Thursday, August 27, 2009

My additional comments for the public record

Click the "Continues..." link below to see the text of my additional comments, submitted by email today to the U.S. Army Corps. My original statement is at this link.

Continues...Public Information Meeting Comments - Cobblestone Landing
U.S. Army Corps of Engineer
Memphis District
Attn: Mitch Elcon (
167 North Main Street
Room B-202
Memphis, Tennessee 38103-1894

Dear Sir:

My additional comments, for the public record, are as follows:

1. The RDC's "Historic Cobblestone Landing Restoration and Walkway Project" (the Plan) is fatally flawed and must go back to the drawing boards, for the following reasons, among others.

2. Regardless of how they titled it, this Plan (by RDC's own statements) is clearly intended just to preserve the cobblestone-covered areas, not to preserve the historic Cobblestone Landing, which is today an active public wharf and landing for riverboat cruises.

3. When the RDC claims the Plan offers "improved boat docking," that is a misleading statement by the standards of ordinary English. They mean "to dock" only in the incomplete sense of "to park" -- not for the loading and unloading of passengers and baggage.

4. The Plan is directly contrary to the Riverfront Master Plan agreed to by City Council in 2002. It is questionable whether the RDC even has the authority to propose this Plan, much less to carry it out.

5. Rip-rap is for erosion control, not for boat landings. Any boater can tell you that. The use of rip-rap in this plan is compelling if not prima facie evidence that the RDC intends to de-commission an active boat landing.

6. The north-south walkway is inauthentic and obstructs the Cobblestone Landing's use as a boat landing.

7. The RDC told City Council over a year ago they planned for the Memphis Queen Lines to board and de-board passengers at the (to-be-built) Beale Street Landing, but because of the Queen II's historic status they would probably have to let it dock (park) at the Cobblestones in between boarding times. I can produce an audio record and transcript of those statements.

8. I question whether Federal transportation money can lawfully be used to shut down an active transportation facility, as is clearly the RDC's intention.

9. Because RDC is a private company, not a government entity, it should always be compelled to testify under oath and penalty of law. It is not sufficient for the public to listen to marketing promises while viewing PowerPoint presentations.

10. In 2007, TDOT allowed Beale Street Landing (BSL) to be approved over the strenuous objections of historic preservation specialists, such as TN-SHPO, following the questionable theory that BSL only impacted a small portion of the Cobblestone Landing where the two overlapped. If TDOT allows this Plan to decommission the Cobblestone Landing to go forward, it would amount to enshrining its own 2007 mistake, and would cause irreparable harm to Memphis historic preservation.

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