Loading...
HomeMy WebLinkAboutMnDOT Analysis of Transportation System Management 1990-11-28 I 1 i i I I • AN ANALYSIS OF TRANSPORTATION SYSTEM MANAGEMENT (T8,1) IN DOWNTOWN STILLWATER i November 28, 1990 i Minnesota Department of Transportation 1 i i I i i i 1 INTRODUCTION ' The aim of this report is to analyze potential traffic system management (TSM) ideas to improve traffic flow through downtown Stillwater. The main focal point of Stillwater's congestion ' problem is• the signalized intersection of Chestnut and Main Streets, located two blocks west of the existing drawbridge. TSM efforts in downtown Stillwater could be useful as an interim measure to reduce congestion until a new crossing can be constructed. In addition, long-term TSM measures could prove helpful in managing on-going traffic increases, even if a new crossing is constructed. However, TSM is not considered to be a principal, long-term solution to the local and regional transportation traffic problems, which require a new river ' crossing to be adequately addressed. Currently, average weekday peak hour volumes exceed the capacity of the Chestnut and Main intersection, which provides a level of service of F, with vehicle delays of up to 2 minutes. (Level of service D is considered to be the minimum acceptable level. ) The situation is much worse on summer weekends, when traffic volumes are up to 25 percent higher. Some of the main problems at this intersection are as follows (see figure 1) : ' * On westbound Chestnut, there is a large volume of traffic which turns left onto Main. Compounding the problem is the fact that the length of the two westbound lanes on Chestnut are restricted by the two lane drawbridge, while the width of the roadway is restricted by buildings on either side. * On eastbound Chestnut (west of intersection) , there are three possible movements from one lane. Parking on both sides of Chestnut restricts the capacity. * On northbound Main, the right turn lane is limited by on- street parking. South of the restricted parking area, both northbound (to TH 95) and eastbound (to Wisconsin) traffic is restricted to one lane each. * The presence of a significant number of pedestrians leads to additional restrictions on the traffic flow in downtown ' Stillwater, especially during the summer. The following sets of alternatives attempt to address these deficiencies, resulting in different benefits and disadvantages. As detailed in the Stillwater-Houlton Draft Environmental Impact Statement, some of these alternatives have already been studied in detail by the City of Stillwater and/or the Minnesota ' Department of Transportation, beginning in the 1960s. Appendix A in this report includes comments submitted to Mn/DOT which review, among other things, Stillwater's views on TSM and downtown traffic problems. 1 1 1 ALTERNATIVES WHICH MAINTAIN A TWO-WAY INTERSTATE TRAFFIC FLOW ON MAIN STREET Three principal alternatives were analyzed to improve the capacity of existing streets without altering the two-way traffic flow on Main Street. Some of the ways the capacity of existing streets might be improved include increasing road width and number of lanes, improving turning radii at corners, and restricting parking. Converting a portion of Chestnut to one-way ' traffic is also an option. The extent of road widening possible in downtown Stillwater is ' restricted by buildings and the need to maintain sidewalks of an acceptable width. In theory, Main Street could be widened to a maximum of four lanes (14/12/12/14 feet) , which would result in a reduction of sidewalk width on each side of the road from 11 feet to 7 feet. Chestnut could have a maximum of four 12 