary to indicate how it addressed comments made as a result of comments received on the Level 1 Ecological Survey and also on the Innerbelt Storm Water Best Management Practice report. 12) The EIS should discuss the development of project specific procurement specification for water quality issues and storm water management. Also, consideration should be given to the development of special allocations and contingency funds specific to water quality and storm water management issues. 13) The project’s Purpose and Need statement should be revised to make it clear that the Innerbelt project should consider and is expected to result in improved management of Innerbelt air quality and water quality environmental issues. 14) In its comments of March 20, 2006 TRANSWAC asked that the Innerbelt project consider designing elements of the drainage system to provide for hazardous spill containment and for precise measurement of storm water loads. The draft EIS does not discuss the containment of hazardous spills nor is there any pledge made to provide monitoring chambers to allow for precise measurement of future storm water loads. 15) FHWA and ODOT should meet with stakeholders and agencies interested in water quality and storm water management issues to solicit assistance and to consult on a schedule to address draft EIS deficiencies. These meetings should also discuss comprehensive EIS commitments to protect water quality and consider supplemental EIS processes to compensate for issues that can not be fully addressed in the next EIS document. Personal Statement to the NOACA Transportation Advisory Committee on 5/15/2009 Submitted as Comments to thee Draft EIS First I would like to thank Chairman Gils and the rest of the NOACA TAC committee for allowing me to provide a comment concerning transportation and water quality. My name is Meagan Mauter and I am a native Clevelander currently pursing a doctorial degree in Environmental Engineering at Yale University. This summer I decided to return to Cleveland to work on developing a consortium of organizations researching urban ecology and biophilic urban design. We will be applying for federal grant money to fund this research, and given my interest and expertise in water quality and public policy, I will be advising the center’s research in these areas. In this capacity, and I currently volunteering with the GCBL institute to investigate stormwater management for the Cleveland Innerbelt project. As I familiarized myself with the interstate development project as a model of transportation planning in NE Ohio, I became concerned about the manner in which stormwater management is being addressed in the Environmental Impact statement process. I am aware that one of the items on your agenda today deals with the submission of comments on the Innerbelt draft EIS, and Andy Vidra of the NOACA staff was kind enough to provide me a copy of this document. Although I am new to this debate, I would like to share some of my thoughts on this issue. I will begin my comments from the perspective of an environmental engineer, but I will conclude on a more personal note as a young professional considering whether to re-establish roots in the Cleveland community. As an environmental engineer familiar with the EIS process, I am concerned that the draft EIS statement 1) insufficiently addresses the impacts of the Innerbelt project on stormwater quality and fails to present options for mitigating these impacts 2) misrepresents or fails to document the extensive debate around issues of stormwater management and water quality protection that have already been raised during the project development phase. Chapter 4 of the draft EIS purports to discuss environmental impacts to aquatic resources and stormwater quality. Chapter 4 asserts that the proposed plan has no anticipated impact on stream or lake water quality. Yet, according to one ODOT estimate provided to the TRANSWAC committee, 33% of the drainage of the Innerbelt project (some 111 acres) goes directly to Lake Erie. Given the large drainage area and the high-traffic volume anticipated on the Innerbelt, I find it surprising that ODOT would not make a more substantial effort in evaluating the environmental impacts on water quality. The stormwater section, in particular, inadequately addresses feasible design alternatives and any improvement to water quality stemming from these design alternatives. There is no mention of the design alternative in which stormwater run-off is treated using conventional wastewater treatment techniques. The draft EIS mentions the possibility of a storm water separation strategy but neglects to evaluate how the implementation of such a system would alter stormwater quality and aquatic resources. My understanding is that EISs are required by law to address all feasible design alternatives and the environmental impact associated with each of these alternatives. Finally, ODOT mentions that best management practices (BMPs) will provide guidance in project design. I am concerned that these BMPs alone are insufficient to protect water quality, and that by simply defaulting to BMPs ODOT is avoiding their responsibility to thoroughly and publicly weigh impacts associated with different design alternatives. This brings me to my second issue with the EIS statement, namely that Chapter 5 of the draft EIS fails to adequately document significant discussions of water quality and stormwater management issues raised during the design phase. Judging solely from the TRANSWAC comments up for approval today, it appears that there have been a number of discussions around stormwater quality issues that are not noted in a section specifically dedicated to summarizing the public record. The purpose of this section is both to document discussion and debate for decision purposes, as well as to help people (like myself), who wish to learn about and weight in on the project. The comments up to this point represent my opinion as an environmental engineer, as well as the opinions of Green City Blue Lake who I am representing here today. In addition to concern over water quality issues, GCBL is frustrated by the failure of ODOT to analyze strategies to reduce traffic demand as part of the alternative analysis for the Innerbelt project. Also of concern is the failure of the project to provide for the significant integration of bicycle paths as part of the Innerbelt project. My next comments will be given wearing the hat of a young professional contemplating establishing a career and sinking roots into this community. As I interviewed for jobs in Cleveland this past spring I was struck by the number of organizations committed to advancing sustainability in their sector of business or community development. Much of my work this summer will be in helping to pull these many organizations together under an umbrella center to look closely at urban ecology in a shrinking urban center. My personal belief is that reversing perceptions of Cleveland as a polluted city on a burning river is a critical first step in reducing urban flight and attracting young, environmentally conscious people to the Northeast Ohio. I hope that City leaders understand the intimate connection between water quality and public health, lakefront property values, and regional identity. As NOACA committee members you have a role both in ensuring that region’s transportation needs are met AND in stewarding projects that protect the environment and promote a new era of sustainable design. I am not yet convinced that area leaders fully understand the connections between environmental sustainability and population sustainability in the region. I have reviewed the comments that your TRANSWAC group has recommended and I strongly agree that these critical issues should be addressed in the final EIS. Of broader concern to me is the disturbing question of why these issues were not more thoroughly addressed in the draft EIS. Given the importance of the Innerbelt project and the importance of environmental protection and sustainability to the Cleveland area, I am wondering if there are additional steps that could be taken to avoid setting up a win/lose conflict, particularly in light of short timeline for stimulus package funding available for this project? How can we ensure that the final EIS is responsive to substantive environmental issues? The possibility of engaging in the process of environmental mediation involving a neutral but NEPA experienced third party is one alternative. The Environmental Law and Policy center in Chicago, for example, would be a qualified organization. The U. S. Institute for Environmental Conflict Resolution is another source recommended as an environmental mediator in the Citizen guide to the NEPA process. So again, I strongly recommend the TRANSWAC comments for adoption by the committee, but also encourage NOACA to consider the additional step of engaging with ODOT and FHWA in a process of environmental mediation. Some of the apparent conflicts seem to be resolvable disagreements over what the NEPA statues require be considered in an EIS. I suggest that this is a reasonable step to avoid the potential future scenario of a challenge to a final environmental impact statement that could potentially delay this critical project. I appreciate your allowing me to share my thoughts with this committee. Thank you From The Council on Environmental Quality’s “Citizens Guide to NEPA”: Third Party Environmental Mediation Given the importance of the Innerbelt project and the importance of environmental protection and sustainability to the Cleveland area, and particularly in light of short timeline for stimulus package funding available for this project, I propose the process of third party environmental mediation for the Innerbelt project. If, for some reason, you believe that the process ahead may be particularly contentious or challenging, given a past history of community conflict or deeply divided interests, consider raising with the lead agency the possibility of designing a collaborative process with outside assistance. One source of such assistance is the U.S. Institute for Environmental Conflict Resolution. Located in Tucson, Arizona, as part of the Morris K. Udall Foundation, the Institute is a Federal entity that offers neutral environmental conflict resolution design, facilitation, education, training, and mediation. Anyone, whether in or out of government, can call the Institute and ask to speak to a professional staff person to discuss the potential for the Institute’s involvement in a proposed federal action. Expected Commitments in the Final EIS Environmental commitments are a way to address the significant gap in environmental impact assessment and analysis work remaining to fulfill the requirements of the NEPA process given the short time frame for the production of a final EIS. The development of environmental commitments would best be accomplished via a third party mediation process. Issues that must be addressed include scope and schedule for: 1) Assessment of existing water quality conditions of near shore areas of Lake Erie and the Cuyahoga River. 2) Conduct quantitative sampling and data analysis, along side a review of existing scientific literature, to determine likely Innerbelt stormwater quality characteristics. 3) Development of stormwater management alternatives. 4) Cost-Benefit analysis of stormwater treatment options. 5) Commitment to ongoing research to develop improved stormwater BMPs that address the specific water quality issues of Innerbelt runoff. Thank you for the opportunity to submit comments. Respectfully, Meagan S. Mauter, M.E.E., M.S., M.Phil. Ph.D. Candidate in Environmental Engineering Yale University 3044 Corydon Rd. Cleveland Hts., OH 44118 meagan.mauter@yale.edu
Meagan Mauter3044 Corydon Rd.meagan.mauter@yale.eduCleveland Hts.OH44118
  
This attachment contains all documents referred to in the NOACA TRANSWAC submittal of May 19, 2009. Accounting of Key Public Participation Dates and Products Relevant to Water Quality Protection and Stormwater Management Issues for the Cleveland Innerbelt Project – Includes Communication Efforts by TRANSWAC and TRANSWAC members Item Original Date Description Location in the Draft EIS.* 1 03/14/2003 NEORSD meeting with C. Hebebrand, ODOT; NEORSD identified water quality as a Innerbelt project concern and encouraged long range coordinated efforts via management of Innerbelt stormwater. Not referenced 2 04/03/2003 Email from Craig Hebebrand to L. Stumpe, NEORSD (assurance that the current goals of the Innerbelt project where inclusive of the goal “protect and enhance water quality”) Not referenced; copy of correspondence not provided in EIS appendices. 3 Resubmitted as comment on Draft EIS 02/09/2004 Erwin Odeal, NEORSD, letter to ODOT (request that ODOT Innerbelt planning comprehensively consider stormwater management issues) Referenced in App. E; copy of correspondence not provided in EIS appendices. 4 Resubmitted as comment on Draft EIS 03/20/2006 Key TRANSWAC Report identifying water quality concerns and identifying 11 issues that should be addressed in the planning process Referenced in App. E; copy of correspondence not provided in EIS appendices. 5 04/21/2006 ODOT statement on Innerbelt stormwater issues Referenced in App. E; copy of correspondence not provided in EIS appendices. 6 8/16/2006 Letter from D. Lastovka ODOT to F. Greenland NEORSD; Project assumptions identified. Noted in Chapter 5, Referenced in App. E and copy of letter provided in EIS 1 of 80 Question asked about ongoing fee for treatment under the option that ODOT would direct a first flush to NEORSD for treatment. appendices 7 10/16/2006 Letter from F. Greenland, NEORSD to D. Lastovka, ODOT; stating that the District has not yet made a determination about the basic fee structure for the stormwater management program that NEORSD is developing Noted in Chapter 5, Referenced in App. E and copy of letter provided in EIS appendices 8 11/20/2006 Letter from D. Lastovka, ODOT to F. Greenland, NEORSD; ODOT expresses intent to investigate separation strategy where hydraulically appropriate. Noted in Chapter 5, Referenced in App. E and copy of letter provided in EIS appendices 9 01/12/2007 ODOT response to TRANSWAC’s 03/20/06 report Referenced in App. E copy of correspondence not provided in EIS appendices. 10 Resubmitted as comment on Draft EIS 03/05/2007 L. Stumpe as TRANSWAC work group chair, comments on EIS scoping issues. Comments identify that ODOT’s formal response of 01/12/2007 do not address the issues of the 03/20/2006 repot by TRANSWAC for purposes of the EIS. Referenced as a public comment in Chapter 5; copy of cover letter correspondence is provided in EIS app. F. Comments and attachments requested to be made part of record are not included. 11 Resubmitted as comment on Draft EIS 04/08/2007 L. Stumpe, Chair, Innerbelt TRANSWAC work group comments on Level I Ecological Survey Report. Particular note is made that the report fails to address Lake Erie impacts. Not referenced; copy of correspondence not provided in EIS appendices. 2 of 80 12 Resubmitted as comment on Draft EIS 04/10/2007 NOACA/ TRANSWAC request to ODOT to include various analysis of stormwater management as a part of the EIS. Request for cost/benefit analysis of centralized treatment of first flush in NEORSD centralized facilities. Not referenced; copy of correspondence not provided in EIS appendices. 13 5/29/2007 Letter from D. Lastovka, ODOT, to F. Greenland, NEORSD; recap of discussions of 4/26/07 meeting including information about specific CSO discharges Noted in Chapter 5, Referenced in App E and copy of letter provided in EIS appendices 14 Resubmitted as comment on Draft EIS 06/22/2007 NEORSD letter to ODOT suggesting approach and cost data to assist in evaluation of cost and benefits of centralized treatment for first flush treatment option Not referenced; copy of correspondence not provided in EIS appendices. 15 Resubmitted as comment on Draft EIS 07/25/2008 TRANSWAC comments on ODOT’s stormwater management BMP report Not referenced; copy of correspondence not provided in EIS appendices. * Presents or absence base upon a review of EIS compact disk provided by ODOT. File folders in participation appendices that cover correspondence dates were searched. (Draft EIS Appendices E&F) ** Table author --L Stumpe: 5/11/09, minor corrections 5/19/09 3 of 80 4 of 80 5 of 80 See attached document relative to my thoughts on an environmental goal. Lester Stumpe Manager of Watershed Programs, Policy and Technical Support Phone: 216-881-6600 Ext. 830 Fax: 216-881-6603 Email: stumpeL@neorsd.org >>> "Craig Hebebrand" 03/19/03 09:43AM >>> Lester, At the March 10, 2003 Scoping Committee meeting you suggested that consideration be given to modifying the Goals and Objectives to specifically include Water Quality. While the Goal and Objectives for the Cleveland Innerbelt Study do not specifically mention Water Quality, they do include (see below) the broader objective to "preserve and enhance the natural environment." Please advise if you consider this more general objective to be sufficient to address your concerns. If not, I would ask you to offer a proposal to revise the Goals & Objectives. Goal V Environment Environmental impacts are often considered as a consequence of the construction of transportation facilities. This goal considers resource usage from fuel consumption to land uses. It also considers impacts to valued community resources such as residential areas, historic structures and districts, parks, or special population groups. While this goal category may have limited performance measures, it is extensively supplemented by the environmental impact evaluations conducted as part of the environmental studies for specific projects. Objectives 1. Preserve, protect, and expand parks and open space throughout the corridor (lakefront, the river, and within the neighborhoods) 2. Adhere to Executive Order 12898 on Environmental Justice 3. Protect historic resources 4. Provide for business relocation within the study area 5. Protect and enhance the natural environment 6. Improve and enhance lighting 7. Include environmental considerations within the life-cycle cost analysis Please note that I believe that the existing general objective is sufficient and would suggest that your concerns might best be addressed through the mutual development of appropriate performance measures related specifically to Water Quality. If you have any questions regarding this matter or if you require any additional information, please do not hesitate to ask. Respectfully, Craig K. Hebebrand, P.E., Ohio Department of Transportation, District 12 5500 Transportation Boulevard, Garfield Heights, Ohio 44125 Telephone: (216) 581-2333, Ext.409/NEW Facsimile: (216) 584-3508 E-Mail: craig.hebebrand@dot.state.oh.us 6 of 80 ATTACHMENT Craig, I thought about trying to incorporate the objectives that I envision in this new goal with existing Goal V. While I would be willing to try, I felt that it would muddle the intent particularly at the early stage of discussion. Goal --- Reduce and mitigate impacts of highway run off and habitat disruption Transportation replacement and/or re-construction projects offer the opportunity to construct facilities that have less environmental impacts then current systems. Decreased water quality impacts and improved habitat features (including decreased wildlife mortality incidents and increase compatibility with surrounding urban features) are two areas in which significant gains may be possible. Transportation replacement and/or re-construction projects also offer the opportunity to provide mitigation for the direct impacts of the transportation system that cannot be eliminated by context-sensitive design processes. The intent of this goal is to identify at the earliest possible juncture the steps that can be taken to meet the stated objectives. Identifying issues and possible actions may be a factor in developing and/or refining transportation options at the planning level. Consideration of environmental enhancement opportunities in the MIS phase will also allow the transportation planning process to consider the potential project costs associated with environmental measures and will help assure that the recommend plan identifies any options that should be considered in additional depth in the next phases of the transportation planning process. Measures of performance to evaluate planning level options against this goal are likely to be more qualitative then quantitative in nature. This general goal is consistent with NOACA transportation planning principles that call for transportation project to result in enhancements to the natural environment. Objectives 1. Create and/or consider planning level options with the objective of minimizing and/or treating the pollutant loads that are created by stormwater run off from the highway corridor. 