ECHDC Nov 19 Public Meeting Comments

On November 19, 2018, the Erie Canal Harbor Development Corporation held a public meeting to Introduce updated plans for the Outer Harbor Activation and Access Project. Specific plans providing three options were provided for the First Buffalo Marina site at the Connecting Terminal, Wilkeson Pointe to the Bell Slip; and Terminal B. The ECHDC has a public comments survey that can be found HERE.

Public comments and the survey response are open until December 23, 2018.

In the coming days we will post comments here from the Our Outer Harbor Coalition, coalition members, and individuals that have shared comments with us.

We realize that the survey is confusing, especially if you did not attend the public meeting. In some cases, all of the options that you are asked about may not be acceptable to you. We urge you to fill out the survey, and where asked, add your own comments. please do.

Our Outer Harbor Coalition Comments

These comments were developed at a meeting of the leadership group of the Our Outer Harbor Coalition based on a variety of comments from members of the coalition. This is the OOH general response to ECHDC November 2018 proposals based on the OOH "Citizen CHECKLIST for Sound Waterfront Development." Find the Checklist CLICK HERE

ACCESS/PUBLIC TRUST: "Does the plan/project retain and expand public lands?"

Generally public access opportunities have greatly improved since earlier proposals. However, there is no firm commitment to conserving public lands and public access and to excluding resource and infrastructure-intensive private uses such as housing. We need a master plan!

Public Ownership: Leases of public lands to private enterprises (e.g. state park which includes significant fish habitat), need to be public and accountable. Other examples of exclusive ‘public’ uses include “glamping” and rental of private lodging on the Michigan Street Pier; the “enhanced beer garden” on the Michigan Pier; and lack of public boat access at the Marina.
Include all publics: Some programming favors some groups over others, including investment in equipment that not all Buffalonians can afford.
Non polluting public transportation: The ferry is public, although polluting, and there are bus stop designated but this topic has not received serious attention. More use will increase the demand for more parking so access without cars must be addressed now.
Avoid Sprawl: The intention appears to make this ‘light’ and seasonal and therefore different from the urban fabric. However, across the proposals there is much duplication and density of human uses.

2. PARKLAND: "Does the plan/project support The vision of our Erie Lakefront as park?"

Not clear but if this intervention is used as a demonstration for how to provide waterfront access and habitat to all the Great Lakes cities dealing with post-industrial shorelines, our Outer Harbor could be a regionally and globally significant urban coastal park.

Water-based or water-dependent uses: The plans provide water connection uses within the limits of the Lake Erie shoreline but these could be expanded if we cleaned up our CSO problem.
Support 21st Park honoring Olmsted’s legacy: Yes, but more work is needed, especially on connectivity.
Comply with ‘quieter, simpler waterfront?’ Some areas do that; others encourage more active recreation. Is there sufficient balance? Consider this in relation to new investments in LaSalle Park.
Physical and visual public access to shoreline: There is a clear intent in all the proposals to give people a visual link to the shoreline. A physical link is more difficult given the hard shoreline. Is it sufficient?

3. HABITAT AND HEALTH: "Do the proposals promote healthy human and wildlife habitat?"

Habitat and health issues plus the climate smart objectives listed below (#5), are the least developed of all the proposals. The Outer Harbor/Lake Erie Shoreline is the most significant undeveloped tract of land in the City of Buffalo. It is our best hope for resetting the landscape trajectory towards a future that includes clean water; high quality green space; urban access to nature and recreational opportunities; viable habitat for fish and wildlife; climate resiliency; and a sustainable economy. What balance of total resources will be dedicated to “regenerative landscape” work? The public needs to know at least the relative costs of all options to provide informed input. We need a master plan!

Conserve significant habitat for fish & wildlife: Yes and no. Not enough attention to fish and wildlife needs such as habitat connectivity, undisturbed areas, softer shorelines.
Clean-up or sequester contaminants: The entire Outer Harbor is contaminated with industrial and urban waste. It is a listed brownfield. Explicit environmental testing must be performed BEFORE any soil disturbances occur. The Radio Tower area (Terminal B part of the ECHDC proposal) is the most dangerous. Environmental issues there should be revisited as soon as possible.

Details on approach and management, including phytoremediation, should be part of the “regenerative landscape” proposals which should extend across sites 1 – 3.

Protect water quality: There is an increase in ‘natural vegetation’ throughout that could help clean water, and removal of hard surfaces works to protect water quality. All proposals should be based on a commitment to reduce impervious surface, minimize disturbance to soils and sediment that could impact Buffalo’s sole source of water, including prohibiting (and monitoring) off-road motorized vehicles.
Provide trail options and connectivity: For people, yes. For wildlife, connectivity could be clearer.