foot lanes, with 6 foot sidewalks_ However, these sidewalk widths are I considered less than acceptable due to the large number of pedestrians in downtown Stillwater. Consequently, the revisions described below utilize parking limitations, turn restrictions, and/or one-way traffic flows on Chestnut to improve capacity: * Revision A prohibits left turns from eastbound Chestnut and extends the right turn lane on northbound Main south to Nelson ' Street (see figure 2) . Eastbound traffic on Chestnut would be able to turn left one block east at 2nd Street. Extending the right turn lane on Main would result in the loss of 15 on-street parking places_ * Revision B incorporates the changes made above, but further limits parking on Chestnut and Main (see figure 2) . Traffic on eastbound Chestnut turning right onto Main would be able to use a right turn lane, due to more limited parking south and west of the intersection. In addition, traffic turning right onto Main from westbound Chestnut would also be able to take advantage of a new lane made available by parking restrictions. * Revision C removes eastbound vehicles from Chestnut between Main and 2nd Street, improving the signal phasing (see figure 3) . A disadvantage of this option is that it increases traffic volumes at the intersection of Myrtle and Main, one block to the north_ Left turns from southbound Main to eastbound Chestnut will also increase with this option_ Revisions A through C do not solve the intersection traffic ' problem for average weekday traffic; they do even less for summer weekend traffic, when vehicle volumes and pedestrian traffic are significantly higher. As depicted in table 1 below, the present configuration is rated at level of service F, the failure level. Revisions A, B, and C provide successively better results_ 1 2 1 II TABLE 1 I TSM REVISIONS IN DOWNTOWN STILLWATER: TWO-WAY TRAFFIC ON MAIN STREET (Average Weekday Traffic) IIConfiguration Level of Service/Vehicle Delay in Seconds 1969 1994 1999 2004 I Present * * * * IRevision A E/42 E/56 * * Revision B D/38 E/51 * * IRevision C D/27 D/32 E/51 * I (*) Failure--worse than level of service F. Vehicle delay is an average computed for all vehicles entering the intersection- !' However, even the most successful revision (C) attains a level of 1 service F by the year 2004_ ALTERNATIVES WHICH CONVERT MAIN STREET TO ONE-WAY TRAFFIC FLOW IIIt is possible to improve traffic flow at the Chestnut/Main intersection by restricting Main Street to one-way, southbound I traffic. One-way streets improve capacity by reducing turning movements at intersections (thereby improving signal timing) , without the need to widen lanes or add new ones. Main Street 11 would remain as it is now (10/12/12/10 feet) , with 11 foot sidewalks. Conceivably, northbound traffic which formerly utilized Main I could be routed on to Water Street or the railroad right-of-way (both located between Main and the river) . Second Street, which is located west of Main Street, is not considered a candidate for Ione-way pairing due to topography. All of the one-way pair alternatives investigated here would I result in larger socio-economic impacts than revisions A through C, which maintained two-way traffic flow on Main. The Water Street alternate would, for example, require the acquisition of the grain elevator or feed store located south of Nelson Street, I in addition to the loss of considerable parking spaces. Pedestrian movement in the downtown area would also be altered. I3 1 1 II Alternatives which employ one-way traffic pairings hold the II potential for substantial impacts to the historical resources in Stillwater. A significant portion of