2. Create and/or consider planning level options with the objective of minimizing transportation related spills that might damage the ecology of area water resources. Identify any particular merits of transportation options to capture or otherwise minimize the impacts of spilled hazardous materials. 3. Evaluate at a planning level the opportunities and costs to provide long term environmental mitigation for the impacts of the transportation project that cannot be eliminated. 4. Consider opportunities, benefits and urban compatibility issues for natural habitat improvements associated with transportation options and potential environmental mitigation projects. The existing environmental goal for the Inner belt study is as follows Goal V Environment Environmental impacts are often considered as a consequence of the construction of transportation facilities. This goal considers resource usage from fuel consumption to land uses. It also considers impacts to valued community resources such as residential areas, historic structures and districts, parks, or special 7 of 80 population groups. While this goal category may have limited performance measures, it is extensively supplemented by the environmental impact evaluations conducted as part of the environmental studies for specific projects. Objectives 1. Preserve, protect, and expand parks and open space throughout the corridor (lakefront, the river, and within the neighborhoods) 2. Adhere to Executive Order 12898 on Environmental Justice 3. Protect historic resources 4. Provide for business relocation within the study area 5. Protect and enhance the natural environment 6. Improve and enhance lighting 7. Include environmental considerations within the life-cycle cost analysis 8 of 80 9 of 80 10 of 80 11 of 80 Finding and Recommendations Report of the Transwac Innerbelt Work Group 3/20/2006 Transwac Innerbelt Work Group Findings: 1. There is reasonable evidence to suggest that untreated runoff from the Innerbelt may have deleterious effects on the aquatic and ecological health of the Cuyahoga River, and nearshore waters of Lake Erie. Attachment A provides supporting documentation for this conclusion. 2. The Department of Transportation for the State of Washington and CALTRAN have developed models for assessment of water quality impacts which may prove useful in more specifically assessing the impacts on water quality of the proposed Innerbelt facility. (Representative materials documenting these processes are assembled at an ftp site developed by the Transwac work group.) 3. Engineering decisions regarding the Innerbelt drainage systems and the treatment of runoff are likely to affect the feasibility of future options to provide for high levels of treatment of storm water, should new treatment requirements be determined necessary. 4. A substantial portion of the Innerbelt project will be constructed on elevated structures. This creates special problems related to storm water runoff management, and requires careful consideration in the planning and design of these structures. (It is noted that the National Cooperative Highway Research Program report “Assessing the Impact of Bridge Deck Runoff Contaminants in Receiving Waters” provides detailed guidance for assessing impacts and developing runoff management programs.) 5. The Greater Cleveland Community is embarking on a major capital program to control combined sewer overflows and is in the process of establishing new standards to control storm water for development and redevelopment projects as a measure to protect the ecological health of the area water resources. Recommendations for the Conduct of the Innerbelt Project Development Process: 1. The Project Development Process (PDP) is encouraged to evaluate the likely environmental impacts (i.e., water quality and aquatic ecological impacts) attributable to highway runoff and develop storm water management practices that are responsive to the particular environmental concerns of the applicable receiving waters. 2. In as much as untreated runoff from the proposed Innerbelt facility appears to have the potential to cause environmental harm and may result in the violation of water quality standards the PDP should consider treatment of all runoff from the reconstructed facility, as opposed to only providing treatment for volumes of 12 of 80 runoff associated with new pavement area. Design events used to calculate runoff volume should be based upon controlling requirements considering both Ohio’s general storm water permit and the need to prevent violations of Ohio Water Quality Standards. 3. The PDP should consider potential long-term treatment needs for storm water in selecting design alternatives for the drainage of the Innerbelt facility. Some drainage options may limit opportunities for providing additional treatment for storm water runoff, should a higher level of treatment be determined as necessary in the future. 4. The PDP is encouraged to consider the specific characteristics of Innerbelt runoff as well as proposed passive best management practices in evaluation of alternative storm water management strategies. 5. It is recommended that the options evaluated for treatment of storm water include, but not be limited to the following: a) Detention and/or retention facilities above or below grade utilizing current or future green space near the Lakefront. b) Tie-in of all or part of the runoff to the improved combined sewer storage facilities which being designed by the Northeast Ohio Regional Sewer District. 6. The management and treatment of runoff should be considered as an integral part of preliminary engineering for any new or reconstructed bridges crossing the Cuyahoga River. Containment of hazardous material spill should also be assessed. 7. For any proposed direct discharges of storm water to receiving waters or to separate storm sewer systems that subsequently discharge to receiving waters, preliminary engineering should begin planning for monitoring chambers that will facilitate the monitoring of highway runoff. Planning for any such discharge points should also consider provisions to assist in containing hazardous material spills. 8. ODOT is encourage to provide for at least two review points for interaction with the TRANSWAC Innerbelt work group prior to the completion of the drafts for the environmental documents for the project. 9. If the PDP concludes that the treatment of storm water runoff called for by permit or by the need to prevent a violation of water quality standards is not feasible, such a finding should be supported by an engineering cost feasibility study demonstrating that treatment is not feasible. A format for an engineering cost feasibility study is provided at the above noted ftp site. 13 of 80 10. As highway storm water runoff may affect water quality at various parks including portions of the Cleveland Lakefront State Park, the PDP should consider any applicable requirement of the Federal Highway Administration’s Section 4(f) policy. This policy may suggest the need for specific studies or impose certain requirements on the management of storm water. 11. As key stakeholders, Ohio EPA and ODNR should be encouraged to fully engage in the review of PDP step reports, as well as project environmental documents to evaluate whether or not proposed storm water management practices are protective of receiving water resources. 14 of 80 Attachment A: Review of Water Quality Environmental Impact Concerns The purpose of this document is to review the data developed by the Innerbelt work group, focusing on the question of whether the storm water runoff from the current and proposed Innerbelt facility has a reasonable potential to cause harm to the Cuyahoga River and the lakefront area of Lake Erie. This review was not meant to be exhaustive nor intended to fully evaluate the impact of Innerbelt storm water runoff. Rather, the purpose of this document is to aid in making a determination of the need for a more detailed analysis of likely water quality impacts as a part of the ODOT Project Development Process. Four topics are considered in this document: 1. The summary findings of a literature review undertaken by the United States Geological Survey for the Federal Highway Administration, documenting the impacts of highway runoff on the ecological health of aquatic communities. 2. Summarization of the findings of the Cuyahoga River RAP Stage 1 report concerning local water resource impairments. The particular focus of this review is on the findings related to eutrophication and impairments to the benthic community. 3. Summarization of the Lower Cuyahoga TMDL, which sets targets for the Lower Cuyahoga for total phosphorus levels. 4. Comparison of published values for pollutant in highway runoff quality with Ohio water quality criteria. 1. Literature Review of Water Quality Impacts of Highway Runoff A comprehensive literature review of the impacts of highway runoff was conducted by the USGS for the U.S. Department of Transportation. The report, “Assessing Biological Effects from Highway-Runoff Constituents,” was released in 1999. (Open-File Report 99-240). This report reviews 44 articles and published papers incorporating fieldwork from 1970 through 1996. The last paragraph of the Summary of this document is provided below. “A review of 44 reports on the biological effects of highway runoff on local ecosystems reveals several information gaps. The use of different methods from study to study and a general lack of sufficient documentation preclude making quantitative comparisons among different studies using the existing data. Qualitatively, the literature indicates that constituents from highway runoff and from highway-runoff sediments deposited in receiving waters near the highway are found in the tissues of aquatic biota, and that these sources may affect the diversity and productivity of biological communities, even though bioassays would suggest that highway runoff is not often toxic to aquatic biota. To provide the quantitative information needed, it is necessary to obtain information using standard methods, and to document study results in a manner that will be useful for a national or regional synthesis.” 2. Cuyahoga River Remedial Action Plan Stage 1 Report The Cuyahoga River Remedial Action Plan in its Stage 1 report concluded that relative to the impairment of Eutrophication the Navigation Channel of the Cuyahoga River is 15 of 80 “Probably Impaired” and that the near shore area of Lake Erie is “Impaired.” The Lower Cuyahoga is listed as “Probably Impaired” due to a lack of an adequate database on which to base a more definitive conclusion. Additionally, the Stage 1 report concluded that the benthic community is “Possibly Impaired” in the Navigation Channel and “Impaired” in the near shore area of Lake Erie. The “Possibly Impaired” determination reflects that existing studies note problems: however, at that time there were no clear standards applicable to the navigation channel on which to base a more definitive determination. As a part of the procedure of making a determination of impairment for the benthic community, the Stage 1 process prepared separate technical reports on the benthic communities in the Cuyahoga River and in the Cleveland Harbor and near shore areas. The Cleveland Harbor and near shore benthic reports reference several studies conducted during the period 1976 through 1989. 3. Ohio EPA TMDL Report for the Lower Cuyahoga Ohio EPA’s September 2003 Total Maximum Daily Load Report found that the lower 7.2 miles of the Cuyahoga River are in non-attainment of water quality standards. Causes of impairment are listed as organic enrichment, habitat alteration, priority pollutant organics, metals, other organics, and oil and grease. The report concluded that “Phosphorus is the limiting nutrient in the Cuyahoga River system.” The report sets a TMDL target at 0.12mg/L and calls for a 48% reduction of current phosphorus loading levels for non-point runoff sources. In appendix L the report notes that Cuyahoga River is targeted as a significant contributor to the enrichment conditions of nearshore of Lake Erie. 4. Highway Runoff Pollutant Values Compared to Ohio Water Quality Criteria Ohio EPA sets water quality criteria for designated waters of the state. For example, the agency has established aquatic life uses for the Lower Cuyahoga river and for Lake Erie. Numerical criteria are found in ORC 3745-1-07. One example of criteria are the numeric allowable limits for concentrations of pollutants within the mixing zones created by a direct discharge. These Inside Mixing Zone Maximum (IMZM) criteria were developed to prevent acute lethality to aquatic life, and accordingly they are applicable for any individual sample rather than for an average of samples. The Outside Mixing Zone Maximum (OMZM) criteria are similarly applicable to individual samples. Compliance with the OMZM criteria involves determining the pollutant concentrations of the available dilution water and the amount of mixing which occurs. For the purpose of this analysis, the review was limited to heavy metals commonly found in highway runoff. Exhibit 1 is a table comparing literature values for highway runoff pollutant levels with Ohio EPA established criteria for IMZMs and OMZMs. Criteria are established for both total metal concentrations and dissolved metal concentrations. Comparison of these published values with Ohio EPA criteria suggests that untreated Innerbelt runoff, to the extent that is similar in reported literature pollutant values, may result in violations of water quality criteria if discharged untreated to Lake Erie or the Cuyahoga River. 16 of 80 Exhibit 1 ---referenced in Attachment A to the 3/20/06 "Findings and Recommendations" Report of the Transwac Work Group TOTAL RECOVERABLE METALS CRITERIA Hardness Copper Lead Zinc Cadmium 100 mg/L hardness 100 mg/L hardness 100 mg/L hardness 100 mg/L hardness IMZM OMZM IMZM OMZM IMZM OMZM IMZM OMZM mg/L Micrograms/L Micrograms/L Micrograms/L Micrograms/L Ohio EPA water quality criteria* Total recoverable concentrations 28 14 240 120 240 120 9 4.5 For the parameters noted the Ohio criteria values are the same for the Ship Channel and Lake Erie Sansalone et.al. (Feb. 1997) 5 events Cincinnati Event mean Conc. Min 52 43 x 31 459 x 5 x Max 92 325 x 97 15,244 x 11 x Milwaukee 1970s Three sites Average Total Event Mean Conc. Min 75 x * Note 1 336 x 11 x Max 155 x * Note1 465 x 29 x * Note 1-- High values due to lead in gas (738 to 1457) FHWA-PD-96-032 (June 1996) & FHWA-RD-88-006 (April 1990) Urban highway sites with Average Daily Traffic Values over 30,000 Event Median Concentrations median site 52 54 x 400 x 329 x highest 10% 119 x 1,562 x 564 x Lowest 10% 25 x 102 192 x IMZM --- Inside Mixing Zone Maximum criteria OMZM --- Outside Mixing Zone Maximum criteria * Water quality critiera values are determined by an equation in which hardness is an independent variable. Higher criteria would be higher for elevated hardness values. Lower values of hardness lessen allowable metal concentrations. For example a hardness value of 50 mg/l might decrease allowable values in the above table by a factor in the range of 2. Format Notes "x" denotes potential problem with Outside Mixing Zone Maximum criteria Bolded denotes that values are greater then the IMZM criteria 17 of 80 Exhibit 1 (continued) DISSOLVED METALS CRITERIA Hardness Copper Lead Zinc Cadmium 100 mg/L hardness 100 mg/L hardness 100 mg/L hardness 100 mg/L hardness IMZM OMZM IMZM OMZM IMZM OMZM IMZM OMZM mg/L Micrograms/L Micrograms/L Micrograms/L Micrograms/L Ohio EPA water quality criteria* Dissolved 27 13 190 97 230 120 8.5 4.3 For the parameters noted the criteria values are the same for the Ship Channel and Lake Erie Sansalone et.al. 5 events Cincinnati Dissolved fraction translator (mean from 4 events) 0.524 0.279 0.771 0.662 Event mean Conc. Adjusted** Min 52 23 x 9 354 x 3 Adjusted** Max 92 170 x 27 11753 x 7 x FHWA-PD-96-032 (June 1996) & FHWA-RD-88-006 (April 1990) Urban highway sites with Average Daily Traffic Values over 30,000 Dissolved fraction translator 0.4 0.1 0.4 Adjusted** median site 52 22 x 40 132 x Adjusted** highest 10% 48 x 156 x 226 x Adjusted** Lowest 10% 10 10 77 NOTES IMZM --- Inside Mixing Zone Maximum criteria OMZM --- Outside Mixing Zone Maximum criteria * Water quality critiera values are determined by an equation in which hardness is an independent variable. Higher criteria would be higher for elevated hardness values. Lower values of hardness lessen allowable metal concentrations. For example a hardness value of 50 mg/l might decrease allowable values in the above table by a factor in the range of 2. ** Adjusted values were obtained by multiplying the total metals data by fractional values that the report suggests as representative of souble portion of the total metals concentration. The fractional value is listed in the table as the "dissolved fraction translator". Format Notes "x" denotes potential problem with Outside Mixing Zone Maximum criteria Bolded denotes that values are greater then the IMZM criteria lastumpe 3/20/06 18 of 80 Lester Stumpe, P.E.; 3044 Corydon Rd. Cleveland Heights, Ohio 44118 216-321-2566 Lesmnmjus@gmail.com March 5, 2007 Ohio Department of Transportation 5500 Transportation Blvd. Garfield Heights, Ohio 44125 Att: Cleveland Innerbelt Project Manager The substance of this comment is to address ideas around the handling of stormwater runoff from the proposed Innerbelt facility. In summary, I encourage ODOT to vigorously assess the potential impacts of stormwater runoff on the water resources that will receive these discharges as an element of the Draft Environmental Impact Statement. Further, I urge ODOT to fully weigh alternatives for treating stormwater runoff in the draft EIS document. This should include assessment of potential alternative treatment technology as well as an assessment of the environmental benefits of providing