The following comments were submitted via email to the Nebraska Environmental Trust for consideration by members of the board.
The following comments regard the Nebraska Environmental application submitted by the Public Works Department of the city of Omaha: Spring Lake Pond Restoration, Phase 4, grant number 12-146.
The applicant requests $3.142 million, with small amounts attributed to partners ($10,000 from Papio NRD; $2,320 from Keep Omaha Beautiful and $15,904 from Spring Lake Park neighborhood groups (which are inkind services rather than actual funds), and which are an insignificant portion of the more than $11 million total expected cost for this specific project, with a proposed spring 2014 start.
There are a number of reasons why NET funds should be not be provided for this application. Based upon a close review of the grant application, particular and obvious concerns occur. This grant applications uses opinion to convey benefits, with assumptions based on false premises, has a lack of specific details on how funds would be spent, promotes change though the current situation suits the park, conveys a blatant degradation of the current park setting, all based upon the lack of a final design.
Some of these comments were originally prepared November 15, 2011, after having attended a public meeting which presented a "10%" plan for the CSO project as its involves Spring Lake Park. There were public comments given that evening at South High School which conveyed a community perspective. There have also been further considerations, with additional comments prepared in January 2012 after further review of the grant application submitted to the NET. There was also a meeting of discussion with project planners — at their email request as attended via a bicycle ride in mid-morning — on January 9 when these comments were conveyed, and considered further in a collaborative manner.
The apparent plan as known in mid-January 2012, reflects an unknown design and changeable design. If the project design is only ten percent completed, how can an application state with any accuracy the expected results from any grant funds. With only a small portion of the design known, any project plan cannot accurately convey the final design with the details necessary to indicate how money would be spent on specific features, rather than concepts as presented in the reviewed application.
NET should not provide money to a project that would negatively impact a unique and historically significant Omaha park. The Trust should not provide funds for this grant, especially since the presented plan is incomplete and vague.
Particular items to consider, include the following specific items.
The $3+ million requested from NET is a large and significant portion of cost for this Omaha project. The applicant should pursue other sources as there are many other proposals which could benefit from the dollars which might be used for one project.
Project proponents did not adequately announce the early November meeting — nothing was seen in the newspaper or on a regularly watched television station? Yet, the project conveys that community awareness is one of its more important features.
How does the stormwater project preserve the meadow and sparse wetlands as specifically recognized in a document prepared years ago in association with recognition of parkland features?
"Wetland, pond, and dry detention facilities will enhance wildlife habitat within the park" - this is conjecture as there are no particular details given on how it would be achieved.
"Wetland, pond, and dry detention facilities will keep the uniqueness of a natural area within an urban park" says the grant application. This is a twisted claim. Newly constructed features cannot keep any uniqueness within the park, as they would be new and something new cannot retain any sort of unique aspect because they have never been present.
The park is unique because of its woodland features, and any mention of wetlands, a pond or dry detention item indicates that the project would create something and the creators could say it is unique. A piece of distinctive trash thrown along a street could potentially derive great value for its uniqueness, but would it really mean anything?
The application states: "Does not cause harm to the environment and results in a net gain for the environment because it enhances existing wetlands, provides additional wildlife habitat, and improves stormwater quality." This is a mish-mash of perspectives that should be addressed individually. There will be no enhancement to existing wetlands, because based upon the "10% plan" the existing wetlands would be inundated, and which is obviously no enhancement but an outright destruction. Any newly created wetlands would increase habitat diversity and perhaps increase the variety of flora and fauna. It does not provide additional wildlife habitat, but provides a different mix of habitats. There is no additional property that would be included because of this proposed project. It is proposed for certain tracts within a constricted area, thus nothing more. As for improving stormwater quality. Making sure that stormwater runoff is not tainted with sewage is an obvious improvement, and would occur even without altering the Spring Lake park environs.
Information within the grant application does not present any details on the wildlife present — especially the wild birds — so how can project proponents indicate any sort of enhancement?
If the park cannot be kept clean of trash and free of tires now, how would the project result in making the place more attractive or discourage illegal dumping? Park cleanups in recent years have never accomplished the goal of completely removing unwanted trash or debris from the park woods. A POP-TOP document was personally prepared many years ago about the pervasive trash in three Omaha parks, including Spring Lake Park. Nothing has changed, with tires still a prominent feature, as well as trash from runoff from city streets.
How will project address ongoing erosion due to runoff into park from the corner at 18th and G Street? This is now a dangerous situation for hikers in the park woods. It seems that project designers are aware of this unacceptable situation, though the engineered solution is unknown.