downtown Stillwater is in the process of being nominated as a National Historic Commercial District; the City has expressed concerns about the potential I impact of large traffic volumes on the integrity of existing cultural resources and the future historical district (see appendix B) . The Freight House Restaurant, which is located II between the railroad tracks and Water Street, is presently listed on the National Register of Historic Places and could be adversely affected by these alternatives. I In part because of historical concerns, there are serious geometric constraints with the one-way alternatives which would make them difficult to implement. Water Street, for example, II offers only 48 feet between building faces; this would provide for just two 14 foot lanes, with 10 foot sidewalks on each side_ There would be no room for on-street parking, and truck deliveries would become much more difficult. The one-way alternatives (revisions D and E) which utilize Main and Water Streets for southbound and northbound traffic, IIrespectively, are as follows (see figure 4) : * Revision D utilizes Chestnut movements which are most similar Ito revision A, with fewer turns possible because of one-way traffic on Main. Parking along Main is permitted without restriction_ I * Revision E converts Chestnut west of Main to a westbound one- way, similar to revision C. This change will result in vehicles entering the Chestnut/Main intersection from only two directions, 1 instead of the four at present. However, three destination directions remain on southbound Main, as Chestnut (east of Main) must continue carrying two-way traffic to maintain access to the I bridge. As depicted in figure 4, the feed store at the southeast corner of Main and Nelson would be acquired in order to provide better I access to Water Street. Another way to route northbound traffic onto Water Street would be to use the land south and east of the Brick Alley parking lot (see figure 5) . This alternate would II utilize the same Chestnut and Main configurations illustrated in figure 4 (revisions D and E) , but would require the acquisition of the grain elevator instead of the feed store. The grain elevator route would improve access to Water Street, but would eliminate additional parking spaces south of the Brick Alley. The operation of revisions D and E at the Chestnut and Main intersection would not be affected by the route chosen to direct IItraffic to Water Street. 1 4 1 1 As indicated in table 2, revision E provides a level of service I of C for average weekday traffic through 1999, the best of any of the alternatives analyzed in this report. It is estimated that revision E would provide acceptable levels of service for average weekday traffic until the year 2004. IIt is important to note that both of these alternatives are less successful in addressing average summer weekend traffic at the I intersection. Revision E is estimated to exceed level of service D on weekends around the year 2000. ITABLE 2 TSM REVISIONS IN DOWNTOWN STILLWATER: ONE-WAY PAIRING (Average Weekday Traffic) I Configuration Level of Service/Vehicle Delay in Seconds 1989 1994 1999 2004 2009 2014 IPresent * * * * * * Revision D D /30 D/35 E/55 F/88 * * IRevision E C/16 C/18 C/23 D/31 E/46 * II (*) Failure--worse than level of service F. Vehicle delay is an average computed for all vehicles entering the intersection. 