treatment of all of the runoff that emanates from the Innerbelt facility. These recommendations are amplified by the attached analysis document. The substance of my comments are structured around the response that ODOT provided for the Findings and Recommendations report dated March 20, 2006 prepared by the Transwac Work group and subsequently submitted to ODOT on behalf of NOACA. As elements of this comment letter I incorporate both the original Transwac Findings and Recommendation report and the ODOT response as attachments. I believe that it is critical that they be made part of the public record of the Draft Environmental Impact Statement. It is my intent that the recommendations of the analysis be considered as comments and suggested direction to ODOT, and as applicable FHWA, by the undersigned. While providing comments, I am also requesting an extension of the period for inclusion of public comments for incorporation into the draft EIS for at least an additional 30 days. In support of this request I note that a critical ODOT Innerbelt document, the Level 1 Ecological Survey Report, is just now in the process of being released to the public. To my knowledge it is not yet available on the ODOT Innerbelt internet site. Logically, scoping of the draft EIS would be greatly enhanced by the benefit of public comment on this ecological report which was developed to help inform the EIS scoping process. Additionally, the requested extension of public comment period would also allow for the NOACA Transwac subcommittee to meet to collectively evaluate and provide comment to ODOT. Finally, an extension of the comment period would allow the Lead Agencies in preparation of the EIS to identify appropriate cooperating and participating agencies as in compliance with Sec. 6002 of SafetyLU. To my knowledge these invitations have not yet been extended. Additional time would allow agencies that are identified, either as 19 of 80 cooperating or participating agencies, to add comments to the record for use in preparation of the draft environmental impact statement. Due to storm conditions NOACA was forced to cancel a recently scheduled Transwac subcommittee meeting which was anticipated to have worked to develop comments to ODOT. Further, NOACA has very recently been advised by ODOT that it is not anticipate granting an extension of the comment period. Facing the prospect that the comment deadline might not be extended NOACA staff advised member of the Transwac committee to submit individual comments. At this late juncture this situation results in the need to submit comments as an individual citizen. Sincerely, Lester Stumpe Copies: Erwin J. Odeal, Northeast Ohio Regional Sewer District Craig Hebebrand, ODOT District 12 Dave Lastovka, ODOT District 12 Mike Armstrong, FHWA David Snyder, FHWA Howard Maier, Northeast Ohio Area Wide Coordination Agency 20 of 80 Comments and Recommended Direction Pertaining to the Assessment of Innerbelt Environmental Impacts and Design of Innerbelt Stormwater Facilities (Note the following comments are formatted to be consistent with Transwac Subcommittee Finds and Recommendations report dated 3/20/06 (Attachment A) and ODOT’s response dated 1/12/07 (Attachment B)) 1) Transwac’s first recommendation was to request ODOT to investigate the specific likely environmental impacts of Innerbelt runoff. (Transwac made this recommendation after a literature review, which concluded that there is the potential for Innerbelt runoff to cause violations of water quality standards. (An ftp site was established for the Transwac Subcommittee, and is available to ODOT (a subcommittee member), which contains over 40 pertinent document addressing water quality impacts and context sensitive transportation planning. An index of documents at this ftp site is included as Attachment C) ODOT’s response does not dispute the findings of the Transwac work group’s report showing the potential harm to aquatic resources and the possible violations of water quality standards. Rather, the focus of ODOT’s response appears to derive from current regulatory requirements as established by Ohio’s General Construction permit. However, having a limited focus on regulatory requirements runs the risk of producing poor public policy. Just as regulatory requirements are not the driving force for many of the design decisions for a reconstructed Innerbelt, they should not be the only consideration in treatment of stormwater runoff. It should be taken into consideration that the planning and design work done as a part of this project will fix drainage patterns that will likely have significant consequences for lakefront water quality for the next 100 years. Additionally, it is to be noted that the supplemental material supporting the project’s Purpose and Need Statement included the goal of protecting and enhancing the natural environment. ODOT suggests that its direction on stormwater treatment is largely set by ODOT policy related to requirements of Ohio’s General Construction permit. However, this permit was not designed for, and can not be expected to provide, adequate guidance for long-range planning processes involving protection of water quality. For example, by permit terms, Storm Water Pollution Prevention Plans (SWP3s) identifying selected BMPs do not need to be developed for potential review by Ohio EPA until 21 days prior to commencing construction. Further, although the general Construction Permit contains provisions affirming the need for post-construction discharges to comply with water quality standards and includes a provision for reopening a permit on the basis of evidence indicating potential impacts on water quality, reopening is not a common practice. Provided that a Storm Water Pollution Prevention Plan (SWP3) has been prepared, there is the presumption that water quality standards will be protected. Thus any action pertaining to a post-construction discharge would only likely occur after construction of the project and subsequent monitoring which demonstrated a violation. While this 21 of 80 approach may be reasonable as a regulatory policy, it does not seem appropriate as guidance for the public’s billion dollar investment in Innerbelt reconstruction. The Plan Development Process (PDP) and the National Environmental Policy Act (NEPA) procedures are the appropriate forums for deliberative processes to consider the long-term view of proper management of stormwater discharges to high value urban water resources. But these processes must be informed with adequate data. In particular Transwac encouraged an assessment of the specific potential impacts of Innerbelt runoff on the Cuyahoga and Lake Erie. There is some uncertainty regarding ODOT’s written response that “in summary the PDP involves a considerable amount of documentation of water quality and aquatic ecological impacts.” Most recently, ODOT has suggested that these issues would be addressed in the Ecological Survey Report. That report dated 2/16/2007 and received by the Transwac work group 2/28/07 does contain a discussion of the lower Cuyahoga and Ship Channel and includes statements about impact. A preliminary review of the report identifies two notable points. First, the report does not provide any substantive discussion of the aquatic resources or impacts to the near shore waters of Lake Erie. Second, the report does not address the concerns raised by the Transwac report, particularly that runoff discharges have the potential to be responsible for violations of Ohio’s water quality standards. It is recommended that the Ecological Survey Report be revised to include the two noted deficiencies. (Note that other comments may be generated after substantive review of the document.) Further, these issues should be addressed in the draft Environmental Impact statement. The point of the ODOT PDP process is to incrementally develop information in early steps to help define the study needs of successive steps. The environmental impacts of stormwater were raised as an issue very early in the process and reiterated at the end of Step 4 in the PDP process. Along the way ODOT has been encouraged to include environmental work to evaluate the specific impact of stormwater runoff in the study scope for the Step 5 process. Due to lack of preliminary information on the potential impact of discharges on Lakefront water quality future planning steps run the risk of being less well informed. In summary there remains a strong need for ODOT to investigate the specific likely environmental impacts of Innerbelt runoff on the specific receiving water resources and in particularly near-shore areas of Lake Erie. Further, if ODOT moves aggressively, there is time to inform the decision making process. ODOT should engage Transwac and pertinent stakeholder agencies in transparent deliberations on this issue. As a first step ODOT is encouraged to make available to the Transwac committee the list of intended agency reviewers to allow Transwac to provide information to and engage in conversation with these agencies on the issues of environmental assessment and stormwater runoff impacts. 22 of 80 2) Transwac’s second recommendation was for ODOT to consider treatment of all of the runoff from the Innerbelt facility, to avoid environmental harm, and to assure compliance with water quality standards. ODOT’s response states that it will consider providing for BMP treatment for 100% of the runoff from the Innerbelt facility. This is a positive step. However, the treatment of 100% of the runoff is not sufficient if the end result does not provide the level of treatment that is required to avoid harm to water resources, and assure compliance with water quality standards and other regulatory requirements. ODOT’s other responses suggest that they will make BMP choices from a limited menu. This limited approach raises the issue of the adequacy of the options that will be evaluated. ODOT suggests that it does not have a regulatory requirement to provide treatment for all of the runoff from the Innerbelt. This may be true. Nevertheless, ODOT has a responsibility to consider whether a strong environmental case can be made for providing a high level of treatment for all of the runoff as a part of its PDP process and the NEPA environmental review process. Engineering experience suggests that providing for full treatment of the runoff at the time of complete reconstruction will be less costly then trying to design for retrofit treatment later. ODOT is encouraged to take a broader view of its responsibilities in the PDP in order to develop solutions that seek the highest value for the citizens of the state regardless of permit requirements. For example, the state of Washington has a developed guidance on when a highway reconstruction project is substantial enough to warrant provision of treatment of all of the runoff from a facility. (Reference: Chapter 5, Washington State, Highway Runoff Manual M 31-16) 3) The third Transwac request was that ODOT consider potential future long-term needs for stormwater treatment in the selection of designs for Innerbelt drainage. In response, ODOT states that it cannot determine what future treatment levels will be required. One of the purposes of the ODOT PDP, the NEPA process, and the Transwac review process is to encourage long term planning that necessarily weighs uncertain outcomes. It would be truly unfortunate if, for lack of consideration of the potential future treatment needs, ODOT designed a drainage system that would work against future potential treatment options. In considering drainage systems ODOT should consider the potential future long-term needs for stormwater treatment. Additionally, the response errs in assuming that the project treatment requirements it sites in its response are only controlled by policies developed to in response to Ohio’s General Construction permit. Further, while it is appropriate for ODOT to consider the most current EPA policy at the time of the final design, certain options may have closed for lack of identification of identification of needs at an earlier point. ODOT should reconsider its position and undertake a more proactive analysis. 23 of 80 4) The fourth Transwac comment was intended to encourage consideration of specific characteristics of Innerbelt runoff in selection of proposed treatment practices. ODOT states that it believes that the Innerbelt runoff is typical of urban runoff. In contrast, the Transwac literature review suggests that runoff from highways with high traffic counts has a higher concentration of certain pollutants when compared with typical urban runoff. (See Exhibit 1 of Attachment A of the Transwac report.) If ODOT has different data / information suggesting otherwise it should provide the data and discuss its conclusions. ODOT provides insightful information in noting that the shoulders for the new facility will have a width that facilitates shoulder sweeping. If ODOT is suggesting that shoulder sweeping is an important and effective strategy in combination with other BMPs, then it should develop and present a reasoned sweeping routine with consideration for the range of weather conditions that will be experienced by the Innerbelt facility. Based upon this intended routine, ODOT should estimate the level of pollution reduction that it hopes to achieve. The expected quality of Innerbelt runoff and in particular metals concentrations should be described and compared to Ohio Water Quality Standards in the Draft Environmental Impact Statement. 5) Transwac’s fifth recommendation was to suggest two options for treatment that relate to the unique opportunities attendant with the project site. These including integrating treatment with green space along the lakeshore and connecting to NEORSD facilities. ODOT’s response is twofold. Earlier in the response letter and here again, ODOT suggested that a decision has been made to pursue a stormwater separation strategy. It seems inappropriate that ODOT would announce a decision to pursue a stormwater separation strategy without providing an engineering analysis to show the value of the option, and without soliciting public input on this decision through the PDP process and in the project’s environmental documents. Again, it is noted that Transwac has made a recommendation that the drainage system should be designed with consideration for enhanced future treatment options. ODOT should consider Transwac’s suggestions for stormwater treatment as a part of the draft Environmental Impact Statement document. ODOT’s letter suggests that removing stormwater will result in lower pollution loads to the receiving water as opposed to discharging to the combined sewer system. Yet ODOT does not provide justification or reference to a study to support this claim. In certain cases, removal of contaminated stormwater from combined sewer system may lead to higher pollutant loadings. Given the Transwac demonstrated potential for high metals concentrations in Innerbelt runoff, this possibility requires close examination. The calculation to determine which strategy yields the lowest pollutant loads is dependent upon the level of treatment that is provided for the pollutants of concern, before and after 24 of 80 the proposed removal from the regional treatment system. This calculation should be presented in the Draft Environmental Impact Statement. Further, ODOT continues to suggest it can meet its regulatory requirements by selecting BMPs from a pre-screened inventory of BMPs that are listed in its Location and Drainage (L & D) manual. It is unclear why ODOT asserts it does not need to consider other possibilities, particularly when dealing with post-construction runoff that could cause violations of water quality standards, and when other unique options are available for treatment of stormwater. It is well known that ODOT has been in discussion with Ohio EPA regarding identification of effective BMPs as a way of facilitating compliance with the provision of the General Construction permit. It is likely that these identified options include favorable choices for the majority of ODOT’s transportation projects. However, these negotiations do not constitute rule-making and do not override the provisions in other environmental regulations or the provisions of the General Construction permit, which speak to maintenance of water quality standards where there is the potential for violations. For example, the Construction permit notes the primacy of water quality standards and requires the selection and implementation of BMPs to reduce pollutants and ensure compliance with Ohio’s water quality standards rule. 6) Transwac’s sixth comment asked ODOT to consider treatment of runoff and the potential for containment of spills in the design of new or reconstructed bridges. ODOT’s response confirms its intent to consider the Cuyahoga TMDL goals in considering the treatment of runoff from the projects bridges. However, the response is silent on the matter of designing to address the hazards associated with spills. ODOT should consider spill containment as part of the bridge design effort and should discuss the issue in the draft Environmental Impact Statement. 7) Transwac’s seventh request asked that the drainage design engineers consider features that promote environmental monitoring and containment of spills. ODOT asserts that its standard manholes and inlet structures provide adequate access for any necessary future monitoring. The response fails to address the idea of providing an integrated system that addresses spill containment. Further, the point of the comment is not to provide adequate access; rather, it was a request to consider features that facilitate accurate flow monitoring and safe and representative sample collection. Standard engineering practice to meet these goals has evolved well beyond providing standard manholes. Future monitoring needs should be a consideration in Innerbelt drainage design. ODOT should identify its intent to perform environmental monitoring of runoff in the Environmental Impact Statement. 25 of 80 Additionally, ODOT’s response continues a pattern by noting that there are no specific regulatory requirements for monitoring. Again, the PDP should not be driven by the minimum that is needed to meet regulatory requirements. 8) Transwac’s eighth comment encouraged two meetings with the Transwac Innerbelt work group prior to the completion of the drafts for the environmental documents for the project. The lack of anticipated key materials and reports has so far frustrated this goal. ODOT is encouraged to share with Transwac the scope of work for both the Step 6 PDP document and the draft environmental impact statement. Transwac’s input should be sought in development of these documents. To facilitate development NOACA should be invited to be an official “Participating Agency” in the development of the Environmental Impact Statement. 9) Transwac’s ninth comment addressed the potential issue that cost could be a factor in determining feasibility in selecting treatment options to prevent violations of water quality standards. We provided reference to a format for cost feasibility studies to demonstrate the necessary tradeoffs, should cost become a significant factor. ODOT’s response to this recommendation discounts the possibility that cost could potentially be a factor in selection of treatment options. However, previous comment responses suggest that ODOT only intends to consider the limited set of BMPs in its L&D manual. The Transwac report makes the case for consideration of a wider range of treatment options. Some of these options could involve significant cost. Accordingly, the Transwac provided reference to the suggested format for cost feasibility studies may ultimately prove helpful. 