4. CONSISTENCY: "Is this plan consistent with existing plans and polices INCLUDING THE LWRP, Niagara River Greenway Principles, Greenway Pollinator Partnership, etc."

More consistency is needed with the 10 goals of Buffalo’s Local Waterfront Revitalization Plan (LWRP), which include: “Safeguard the City’s access to clean Great Lakes water,” “Maximize coastal resilience,” “Provide public access,” “Protect/rebuild the Erie-Niagara food web.

Transparent and democratic process: Getting much better – thank you!
Conserve and promote natural and cultural heritage: Proposals to protect existing buildings and to protect and create fish habitat and new wetlands/grasslands are moving in that direction.
Reuse existing structures: only one option tears down a building (Terminal B) so hopefully the terminals will be preserved. Terminal B is so tied into edge armoring that removing it could cause serious impacts to shoreline integrity and water quality. Connecting Terminal is protected/reused.
Public art and signage: not yet addressed.

5. CLIMATE SMART: "DOES THE PLAN/PROPOSAL FOSTER CLIMATE RESILIENCY?"

Given the latest reports regarding the short time frame for actually addressing climate change, the question has to be asked if doing anything except conserving existing natural systems, native habitats and ecological functions makes any sense. We might even ask whether restoring this area should be our priority in the next 10 – 15 years—our gift to the next generation.

Clear assessment of risk and resilience factors on the Erie Lakefront: Not addressed. We need a climate smart master plan!
Protect city and taxpayers from costly risk of unsuitable development: Not clear but this type of analysis is critical to public understanding of value of investment.
Preserve, restore and buffer natural in-lake and coastal habitats and functions: This desire appears to be embedded in some proposals but without risk assessment, how do we determine potential resilience?
Foster Sustainability: The transition away from privatization of the Outer Harbor is a giant move toward sustainability.

Comments from Lynda Schneekloth, Jay Burney, Margaret Wooster.
Comments on ECHDC Proposal Outer Harbor Access and Activation Project
Submitted by Lynda Schneekloth, Margaret Wooster and Jay Burney
What follows are comments on the three areas covered in the recent ECHDC presentation (11.19) based on the display at Key Center and also through a review of the material on the website. The notes are organized into general comments and specific proposals in the three areas under consideration: The Marina, Wilkeson Pt to Bell Slip, and Terminal B.

MARINA
Vision: This OH area is a complement to the urban Canalside, is visually connected, and during the summer, is physically connected. It should be different from the Inner Harbor – much more park-like, much more vegetation and habitat; relaxing space with great view of a beautiful city; place to wait for ferry, small amenities. Leave the big moves, like wide boardwalk for lots of public, to the city.
Remember it will mostly be seen from the city for 8 months out of the year from the city – from windows in tall buildings and from the land across the river at Canalside.
General Comments:

Range of interesting ideas and creative solutions to boat storage.
Takes advantage of Connecting Terminal.
Carefully considers connection between Inner Harbor and ‘gateway’ to Outer Harbor
Acknowledges that most activity will happen in the summer as level of investment depends on Ferry (i.e., use Connecting Terminal for activity, or popups)
Boardwalk along water is a must – thanks.
Scale is too big! This space should feel comfortable with 25 – 50 people so boardwalks, open spaces, etc., need to reflect that scale and be more articulated
Beach is a great idea and could use more ‘water’ activity such as splash pad, canals of running water next to adventure play area
This area should consistent review plans to ensure the protection of Times Beach
When working within the limited budget we know we have, attend to the entire area and don’t do ‘spots’ and leave other areas unattended to. In other words, when thinking of phasing, think in terms of layers, not specific spaces so that each interventions feels complete to users.

Boat Storage and Ferry docking:

Solutions in A and B are decentralized and this seems to work. But, please explore the solution of putting all the storage under the skyway on the south side of the Connecting Terminal and next to the adjacent private marinas – out of sight and could be used for parking in the summer. In the long run, it would be good to move off-site.
Alternatively, interesting proposals to use space of boat storage for summer pop-up such as pools but could be volleyball? Other activities?
The best place for the Ferry is right outside the Connecting Terminal which should be the center of human activity on the site.
Parking areas need to be designed with green infrastructure principles in mind, protect the waterways from contamination, and not be lit at night during migration season.

Connecting Terminal:

Use this! Don’t add additional buildings except as parasitic structures attached to the silos (like greenhouse that is not permanent.
The observation deck open during the day is great but no restaurant because it would by necessity be open at night! “Dark Skies” legislation in the state of NY says no lights at night to protect migrating birds.
An Industrial History Center and Ecology Center – whatever makes sense is fine if there is some group to manage.