1 Another possible alternative would be to use the railroad right- , of-way for one-way northbound traffic (see figure 6) . (A variation of this option would be to maintain two-way local traffic on Main Street while routing two-way interstate traffic I next to the railroad tracks--see figure 7) . With the rail line alternative, less than 50 feet would be available for a new road, permitting only two 14 foot lanes. Up to 150 parking spaces could be lost with the railroad alternative. Due to access needs ' of the Minnesota Railroad Museum (located north of Chestnut) , the railroad tracks must remain in place, necessitating an inconvenient, acute angle road crossing. IThe railroad option has the potential for severe impacts to neighboring Lowell Park, which is a heavily used recreation site and part of the proposed historical district. Access to the park Iwould become more difficult, and visitors would be subjected to increased noise and air quality impacts from vehicles using the railroad right-of-way. I5 I 1 1 1 Another important consideration is that some land from Lowell Park would need to be acquired to develop the railroad option. ' Use of this parkland would invoke the Federal Highway Administration's Section 4 (f) criteria; under Section 4 (f) , an alternative which affects significant parkland or National Register sites may be selected only if there is no other ' "feasible and prudent" alternative. Downtown Stillwater depends heavily on historical and ' recreational resources for its economic base, and impacts to these amenities could have serious consequences for downtown businesses. Because of social, economic, historical, and parkland impacts, use of the railroad is not considered to be an acceptable alternative. Compared to the railroad option, use of Water Street in a one-way pairing with Main would produce fewer adverse impacts and result in the same traffic improvement. 1 CONCLUSION I' 1 None of the alternatives discussed in this analysis comes close to being a primary solution to the transportation problem in downtown Stillwater. Even the best option would fail before the year 2014 for average weekday traffic; a level of service rating of F would be reached earlier for heavier summer weekend traffic. In addition to not providing a satisfactory solution to the ' transportation problem, each of the downtown TSM options would have varying adverse impacts on parking, access, pedestrians, 1 businesses, parkland, and/or historical resources. The one-way pair option, in particular, would have an adverse impact on the Stillwater waterfront and the area around the historical Freight House. Impacts would be particularly severe with the railroad right-of-way alternative. The principal utility of the TSM study alternatives in downtown Stillwater would be the possibility of reducing traffic congestion on an interim basis before a new bridge is built. In addition, they might prove useful as long-term measures to help Stillwater manage growing traffic volumes in conjunction with a new river crossing. By the year 2014, forecasts indicate that there will be more traffic in downtown Stillwater than there is currently, even if a new bridge is constructed. 1 1 1 1 6 .--r 0 rn Li- z I ' J I I a 1 z I N N I I 1 1 w ■ I- -\ O \ ■ - w \ \ - o %\ \ /- - \ ' \ `\ \ / - �/ ' \ L\ \ ■ \\ \ - ✓ 1 /-�\ \ \•L \ \ \ \ �- -- - ' \ \ ■\ \ \ \ ■ /' \ , ■\ ' \ \ ' ■- - - - \ \ \ \ \ \ \ ■ \ • \ \ \\ \ \ \ \ \L , 3 \ \ \ \ \ \ RC1p\./ \ \ \ \ \ \ \ G0 / - - \ \ \ \ ■ \ \ W '\ '\ '` \ L,\ \ '` \ \ \ \ > �-- "I ' �\ 'fie,\ + �n ' " ^ '\ ' '\ �11% 1 0'0, X00 W X X I., , -" 4011 \ X 0, X %. -.% \\,_,..e) 0 - -' \ \ \ \ - r7 \. \ \ \ I— Z --d f - -A \ \ \ \ /o, / fi.` ; ` � , \ -X \ .X \\ (X U.) X L \ _.� \ - \ \ \ \ 1- v \ \ • - \ L O \ \ N \ ' M + \ \ \ \ \ OL \ \ \ \ \ 1 \ •\ \ ■ \L \ ' - - \ •\ ` \ %■\ '\ ' \/ ' ' r " \ \\ % '' ■ \ ice / '\ \ \ t �)� • \\ \ 1 ‘\•,.,„/•%.c',\.?/N s..,1\: • \\\ \\ %` \\\ \ \\•,�` \ \\\ \\• (\\ DOCK `--\ .I-c--■_V X*.