10) Transwac’s tenth comment addressed the need to determine the applicability of the FHWA’s 4(f) policy. ODOT’s response clarifies that FHWA is in charge of making a 4(f) determination. Transwac should be advised as to whether ODOT has shared the specific request for a 4(f) determination with the FHWA. Also, Transwac should be informed of when FHWA would make such a determination. Finally, the applicability of Section 4(f) should be discussed in the draft Environmental Impact Statement. To the extent that it is applicable the information and assessments required by 4(f) should be part of the Draft Environmental Impact Statement. Unfortunately, the lack of a timely response may already impacts the ability of the Lead EIS agencies to gather appropriate information concerning this issue for timely consideration. 26 of 80 11) Transwac’s eleventh comment focused on the need to encourage the full engagement of stakeholder agencies in review of the PDP Step reports and the environmental documents. ODOT pledges to engage stakeholder agencies in development of the Ecological Survey Report, this pledge should extends to receiving input on the development and review of the project’s other PDP documents, including the project’s environmental documents to satisfy NEPA requirements. It is critical that in the process of involving these agencies be fully transparent and that these agencies be fully informed of the specific concerns that have been raised by the Transwac Subcommittee. It is noted that these agencies were not copied on the ODOT response letter to Transwac. Particularly, there is a need to engage a range of stakeholder agencies to consider the question of the appropriate level of protection of Cleveland’s unique and highly valued water resources. ODOT should adopt this broader view of the protection of Cleveland’s water resources. las:3/05/07 27 of 80 Finding and Recommendations Report of the Transwac Innerbelt Work Group 3/20/2006 Transwac Innerbelt Work Group Findings: 1. There is reasonable evidence to suggest that untreated runoff from the Innerbelt may have deleterious effects on the aquatic and ecological health of the Cuyahoga River, and nearshore waters of Lake Erie. Attachment A provides supporting documentation for this conclusion. 2. The Department of Transportation for the State of Washington and CALTRAN have developed models for assessment of water quality impacts which may prove useful in more specifically assessing the impacts on water quality of the proposed Innerbelt facility. (Representative materials documenting these processes are assembled at an ftp site developed by the Transwac work group.) 3. Engineering decisions regarding the Innerbelt drainage systems and the treatment of runoff are likely to affect the feasibility of future options to provide for high levels of treatment of storm water, should new treatment requirements be determined necessary. 4. A substantial portion of the Innerbelt project will be constructed on elevated structures. This creates special problems related to storm water runoff management, and requires careful consideration in the planning and design of these structures. (It is noted that the National Cooperative Highway Research Program report “Assessing the Impact of Bridge Deck Runoff Contaminants in Receiving Waters” provides detailed guidance for assessing impacts and developing runoff management programs.) 5. The Greater Cleveland Community is embarking on a major capital program to control combined sewer overflows and is in the process of establishing new standards to control storm water for development and redevelopment projects as a measure to protect the ecological health of the area water resources. Recommendations for the Conduct of the Innerbelt Project Development Process: 1. The Project Development Process (PDP) is encouraged to evaluate the likely environmental impacts (i.e., water quality and aquatic ecological impacts) attributable to highway runoff and develop storm water management practices that are responsive to the particular environmental concerns of the applicable receiving waters. 2. In as much as untreated runoff from the proposed Innerbelt facility appears to have the potential to cause environmental harm and may result in the violation of water quality standards the PDP should consider treatment of all runoff from the reconstructed facility, as opposed to only providing treatment for volumes of 28 of 80 runoff associated with new pavement area. Design events used to calculate runoff volume should be based upon controlling requirements considering both Ohio’s general storm water permit and the need to prevent violations of Ohio Water Quality Standards. 3. The PDP should consider potential long-term treatment needs for storm water in selecting design alternatives for the drainage of the Innerbelt facility. Some drainage options may limit opportunities for providing additional treatment for storm water runoff, should a higher level of treatment be determined as necessary in the future. 4. The PDP is encouraged to consider the specific characteristics of Innerbelt runoff as well as proposed passive best management practices in evaluation of alternative storm water management strategies. 5. It is recommended that the options evaluated for treatment of storm water include, but not be limited to the following: a) Detention and/or retention facilities above or below grade utilizing current or future green space near the Lakefront. b) Tie-in of all or part of the runoff to the improved combined sewer storage facilities which being designed by the Northeast Ohio Regional Sewer District. 6. The management and treatment of runoff should be considered as an integral part of preliminary engineering for any new or reconstructed bridges crossing the Cuyahoga River. Containment of hazardous material spill should also be assessed. 7. For any proposed direct discharges of storm water to receiving waters or to separate storm sewer systems that subsequently discharge to receiving waters, preliminary engineering should begin planning for monitoring chambers that will facilitate the monitoring of highway runoff. Planning for any such discharge points should also consider provisions to assist in containing hazardous material spills. 8. ODOT is encourage to provide for at least two review points for interaction with the TRANSWAC Innerbelt work group prior to the completion of the drafts for the environmental documents for the project. 9. If the PDP concludes that the treatment of storm water runoff called for by permit or by the need to prevent a violation of water quality standards is not feasible, such a finding should be supported by an engineering cost feasibility study demonstrating that treatment is not feasible. A format for an engineering cost feasibility study is provided at the above noted ftp site. 29 of 80 10. As highway storm water runoff may affect water quality at various parks including portions of the Cleveland Lakefront State Park, the PDP should consider any applicable requirement of the Federal Highway Administration’s Section 4(f) policy. This policy may suggest the need for specific studies or impose certain requirements on the management of storm water. 11. As key stakeholders, Ohio EPA and ODNR should be encouraged to fully engage in the review of PDP step reports, as well as project environmental documents to evaluate whether or not proposed storm water management practices are protective of receiving water resources. 30 of 80 Attachment A: Review of Water Quality Environmental Impact Concerns The purpose of this document is to review the data developed by the Innerbelt work group, focusing on the question of whether the storm water runoff from the current and proposed Innerbelt facility has a reasonable potential to cause harm to the Cuyahoga River and the lakefront area of Lake Erie. This review was not meant to be exhaustive nor intended to fully evaluate the impact of Innerbelt storm water runoff. Rather, the purpose of this document is to aid in making a determination of the need for a more detailed analysis of likely water quality impacts as a part of the ODOT Project Development Process. Four topics are considered in this document: 1. The summary findings of a literature review undertaken by the United States Geological Survey for the Federal Highway Administration, documenting the impacts of highway runoff on the ecological health of aquatic communities. 2. Summarization of the findings of the Cuyahoga River RAP Stage 1 report concerning local water resource impairments. The particular focus of this review is on the findings related to eutrophication and impairments to the benthic community. 3. Summarization of the Lower Cuyahoga TMDL, which sets targets for the Lower Cuyahoga for total phosphorus levels. 4. Comparison of published values for pollutant in highway runoff quality with Ohio water quality criteria. 1. Literature Review of Water Quality Impacts of Highway Runoff A comprehensive literature review of the impacts of highway runoff was conducted by the USGS for the U.S. Department of Transportation. The report, “Assessing Biological Effects from Highway-Runoff Constituents,” was released in 1999. (Open-File Report 99-240). This report reviews 44 articles and published papers incorporating fieldwork from 1970 through 1996. The last paragraph of the Summary of this document is provided below. “A review of 44 reports on the biological effects of highway runoff on local ecosystems reveals several information gaps. The use of different methods from study to study and a general lack of sufficient documentation preclude making quantitative comparisons among different studies using the existing data. Qualitatively, the literature indicates that constituents from highway runoff and from highway-runoff sediments deposited in receiving waters near the highway are found in the tissues of aquatic biota, and that these sources may affect the diversity and productivity of biological communities, even though bioassays would suggest that highway runoff is not often toxic to aquatic biota. To provide the quantitative information needed, it is necessary to obtain information using standard methods, and to document study results in a manner that will be useful for a national or regional synthesis.” 2. Cuyahoga River Remedial Action Plan Stage 1 Report The Cuyahoga River Remedial Action Plan in its Stage 1 report concluded that relative to the impairment of Eutrophication the Navigation Channel of the Cuyahoga River is 31 of 80 “Probably Impaired” and that the near shore area of Lake Erie is “Impaired.” The Lower Cuyahoga is listed as “Probably Impaired” due to a lack of an adequate database on which to base a more definitive conclusion. Additionally, the Stage 1 report concluded that the benthic community is “Possibly Impaired” in the Navigation Channel and “Impaired” in the near shore area of Lake Erie. The “Possibly Impaired” determination reflects that existing studies note problems: however, at that time there were no clear standards applicable to the navigation channel on which to base a more definitive determination. As a part of the procedure of making a determination of impairment for the benthic community, the Stage 1 process prepared separate technical reports on the benthic communities in the Cuyahoga River and in the Cleveland Harbor and near shore areas. The Cleveland Harbor and near shore benthic reports reference several studies conducted during the period 1976 through 1989. 3. Ohio EPA TMDL Report for the Lower Cuyahoga Ohio EPA’s September 2003 Total Maximum Daily Load Report found that the lower 7.2 miles of the Cuyahoga River are in non-attainment of water quality standards. Causes of impairment are listed as organic enrichment, habitat alteration, priority pollutant organics, metals, other organics, and oil and grease. The report concluded that “Phosphorus is the limiting nutrient in the Cuyahoga River system.” The report sets a TMDL target at 0.12mg/L and calls for a 48% reduction of current phosphorus loading levels for non-point runoff sources. In appendix L the report notes that Cuyahoga River is targeted as a significant contributor to the enrichment conditions of nearshore of Lake Erie. 4. Highway Runoff Pollutant Values Compared to Ohio Water Quality Criteria Ohio EPA sets water quality criteria for designated waters of the state. For example, the agency has established aquatic life uses for the Lower Cuyahoga river and for Lake Erie. Numerical criteria are found in ORC 3745-1-07. One example of criteria are the numeric allowable limits for concentrations of pollutants within the mixing zones created by a direct discharge. These Inside Mixing Zone Maximum (IMZM) criteria were developed to prevent acute lethality to aquatic life, and accordingly they are applicable for any individual sample rather than for an average of samples. The Outside Mixing Zone Maximum (OMZM) criteria are similarly applicable to individual samples. Compliance with the OMZM criteria involves determining the pollutant concentrations of the available dilution water and the amount of mixing which occurs. For the purpose of this analysis, the review was limited to heavy metals commonly found in highway runoff. Exhibit 1 is a table comparing literature values for highway runoff pollutant levels with Ohio EPA established criteria for IMZMs and OMZMs. Criteria are established for both total metal concentrations and dissolved metal concentrations. Comparison of these published values with Ohio EPA criteria suggests that untreated Innerbelt runoff, to the extent that is similar in reported literature pollutant values, may result in violations of water quality criteria if discharged untreated to Lake Erie or the Cuyahoga River. 32 of 80 Exhibit 1 ---referenced in Attachment A to the 3/20/06 "Findings and Recommendations" Report of the Transwac Work Group TOTAL RECOVERABLE METALS CRITERIA Hardness Copper Lead Zinc Cadmium 100 mg/L hardness 100 mg/L hardness 100 mg/L hardness 100 mg/L hardness IMZM OMZM IMZM OMZM IMZM OMZM IMZM OMZM mg/L Micrograms/L Micrograms/L Micrograms/L Micrograms/L Ohio EPA water quality criteria* Total recoverable concentrations 28 14 240 120 240 120 9 4.5 For the parameters noted the Ohio criteria values are the same for the Ship Channel and Lake Erie Sansalone et.al. (Feb. 1997) 5 events Cincinnati Event mean Conc. Min 52 43 x 31 459 x 5 x Max 92 325 x 97 15,244 x 11 x Milwaukee 1970s Three sites Average Total Event Mean Conc. Min 75 x * Note 1 336 x 11 x Max 155 x * Note1 465 x 29 x * Note 1-- High values due to lead in gas (738 to 1457) FHWA-PD-96-032 (June 1996) & FHWA-RD-88-006 (April 1990) Urban highway sites with Average Daily Traffic Values over 30,000 Event Median Concentrations median site 52 54 x 400 x 329 x highest 10% 119 x 1,562 x 564 x Lowest 10% 25 x 102 192 x IMZM --- Inside Mixing Zone Maximum criteria OMZM --- Outside Mixing Zone Maximum criteria * Water quality critiera values are determined by an equation in which hardness is an independent variable. Higher criteria would be higher for elevated hardness values. Lower values of hardness lessen allowable metal concentrations. For example a hardness value of 50 mg/l might decrease allowable values in the above table by a factor in the range of 2. Format Notes "x" denotes potential problem with Outside Mixing Zone Maximum criteria Bolded denotes that values are greater then the IMZM criteria 33 of 80 Exhibit 1 (continued) DISSOLVED METALS CRITERIA Hardness Copper Lead Zinc Cadmium 100 mg/L hardness 100 mg/L hardness 100 mg/L hardness 100 mg/L hardness IMZM OMZM IMZM OMZM IMZM OMZM IMZM OMZM mg/L Micrograms/L Micrograms/L Micrograms/L Micrograms/L Ohio EPA water quality criteria* Dissolved 27 13 190 97 230 120 8.5 4.3 For the parameters noted the criteria values are the same for the Ship Channel and Lake Erie Sansalone et.al. 5 events Cincinnati Dissolved fraction translator (mean from 4 events) 0.524 0.279 0.771 0.662 Event mean Conc. Adjusted** Min 52 23 x 9 354 x 3 Adjusted** Max 92 170 x 27 11753 x 7 x FHWA-PD-96-032 (June 1996) & FHWA-RD-88-006 (April 1990) Urban highway sites with Average Daily Traffic Values over 30,000 Dissolved fraction translator 0.4 0.1 0.4 Adjusted** median site 52 22 x 40 132 x Adjusted** highest 10% 48 x 156 x 226 x Adjusted** Lowest 10% 10 10 77 NOTES IMZM --- Inside Mixing Zone Maximum criteria OMZM --- Outside Mixing Zone Maximum criteria * Water quality critiera values are determined by an equation in which hardness is an independent variable. Higher criteria would be higher for elevated hardness values. Lower values of hardness lessen allowable metal concentrations. For example a hardness value of 50 mg/l might decrease allowable values in the above table by a factor in the range of 2. ** Adjusted values were obtained by multiplying the total metals data by fractional values that the report suggests as representative of souble portion of the total metals concentration. The fractional value is listed in the table as the "dissolved fraction translator". Format Notes "x" denotes potential problem with Outside Mixing Zone Maximum criteria Bolded denotes that values are greater then the IMZM criteria lastumpe 3/20/06 34 of 80 35 of 80 36 of 80 37 of 80 38 of 80 39 of 80 40 of 80 41 of 80 42 of 80 Document list for reports at ftp site established for Transwac Current as of 3/05/07 Item # Report or Item Identifier Document file name Published by Notes 0 Post Construction Storm Water Management Interim Policy—volume 2 revisions 00~Abstracts and Summaries for Innerbelt Work Group ODOT Sept 2003 1 Post Construction Storm Water Management Interim Policy 01~ODOT post construction policy ODOT Sept 2003 2 1/20/06 Update of ODOT Location and Design Manual 02~Location and Design Manual 1.20.06 update ODOT Jan 2, 2006 3 Is Highway Runoff A Serious Problem 03~Is Highway runoff a serious problem From: FHWA web site April 2003 4 Highway Runoff and Water Quality Impacts 04~East-west gateway coordinating on Stormwater East-West Gateway Coordinating Council—I believe this a California Agency August 2000 5 Pollutant Loadings and Impacts from Highway Stormwater Runoff: 05~FHWA-RD-88-006 FHWA April 1990 43 of 80 Volume I: Design Procedure 6 Pollutant Loadings and Impacts from Highway Stormwater Runoff: Volume, III: Analytical Investigation And Research Report 06~FHWA-RD-88-008 FHWA April 1990 7 Chapter 2 of Evaluation and management of highway runoff water quality: 07~National Highway Runoff–Coordination with Environmental Agencies and the Public (an HTML document) Federal Highway Administration Final Report FHWA-PD-96- 032, 480 p. 1996 Young, G.K., Stein, S., Cole, P., Kammer T., Graziano, Bank F., 8 A Review of Semivolatile and Volatile Organic Compounds in Highway Runoff and Urban Stormwater 08~Review of Semivolatile and Volatile Organic Compounds: OFR98-409 U.S. Geological Survey &U.S. Department of the Interior 1998 9 Assessing Biological Effects from Highway-Runoff Constituents 09~Assessing Biological Effects: OFR99-240 U.S. Geological Survey &U.S. Department of the Interior 1999 44 of 80 Item # Report or Item