Adventure Playground

This is a great idea and in addition to a designated area, opportunities for this kind of play can be scattered across the site.
Alternatively, the playground could be located near other amenities such as snack bar so parents feel comfortable letting their kids play while they have a beer.
Include water features that kids can’t drown in, but with moving water, splash pads, near sand, etc., to maximize the play value.

Landscape Vegetation:

Use native vegetation in gardens and swaths across the land; there is a lot of area to fill. Avoid goose habitat – too much lawns attracts poop.
Use appropriate native plants to heal the land; provide habitat as in living shoreline
Buffer Times Beach

Don’t see: Place for tie-up for folks in small craft of small boats who want to take advantage of amenities.

WILKESON POINTE TO BELL SLIP
Vision: Overall, this is the naturalized park. Buffalo can demonstrate how to restore brownfields with degraded soil into diverse habitats that support existing wildlife (fish and birds) that can be modeled by other Great Lakes waterfronts. This waterfront area can be designed for climate resilience and protection of land, water, and human life. Experimentation with climate resilience, restoration of soils and habitat preservation/creation is an educational opportunity for the people of the region if interpretative information and programs are available. These support and add diversity to the recreational opportunities.
General Comments:

The background boards are excellent! Thanks. [One corrections under “Cottonwood Copse” where the ‘native plants confined to wetland area’ ignores the sand dunes, spotted bee balm, horsetail, etc.]
The area actually has two parts and they probably need to be considered with different visions. The primary vision is listed above – the regenerative landscape demonstration project. The Wilkeson Pointe area has the activity center/amenities and more traditional park areas.
The activities along the waterfront need to be concentrated into a small space which does two things: makes it easier for folks to locate and creates some density that is welcome and appropriate for comfort/support; and it also lets the rest of the park area be a bit more restful and quiet for those looking for more passive recreation.
No privatization that excludes people! No glamping or cabanas or private overnight rentals; Options, spend the night on a boat! This is not Roosevelt Island. We should not be expected to provide public support for security; it would not be perceived to be equally welcome to all of the community.
No need for amenities or comfort between Wilkeson Pointe and Terminal B.
A high point to over look and see over the water is a great idea but please, no rolling topography that covers all existing landscape and vegetation. Take advantage of existing high spots such as along Fuhrmann Blvd for views, perhaps with modest sun/rain protection.

Specific Places and Issues:
Wilkeson Pointe and Gateway

Buffer at Times Beach great
Enhance Wilkeson Pointe by reinforcing the parklike setting and removing more intense activities; reduce lawn area as not needed without festivals. Provide opportunities to educate about habitat and restoration and use grass only as needed to avoid goose habitat that would ruin other recreational opportunities
Use as gateway to larger more naturalized area to Bell Slip and beyond into the South End.
Concentrate activity in the space between Fuhrmann Blvd and the water at the east end of Slip 3. The closest of option is B but with some differences but I suggest you move a bit south to provide a bit more protection for the Restoration of Slip 3. I’m not convinced we need a swimming pool but don’t think this is a good place for it.
Preserve Michigan Avenue Pier as a quiet space . . . sunset viewing is fine. Fishing Access.
Work with Army Corp and science advisory folks on habitat project – great opportunity!
Adventure Playground is a great idea and can be scattered throughout the site. Be sure that the main part is close enough to amenities so parents feel comfortable for their kids to be there without ‘babysitting’ them.
Boat tie’s up along Slip 2 is good, but it is often very wild and chopping! Study thoroughly. What are options? Along North edge of Wilkeson point?
Would existing restrooms appear so ‘strange’ if things grew up around them? May they can be reused.
No bridges between Michigan Street Pier and Wilkeson Point over Army Corp water habitat. Let’s see how this develops and what would be best once we know how it functions.

Naturalized Landscape – Slip 2 to Bell Slip

Whenever possible, use existing land and features. There is no way to replace the entire site of degraded soil/fill, so let’s experiment. And celebrate experimentation with ongoing information on what is working and why. And sometimes it won’t work and that will be a part of the information communicated.
Option B is closest to wildlife idea although it is good to start with existing paved areas for paths, the actual layout needs some work.
The view from the existing road to the lighthouse is amazing – do not ruin. Some path areas can be curved, especially off the existing path, but there can be a lot of diversity and straight is OK at times. What is important is that if you curve, there is a reason/obstacle/features that has it make sense.
Use special features as in ‘fractured garden’; building parts as art works, etc.
Eliminate invasives as much as possible, especially in Cottonwood Copse . . . that has come a long way by itself and needs some gentle support.
Use areas of native plantings in the middle of various grasslands to generate seed source. Monitor and research.
Boardwalk, controlled access to Cottonwood Copse with interpretation
Redo Parking from to roundabout near circle; remove existing paving at Bell Slip and replant with natives.
No more visitor centers or eco-interpretation. These should be at Marina.
Fishing platform, or way to get to the water at Bell Slip – controlled so habitat is not disturbed.
Management plan for natural areas including Deer Control plan

Old Seaway Pier Site

This is clearly a significant point on the whole Outer Harbor in location and prominence. The proposal for a Sunset Prow is an example. I’m not thrilled with this proposal and think we should keep working on it. Something ‘tall’ would make more sense.