‘' ' \ `.�\• \' ` �✓) \ \ - •„\ \ \\ `` \\ \, -11 \\ \` ` \\• \ \ \ a d1 •\+ \ \ \ ( \ :Itt ,, \\\ • • v1 P P P P P ..., 111111 MI MI MO MI 1.11 11= 1111111 aill MO MN OM IMO MI 111111 MIN NM ON MN N . 0 v'1 H 0+ LL rr I ' -J . I I z 1 1 U 1 1 w 1 1 N N 1 , w \ \ 0 r -\ 0 z \ \, - - \ 0 \ % - \ r \ \ \ \ \ - \ \ r- ' d' r r - - \ \ \ \ r \ -r •••• - \ \t \ \ - -r • '- \ \ \ -r Ic \ \ \ ' ' \\ r- ✓ r \ \ \ \ \ r .•' \ \ \ \ \ \ Z. \ \ \ it \ \ \ \ \ '2 \ \ \t \ 3 \ \ \ \ \ \ \ Cp H1 - \\ \ \ SNH1 \ \ \ \ G - \ \ CH� \ \ \ \ a \ \ \ \er \ \ \ V - - \ \ \ ■ ` � ' \ \ \\ \\ \\ C' 'r - \\ \\ \%%%%%t \ \ \\ \MONINAENT Cr \ \:i'::>\ \t\ ^\, \ r e - \ \ r v II II• - �; •\ \ \ \ `\ \ \ I I III X I H •' - \ \ \ 2\%t\ \ \ iII\r• r \CO \ \ I --\ \ "lt-E -- ' \ - ,I ,10 \ ` \ \ - I I I w \ \ \ r rr - \ \ \ \%t\ `r • \ \ - \ N Q \ \. -` - \ \ \ \ \ \ \ \ \ j r •'" \ \ ■ r r X C\ \ \ \ I - z r rr- \ \ \ \ - r rl ® ' ^\ \ \ Nils:r-r \ \ \ \ 1 t \ \ \ \ • ■ If X 14 W 1 r-. \ r I \ \ \\ Q% \LL \ \ ■ -. 1-1 \r r \ 1 J \ \ O r J ... % \ \ \ 60.`. / \: --' x r \ GN \ \\ \\ ;%\\ Y - �l\ \\ fah' r \•. ,\ \ \\ \ \ \\ G\-ZV£- r \ \ \ k. \\ \• \ \ \ \r r \ \ \ \ • L■% \t \\ r r GHES V� \\ 1%\t (\ �\ r L6 `)%\ - - \ \ 0pqs-- ... yr \tt \ -\ � r-'' -'-\ ■ \ - - ale / ('. `�� ` 1 - r r \ \\ \ \ r-a'.'I - , \\ \\ \\,\ \ 1 % \ \:*.4 / \ `. .\ \ \\ \\ \\ \\ l.I— . ', \ \\\ \... \ .\` \ • \• \\ \ V '\ \ \\. `\\ \\• N. \ X 1..jsk3s.r....4.\\<....4121 -•• ,or J 0\ 04 x r: \\ \ 1 \\ P P P P Q \\* Hc.s1W1 `� 1--1 O GHES�Pv '��, \tig G �� > ILl SeSS REFS \\\,..,:i. >Paa' W 1.11 1111 an MI - - M - - MB - - M - - - 1 M IMO re) • . Li— N 01 X I I I I I 1 N ■ 1 -_ 1 N ■. 1_ - - ' 1 v) w 014 , - -- `\ \ F ■ ■ - - -1 1 1 ■ w if ,1: \ 1 _ '- ✓ 1 - ■ \ 1 ■ \ - - 1 ■\ \ t1 ■ ■ 11 % ■ -- ' - ` ■ \ 1 ■ 1 ■ ■ � ... ■ \ \ ■ ■ ■ ■ \ 1 t \ \ ■ 1 \ \ 1 \fib \ .1 1 \ 1 . \ ■ ■ \ RCS,NV- _ ' ■ \ 1 \ 1 ■ \ CU .... -' ■ ■ ■ \ \ \ \ _ _ - 1 1 \ \ ` \ \ 1 -- ' \ 1 • \ \ 1 Cr \ \ \ 1 1 \1 \ 1 W \ \ \ ;_ ■t ■1\ 1 t ■ \. '1 '1 \\MONU ENT > ■ \\ ■ 1 1 t\ \ ■ .1 \ • + ■ \ 1 \\ \\ 1■ ' -e \ 1" 1 \ - ' \ \ ■ ■ ■ 11 \ \ - ' \\ • \ % 1 •"" r A • ‘ 0,.111, .........,, \ 1 , , , ..... ,...„ , 1 • It . • 1,__, , ...„ 0 ,.,., cc ,.. 1 1. - 1 1 1 \ 3 1 a V,... O ' - -' \ ■ 1t \ -' O \ \ \\• `. 1-:.f (n ■ 1 \► ' ry - \ 1 \ \ \ O H `� \11 \1 --+? \1' •• - - -- \\ 1\1 1\ t 1 IMAL�\ \ \\ -J L L W ■ 1\ C1i651 - ■ 1t \ 1 \ \ .1 1.11 ■ \ 1 1 1 \ \ 1 i ■ e►1\ \\ N \1 t\ 1) ■\ 1 ‘ \ \ \i \ \ A t 1 _r ' \ y\ 1 \ \ t1 , -> > - 1 \ -11\' \ "1\ 3 - - \1 \ - - s. - " \, \ \t�\. \\ -.`r\ \ ) r"" A A r \\ s ‘ / \\\ \ 11 \ \- - ON \ p \ ■ + \ DOCK ( \ ■ \ ■1 ■ \\ \ ■\ \ ` \ �\•• 1 ■ \ + \ •\\ \ \ /) \ \ \ \ \ 0./ \ 1 \\ \ \\• \ 1:::%...3+ 1 1 \ 1 \ \ \ - - 1 1'\' \ \1 \ \\\\\ 1 Uj V CNESjN v P P v v 0 v is mit wie mi I= Iwo No I= ow =it me EN Ns ilim V' 0 .H U- 33I 4 1 or I 1 I I -J a Q I < Z !III ' o N N 1 n w tri tt e f . .` 1 z \ -'1 1 1 \ \ -- - a,,r - ' \ \ \ \ - \ \ \ 1 \ \ � - V - 1 \ 1 1 ' -'r + .\ \ \0% 1 \ 1 . 1 1 1 \ \ 1 \ - 1 1 \ 1 \ \ 1 --.. \ \ 1 \ 1 1 \ \ \ ` \ 1 ` 1 1 1 i t% \ ) \ \ \ 1 1 1 1 ac,. 01'-'t^ 11 1 1 1` \1 \1 1\ rCp ' ).1x 1 \1 \\ \ \ 1 \ \ \ 1 \ X 1• --1..„-,-,c.-..\. i. I \\ \1 1\ - ' \\ \\ %%fit\1 \ '., 1 1 MONUMENT %1 1 \ \ \ tip \ \ 1 \ \ W \ 1 \ 1 l 1 > • \ 1 \ \ \ 1 �\,\ ` \ 1 1 \ pf,�,i , • ...•X \ \ .\* 0 X•■•.... ...... 0 1 \ -›- `\ 1 1' 1 i 9 \ �0 �▪ , Ct 1 1 .' i ▪i H Q \ \ -- r+ - 1 1 1 1l, 1 1- \ `- CC W \ Al•O --' -- - \\ \\ \\ t\ -1 O ,P. "�°a-t�' \ \1 \ '. \ Y c,'. 7\\x• D V) \, 1 1 1 - 1 \ , \ J..•...,.... iii 1--4 \ 1 045 - - - 1 1% 1 %- \ o Z LL W 1 1 - - - 0 1- - % 1 1 11 `'' 1 -- - 1 \ 1 % r< \ CC % % 0-Al.. ." ..,:err•A„ -f1"-%':".. '‘ % k.