Identifier Document file name Published by Notes 10 Volume I – Technical Issues for Monitoring Highway Runoff and Urban Stormwater 10~Technical Issues for Monitoring—Volume 1 EP03-054 U.S. Geological Survey & U.S. Department of the Interior 2003 The National Highway Runoff Data and Methodology Synthesis 11 Volume II --National Highway Runoff Water-Quality Data and Methodology Synthesis, -Project Documentation 11~National Highway Runoff—Project Documentation—Volume 2 EP03-055 U.S. Geological Survey The National Highway Runoff Data and Methodology Synthesis 9/30/2001 12 FHWA Stormwater BMP ultra urban 12~FHWA Stormwater BMP ultra urban FHWA FHWA web site 13 2005 guidance on 4 f policy 13~Final 4(f) PP 3-1-05 FHWA Office of Planning, Environment and Realty 2005 14 ODOT Project Development Process PDPcomplete_1104.pdf ODOT Nov. 2004 15 Section 204 of ODOT Project Development Process 15~Section 204 from PDPcomplete_1104 ODOT Nov 2004 16 NPDES Permit No 16~Darby StormWater OEPA Dec 2005 45 of 80 OHC100001: General Permit for Discharges of Storm Water Associated with Construction Activity Located within the Big Darby Creek Watershed Draft FS_December 2005 17 Picture of Darby Creek Watershed 17~Darby StormWater Draft GP Attachment A OEPA Dec 2005 18 Authorization for StormWater Discharges Associated with Construction Activity within DCW under the NPDES 18~Darby StormWater Draft GP OEPA Dec 2005 19 Supplemental Specification: OEPA authorization for Stormwater Discharges associated with construction activity under NPDES 19~Ohio EPA Permit OEPA April 2003 Item # Report or Item Identifier Document file name Published by Notes 20 Selected Material from Stage 1 RAP reports 20~ Selected Material from Stage 1 RAP reports Cuyahoga River Remedial Action Plan Coordinating Committee June 1992 21 First Flush Phenomenon 21~ First Flush Phenomenon California Department of August 2005 46 of 80 Characterization Characterization Transportation, Division of Environmental Analysis 22 Storm Water Monitoring and BMP Development Status Report 22~CALTRANS Storm Water Monitoring and BMP Development Status Report CALTRANS Nov 2004 23 Review of Contaminants and Toxicity Associated with Particles in StormWater Runoff 23~CALTRANS Review of Contaminants and Toxicity CALTRANS August 2003 24 Stormwater Pollution Prevention Plan, Water Pollution Control Program, Construction Site BMPs Guide 24~Project Planning and Design Guide—PPDG— with revisions 7.26.05 CALTRANS Sept 2002, reprint April 2003 25 Guidelines for the Preparation of the Preliminary Environmental Analysis Report 25~PEAR manual CALTRANS Dec 2001 26 Appendix E of the Storm Water Data Report Project Planning and Design Guide 26~ Appendix E of the Revised PPDG CALTRANS May 2005 27 Appendix E of the Storm Water Data Report Project 27~Work in Progress Appendix E of the Revised PPDG CALTRANS May 2005 47 of 80 Planning and Design Guide with comments and deletions marked 28 WSDOT Highway Runoff Manual for 2005 28~WSDOT Highway Runoff Manual— WSDOT 2006 29 Water Use Designations and Statewide Criteria, OAC 3745-1-07 29~OAC 3745-1-07--Water Quality Standards Ohio Administrative Code Dec 2002 Item # Report or Item Identifier Document file name Published by Notes 30 Highway Runoff Water Quality Research 30~Cazenas-FHWAHighway Runoff Presentation FHWA Dec 2003 31 NCHRP Report 521: Identification of Research Needs Related to Highway Runoff Management 31~NCHRP 521— Identification of Research Needs Transportation Research Board of the National Academies 2004 32 NCHRP Report 474: Assessing the Impacts of Bridge Deck Runoff Contaminants in Receiving Waters: Volume 2— Practitioner’s Handbook 32~NCHRP 474 —impacts of Bridge Deck Runoff— Practitioner’s Handbook Transportation Research Board of the National Academies 2002 33 Selections from “Continuous 33~ Continuous Deflective Separation WEF 1997 48 of 80 Deflective Separation: Its Mechanism and Applications” 34 Presentation of The Nature and Control of Urban Storm Water— A Physical-Chemical Perspective 34~Sansalone-- The Nature and Control of Urban Storm Water Sansalone, from the Civil and Environmental Engineering Department at Louisiana State University Nov 2001 35 Sansalone and Teng— In Situ Partial Exfiltration of Rainfall Runoff. 1: Quality and Quantity Attenuation 35~Sansalone and Teng— In Situ Partial Exfiltration of Rainfall Runoff Journal of Environmental Engineering Sept 2004 36 Design of Road Culverts for Fish Passage, 2003 update 36~WSDOT Design of Road Culverts for Fish Passage Washington Department of Fish and Wildlife 2003 37 Upcoming revisions to the 3/2004 WSDOT Highway Runoff Manual for 2005, Appendix 3A 37~WSDOT HRM—2005 Pending Draft Appendix 3A WSDOT March 2005 Item # Report or Item Identifier Document file name Published by Notes 40 Upcoming revisions to the 3/2004 WSDOT Highway Runoff Manual for 2005, Chapter 3 40~WSDOT HRM—2005 Pending Draft Ch. 3 Stormwater Planning and Design WSDOT March 2005 49 of 80 41 WSDOT Hydraulic Manual 41~ WSDOT Hydraulic Manual WSDOT March 2005 42 Statement on Cleveland Innerbelt Strom Water Issues 42~ODOT Statement of Storm Water ODOT April 2006 43 NOACA’s Transwac Committee Findings and Recommendations report 43~Transwac WG Findings and Recommendations NOACA Transwac Work Group; Approved by the NOACA Transportation Advisory Committee May 19, 2006 March 20,2006 44 ODOT response to Transwac Findings and Recommendations report 44~ODOT response to Transwac Findings and Recommendations Report ODOT January 12, 2007 45 Level 1 Ecological Survey Report Cleveland Innerbelt Project 45~ESR Final ODOT Feb 16,2007 50 of 80 51 of 80 Comments for: LEVEL I ECOLOGICAL SURVEY REPORT CLEVELAND INNERBELT PROJECT 1) Applicability of Ohio’s General Construction Permit to selection of storm water treatment methods Ohio’s General Construction permit was not designed for, and can not be expected to provide adequate guidance for long-range planning processes involving protection of water quality. For example, by permit terms Storm Water Pollution Prevention Plans (SWP3s) identifying selected BMPs do not need to be developed for potential review by Ohio EPA until 21 days prior to commencing construction. Clearly these kinds of conditions are not appropriate to provide guidance for current engineering work for a project that may cost as much as a billion dollars, will not be completed for more then 15 years, and sets drainage patterns that may affect lakefront water quality for decades. The General Construction permit does contain provisions to allow Ohio EPA to issue an individual permit. Specifically, Part 4A contains the following provision: “If there is evidence indicating potential or realized impacts on water quality due to any storm water discharge associated with construction activity covered by this permit, the permittee of such discharge may be required to obtain coverage under an individual permit or an alternative general permit in accordance with Part I.C of this permit or the permit may be modified to include different limitations and/or requirements.” Ohio EPA should be engaged to discuss whether an individual permit would be appropriate for the Cleveland Innerbelt project and if so to explore potential options for the permit’s timing and substantive requirements. 2) Applicability of the Section 4(f) The Innerbelt project should trigger a review of impacts regulated by the Section 4(f) process. Two cases should be considered. A) The first case is the possibility that water pollution from the proposed direct discharge to Lake Erie could affect the water quality of the East 55th Street Marina, an element of the Cleveland Lakefront State Park. This may potentially constitute a constructive use of 4(f) property. B) The second case is based upon the potential cumulative impact of failing to provide for aggressive storm water treatment when properties draining to the Lakefront are redeveloped or reconstructed. A “large portion” of the natural drainage that would affect lakefront water quality is intercepted by combined sewers and treated at regional facilities. However, something in the range of 2000 acres of Cleveland Lakefront properties, including significant acreage of roadway surface, is believed to directly discharge to Lake Erie. Failure to provide for aggressive storm water treatment, when these properties are re-developed or reconstructed, is likely to have a cumulative negative impact on the anticipated public uses of the Cleveland Lake Front Planning 52 of 80 District. By virtue of the public’s ownership of these lands and their current projected use in the time frame of the Innerbelt project, Cleveland Lakefront property in public ownership should be evaluated as 4(f) properties. In evaluating the substantive nature of the impact of storm water discharges, attention should be given to the hours of potential water quality impairment caused by repeated storm discharges of varying magnitude. 3) Consideration of Coastal Zone management requirements In considering appropriate pollution controls for Innerbelt storm water consideration should be given to the Ohio Coastal Nonpoint Pollution Control Program Plan. 4) The following comments are referenced to specific sections of the Level I Ecological Survey Report – Cleveland Innerbelt Project. Place Section Excerpt Draft Transwac Comments Hardcopy Page iv, 1st comment (Executive Summary Section, paragraph 2) EXECUTIVE SUMMARY “Field surveys of the study area were conducted in June, July and August of 2005. Aquatic, terrestrial, and wetland resources, as well as endangered species were investigated. The Cuyahoga River is the only aquatic resource in the study area. No direct operational or construction impacts on aquatic resources are expected.” At the very minimum: 1) Reconstruction of the Innerbelt facility will renew the pollution source of highway runoff for the life of the project. 2) Direct discharges of stormwater during construction of the roadway and new bridges could have a water quality impact on both Lake Erie and the Cuyahoga. 3) Without changes in drainage patterns stormwater runoff from the Innerbelt facility will have an ongoing operational impact on the Cuyahoga River and Lake Erie. Hardcopy Page iv, 2nd comment (Executive Summary Section, paragraph 4) EXECUTIVE SUMMARY “A wetland delineation investigation was conducted within study area boundaries. No wetlands or other waters of the U.S. (other than the Cuyahoga River) were identified within study area boundaries. Therefore, no impacts to wetlands or other waters of the U.S. are expected.” Figure A on page 4 clearly shows that the study area boundary includes Lake Erie. Even the mapped corridor touches Lake Erie. Clearly, the impacts to Lake Erie should be considered so that, to the best of our knowledge, the plan is to maintain some form of the existing Lake Erie discharge. Executive Summary EXECUTIVE SUMMARY The report does not consider the potential impacts of a stormwater discharge on the Cleveland Lake Front State park. To the extent that this represents a constructive use, the Sec (4)(f) policy would apply and would require certain study efforts be undertaken. 53 of 80 Hardcopy Page 3 (Section I, Subsection A, part 2) Continued from previous page 2. Purpose and Need “The Purpose and Need statement for the Cleveland Innerbelt Project was completed in April 2003. The Purpose and Need Statement identified four categories in which transportation improvements are necessary and will become critical as traffic and congestion continues to increase. These four categories are: (1) physical condition (Section 3.1-B & N Report), (2) safety (Section 3.2-Step 5 Report), (3) operational performance (Section 3.3-B & N Report), (4) access (Section 3.4-B & N Report). The categories are discussed below. Additional detail regarding the Purpose and Need for the Project may be found at: www.innerbelt.org/Innerbelt/Docutments/P urpose%20and%20Need.pdf.” The Purpose and Need Statement is supplemented by materials at the referenced website. Supplemental materials identify the goal of enhancing and protecting the natural environment. If there is a need to assure a complete consideration of alternatives for the treatment of stormwater in the draft EIS enhanced treatment of Innerbelt stormwater, runoff should be added to the purpose and need statement. Hardcopy Page 8 (Section I, Subsection A, part 3) Study Area Description and Description of Alternatives 1) Descriptions of alternatives should include descriptions of alternatives for stormwater treatment. In particular, the report should consider the potential rightof- way that might be useful for stormwater management. Transwac has previously suggested that some stormwater management might be accomplished at the northern-most end of the project. There may also be an opportunity to accomplish some pollution reduction in the right of way which will be used as a part of flattening the curve where the Innerbelt transitions to Lake Shore Blvd and I-90. 2) Previous correspondence with the Transwac Work Group suggests that at least a tentative decision has been made to separate stormwater. If this is the case, the logic for this should be presented and discussed somewhere in the report. 3) The report should consider the ability to obtain or use current right of way to install ultra-urban BMPs which have been identified by USEPA. Newer emerging technologies for treatment of stormwater should be considered. 54 of 80 4) Alternatives for treatment of bridge runoff from both the proposed new bridge and the reconstructed bridge should be discussed. Hardcopy Page 15 (Section I, Subsection B) B. STUDY OBJECTIVES “This Ecological Survey Report documents the findings of a detailed field investigation to characterize the study area’s aquatic, terrestrial and wetland resources and endangered species, and to determine the project’s impact on these resources. Specific study objectives were to: (􀁹) Identify and evaluate the significance of aquatic, terrestrial and wetland resources and endangered species which may be directly or indirectly affected by the proposed Cleveland Innerbelt Project; (􀁹) Comply with state and federal requirements and policies ensuring that wetland resources and endangered species are taken into account as part of the overall project development and decision process; (􀁹) Evaluate any river, stream and/or wetland identified within the study area by utilizing the most current versions of the Qualitative Habitat Evaluation Index (QHEI) and the Headwater Habitat Evaluation Index (HHEI) and the Ohio Rapid Assessment Method (ORAM). Objectives should include 1) Evaluation of impacts on Lake Erie water quality should be added as an objective. 2) Evaluations of stormwater runoff impacts on uses planned for the Cleveland Lakefront. Hardcopy Page 16 (Section II, Subsection A) METHODS A. AQUATIC RESOURCES “The ODOT Ecological Manual (ODOT, 2005) sets requirements for data collection in aquatic systems. For streams where the drainage area upstream of the project location is greater than 200 mi2, full aquatic biological sampling is not required; a QHEI may be performed is possible (Rankin, 1989). Water quality and biological data for projects containing large streams may be extracted from published sources. The Cuyahoga River has a drainage area greater than 200 mi2 upstream of the project area, thus full sampling is not required for this project.” 1) Any potential contributions to the impairments as identified by the Lake Erie LaMP should be considered. 2) Any potential contributions to the impairments as identified by the Cuyahoga River Remedial Action plan should be considered. The RAP "Area of Concern" includes the Cuyahoga River and the nearshore areas of Lake Erie. 3) Methods should include evaluation of any impact on the goals and protection requirements established for the near shore areas of Lake Erie as an element of the Ohio Coastal Management Program. 4) An estimated range of pollutant concentrations should be developed based upon projected traffic density prior to the 55 of 80 Continued from previous page application of any BMPs to determine worst case discharge concentrations. These concentrations should be compared to Ohio Water Quality Standards to determine if there is a potential for the Innerbelt runoff to cause or contribute to a violation of water quality standards. Hardcopy Page 17 (Section III, Subsection B, paragraph 2) B. TOPOGRAPHY AND DRAINAGE “The Cleveland Innerbelt Project lies within the Lake Erie Coastal Zone Management Area. The Ohio Coastal Management Program (OCMP) oversees the management, use, conservation and development of the coastal area within the State of Ohio. Therefore, ODOT will need to contact the Ohio Department of Natural Resources, Office of Coastal Management prior to commencement of the Cleveland Innerbelt Project construction.” The Office of Coastal Management should be involved in review of the subject document and in early discussions regarding EIS review of alternatives for stormwater management. Hardcopy Page 20 (Section IV, Subsection A, paragraph 1, sentences 1—3) A. AQUATIC ECOLOGY 1. Existing Literature Description of the River “The Cuyahoga River is the sole aquatic feature mapped in the study area. The Cuyahoga watershed drains 813 mi2. From its headwaters in northern Geauga County, the Cuyahoga flows generally south to the Kent and Akron area.” Figure A shows that Lake Erie is a mapped feature of the study area. Chapter 4 should be revised to include a section dealing with the nearshore areas of Lake Erie. Hardcopy Page 21 (Section IV, Subsection A, paragraph 4) Summary of Recent Water Quality Studies In summarizing, water quality studies the report should consider the Stage 1 report of the Cuyahoga RAP. Water quality data and reports by the Northeast Ohio Regional Sewer District should also be consulted. Hardcopy Page 22 (Section IV, Subsection A, paragraph 10) Summary of Recent Water Quality Studies “Aquatic plants require a host of nutrients for proper growth. Perhaps the two most important are nitrogen and phosphorus. Excessive concentrations of nitrogen and phosphorus are found in the lower Cuyahoga. It is important to note that aquatic plants require a fairly specific ration of nitrogen to phosphorus for normal growth, generally around 7:1. Because 1) The TMDL for the Lower Cuyahoga also establishes limits for indicator bacteria. Highway runoff can, in some cases, be a significant source of bacterial contaminates. 2) As a discharge direct to Lake Erie is being considered, Nitrogen may be a significant nutrient in evaluating runoff impacts 56 of 80 both nutrients are essential, growth is generally limited by the nutrients present at the lowest concentration that is present at the shortest supply. In aquatic systems where the N:P ratio is greater than 10:1, phosphorus is the limiting nutrient. The average N:P ratio in the lower Cuyahoga was 19.5:1 in 2000, indicating phosphorus is the limiting nutrient in this system. The import for pollution management is that reductions in nitrogen would not likely result in changes in the biological indicators of eutrophication until phosphorus is first reduced. The TMDL for the lower Cuyahoga focuses on phosphorus reduction.” Hardcopy Page 23 (Section IV, Subsection A, paragraph 17) Continued from previous page Aquatic Summary “The TMDL for the lower Cuyahoga lists several causes of impairment that could conceivably be related to highway runoff. These include metals, other inorganic materials and oil and grease. However, it is doubtful that the interstate system in and near the study area makes substantial contributions to loads of these materials that reach the Cuyahoga. Cleveland occupies approximately 25,666 acres, with approximately 19,737 acres in the high density urban area. Estimates indicate approximately 87% of the city consists of impervious cover, roughly 17,000 acres. Total existing paved area within the entire Innerbelt project area is 96 acres, or approximately 0.5% of the total impervious surface within the urban core of Cleveland. The Innerbelt is surrounded by a massive amount of impervious surface within the urban core of Cleveland. Given the urban, paved nature of the center of Cleveland, and the small contribution the Innerbelt project makes to this total, it is unlikely that the Innerbelt alone makes a substantial contribution to the total pollutant load in the Cuyahoga.” 