TERMINAL B
VISION: The areas occupied by Terminal A and B should be the center of activity on the Outer Harbor – place for larger groups of people to gather, commercial activity, festivals and more active recreation to contrast and protect the more naturalized areas.
[It is hard to plan without considering both buildings and their slip so all of these comments should be very tentative. OOH Proposal for Terminal A is for light commercial and amenities in structure owned publicly with possibility of deep water port for tall ships and cruises.]
General Comments:

Reuse the building, do not tear it down. The proposal to partially remove is interesting but depends on the future programming. (Also, it is tied into the breakwall and this has to be considered)
Extension of Greenway Trail – YES
Amenities such as bathrooms and concessions obvious support; how about bike repair center, etc.
Keep it simple – (1) Investment here precludes investments in other areas and the difference between making it accommodating and useable would not be greatly enhance by other public amenities such as boardwalk over lake, elevated walkways, sloping ground, etc.. (2) Minimize investment until planning for Terminal A. Then ask where should these types of investments be made. (3) No new buildings like pavilions.

Specific Issues
The Terminal B Building

If the building didn’t exist, you’d have to build one. It is always better to reuse a structure given embodied energy.
This building can be programmed over time – don’t eliminate potential uses that may not be understood right now.
Use as ‘backspace’ for festivals and events
Use to provide public comfort and amenities rather than building new
Be creative… observation on top may be a good idea, remembering no lighting at night during migration season

Recreation:

We’re not supportive of these forms of active recreation believing there can be elsewhere. But if going to do them, having the active BMX and Ropes course next to the urban bike trail makes sense. Don’t use public money and partner for costs, maintenance, and operations. (any lease should have public involvement. Avoid cutting off access to public in general.
Options C amphitheaters option makes sense to accommodate different types of performances. This action would not be impacted by the future use of Terminal A.

GENERAL COMMENTS
The site should be fully ‘public’, open to all regional citizens for their health, access to water and the natural world. According to the LWRP, all interventions should be water based or water dependent; protect and restore the natural environments and habitats. Development should comply with existing policies, complement the urban city by not contributing to sprawl and conserve/protect our natural and cultural heritage. All interventions should contribute to the sustainability and resilience of the city and be climate smart.
The development and management should be transparent and democratic. Include public in structuring vendor contracts so that public interests are addressed.
The Outer Harbor’s master plan emerging should continue to provide opportunity for public comment, including the management and operations plan.

Comments from the League of Women Voters Buffalo-Niagara

Erie Canal Harbor Development Corporation
95 Perry Street,
Suite 500 Buffalo, NY 14203-3030

Dear Mr. Ranalli:

League of Women Voters Buffalo-Niagara members attended the open house offered by the Erie Canal Harbor Development Corporation (ECHDC) on November 19th, held at the KeyBank Center in downtown Buffalo. This letter offers comments from the LWVBN as a whole, in accordance with the League position on the Buffalo waterfront. We were overwhelmed by presentations and displays offered by the consultants who responded to the Request for Proposals offered by the ECHDC this past January. Some of us submitted comments on the spot; others planned to submit individual comments at the website: outerharborbuffalo.com/accessandactivation.

The various development projects offered by the consultants do show better sensitivity to the ecological importance of the Outer Harbor. Space is set aside for meadows and overlook locations are recognized. The sand dunes are protected. Attention is given to water habitat for fish spawning. However greater attention must be given to the reality that the whole of the Outer Harbor lands is contaminated landfill and must be respected as a brownfield, much of which must not be disturbed. The first priority should be to leave the soil intact and then to let the spaces evolve to benefit the natural environment.

As for the marina area opposite Times Beach, we are encouraged by the various proposals to bring the public in contact with the Connecting Terminal grain silos. This fits with our LWVBN waterfront principle, to document and preserve the significant industrial history of the Outer Harbor. However, any changes in the marina area should preserve all the boating docks and facilities currently at the site, as an appropriate and water-based commercial use.

As for Terminal B, we question the intent to demolish that structure, which does witness to the commercial history of the site. The suggestion to install a BMX racing oval inside the building violates the water-dependent principle for commercial development on the Outer Harbor. Furthermore, the ECHDC should determine the impact on water and shoreline if the pilings that support Terminal B are removed.