-. % - w - � \ - -- 1 \ ate \ \ \ .` • _. .„..I`% - - - \ 1 \ \ -r„ - . \ # „\ \\ \ \ 1 1 \ \ ♦■ ♦ `y t \.\ •x\ \.\ \ DOCK 6� \ G • ci • \ ' •.\ \ \ d.) % �„ S\fir \ . \ J '- k O 1 1 wa, 1 W • \I%1. Q \\\ �-2 v ee - w le St0 , i co- �NUj Z CHES p LLI O P P 1--1 P \et{0 wit Y 1-4 P >P w I CC Eni P MN O — O l — M — i — M MN i M Ma M MO In • • O H L.L in a) Ix 1 . I I 1 I )• 1l'1 s la I I $ J I 1 H a z t% ' m „ -'\ O .' \ N • .�\ \ „r- ` N \ .r 1844 r \ \ O c'\ \ r" ' '\ \` \ \ W%% ' --\ r ' \\ \\ \\tt\\ O if „ ,1\ %\ `rr ' - r ' \ \ \ ` \ \ \ \ \ t• \ \ \ \%\ \4 % PL -.1 '\ \\ \\ \ \ \ �-6+.�„�,- r `mot ` \ \ \ • \\ %\ %\ `\ Gi a►,r� -' - \ \ \ \ • \ \ \ \r r ~ '''.... r '\ \\ \ \ \� \ \ \ \ \ \ \ \ \ \\ \\ \` ;r ' ;`,\ `\tt'\ \ ; \• \MONUIENT W X i. \ ' ' / H-1%X X X \ 13\ At% ... •••"' X ' �Q \ t\ \% \ r O ,« ' \ \ ` i � ,�� X \S \ \ \ s• \ \ \, `� ,•O �". \*-Aidi\k , CC r - �\ ' `\ 'woks $1`\^' \ ` • u' CC r-'r rr j \ ` ` t\ j, 41t or ?,\ \ \'\ ;\ •� ` -` \ Q l/) LL Z S rr - \ ►\ Q e• \ N \ ' tf \ \ \ ; \ \ s \ \ \ J \ \ \ % °Ll- ;. ,• ,. - - \ \ . \ •\ %\ t\ ,a r- \ ' \\ \\\ • RI 1 % % 001%, -•"..,.. %/% % "1 '\-\ '-‘•"1 ? 4 ••• .... r- r - ' \r—r r- \ , \\. \ .. ' - - - - \ \ ' -a'�iw4- \ \ \ i c.% -' r \ t\ \ \r - pN \ � o ` 4 .‘ Nlirlierr"----...„,\,\ I-- X X X \\ NN ‘•,.‘\ \ \ D % % % % Q.„.-t (1) \ " H 44 > \ \ \\\ W CC H \ /1\Q cr un CT'O <L w LL 0 J V .f' z a. • 0 H 01- (1) a W V) W I— Z H ;,. 11.11 MI 111111 - 1.111 1111111 MI NM 1111111 11111. IMi Miii NM Milli IIIII Mill OM INN IMO IIIIIII ' 1 - 0 M LL 0) Z , 1 1 1 Ii,, s I c !- ;---\ ' • \ r • \ 0L0 - \ \ --. N \ \ --'f --\ \ ■ t U, ■ \ \%t\ F + ' -- \ \ \ \ o z \ \ -''I I �\ \ \e,\ \ \ \ \�- ' + '+ f \ \ \ \ \ \ \ -' \ \ \ \ \ \ \ C. \ t \ \ \ \ \ \\ \\ \\ \\ CO -—�-\3'-%" \\ \\ \\ \ b \ \ \ \ •'''40, .. \ \ \ \ \ \ \ \ \,.. \ \ \ \ \ CC i i \ \ - \ \ \ \ \ • . W \ \ \ \\ \\ \\ ;- ;,`\ \%. \\ \ ; r.„ •\ \\IAW\IUTAENT N 1. \ \ \ \ \ \ \. •\ ,r • \ - Cr 1 % % % \ \e‘ ......\s;I\ , . , , , , , ,c. , \ .. .0a 4. v x\ ', 3 • 1--''• ...‘ •-• 10 X X ..•••'1 Cr X X ikl LC' .... ".• ...''.. X X . *Ali,' 0 0 cr a ••••••1.0 • X be LLJ 0 -'' \ \ \ , \\ --- 010.--.-. © \ \ \ \\\• t \ \\ J , V .4 H \ \ ST140--+ --'' ■ \ \ /WALE \ r� o r'd ■ A x CO \ y\\ \ \ $ \ + + \ \ X \ a Cr X z \\ \ \ \\ OL1V6 w, \ V. \, \ k \\ • \\ \ 's+r-�\ \ t o S 1`t ` ✓to O 0 3 t• ■ \ \\ \\ \ \\ \N / \\ \:\\ \ DOCK 6�,■■ \ \ \ ■ \ \ •\\. /) \ \ \ \ \ \\ ✓ \ .\\ •\• 0-1., i::::.•••i,,I, X \ \\ . \ \ 1 al \�N - .\ - �\\ \ \ in \ W z a J V \ 1 i 3 0 43 J i , MI MI NM NM E MN 11111 M r NM M M r '• I • CD H I L I I I I I I ► \ \ \ /1 J % ► / ' / \ Z \ N �/ \ \ "\ Z /-- \ \ ►% \ W c) % - . , , ,, , , _\ \-/ ' / ' \ \ \ \ \ \ \ \ \ ' \ ► \ \ \ \ \ \` ) \ \ \ \ \ \ \\ gGip�' \ \ \ \%\ \ \ \ c _ '/ /_ \ \ \ ► \ \, ,. / \ \ \ \ . \ \ \ ► \ \ ► \ cli \ \ 1 c \ ► \1i\ \ \ ►MONUMENT - \ \ \ \ %t \1 ■ \ \ \ \ ■ W•\ \ \ \ \ t\ ► \ •% . \ >,‘ X X \ n:, \, 1 1 ..... ...... .,...•1 X 0 ilk 1 ,- , ,_, cr 1 1 1 , , , .t ,-- •-- 0 1 \ • ...._ 1 , _ 4... , _-- --\‘‘‘ ‘,1 ... ....‘ . 7%, \Ili 0 0 H 0- 1 Ct \ \ N • '-\ ► r cc \ � \ � '/ \ \ / ' r ► /' \ \ \fit\ \ `�/ /■ Q \ \ 1 ■1� \ / / O �\ \ \`.� \ W ..� \ \ \ \ ► 1 \ \ �c 1 , F--1 11\ \1 GNES�M jT`i \\_:\\/ ,\ ` 1\11 1\\ �\n���` \ \\ V Y Qy \ \ Z ■ \ \ \ ., - N., r \ F O 1 \ p\ \ \\ \ ■ i■cr. % ■■ 1\\ \ \■ \% ►\ \\ N % ,- % ■ oys„. -• "' ".. -%%II% ,-I , ..t ., ‘\\\\ / _ \- As % V % ►/ ' / SON \ \ � o . \ ■ \ /''NEB" t \ \` .� N. "/1 1 \ 1 \• • ► \ 1 \ 0.:.