1) Following control of the combined sewer load which is scheduled in the same time frame as construction of portions of the Innerbelt, urban runoff will constitute a significant portion of the load discharged directly to Lake Erie. The impact of urban runoff occurs as a result of the cumulative impact of many discharges which may not by themselves be significant. This requires that all sources be considered for stormwater management. 2) The Ecological survey should estimate both the concentration and the pollutant load represented by current Innerbelt runoff. This information should be compared with water resource impairments. 57 of 80 Hardcopy Page 30, 1st comment (Section V, Subsection A, paragraph 4, sentences 1, 2,& 3) V. IMPACTS ASSESSMENT A. AQUATIC RESOURCES “It is important to note that the primary causes of impairment in the lower Cuyahoga River watershed are organic enrichment, nutrient enrichment, low instream dissolved oxygen, toxicity, sedimentation, and habitat degradation. Nutrient enrichment and organic enrichment are closely tied to each other in the Total Maximum Daily Load (TMDL) river segment. Due to the large number of Combined Sewer Overflows (CSOs) and sewage treatment plants in the TMDL subwatershed area, both appear as sources of non-attainment.” The TMDL report finds that pollutants from all named sources including urban runoff contribute to non-attainment. The fact that the TMDL establishes targeted reductions sewage treatment plants and CSOs should be noted. Specifically, the NEORSD Long Term Control Plan is recommended for the control of CSOs. WWTR plant discharges are target for specific phosphorus reductions. A general target is also established for other nonpoint sources, which would include urban and highway runoff. Hardcopy Page 30, 3rd comment (Section V, Subsection A, paragraph 4, sentence 4) V. IMPACTS ASSESSMENT A. AQUATIC RESOURCES “The remaining nutrients, at this time, are believed to be associated with phosphorus.” The thought intended to be conveyed by this sentence needs to be expanded/clarified. Hardcopy Page 30, 4th comment (Section V, Subsection A, paragraph 5, sentences 1 and 2) V. IMPACTS ASSESSMENT A. AQUATIC RESOURCES “Urban runoff is identified in the final TMDL report for the lower Cuyahoga River as a source of water quality impairment in the watershed. The report identifies specific pollutants of concern in storm water discharges for MS4s involving phosphorus and fecal coliform.” The specific reduction target for phosphorus should be noted Hardcopy Page 30, 5th comment (Section V, Subsection A, paragraph 6, sentences 3) V. IMPACTS ASSESSMENT A. AQUATIC RESOURCES “While highway runoff is assumed to be part of the urban runoff/storm sewers category, the report does not name transportation facilities as a “significant contributor” to the problems from a TMDL perspective.” Clarity is sacrificed in an attempt to use wording to verbally minimize the contribution of highway runoff. The matter is actually quite straight forward. Highway runoff is a component of urban runoff and urban runoff is identified as a significant contributor to problems. 58 of 80 Hardcopy Page 30, 6th comment (Section V, Subsection A, paragraph 6, sentences 5) V. IMPACTS ASSESSMENT A. AQUATIC RESOURCES “Along Cleveland Harbor front, discharges from existing CSOs, storm sewers, dredging, and lack of habitat are primary sources of pollutants of concerns and causes of impairment.” The "Cleveland Harbor front" should be defined as it is used in this paragraph. The source of this conclusion should be identified and the strength of the conclusion should be discussed. It should be noted that highway runoff is a component of wet weather discharges to the Cleveland Harbor front. Hardcopy Page 30, 7th comment (Section V, Subsection A, paragraph 7) V. IMPACTS ASSESSMENT A. AQUATIC RESOURCES “Given the extended time frame envisioned to complete all of the construction in this corridor, it is anticipated that many, if not all, of the Innerbelt construction contract groups will be constructed under a future NPDES Construction General Permit. ODOT will continue to work with the Ohio EPA to ensure that the BMPs selected for the linear transportation environment are appropriate, effective and maintainable.” According to the Ohio General Construction permit BMP's are to be selected to assure maintenance of Ohio's water quality standards. Hardcopy Page 30, 8th comment (Section V, Subsection A, paragraph 8, sentence 1) V. IMPACTS ASSESSMENT A. AQUATIC RESOURCES “In addition, ODOT is preparing a Separation Feasibility Study, as a means of assessing both the water quantity and water quality issues related to ODOT runoff currently being collected and conveyed by the North East Ohio Regional Sewer District combined system in the Central Interchange and Innerbelt Curve portions of the project.” This discussion should be expanded with more details of the scope of this study and the expected date of completion for this work. What water quality issues will be discussed that are not covered in the subject Level 1 Survey? Will the Separation Feasibility Study be sent to collaborating agencies for review as a part of the draft EIS process? Hardcopy Page 30, 9th comment (Section V, Subsection A, paragraph 8, sentence 2) V. IMPACTS ASSESSMENT A. AQUATIC RESOURCES “ODOT will also apply the current policy to address storm water runoff associated with the Central Viaduct Bridge portion of the project.” What "policy" is being referred to in this sentence? The applicability of the "policy" to particular circumstances should be discussed. In previous discussions and correspondence with the Transwac Subcommittee reference has been made to a policy that derives from the Ohio General Construction Permit. It would appear that the policy would not be controlling if application of the policy results in a violation of water quality standards. Further in this case the application of any "policy" would only be appropriate after a showing thru the EIS process that the policies application will 59 of 80 appropriately consider the publics interest in environmental protection as required by NEPA. 60 of 80 61 of 80 62 of 80 63 of 80 64 of 80 65 of 80 COMMENTS FOR CLEVELAND INNERBELT CORRIDOR STORM WATER BEST MANAGEMENT PRACTICE REPORT 8/17/07 INTRODUCTION The subject report as a tool to consider BMPs may does not appear to be fulfilling a particular policy or regulatory requirement. Accordingly, the report could be viewed as a preliminary engineering report which provides background information as a precursor to a design effort. In this situation, there is wide latitude in defining the level of detail which is appropriate. The subject report typically limits itself to providing guidance in the selection and design of appropriate storm water management practices. It should be acknowledged that the report does a good job in pulling together a substantial amount of information which is relevant to the design and selection process. The following comments are prepared in the context of the belief that specific environmental and water quality concerns should be addressed at a reasonably early juncture in the planning process, certainly prior to the publication of a draft Environmental Impact Statement for the project. Unfortunately the subject report, at least at this draft stage, misses an opportunity to go deeper then a cursory look at water quality issues. Had it done so, its guidance to designers in the selection of BMPs may have been significantly different. In addition it may have pointed up the need to consider issues such as planning for right-of-way for storm water management prior to the design phase. The public record for the project has previously made the case that ODOT should take into account specific concerns related to the receiving water bodies and the unique opportunities to provide a storm water management approach that will have flexibility to care for these important resources for the long term. To generate effective solutions that will meet these goals ODOT is encouraged to engage in a level of analysis that goes well beyond the requirement of the applicable current general storm water permit or the standard practices as defined in its own current Location and Drainage manual. OVERVIEW COMMENTS 1. The stated purpose of the subject document is to present proposed BMP practices. The purpose statement presupposes that following the application of appropriate BMPs, storm water discharges will not cause or contribute to the violation of water quality standards. In reality, where there is an expectation that water quality standards would be compromised, additional measures beyond BMPs are required to comply with Ohio Water Quality Standards. The public record for this project has raised the issue of DRAFT 66 of 80 potential violations of water quality standards related to heavy metals in both dissolved and solid forms. The public record has also cited scientific literature, which raises the potential that the combined characteristic of high-traffic count highway runoff may have general harmful effects on receiving water quality. Further ODOT’s letter to NEORSD of May 29th, 2007, provided in Appendix W of the report, notes the intent to install BMPs to address water quality requirements. Despite documented water quality concerns and ODOT’s pledge this report has given very little consideration to specific issues of water quality in selection of BMPs. It should be noted that the report does is several places acknowledge the existence of a Total Maximum Daily Load report (TMDL) for the lower Cuyahoga. However, even for this issue the report fails to identify specific goals which would appear to be applicable to the project. Lacking specific goals for pollutants of concern, the report does not factor into its BMP recommendations the specific pollutant removal capabilities of BMP options. 2. NEORSD acknowledges that there may be areas where removal of drainage from the combined sewer system might represent the highest value option depending on a number of case specific factors. For example, separating out highway storm water may be the most cost-effective solution to reducing combined sewer overflows in some instances. During the preparation of its Long Term Control Plan, NEORSD did not have the benefit of understanding what changes to the highway system were anticipated or possible. The potential to use storm water to create environmental features such as a constructed wetland might be also present an important opportunity which weights in favor of separation of storm water from the combined sewer system. The assessment of environmental benefits, however, requires the consideration of a number of factors. The report’s approach of claiming environmental benefit simply by virtue of reduction of hydraulic load to a combined sewer system is overly simplistic as a standard for guiding selection of BMPs. In some cases storm water separation may be a wise choice, because in specific instances it might represent the most cost effective way to reduce the pollutant load on the environment. In other cases the Long Term Control Plan proposed by NEORSD may be the most effective approach to reducing the pollutant load seen by the environment both for separate storm sewered areas currently going to the system and also for separate storm sewered areas not presently discharging to NEORSD. Attachment A was prepared to help illustrate some of the key variables that would affect an assessment of which option results in the smallest pollution load to the environment. The standard for comparison is discharge to NEORSD’s proposed system as specified in its Long Term Control Plan. (i.e., Limiting CSOs to 4 discharges per year.) It is assumed that additional capacity would be added to the collection and storage system for any new storm water sources to meet the same level of capture efficiency. As shown by these example calculations, key variables include the capture efficiency of the combined sewer system, the capture efficiency of the alternate system which would provide treatment of separate storm water, the relative difference in pollution loads represented by combined sewage and storm water runoff and the respective treatment efficiencies of NEORSD’s central treatment facilities and the storm water treatment that would be provided for Innerbelt runoff. The calculations show that that the outcome is somewhat specific to the pollutant being considered. Still, important generalizations can be discovered in these simple calculations. Particularly, these calculations suggest that for metals and a number DRAFT 67 of 80 of typical conventional pollutants the separate storm water treatment efficiencies would have to be quite high (for example in the range of 65 to 70% range) to result in an equivalently low pollution burden to the environment even if the new separate storm water treatment system is credited for 100% capture of all wet weather flows. Such high levels of removal are not typical for many storm water BMP practices. Some value in favor of separate treatment might be claimed where there is a lag between treatment of storm water that would be provided by new Innerbelt treatment facilities and construction of particular elements of NEORSD’s proposed system. But even in this case calculation should be done as the high removal efficiency of NEORSD’s treatment facilities may outweigh the treatment efficiency of a selected BMP enough to compensate for the combined sewer overflow that would result by adding storm water flow to the existing collection system. Further, in some cases it would appear that options exist to design highway drainage facilities to regulate or transfer some or all of the flow from separate sewer systems only after construction of new NEORSD storage facilities are complete if they lag ODOT project construction.. 3. Both ODOT and NEORSD have been encouraged by the TRANSWAC work group of the NOACA Transportation Advisory Committee to cooperate in analysis of the option of using NEORSD’s collection system and centralized treatment system as a storm water management tool for area’s not currently connected to the system. (This could include full or first flush capture.) Early in this process ODOT identified its need to be able to project future charges for water management for discharges to NEORSD’s centralized collection system. NEORSD noted that it does not presently have a storm water charge structure and in fact has yet to make basic decision would greatly affect any future rate structure. This past summer, NEORSD provided a letter to ODOT suggesting an approach that might assist ODOT in estimating the cost-effectiveness of storm water management via discharge to central treatment facilities. Particularly, NEORSD suggested that the matter be approached by conducting a “present value” analysis for various treatment options without consideration for which pubic agency would be paying for the cost of treatment. The logic is that collectively our respective agencies should be concerned with the overall lowest cost for the public independent of how public revenues are collected. To further this suggested approach NEORSD provided both specific cost data and approaches for obtaining other cost data which could be used in a “present value” analysis. Unfortunately it appears that ODOT has chosen not to consider the cost effectiveness of treatment via discharge to centralized facilities where separate storm water is not already being handled in this manner. While we acknowledge that centralized treatment may be more costly then other storm water management options, both costs and the benefits of the reduction of pollutants provided by centralized treatment of storm water should be considered for specific cases. 4. The report could be improved by adding a planning level estimate of potential increases in drainage area for each of the drainage segments identified in the report. 5. The report could give more attention to the matter of phosphorus reduction where there is an anticipation of separation and discharge to the Cuyahoga River. The Cuyahoga DRAFT 68 of 80 TMDL sets targets for phosphorus reductions for non-point and storm water discharges. Accordingly it would be appropriate for ODOT to consider at this planning stage how treatment of highway run off can help to achieve TMDL goals. There is a presumption in the TMDL report that current and future storm water regulations will result in appropriate phosphorous loading reductions. At the current planning stage this would logically involve development of a planning level estimate of current and projected phosphorus loads along with an analysis of storm water management treatment options that are capable of achieving the goals of phosphorous reduction. 6. The report does not clearly summarize those areas where options to make changes in current drainage patterns will potentially impact local sewers. The report could also do a better job of identifying the issues that changes in drainage patterns might present for the City of Cleveland. Identifying these issues now would be valuable to the City’s current asset management efforts. For example, ODOT actions to separate certain pipes from the combined sewer system would likely result in storm water quality management requirements for areas of Cleveland. It could also raise the issue of whether adjacent drainage areas should also be converted from combined to separate sewers. An ODOT plan to construct new (perhaps larger outlet pipes) offers an opportunity for the City to consider complementary changes in its upstream system. Perhaps there is a need for additional capacity to solve upstream flooding problems. Conversely, there may be areas where the best overall solution for storm water management involves joint efforts between ODOT and Cleveland to direct separate storm water or at least the first flush of storm water to the central combined sewer system. 