It is not possible to improve water quality in the park, as the only water now in the park is spring water, and it does not need any improvement! This is another example of a false claim.
What is the depth of the proposed pond just north of F Street; what type of fishery would it provide? How much of the present woods need to be inundated to provide any sort of fishing experience. The tradeoff is not acceptable.
What are the infiltration basins, proposed for just south of F Street? These constructs would appear to impact the woods, and the actual influence is unknown.
A given reason for bonus points is: "Recognizes community and economic values that may affect conservation action and designs appropriate actions to enhance attainment and sustainability of resource objectives." This statement is basic mumbo-jumbo which conveys nothing of any sustenance or indicates actual measures which a grant might finance.
This project would not supplement or enhance groundwater — though this is mentioned as a bonus feature. And as if this means anything in this area anyway where there is no use of groundwater and no recognition given now to its occurrence!
How does this project help sustainability of resources? This is an opinion of the grant writer.
The habitat in the park does not need the type of so-called enhancement as indicated for the project; "Significant tree removal required -- an indicated five acres -- for the middle pond" — with removal of shrubs to increase visibility also mentioned. The park setting is just fine now, and could continue in its present condition for decades without either of these two proposals as given in the grant application.
The grant proposal says that in order to make the site more attractive, underbrush would have to be cleared. Habitat is not enhanced by clearing underbrush, so any claim associated with this item, is a biased opinion.
How many tons of "ugly" rock would be used with the constructs of this project and get dumped into this green space? The many stormwater drains proposed will cut through the woods, fragmenting this feature, and seemingly require constructs on the low end to dissipate the runoff in a manner which would not result in erosion. There is no indication of how this would be accomplished in a manner conducive to a park space. Cement boxes of the sort newly placed in Elmwood Park, do not — in any manner — enhance the natural setting currently present. The new box at Elmwood may work to retard stormwater runoff, but the results of its design include a prime condition to create a mosquito breeding nuisance.
A 450' riprap channel - four feet wide, 2 feet high and deep - is not a feature conducive to a park setting, yet this would be installed to provide a drainage channel for the middle pond.
Spring Lake Park has a bird history of more than 120 years. The first known notes on birds are from June 1890. More than 100 species have been subsequently recorded, primarily since 2000, as derived from nearly fifty personal surveys. The grant proposal does not even recognize this resource, though it does refer to subtropical birds. There are no such species of this sort, which occur anywhere near Omaha. Perhaps the grant writer meant neotropic migrants.
The grant indicates a plan of intent for changing habitats, yet there is no evaluation of how the proposed changes would impact the local avifauna within the park.
The pond proposed just north of F Street will inundate several distinct springs; there are none similar in any other Omaha park — existing wetlands and brooks are not enhanced by inundation. The plan does not enhance existing wetlands, it inundates the scant bits now present! To create this pond and its adjacent walkway, trees would have to be cleared and it would require "slicing away" slopes so a cement sidewalk -- which would increase runoff -- could be provided for an occasional walker(s).
The project developers, at the public meeting, had not even considered alternative pond sites, especially south of F Street where there would be no impact on the native woodland habitat and springs. The city was averse to this particular site - -- an unused portion of the park -- because it would also require cleaning up a historic landfill. Removing the landfill material and placing the pond there would an obviously preferential option.
Many of the proposed project items do not necessarily represent Best Management Practices; educational signage would be nothing but an opinion of an erroneous sort. Anyone can claim that inundating natural springs is a best management practice, but that is an entirely false assertion. Destroying an ever-flowing brook is not a best management practice! Removing natural earthern features and their native flora is not a best management practice. Clearing shrubs and trees - prominently used by native fauna - is not a best management practice.
Several members of the Omaha Audubon Society familiar with the park are opposed to any changes which would ruin the natural setting of the park and be detrimental to the bird life. They would especially not like to see any inundation of the natural springs and the resultant creek or brooks.
These particular items are a multitude of reasons why this grant should not receive any funds from the Nebraska Environmental Trust.
The city of Omaha is using Spring Lake Park as a means to an end. They have not adequately considered the current natural features of this park, but instead consider it a place to render into a "facility" to assist with stormwater runoff problems.
Spring Lake Park is a historic place of significance, yet is being blithely considered as a public property suitable to address a current mandate to address stormwater runoff. A park is a park, and should not be drastically altered just because it is there.
Are there are other alternatives being ignored since a park site is convenient and can be altered? A park is a park and not property to convert to a stormwater site.
These comments were presented to project planners including city of Omaha officials, a project designer and a resident of the neighborhood, during a one hour meeting on the morning of January 9th.