-_-1 \ \� �\ • \• ` \ \ ►\ �\ ( ♦� X X\ ip/ ,...., ,t„,,.......... •....., .. \\ \ o \ \ F"�n \ w 7' ►t w zF V -1-, \ i APPENDIX 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 Appendix A 1 DOT METRO PIST . TEL No .612-297-7328 Jun 8 ,90 10 :06 No .001 P .05 II . RP 07 '90 it:1.14 PIN.F/kr1 Acz.ST CG''N9 PM 42;.; P.4 COMMENTS ON I STILLWATER/H' ONS'T:CR0IX RIVER • CSS?NG _ The Draft Environmental Impact Statement for a new Stillwater-Moulton Bridge I - is being reviewed. This project has been discussed many times and it seems likely at this time a bridge at some location will.be constructed because of the need for a bridge, from a regional as well as local perspective. The 1980 U City of Stillwater Comprehensive Plan calls for such a bridge and previous plans back to the 60' s discuss Downtown congestion and the need for a new bridge across the St/ Croix. IA new Stillwater/Houlton Bridge will significantly affect the City of Stillwater and environs - possibly more than any other public works construction project in its history. In determining its position regarding a I preferred bridge corridor location, the Stillwater City. Council has reviewed the Draft Environmental Impact Statement and special reports, held special meetings to describe the project to the public, receive comments and attended I MnDOT meetings to discuss the project. Recommendations regarding bridge locations have been received from the City Planning Commission, Downtown Plan Steering Coitfflittee, Certified Heritage Preservation Commission, nowntown Business Association, Chamber of Commerce and Downtown Development ICorporation. • It is now time to make the City ' s position regarding the bridge corridor I location known to the State and the Stillwater community. The major environment, transportation, land use, historic and cultural resources and economic impacts of the bridge alternatives are well documented. It is II important to make the City's position known and actively try to influence the decision making process because of the importance of the "bridge issue" in the future for Stillwater. Depending on location, the bridge could solve many of I the Downtown traffic problems or cause irreparable damage to an endangered cultural and historic resource, Downtown Stillwater. Beyond the Downtown, interchange locations and designs could significantly affect other parts of Stillwater; the Highway 36 commercial corridor, major City streets, South Fourth Street, Greeley Street, and County Road 5. Once a bridge corridor location is selected, careful attention will have to be paid IIto specific bridge and frontage road design and appearance. Based on the community input the Draft EIS and local transportation needs, the II following facts and statements present the City's position regarding the bridge corridor location and Draft EIS. COMPREHENSIVE PLAN CONSISTENCY '�Fae` nor an centra rt ge corridor locations are inconsistent with the City's Comprehensive Plan. The plan calls for a new St. Croix bridge outside of the Downtown. The overall goal statement in the Downtown Plan recognizes I . .... Stillwater historic rivertown image and natural setting: . . "The image and identity-of Downtown Stillwater is of primary 1 importance. It is represented in its historic buildings, its natural setting, and in its dedication to open spaces and the river. The goal of the Downtown Plan is to enhance and retain the IIhistoric rivertown image of Stillwater through a conscientious and I DOT METRO DIST . TEL No .612-297-7328 Jun 8 ,90 10 :06 No .001 P .06 JUN E1? '93 16:04 MNI/LD01 ASST C OM i F'M 41:. r.y. li II gradual process of change and economic growth so that Stillwater, the Birthplace of Minnesota, continues to be a special place to IIlive, to work, and to visit. _" A Central Corridor bridge would be inconsistent with the underlying goal II for the area. More specifically, the Downtown