7. Potential solutions to direct storm water to the Cuyahoga River may present special challenges and opportunities. An early consideration of these challenges and opportunities is appropriate as various entities are actively seeking to improve the water quality and surrounding environment of the Cuyahoga. The report identifies land below the proposed new Central Viaduct Bridge for the joint purposes of construction access and subsequent storm water management. Bio-retention cells were mentioned as potential appropriate innovative technologies for this location. It appears that wetland treatment was ruled out as not practical “upfront” due to lack of space and cost. The potential value of bio-retention areas and wetland treatment for several other project drainage areas should be reconsidered. First, the need to achieve water quality goals may require these more aggressive forms of storm water management. Second there may be appropriate space that should be considered for these technologies. For example the “Tregate” district of the Cuyahoga Valley Initiative is within a reasonable distances of potential storm water discharges from proposed improvements for the central interchange and all three I-77 improvement drainage catchments. Further, the Cuyahoga Valley initiative has specifically targeted the Tregate district as an appropriate place for naturalfeature storm water treatment. It is recommended that ODOT enter into early discussions with environmental planning water resource management agencies to explore possibilities for projects which would assist in meeting storm water management goals and help to create desirable environmental features. DRAFT 69 of 80 9. The report widely recommends exfiltration trenches as stand alone BMP storm water treatment technology. Exfiltration trenches appear to be a new or experimental technology. Given the report’s recommendations heavy reliance on this technology the report should discuss the mechanisms and expected effectiveness of this technology in removal of pollutants which are expected to occur in highway runoff. 10. The subject report does not discuss non-structural approaches to minimize the pollutant load form the project. It would seem that non-structural approaches, such as advanced sweeping and deicing measures, should be considered along side structural approaches as a complementary management measures. The provision of non-structural might appropriately influence the selection of structural BMPs. EXECUTIVE SUMMARY COMMENTS Page E-2 In Table ES-1, under “Potential Best Management Practices Identified” Comment: The study fails to adequately consider connection of current separate sewer areas to the combined sewer. The alternative of capture of the first flush of separate storm run off should also be considered Page E-3 Comment: The study seems to have focused on the narrow objective of reducing hydraulic stresses to minimize overflows. NEORSD has developed an independent plan with this same objective. ODOT should be concerned with the large perspective of choosing an appropriate level of treatment which result in appropriate treatment of pollutant loads from it facility. SECTION 1 COMMENTS Page 1 First paragraph, first sentence: The objective of the report is to ….present proposed project Stormwater Best Management Practice (BMP) Comment: A major theme of these comments and of previous work by the TRANSWAC work group has been to encourage consideration of appropriate storm water management to address water quality of concerns. In doing so ODOT may have to look beyond what it considers Best Management practices. While the focus of the general permit covering ODOT’s discharges is on Best Management Practices, sections of the permit also clearly establish that the NPDES permit is not the final authority where water quality is at issue. Additionally, ODOT should consider the larger context of this project. Treatment of stormwater should be selected in consideration of the opportunities to provide protection to the lakefront and the Cuyahoga. Consideration should also be given to the creation of environmental features which would add value to the community. SECTION 3.1 COMMENTS DRAFT 70 of 80 Page 15 Decisions Box: Bullet 1: Comment: The report suggests that NEORSD’s Long Term Control Plan (LTCP) contains no system capacity information. In fact extensive sewer system modeling was done as a part of development of the LTCP with the purpose of developing system capacity information and identifying new system elements. Is this a matter of attribution of different meanings to the term “system capacity”? Page 15 Bullet 3: Comment: As noted in our general comments and elsewhere it is inappropriate for ODOT to solely focus on improvements to the “combined sewer system” or “reduction of combined sewer overflows”. These are also objectives of a planned major improvement embodied in the LTCP. NEORSD appreciates ODOT’s cooperation in identifying costeffective ways to accomplish these objectives. However, ODOT is also encouraged to focus on the cumulative impact of its project and the contribution the project make to addressing water quality issues. Page 15 Bullet 3 in the Decision box: Comment: The report notes the close cooperation that will be needed between ODOT and NEORSD during the design phase. Particularly, it it noted that ODOT should plan to work closely with the District staff including the CSO program management team to ascertain proposed benefits and impacts of ODOT action or proposed alternatives. Page 17 Fourth bullet, the third sub-bullet suggests that OEPA regulatory criteria were considered as part of the strategy of developing BMP recommendations: Comment: The report does not address the potential role of water quality standards and provides only a cursory analysis of the contributions that the project will make towards TMDL reduction goals. Comment: The selection of BMPs should be influenced by the ability of the BMP to address pollutants which are of concern for the particular receiving water body. Page 17 Third paragraph: Comment: Additional discussion of the relations between the various flow charts should be provided either here or in Appendix K for improved clarity. Page 18 First paragraph, second sentence notes suggest that in agreement with Ohio EPA BMP selection no longer requires that a feasibility study be performed in support of the BMP selection. A letter from Ohio EPA in Appendix E is referenced. DRAFT 71 of 80 Comment: The referenced letter does not address whether or not feasibility is appropriate in support of BMP selection. Regardless of ODOT’s standard policy, it would appear that the complexity of the Innerbelt project, the value of the resource being protected, the existence of TMDL goals, the potential for the project to result in violations of water quality standards, the heavy reliance on the new or experimental technology of exfiltration trenches, and the opportunity to create environmental features all suggest the appropriateness of a feasibility study in the selection of BMPs. SECTION 3.2 COMMENTS Page 21 Figure 6 – Final Project Approach for BMP Selection: Comment: The approach as shown in the table does not take into account the role of Water Quality Standards. Neither does the approach consider the net impact of removal of drainage from the combined sewer system or the potential timing of removal. The desired level of service for municipal separate storm sewer systems does not appear to have been considered. Page 22 First paragraph/bullet on page, third sentence: Comment: The lack of discussion regarding the role of water quality standards is noticeably absent. The goals set by the TMDL for phosphorous reduction are not discussed here or elsewhere in the report. Page 22 Third bullet second sentence: identified to have value to be separated from combined sewer systems. Comment: As previously state the report does not support its statements of “value” with environmental burden estimates or a cost-effectiveness analysis for alternatives. Page 22 Fourth bullet: Comment: The text here references Section 4.4 as providing some detail on the requirements of the Cuyahoga TMDL. Section 4.4 does not provide applicable details. In particular, there is no discussion of the reduction goals applicable to storm water discharges. SECTION 4.1 COMMENTS Page 24 First paragraph, first sentence: Comment: Replace typo “R” in “BMPR” with “s”. Comment: Ohio Water Quality Standards should be noted as a potential driver in BMP selection. DRAFT 72 of 80 SECTION 4.4 COMMENTS Page 27 Fifth paragraph: Non-regulatory heading Comment: “Non-regulatory” may not be the most appropriate descriptor for TMDL goals. The goals for phosphorus reduction in the TMDL are part of Ohio’s State Water Quality Management Plan. Further, there is a presumption that current regulatory programs, for example storm water permitting will result in the achievement of TMDL goals. At the same time there is an expectation that dischargers and regulating authorities will be evaluating actions to achieve TMDL goals at various decision mileposts. SECTION 5.1 COMMENTS Page 29 First paragraph regarding the cost of NEORSD’s Long Term Control Plan.(LTCP) Comment: The most recent cost estimate for implementation of the LTCP is $2.3 billion as opposed to the 1.6 billion noted in the report. Also note that the LTCP calls only few separation projects. Sewer separation needs to be carefully assessed to assure that it results in positive environmental benefits. SECTION 5.2 COMMENTS Page 30 Second paragraph: Comment: In describing the evaluation process and discussing NEORSD system capacity the report does not make a distinction between the current system and NEORSD’s proposed Long Term Control Plan. Acknowledgement that implementation of the LTCP will dramatically increase system capacity would be appropriate. Comment: This paragraph may be the only point at which the report acknowledges that separation of storm water from current centralized treatment system needs to consider water quality concerns at the new outfalls. However, the report does no further investigations along these lines. Further, the report does not investigate the potential that discharge points not now connected to the central system may now or under the expanded project carry pollutions loads which would raise water quality concerns. The report does not consider connection of drainage areas that are now separate where water quality concerns may be at issue. Page 31 Fifth bullet “step 7”: Comment: Again ODOT seeks to attribute value simply to the reduction of hydraulic loading and presumed resulting decrease in CSO volume without consideration of the impact of its decision on the annual loading DRAFT 73 of 80 as seen by the receiving water body or other factors of environmental benefit. SECTION 5.3 COMMENTS Page 37 Subsection 5.3.2, first paragraph has The CSO control strategy recommends separating …... Comment: Suggest clarification by noting that it is NEORSD’s Long Term Control Plan that is the basis for the recommendation. Page 37 The CSO 235 Information box suggest their in no LTCP for control of CSO 235 Comment: The District’s March 25th 2005 LTCP call for construction of the Canal Avenue in-line storage system, a Stone Levee storage tank, and upgrades to the Stone Levee pump station and regulator E-24 to provide appropriate controls. Page 39 Subsection 5.3.3, Third sub-bullet suggests that one option would be to provide a storm only pipe with in the project right-or-way. “NEORSD would need to determine how to convey flows to the shoreline Tunnel.” Comment: NEORSD records indicate that the District currently owns an existing conveyance sewer within the right-of-way for the wet weather discharge of regulator E-09. Perhaps the comment is meant to suggest that NEORSD might choose to route E-09 flows to the Shoreline Tunnel and CSO 098 by an alternative conveyance system. Comment: Two logical options are not considered. Consideration should be given to capture of the first flush of runoff from the trench area in NEORSD’s proposed Shoreline Tunnel. SECTION 5.6 COMMENTS Page 44 Subsection 5.6.1, first paragraph, second bullet, last sentence: ODOT’s drainage design methods and criteria will govern Comment: The need to coordinate with the City of Cleveland where upstream Cleveland flows are involved is noted elsewhere in the report but would probably be appropriately mentioned here as well. SECTION 6 COMMENTS Page 45 Preliminary BMP Stormwater Project Drainage Information Comment: Planning level estimates of current and future drainage area estimate are not included in the report but may be important in selection of appropriate treatment measures. SECTION 6.4 COMMENTS DRAFT 74 of 80 Page 52 Central Interchange/I-77 Approach/I-77 Drainage Comment: Suggest coordination with the Cuyahoga Valley Initiative to investigate whether area is available for detention or wetland treatment as an option to discharge through Kingsbury Run culvert to the Cuyahoga. SECTION 7 OVERVIEW COMMENT Table 10 of Section 7 suggests that the report’s analysis would consider the possibility of connecting currently separate sewered areas to the centralized combined sewer area as a form of storm water management. The option of connection of currently separate sewered areas only for capture of a first flush of storm water is not mentioned as an option. The chapter goes on to develop criteria to be use in making decisions about storm water management. Water quality concerns/issues are not listed as a criteria to be considered in selection of storm water management treatment options. The report does not contain discussion or data related to the application of suggested criteria to arrive at stormwater management recommendations. Further, there is no discussion of why initially mentioned options, such as connection to area’s centralized treatment facility, were not carried forward as a viable option. SECTION 7.2 COMMENTS Page 57 First paragraph: Comment: Add bullets “Water Quality Concerns” and “Opportunities for environmental features.” Comment: The potential for spill of hazardous materials and impact those spills might have on treatment units and the receiving waters should be a factor in selection of stormwater treatment options for this project. Page 58 Table 10, Comment: Other criteria such as receiving water quality regulations/issues/concerns and effect on net loading of pollutants would be appropriate criteria to add to this table. Comment: For the option “Discharge to local combined system” it does not seem logical to list Waste Water Treatment Plant capacity as a concern. The flows from most local systems of any size are controlled by regulating structures prior to the plant. Comment: The option of “Discharge to NEORSD interceptors” needs further explanation to distinguish this as an option different from “Discharge into a system upstream of NEORSD regulator. Page 59 First paragraph, second bullet, fourth sentence: word choice “are” . Comment: Consider “include.” rather then “are” DRAFT 75 of 80 Page 59 First paragraph, third bullet, fourth sentence: where ODOT could have a positive impact within the combined sewer system (i.e., potentially reduce the number of overflow events). Comment: As previously noted creating separate sewer discharges to reduce CSOs may or may not benefit the environment in comparison with other alternatives. Page 59 First paragraph, fifth bullet: Will right-of-way be purchased. . Comment: ODOT should consider purchase of right-of-way for environmental controls as opposed to the limited case of consideration of environmental controls in right-of-way purchased for other project reasons. Treatment options should not be limited soley by their suitability for the existing or proposed right-of-way for construction purposes. SECTION 7.4 COMMENTS Page 64 First paragraph Comment: Overall report clarity might be enhanced by making a distinction between BMP treatment methods and other levels of treatment which may be needed to address water quality issues. Page 64 First paragraph, fourth bullet, first sentence Comment: The potential for separate sewer discharges to cause violations of water quality standards should be noted and considered as a design constraint. SECTION 7.5 COMMENTS Page 66 Supplemental Information for System Inventory and Connection/Separation Options Comment: It appears as though the two bullet points above this section actually belong in this section. Page 67 Discussion of criteria for determining whether to separate stormwater runoff from combined sewer areas. Comment: While TMDL requirements are noted, assuring compliance with Water Quality Standards is not noted. Also selection should consider the need to protect the specific features of the receiving waters. Comment: As previously noted creating separate sewer discharges to reduce CSOs may or may not benefit the environment in comparison with other alternatives. Comment: The report identifies potential criteria but does not document how these criteria were applied to arrive at the recommendations of the report. DRAFT 76 of 80 Page 73 Subsection 7.5.3 Comment: The option of discharging storm water to the combined sewer system as identified in Sec 7.2 is dropped from the scenario list without justification or mention. Page 73 Subsection 7.5.3, third paragraph, bullet section Comment: Table 16 would be improved if the constraints presented on this page where given a number and identified in Table 16. Page 74 Subsection 7.5.3, second paragraph: Comment: First flush capture of storm water for centralized treatment should be considered. Page 74 Subsection 7.5.3, fourth paragraph, first sentence: Comment: “Up front” elimination of certain technologies for cost or other constraints may not be appropriate considering the goals of the TMDL and the need to protect water quality standards. Comment: Constructed wetlands should be considered as a possible option at the mouth of Kingsbury Run. SECTION 8 COMMENTS Page 92 First paragraph, first bulleted section discussing design conclusions: Comment: Consider should be given to designing the drainage system to isolate or clean up hazardous material spills. Comment: The inclusion of structures appropriate for separate storm water sampling and accurate flow metering should be noted as a design consideration. TABLE 15 COMMENTS Page 7 of 7 General notes: Comment: The note G under “General Notes” seems to be designed to identify specific drainage areas where quantity issues may be a factor. While the table does not appear to make use this footnote, doing so could provide some very helpful summary information. A general note identify where interaction with the Cleveland will be needed might also be a helpful feature. TABLE 16 COMMENTS Page 1 Drainage Area and BMP comments: Comment: The notes discuss potential limitations in the use of ramp infield areas for BMPs. It would be helpful for the report to identify what BMPs have been allowed in in-field areas. DRAFT 77 of 80 Comment: The notes suggest that below grade detention may not be feasible near Lake Erie. More justification should be given for this statement. Note that the standard in-right-of-way drainage conveyance system can itself be designed to create detention volume. Supplement parallel storage pipes could also be considered. Previous comments by the NOACA TRANSWAC work group recommended consideration of pumping to above grade storage which could be covered. This alternative does not appear to have been considered. DRAFT 78 of 80 ATTACHMENT A TO COMMENTS ON ODOT BMP REPORT --page 1 Scenario: 97% capture of wet weather flows by future CSO collection system CSO pollutant strength is estimated at 2.5 times that of stormwater (See note 3) Assumes that if new stormwater area is added to the combined sewer system appropriate storage volume will be provided to maintain 97% capture NEORSD treatment plant pollutant removal efficiency is estimated at 70% (See note 3) Treatment efficiency for separate stormwater treatment assumed to be 60% (see note 1) Assumes