Overall, the work of the consultants presented to the pubic on 11-19-18 followed precisely the Request for Proposals offered by the ECHDC. The result is a plethora of well-intended designs to induce more activity by the public at the Outer Harbor and does not reflect a master plan adopted with adequate public participation. The public will be better served when the ECHDC adopts such a master plan.

Sincerely, LWV Buffalo Niagara

Comments from 21st Century Park

December 2018

To: ECHDC and Trowbridge Landscape Architects
From: 21st Century Park on the Outer Harbor, Inc. - comments and    recommendations on ECHDC Plans for 3 sites on the Outer Harbor

21st Century Park assumes that environmental issues on the Outer Harbor will be addressed in advance of creation of safe public parkland. The comments below assume this sequence.
The Bell Slip appears to separate the high-activity areas south to the Terminals, from the more passive parkland uses north to Slip 2.
Fundamental goals for all park development on the OH:
Maximize public access to the waters of Lake Erie
Maximize boating opportunities, water dependent uses and access to water
Strengthen linkages to Greenways, pathways and walkways
Maximize family focused, children friendly healthy outdoor open space
Maximize access with electric shuttles, more frequent water ferries, gondolas, pedestrian    bridge
Minimize need for additional parking; when parking is required, integrate parking into    the landscape to mitigate the intrusive visual and ecological effects
Highlight and use only renewable energy on the OH: use cutting–edge solar technology to    focus attention on Buffalo’s consequential position in solar energy product   manufacturing. (solar lights, charging stations, etc.)
Use sustainable practices throughout
Encourage Great Lakes Cruise Ships, Tall Ships and transient docking
Ensure Times Beach buffer
Ensure environmental safety from soil contaminants
Naturally remediate soil where feasible

_________________________________________________________________________________________________________

Specific comments for Central site on the Outer Harbor:
We strongly favor the following design elements at the Central site:
Serpentine, curvy, undulating pathways – Option A
Maximize lawn areas – Option A
Adventure play area for children in Option A
Food service, restrooms etc. Option A
Create visitor/information center/restrooms to north of Bell Sip from south of Bell Slip –    Option A
Pedestrian bridges – Option B
Creation of high look out points and or “porches” to maximize views
Creation of boardwalks
At least 3 access points to the water from the shoreline – Option C
Dock and boardwalk at Slip 2 – Option C
Design elements opposed for the Central site:
Swimming pools and cabanas – Option A
New paved parking area too large – Option A
Glamping –other locations are more suitable – Option C
Fracture Gardens – other locations would be better - Option C
Beer Tent - Inner Harbor more suitable – not family friendly
_________________________________________________________________________________________________

Specific comments for First Buffalo River Marina site
We strongly favor the following:
Roof Top Restaurant and Lookout – Option C
Move the Ferry Landing closer to Grain Silos – Option C
Marina slips – A,B, C – retaining all exisiting
Boardwalk – Option C
Bridge to Wilkeson Pointe - Option B
Flour Beach – and Play beach -Option B
Seasonal restaurant and viewing deck – Option B

_________________________________________________________________________________________________________
Specific comments for Terminal B site
We strongly favor the following:
Building cladding and courtyard – Option C
Continuous waterfront promenade – Option B
Waterfront experience with lookout over water
Keep more green space
Maximize public art
Great Lakes Cruises
Questionable elements:
Though the following activities are not aligned with water dependent uses keeping the following vigorous activities concentrated at the Terminal site seems to be a better choice than spreading them throughout. This would allow north of Bell Slip to be a more passive area.
BMX competition course and skate course – many other locations possible – i.e.LaSalle Park,    not water dependent use –Option B
High ropes course – other locations possible – i.e. LaSalle Park, not water dependent use -Option C and B

Friends of Times Beach Nature Preserve Comments to the ECHDC November/December 2018

Thank-you for giving us the opportunity to comment on the ECHDC development plans for Buffalo’s Outer Harbor presented in November 2018.

We very much appreciate that there is more green for both wildlife and recreation. We also appreciate the ongoing collaboration that the ECHDC has extended to the Friends of Times Beach Nature Preserve and other stakeholders in this process.
Our major comments continue to reflect our concerns about the Times Beach Nature Preserve.

1. We continue to advocate to move larger recreational activities away from this area and further south towards terminals A&B and the new bike park facility.

2. Activities at night at Wilkeson Pointe, especially during spring and fall migration seasons should take into account migrating and breeding birds, not only at Times Beach, but throughout the waterfront and outer harbor. As most of you know, the Buffalo Outer Harbor is a part of and is the western gateway to the Niagara River Corridor Globally Significant Important Bird Area.

