The NPS Environmental Assessment will in fact assess the impacts of the proposed “lid” on the visitor experience, but only in the context of the proposed west entrance, revitalized Luther Ely Smith Square, and connectivity with the Old Courthouse.

It’s been a few weeks since I published the correspondence between myself and the National Park Service regarding the scope of and the commentary to the environmental assessment study of their CityArchRiver projects. Let me finally take this opportunity to detail my opinions more clearly.

Downtown St. Louis From Under the Arch

The crux of my opinions regarding the project to renovate and re-imagine the Arch grounds revolve around the complete and utter lack of public input sought thus far by CityArchRiver. By public, I do not mean agencies that serve the public interest such as Great Rivers Greenway and MoDOT, but the general public itself.

CityArchRiver has been frustratingly silent for the past 1½ years. Since the selection of MVVA as the winner of the Arch grounds design competition, CityArchRiver has not hosted a single meeting wherein the general public has had an opportunity to comment on any of the elements or changes to the final design. The only attempts at public engagement CityArchRiver has made has been a pair of yearly project update presentations at which no public comments or questions were taken.

The only agency involved with the Arch grounds project that may be worse than CityArchRiver is MoDOT, at this time at least. MoDOT is the agency responsible for major upcoming changes to the roadway infrastructure along I-70. An environmental assessment study for changes to the I-70 corridor was promised last year, but has yet to be made public. My fear is that MoDOT will attempt to expand the scope of the Mississippi River Bridge project studies to get away with making its desired changes without the need for public input.

Public commentary, by the way, is overwhelmingly in favor of removing I-70 from in front of the Arch and past Laclede’s Landing. When the National Park Service announced their environmental assessment in July 2011, they gave the public it’s first and only opportunity in almost a year to comment on the proposed changes to the Arch Grounds. And while no public meetings were held, many people took the opportunity to submit their comments to the NPS, well over 60% of which expressed support for replacing I-70 in front of the Arch with an urban boulevard.

But I was severely disappointed to see the majority of comments categorized as “out of scope”, namely every comment made in favor of highway removal. The explanation from the NPS for the comment classifications was even more disappointing. Its explanation seems to imply that the lid is fait accompli and that it had no opinion or jurisdiction over the possibility of highway removal in favor of an at-grade boulevard.

More specifically, the NPS seems singularly focused on the experience of the out of town visitor and the strip of JNEM land between the Old Courthouse and the new entrance to the Museum of Westward Expansion. The NPS seems to care not about melding the park into the city it calls home. This is unfortunate given that one of the objectives of the NPS’s EA is to “Ensure that revitalization of the park improves connections between the city and the park and from the city and the park to the river.”

The NPS has expressed an opinion before regarding the highway infrastructure that surrounds much of the JNEM. Within the 2009 JNEM General Management Plan, the NPS said that it “would prefer and strongly supports the removal of the Interstate highway between Poplar Street Bridge and Eads Bridge.”

Unfortunately, a memorandum of understanding between many of the agencies participating in the Arch grounds project seems to have silenced, for now, the NPS from publicly commenting on projects within MoDOT’s domain.

So thus far, it’s been 3 years since City to River formed. It’s been 1½ years since every design competition finalist expressed support for the removal of I-70. It’s been 1½ years since the selection of MVVA as the winner of the design competition. It’s high time we had formal public discussions about the planned changes to the Arch grounds and its environs, including the idea of replacing the highway with an urban boulevard. Removal of I-70 may very well not become reality, but the concept should be studied.

And no, public meetings focusing on a proposed sales tax increase to provide additional funding for parks and recreation won’t cut it.


  • MoDOT did announce a public meeting yesterday to discuss “Park over the Highway” alternatives. It will be held on April 10 at St. Louis City Hall from 3-5 PM. More on this later. Even so, I believe my points on MoDOT still stand.