the same delivery volume and hydraulics from the separate and combined sewer catchment (see note 2) ENTRY OF DATA ASSUMPTIONS: Fractional loss Fraction capture fraction removed fraction not removed Capture efficiency 0.03 0.97 Treatment efficiency NEORSD centralized system 0.7 0.3 Stormwater treatment 0.6 0.4 A1-CSO B1-Storm ototal flow C1-storm added to combined Relative strength 2.5 1 Not Applica 1.75 1 1 2 Not Applicable Assume capture efficiency for separate stormwater treatment at 100% LOAD CALCULATIONS: System A1 is a combined sewer system; the environmental burden is estimated as follows: 1 0.03 2.5 + 1 0.97 0.3 2.5 = 0.8025 pounds volume units (million gallons) fraction Not captured relative concentrat ion (lbs per million gallons) volume units (million gallons) fraction captured fraction not removed by treatment relative concentrat ion (lbs per million gallons) 0.075 0.7275 System B1 provides treatment of separate stormwater, pollutant strength is only 1/2 that of combined sewage, the envir. burden is estimated as follows: 1 0 1 + 1 1 0.4 1 0.4 pounds volume units (million gallons) Not captured relative concentrat ion (lbs per million gallons) volume units (million gallons) fraction captured fraction not removed by treatment relative concentrat ion (lbs per million gallons) = Adding the load from system A1 and B1 gives an estimate of the total load to the environment. For this scenario the result is: 1.2025 pounds 2 0.03 1.75 + 2 0.97 0.3 1.75 = 1.1235 pounds volume units (million gallons) fraction Not captured relative concentrat ion of combined waste stream ( lbs per million gallons) volume units (million gallons) fraction captured fraction not removed by treatment relative concentrat ion of combined waste stream ( lbs per million gallons) 0.105 1.0185 CONCLUSIONS: The load to the envir.from systems A1 plus B1 is 1.2025 pounds Compared to the load from system C1 of 1.1235 pounds In this example the load to the environment would be 6.5% less by treating the separate storm water in the combined sewer system -0.0657 System C1 is created by adding the storm water of B1 to sytem A1 (the combined sewer system) and increasing system capacity to provide the same capture as system A1. The environmental load burden is estimated as follows: Relative volume units Note 1: This analysis assumes a treatment efficiency of 60% for the separate stormwater treatment system. This is a high level of efficiency even for BMPs which rely on significant water detention. Significant water detention is not the general direction of BMPs proposed for the Innerbelt project. Note 2: Changing the relative volume of combined sewage vs separate storm water will change the percentage value generated in comparing the two systems. However it does not change which alternative yields the lowest environmental load to the environment. In the above specific scenario the higher the ration of stormwater to CSO the more dramatic the difference. Note 3: The relative strength of combined sewage vs urban stormwater runoff was generated form data collected for the Phase 2 Southerly facilities plan. See page two of this attachment. The efficiency of NEORSD treatment plant was estimated by looking at typicaly performance data for the Easterly treatment plant. Some of this data is also on page two of this attachment DRAFT 79 of 80 ATTACHMENT A TO COMMENTS ON ODOT BMP REPORT --page 2 RELATIVE STRENGTH OF CSO VERSUS PURE STORMWATER DRAINAGE FROM URBAN AREA Calculation of relative strenght using data from Southerly Phase 2 Facility Plan Cd Cr Cu NH3 Pb TP TSS Zn CSO 3.13 73 43.7 0.78 48.7 0.61 102 117 Storm 1.76 24 25.6 0.33 43.2 0.22 31.7 44.7 Relative strength 1.78 3.04 1.71 2.36 1.13 2.77 3.22 2.62 2.33 Conclusion: Two is a good estimate of relative strength if E coli is not considered ANALYSIS OF EASTERLY PLANT REMOVAL EFFICIENCY FOR METALS FROM MONTHLY PLANT 4500 REPORTS Metals data in micrograms per liter. Phosphorus data in milligrams per liter Cd, Cd fractional removal Cr Cr fractional removal Cu Cu fractional removal Pb Pb fractional removal TP TP fractional removal Zn Zn fractional removal 1/07 Average Raw 1.0 14 36 14.0 2.25 106 1/07 Average Final 0.5 1.2 9.8 0.1 0.38 0.83 23 0.50 0.91 0.73 0.99 0.78 2/07 Average Raw 0.0 16 40 15.0 2.72 130 2/07 Average Final 1.0 1.3 10.6 0.0 0.49 0.82 25 #DIV/0! 0.92 0.74 1.00 0.81 3/07 Average Raw 0.0 12 33 16.0 1.85 90 3/07 Average Final 0.7 1.7 9.5 0.0 0.33 0.82 32 #DIV/0! 0.86 0.71 1.00 0.64 4/07 Average Raw 1.0 19 43 7.0 2.05 120 4/07 Average Final 0.3 1.3 12.6 0.1 0.57 0.72 22 0.70 0.93 0.71 0.99 0.82 5/07 Average Raw 0.0 16 48 5.0 2.63 98 5/07 Average Final 0.3 0.5 10.2 0.0 0.51 0.81 18 #DIV/0! 0.97 0.79 1.00 0.82 6/07 Average Raw 2.0 15 47 15.0 2.66 114 6/07 Average Final 0.4 0.7 8.8 0.0 0.36 0.86 23 0.80 0.95 0.81 1.00 0.80 7/07 Average Raw 0.0 46 43 13.0 2.54 92 7/07 Average Final 0.2 0.7 9.1 0.0 0.51 0.80 17 #DIV/0! 0.98 0.79 1.00 0.82 8/07 Average Raw 1.0 17 41 22.0 2.06 86 8/07 Average Final 0.3 1.1 9.9 0.2 0.42 0.80 34 0.70 0.94 0.76 0.99 0.60 9/07 Average Raw 0.0 16 40 11.0 2.76 83 9/07 Average Final 0.2 0.6 7.7 0.0 0.49 0.82 15 #DIV/0! 0.96 0.81 1.00 0.82 10/07 Average Raw 1.0 16 44 0.0 2.72 110 10/07 Average Fina 0.2 1.7 8.8 0.0 0.51 0.81 18 0.80 0.89 0.80 #DIV/0! 0.84 11/07 Average Raw 0.0 19 56 16.0 2.18 111 11/07 Average Fina 0.3 2.2 11.4 0.4 0.47 0.78 22 #DIV/0! 0.88 0.80 0.98 0.80 12/07 Average Raw 5.0 18 36 7.0 1.85 95 12/07 Average Fina 0.3 2.2 12.4 0.4 0.33 0.82 26 Yearly Ave. 0.94 0.88 0.66 0.94 0.81 0.73 For E. coli use 99% reduction is a conservative estimate of treatment plant performance CONCLUSION Use an overall removal eff. of 70% for analysis of pollutant reductions applicable to highway drainage, other then E. coli LAStumpe 3/12/08 DRAFT 80 of 80
Andy Vidra1299 Superior Avenueavidra@mpo.noaca.orgClevelandOH44114
  
We are located on the south Margin between 38th & 40th Street. Our temperature controlled dock is located on 38th street. We currently use the parking lot located across from the dock (The Mounted Police) for the trucks to be able to back into the dock. In the newest proposal for the Innerbelt Project it looks like the access to 38th street will be significantly changed. We would like to review the details of the proposal and how it will affect our business. We would also be open to review what are the other alternatives. the
Tempcraft (Michele Slotta)3960 South Marginal Rdmichele.slotta@alcoa.comClevelandOH44114
  
Craig, The Innerbelt Plan as proposed may accomplish many of the traffic safety and interstate congestion reduction benefits targeted; however, it is unfortunate that this near $2 billion investment appears to offer little to actually improve Cleveland as anything other than the sum of its roadway infrastructure. The Draft Environmental Impact Statement speaks only briefly of Land Use and Development Impacts as if having no or only minor negative impacts are somehow adequate validation for construction of the project as conceived. Potential major positive opportunities were evidently not a part of the study scope and may not have been adequately foreseen by Cleveland’s Comprehensive Plan and as such are not documented. The following three general questions are for your consideration: Assuming the northern alignment of the new WB Central Viaduct is the right alternative, why not relocate EB I-90 to this alignment as well? The current approach seems to consume a lot of land with a substantial zone of ground in Tremont and in the flats between the bridges with limited potential. This negates potential positive aspects of the realignment. (Also I am not sure why we would not build one new bridge and have it over with – a single new alignment would support this possibility or allow for phasing foundation or other construction for a future second span which could then be built “off-line” for MOT considerations.) Secondly, with reference to Figure 4-12, could the East Shoreway be downgraded from limited access to allow for at-grade signalized intersections, eliminating the need for extensive ramps, numerous bridges, frontage roads,and the additional right of way required to soften the Innerbelt Curve? Maintaining this short high speed highway form I-90 to the Rock and Roll Hall of Fame seems unnecessary, particularly in light of the Lakefront West project. Converting the entire Shoreway to an urban boulevard (without grade separated intersections, pedestrian tunnels, etc.) would seem to offer significant opportunities for redeveloping and reconnecting Cleveland’s lakefront by eliminating roadways as obstacles and eliminating the need for redundant marginal roads and other excess infrastructure. Does further discussion of relocating the Port support this opportunity? I am not sure why this may not have been included in the original Innerbelt project planning. Lastly, again with reference to Figure 4-12, the Central Interchange already imposes a big footprint and the proposed project appears to increase this footprint. The proposed changes appear focused on adjusting the existing geometrics rather than contemplating a better solution. As the northern alignment already forces construction with retaining walls, could the Interchange incorporate single point interchanges or a continuation of the Trench to the Cuyahoga River to truly reduce the impacts of the project? At a minimum, could ramp alignments be critically reviewed to ensure that they closely align with the mainline, avoid loops, avoid excessive length, or are configured to meet local street intersections wherever possible? While a northern bridge alignment may have merits a more southern interchange alignment also seems beneficial from a Land Use standpoint in respect to the Gateway investments. A hybrid “Option A-B” could generate broader support, but would require bolder and more creative thinking for the Interchange than simply enlarging the loops. Not only would a reduced footprint reduce right of way and other project impacts, it may reduce construction and maintenance costs as well while again presenting opportunities for redevelopment. More specifically: Exhibit A, Sheets B and C – Consolidating the EB and WB alignments would seem to free up significant amounts of space, lessening the project impact, and actually creating redevelopment opportunities throughout Tremont and the flats. Exhibit A, Sheet B – A straight WB exit ramp to Fairfield in lieu of the loop ramp with a local road connection back to Abbey would significantly reduce the impact to this area. Exhibit A, Sheet C – An approach to the realignment of Commercial Road that eliminates the need to maintain the “dogbone” remnant of the existing road with 2 cul de sacs should be pursued to reduce the impacts to this area. The depicted configuration has much unusable land and excess public infrastructure which might be avoided by negotiating access easements or otherwise preserving access to parcels fronting old Commercial Road. Exhibit A, Sheet C – Is there an alignment that would avoid crossing the EB I90 to E 9th Street exit loop with the WB I90 to SBI77 exit? This seems like a lot of infrastructure. Exhibit A, Sheet C – Is there a design alternative that would avoid the EB I90 exiting loop ramps? Could both E 9th Street and Ontario Street be served from a single loop exiting from I90? Exhibit A, Sheet C – Is there an alignment of NB I-77 to EB I-90 that would avoid impacts to the institutions. Exhibit A, Sheets C, G – Why is Community Avenue and East 14th Street separated? This seems to lead to excess ramp lengths and a lack of connectivity. Exhibit A, Sheets C, G – Could the EB I90 to Central Ave ramp be fitted more closely to the mainline? With the mainline realigned to the north additional take to the south seems unnecessary. Exhibit A, Sheet D – Why are there two exit ramps from WB I-90 to E 26th Street? Exhibit A, Sheet E – A reconceived Shoreway may accommodate a diamond interchange rather than free flow ramps, significantly reducing impacts in this area, reducing construction costs, and creating redevelopment opportunities. This could be a much more inviting entry point to downtown for traffic from the east without flyover ramps, confusing marginal roads, and overall excess pavement. Exhibit A, Sheet G – The Woodland Ave on ramp to I-77 NB seems to set up a weave with the I-77 exit to Community Avenue. Exhibit A, Sheet G – The NB I-77 ramp to East 22nd Street seems a little excessive. Could this link simply occur via Woodland? Could Woodland extend to 14th and 9th Streets? Thank you for considering the above comments, both “big picture” and “design adjustments” in preparation of the Final EIS.
Carl Frey418 Longbeach ParkwayBay VillageOhio44140
  
AS the South Bridge option is inferior to the North by so VERY little ... PROPOSED: the SOUTH BRIDGE splits EARLIER (shortly after crossing the River) -- a group of all 3 exiting lanes comng off (for Ontario, E. 9th, and E14th/and/18th-to-Carnegie), bending Right and then sweeping back WEST. Note these ramps curve COUNTERCLOCKWISE, not clockwise as at present. >> This allows an additional entry, leaving in fact well OVER the 2000 feet for a "weave" >> say coming from E. 18th and/or 9th & entering NORTHBOUND at a spot 2000 feet prior to the entry of I-77 Northbound) (this ramp is a clockwise turn) This is the much-desired RELIEF VALVE for the South half of Downtown -- SOOOO NEEDED because of the Baseball Stadium & two Arenas there. It cures the BIGGEST problem with this design -- the overload in the South half of town. PLEASE do not sluff this off. I was after all ASKED, at the meeting, to submit any design to solve this problem, that did not violate Federal Law. Your people said you wanted to, & discussed a whole bunch that didn't work -- but they sdidn't work because of LACK OF SPACE. In fact, you might even fit a 2nd extra off-ramp: 2000 feet after the split: going to Orange -- Southbound (unlike today, the proposed offramps have no Southbound feed ... but the real value of that is: a secondary split off this ramp gives a SECOND CHANCE ramp, continuing over Orange Ave. & either joining the E.18th option OR can just feed into 1 or more of the 3 major Streets, directly (Ontario, E.9, E.14/18), going NORTH ie, INTO downtown. In a day or so I'll likely have a crude sketch of this posted at myspace.com/custerwilson. Thank You, Charles Wilson
Charles Wilson550 E. Pleasant Valley Rd.custerwilsonaa@aol.comSeven HillsOhio44131
  
PS as my connection broke this may be a duplicate, if so my apologies: AS the South Bridge option is inferior to the North by so VERY little ... PROPOSED: the SOUTH BRIDGE splits EARLIER (shortly after crossing the River) -- a group of all 3 exiting lanes coming off (for Ontario, E. 9th, and E14th/and/18th-to-Carnegie), bending Right and then sweeping back WEST. Note these ramps curve COUNTERCLOCKWISE, not clockwise as at present. >> This allows an additional entry, leaving in fact well OVER the 2000 feet for a "weave" >> say coming from E. 18th and/or 9th & entering NORTHBOUND at a spot 2000 feet prior to the entry of I-77 Northbound) (this ramp is a clockwise turn) This is the much-desired RELIEF VALVE for the South half of Downtown -- SOOOO NEEDED because of the Baseball Stadium & two Arenas there. It cures the BIGGEST problem with this design -- the overload in the South half of town. PLEASE do not sluff this off. I was after all ASKED, at the meeting, to submit any design to solve this problem, that did not violate Federal Law. Your people said you wanted to, & discussed a whole bunch that didn't work -- but they didn't work because of LACK OF SPACE. In fact, you might even fit a 2nd extra off-ramp: 2000 feet after the split: going to Orange -- Southbound (unlike today, the proposed offramps have no Southbound feed ... but the real value of that is: a secondary split off this ramp gives a SECOND CHANCE ramp, continuing over Orange Ave. & either joining the E.18th option OR can just feed into 1 or more of the 3 major Streets, directly (Ontario, E.9, E.14/18), going NORTH ie, INTO downtown. In a day or so I'll likely have a crude sketch of this posted at myspace.com/custerwilson. Thank You, Charles Wilson
Charles Wilson550 E. Pleasant Valley Roadcusterwilsonaa@aol.comSeven HillsOhio44131
  
1) I do not feel that the construction of an additional bridge is ideal for the city or the property owners involved and urge O.D.O.T. to abandon the idea. 2) As a compromise, I would consider having the existing Innerbelt Bridge reconstructed and expanded to eight lanes plus express lanes. 3) The best idea that accommodates the present and future is a new Innerbelt bridge over the current alignment that A) accommodates highway traffic and B) a rail transit system. 4) Further, I want a bi-level bridge that has eight lanes of traffic, plus express lanes with accommodations for pedestrians and bi-cyclists on the upper level and a rail system on the second. As a reference, see Lorain-Carnegie Hope Memorial Bridge. 5) Noise barrier walls should not be built unless requested. 6) Access to Carnegie and Prospect must be maintained.
Franklyn  P.   Kellogg5  Trolleyview   Drivetelephone:  (440) 235-8699Olmsted  Falls,  Ohio44138-3007
  
In anticipation of traffic delays, O.D.O.T. and Greater Cleveland Regional Transit Authority should coordinate an effort for commuter traffic relief. Further, let this be the occasion to institute the Cleveland and (city of) Lorain commuter train proposed, by N.O.A.C.A. Carnegie and Prospect Avenues must be kept directly accessible as now from Interstate 90. An additional bridge must not be built off the present right-of-way. Rebuild and replace the existing bridge on the existing right-of-way. Accommodate all modes of travel: automobile, commuter rail, pedestrian, and bicycle with the new bridge. A double or triple-level bridge is ideal. Overbuild the bridge so we don't meet again for this issue for 100 years. Remember the words of the late Frank Lloyd Wright. He said, "The human race built most nobly when limitations were greatest and therefore, when most was required of imagination, in order to build at all. Limitations seemed to have always been the best friends of architecture."
 Jason  Worcester34290  Lorain  Rd,  No. 1Ttracfone1000@hotmail.comNorth  Ridgeville, Ohio44039-4238
  
As a participant in the Innerbelt Project process from it's inception, I have observed the decision-making and the technical work which has resulted in the preferred alternative which is the the subject of the Innerbelt Draft Environmental Impact Study (DEIS). My PERSONAL views as a citizen of Cuyahoga County are that there are substantive deficiencies and questions regarding the Project development process and the Project recommendations. These are fully detailed in a separate public comment sent via US mail are are incorporated herein. I request these comments and questions be incorporated in the official public comment record and receive a complete response.
Paul Alsenas8384 Settlers Passage palsenas@aol.comBrecksvilleOH44141
  
The plan to reduce access to downtown Cleveland by funnelling all traffic to Chester Ave is going to fail. Chester traffic is already near capacity. The bottleneck downtown with respect to Chester will get much worse if Prospect, Carnegie and Superior traffic is rerouted to Chester. This means that at a minimum, there needs to be ramps as Chester and Carnegie.
Bruce Hogan16020 Nelacrest Rd #202bhogan@redmondwaltz.comEast ClevelandOH44112