3. We appreciate the extended habitat context for Wilkeson Pointe, which will enhance and buffer the Times Beach Nature Preserve. We are pleased to have worked with the ECHDC consultants on aspects of this and like the idea of both sand habitat, and additional appropriate vegetation as the buffer. We advocate for even more buffer including moving the bike and walking pathway even further away from the Times Beach Nature Preserve. We would like to see more native tree and shrub habitat in certain parts of this buffer, including native evergreen, and bird and pollinator friendly shrubs. We are also excited and pleased about the potential for creating a beach buffer that may include a wide row of thorny native beach plants to take the place of the fence that is seasonally damaged by weather, ice, and seiche activity.

4. We are not pleased to see larger lawn areas preserved at Wilkeson Point for recreational use. We would prefer to see almost all recreational use including volleyball, kick-ball, kite flying, concerts, and events including festivals moved away from Wilkeson and closer to or located specifically at the new bike park or at locations related to Terminals A & B. We do not advocate or approve the concepts of rope and ziplines riggings at this location. We do advocate for dark sky events, such as telescope sky gazing at this site. In addition we want ECHDC to recognize that the lawn areas at this site have become nuisance Canada Goose habitat. While we advocate generally for shorebirds and waterfowl, we do know that we have a Canada Goose problem on the Outer Harbor. Lawn areas such as those that currently exist and those that are proposed to remain only exacerbate this problem. Pay attention and do not make this worse by adding more lawn areas.

5. We advocate for the protection of all mature trees on the site, and advocate for the planting of native tree species to replace the eventual decline of the remaining canopy.

6. We advocate for the preservation of the cultural remnants of the original break wall which are characterized as the metal/stone small wall that runs along the Fuhrmann Blvd portion of the site. We advocate that these remnants be evaluated by an archeological specialist because they may relate to the Irish Shanty-Town that once existed here and that is part of the historic legacy of Buffalo.

7. We would like to see permanent signage at both the beach and at other locations at Wilkeson that help to identify Times Beach as a Nature Preserve. Many people, dogs, and bikes, enter the nature preserve from Wilkeson and have no idea that Times Beach is a nature preserve, or that dogs and bikes are not allowed inside Times Beach Nature Preserve. We appreciate your neighborly interest and are sure that Erie County, which manages Times Beach, would be glad to collaborate with Friends of Times Beach, ECHDC, and the consultants on any and all development and installation issues and schedules.

8. We are not pleased that all of the three alternatives for Wilkeson Pointe show expanded beer gardens. We oppose this at this location. We would prefer to see any expanded beer garden to be located further to the south, associated with both the new bike park and Terminals A&B. In addition, parking at lights at Wilkeson Point should be downsized. All street lights at Wilkeson should be night darkened especially during fall and spring migration season.

9. We are ok with the trail-head entrance located adjacent to Times Beach, and expect that this will become an important interpretative area for nature oriented issues at this location. We think that this could become a terrific gateway area, and will compliment a new Times Beach enhance gateway that is scheduled for 2019/20. We would like to see this Wilkeson trail/pathway reduced to a single trail, and not a loop. The trail should enter Wilkeson and proceed to the north center of Wilkeson, around an expanded buffer for times beach (and a decreased lawn/recreational area.)

First Buffalo Marina

10. We advocate that development at the First Buffalo Marina site prioritize recognition of and the preservation and protection of the ecological integrity of the Times Beach Nature Preserve.

11. We are aware that ECHDC and the consultants have and continue to consider this. Our concerns with the options provided for this site include:

12. Parking. All three options include parking near to Fuhrmann Blvd. We are concerned, even though this parking may be behind a fence or a small green buffer. We advocate that no parking occur next to Fuhrmann Blvd, but instead further south on the property and away from Fuhrmann. We are concerned about lighting and insist that any lighting at this site including lights for parking and pathway areas be darkened during fall and spring migration seasons (according to the New York State Lights Out New York policy, created by Governor Cuomo.) Lighting at this site will have negative consequences on the nature preserve, not just for birds but for the biodiversity that we seek to protect and encourage at Times Beach. We strongly urge appropriate lighting standards that reflect these issues

13. We advocate that this area be created as a Gateway Park for the outer harbor. This should be both a natural interpretative area and a cultural interpretative area.

14. We are not opposed to small accommodations such as bathroom facilities and or small seasonal refreshments, but we want the prioritization of the protection of Times Beach Nature Preserve to shine here. No large scale commercial or residential development including a permanent restaurant or play ground facilities please.

15. Please make sure to maintain public access to the shorelines. No privatization of marina docks that prevent public access to the shore is acceptable.

16. The Buffalo News article by Marc Sommer “Sky-high views among ideas pitched for light-show grain elevator”, published on December 11 regarding the Connecting Terminal does not reflect exactly how the option for the reuse of this former grain terminal has been presented to the public. While we support reuse of this building, we are concerned about reusing it as a restaurant, especially if it becomes a large scale restaurant, with more parking and more lights. Any observation platform at the top of the elevator could have positive values, but we are concerned about night time lighting, especially during peak bird migration. Again, we urge that the ECHDC consider protecting the Times Beach Nature Preserve as a priority. No additional recreational activities here. No ropes courses or zip lines.

17. We have no issues with the relocation of the Bike and Pedestrian Ferry docking.

Seaway Pier to the Bell Slip
Birders and nature lovers have long recognized the value of this area to migrating and resident birds of all seasons. We appreciate the context in which the Cottonwood copse and the sand barren area is being characterized by consultants (Conservation Research Institute Report). We are pleased to be interacting with the consultants and the ECHDC on further development of this site.

18. We wish to maintain the view that exists along the road through the center of the site, sometimes referred to as “Outer Harbor Drive.” The direct view to the old lighthouse is both iconic and significant to the enjoyment of the aesthetics of the sky, water, nature, and landscapes.

We advocate a more rural feel with potential wooden fencing that helps to characterize both the cotton wood copse as a natural area, and gives the whole area a more rural aesthetic.

19. We advocate to remove invasive species at the entire site, including the grasslands, the cottonwood copse, and the areas directly adjacent to Fuhrmann Blvd. The sooner this is done, the better and long term management and maintenance strategies will benefit from quick action.

20. We advocate for the restoration of all grasslands on the site, including lakeside and between the lake and Furhmann Blvd. These are aesthetically beautiful and are rare lakeside grasslands in the Great Lakes. They provide habitat for migrating and resident birds and a variety of pollinator species. We have seen such species as Eastern Meadowlarks and Bluebirds (The New York State BIrd) at this site. We would advocate encouraging them to breed here. Investment in targeted native grass species can be beneficial.

21. We urge not to turn these grasslands into recreational areas or lawns. This will only increase the Canada Goose population and associated problems, harm native pollinators and create barren habitat for birds. Leave this area natural. Make it more natural.

22. We advocate for the continued growth of cottonwoods on the site, extending from near the parking lot, to the south towards the Bell Slip. Appropriate invasive remediation is important.

23. Parking Area at Seaway Pier. We advocate for the removal of this parking area and the elimination of all large events at this location including seasonal festivals. Parking and access to these events is harmful for migrating birds and pollinator conservation. Traffic during these events create chaos and lack of access to places like Times Beach Nature Preserve. The Friends of Times Beach Nature Preserve has had to cancel programming at Times Beach during these events. While we support some use of the pier for docking, including tall ships and the potential for future lake cruise ships, we advocate for the reduction of the traffic, parking, and lighting footprint.

23a. The parking area at the Seaway Pier is a place where migrating shorebirds visibly congregate in the spring and fall. Part of this is due to lack of appropriate wetland and shoreline habitat. Part of it is because birds may mistake the dark parking footprint as water. Birds are also at risk here because of people and dogs being allowed to chase the birds. Events held at this location during migratory periods offer significant threats to these birds. We advocate for the introduction of appropriate shorebird habitat on this site, decreasing the parking footprint, including land areas from the Bell Slip to the parking area, and would be glad to discuss this further.

24. We advocate that the area at the Bell Slip between the Cottonwood Copse and the Bell Slip parking area be managed into natural habitat. Invasive plants are abundant here, but bird species such as Barn and Tree swallows use the area and are important contributors to our local and global ecology. (They breed here, and migrate to the Amazon.) Invasives should be removed, but the general pattern of the habitat including native grasses and shrubs should be maintained and managed.

Miscellaneous

25. Wi-Fi We advocate that a functional and well maintained wi-fi system be established to serve all areas of the Outer Harbor from the Coast Guard Station and Lighthouse, to Tifft Street. Wi-Fi access would greatly benefit visitors to the outer harbor and would help to create access to interpretive and informational websites, such as the Friends of Times Beach website, and the Pollinator Conservation Association website which includes descriptions of conservation activity on the Outer Harbor. In addition event schedules (including the bike and pedestrian ferry) and up to the moment information including weather could be accessible. Currently there are a number of blind spots for some cell phone carriers, including at parts of the Buffalo Harbor State Park.

26. Bike and Pedestrian safety. A constant concern is the shared use of trails, walkways and bike paths by both pedestrians and bikers. It is not unusual to to experience collisions or near collisions because there is not adequate information about how to share these important assets. As the outer harbor becomes more popular, the inevitability of bad interactions will increase. The elderly, people distracted by nature, children in carriages, and fast moving bicyclists are in conflict and we need to find better safety measures, including perhaps appropriate signage such as “share the path” will go a long way toward making the Outer Harbor trails a better experience for all.

27. Signage encouraging people to keep pets on leashes and to clean up after dogs is inadequate. Please make this area better for all by creating better information opportunities. While we appreciate that there is signage regards this at places such as Gallagher Beach, these notices are needed throughout the area from the Ferry Dock to Tifft Street.

28. Seasonal Staff We advocate that full or part time staff be created, possibly in partnership with NYS Parks and or Erie County (Erie County Rangers) to provide guidance and information for visitors on the Outer Harbor. During busy times such as summer weekends and holidays, helpful staff dealing with questions and other issues would benefit both visitors and various vendors ranging from the Pedestrian and Bike Ferry, Buffalo Harbor State Park activities, and concessions. Times Beach, and Tifft Nature Preserves can always use more people to explain the whats and whys of the preserves.

29. A growing concern involves waterfowl hunting on the Outer Harbor. As the area becomes more popular, hunters and birdwatchers are using this very special waterfowl area for cross purposes. Rare birds visit the Outer Harbor and unfortunately, hunters are setting up along the Buffalo Harbor park shoreline, or just off shore (20 feet) and at other locations where winter birds are congregating. We advocate that rules about discharging firearms in the city of Buffalo be enforced, clarified, and respected. We advocate that hunter education include information about the appropriateness and legal capacity to hunt within the areas of the Outer Harbor that are in question. We advocate this with sportsman groups, with the DEC, and with the City of Buffalo. We would also like to see the ECHDC and NY State Parks participate as stakeholders in creating special hunting education regarding the areas affected.
Clarification of current laws is an important aspect of hunter and birdwatcher education. In addition, it is possible to create special laws about hunting along the Outer Harbor, especially along state owned property. This is not an anti-hunter advocacy platform, but rather a safety and contextual issue that recognizes how hunters and birds use this area.

30. In general we advocate for birds and other wildlife, including pollinator species and native plants on the outer harbor. While we continue to have problems with Canada Geese, and White-tailed Deer, and while we advocate that the ECHDC address these problems with appropriate local, county, and state agencies, we do appreciate that our concerns about wildlife have been considered by the ECHDC and the consultants. More can and must be done.

31. Climate Resiliency and Habitat. Lake Erie is a fragile and precious natural resource that links to all of the Great Lakes which contain 20% of the earth’s fresh surface water and 84% of North America’s fresh surface water. The lake continues to be linked to a decline in water quality, primarily due to agricultural and urban runoff. This includes both sanitary sewer issues and storm water issues. One of the primary and growing contamination issues involves microplastics, material that enters the water system through a variety of sources and breaks down into microscopic particles that enter drinking water and the bodies of wildlife including fish and birds that use this water. A big part of climate resilience involves addressing pollution issues, including stormwater runoff and the use and discarding of plastic materials that enter the lake. Limiting vehicles that use fossil fuels will promote both clean air and help to prevent the release of automotive fluids which find their way into storm sewers that release directly into the lake. We encourage that all development on the outer harbor be cognizant of stormwater runoff to include any and all parking, trail, and road development. We encourage that any and all vendors or event and activity programs create a strong public focus on the plastic and trash stream. One idea might be to ban plastic containers including straws from being sold by any vendors or events on the outer harbor.

32. Birds use all areas of the Outer Harbor all seasons. It is important to note that the winter months continue to bring unusual and interesting bird activity including incredible winter waterfowl activity, gull migration, and irruptions of rare and unusual species of birds from the north including Snowy Owls. While this bird is not considered endangered in the United States, its populations in North America are rapidly decreasing. This is a bird that faces threats and we can actively promote its conservation by being aware of its presence, its needs, and local conservation strategies. During April of 2018 a total of over 100 Snowy Owls could be seen at the Outer Harbor ranging from the State Park to Times Beach on any given day. Additional large numbers of Common Loons and horned Grebes used the outer harbor for refuge and food during this month, In November and December of 2018, populations of Snowy Owls continue to use the outer harbor from the break walls and shorelines, to the boat docks and land areas stretching from the Union Ship Canal to the Lighthouse. Please make every effort to continue to advocate for the conservation and protection of birds in this location, the western gateway to the Niagara River Globally Significant Important Bird Area.

Thank-you
Jay Burney, Friends of Times Beach Nature Preserve

Photos by Jay Burney April 2018 Buffalo Harbor State Park, and Gallagher Beach
Top: Snowy Owl
Middle: Common Loon
Botton Horned Grebe