Plan called for the retention . of the existing lift bridge recently designated to the National Register of Historic Places, as part of the Downtown historic IIcharacter and for the new bridge to be located in the South Corridor. TRANSPORTATION The City of Stillwater appreciates being involved in the planning and II environmental review process for the proposed new riser crossing over the St. Croix River. The City has been actively cooperating with the Minnesota Department of Transportation and other transportation planning I agencies for the past thirty years in efforts to resolve the existing traffic problems. The City has had an opportunity to review several previous reports from Mn/DDT as part of the environmental review process Iand the Draft Environmental Impact Statement. The City of Sti l lwater i s very aware,'of the deficiencies and capacity II restraints of the existing road system. The City has lived with . congestion caused by the lack of capacity for many years. No other community or agency is impacted by the existing problems like the City of Stillwater. The existing lift bridge and the approaching roadways do I not provide sufficient capacity to accommodate current traffic. The existing roadway is narrow and the intersections are very restricted. The Downtown area is congested and has many .confl icts between pedestrians, automobiles and trucks. The Environmental Impact Statement provides a historical review of past efforts. The City has worked for the'past thirty years to improve the I now of traffic in the Downtown area. The City has removed parking on Main Street from Myrtle Street to south of Chestnut Street. All parking has been removed on Chestnut Street between Main Street and the bridge. I Left turns have been banned and left turn lanes added. This has been done to improve the flow of traffic and has often worked to the detriment of the Downtown businesses by reducing local traffic 11 circulation and removing valuable parking spaces. Numerous other options have been studied over the past thirty years. II Total removal of parking along Main Street and creation of double left turns westbound would slightly increase westbound capacity at the Main Street and Chestnut Street intersection. However, a large, northbound II vehicle would be unable to turn in the remaining portion of Main Street. The use of one-way streets using various combinations of Water Street, Main Street, Nelson Street, Chestnut Street, Second Street and Olive Street have been reviewed and found to be unworkable because of the II narrow rights-of-way and the grades on some of the streets . Reconstruction of the roadways in the Downtown area to include a bypass . through the east side of the Downtown would virtually wipe out much of I the historic character and several of the buildings within the Downtown area. There would still remain a single lane in each direction on a lift bridge creating congestion. The use of other streets, such as Third I . DOT METRO DIST . TEL No .612-297-7328 Jun 8 .90 10 :06 No .001 P .07 JUN 07 '90 16:05 MN/DOT ASST COMM R•i 413 • F.6 II Street, Fourth Street or rtle Street has been reviewed and found to be lacking because of the steep grades and the discontinuous platting of II streets in the residential areas, The City has been bypassed by a route tram Highway 36 and CuuriLy Rued 15 on the west side of Highways 96 and Q5 on the north sine . This marked hypacs has removed only a few Ivehicles. Despite all the efforts the City and the State have made, traffic delays I and congestion have continued to increase. In the 1960' s traffic delays occurred on Friday nights for two to four hours and for a few hours on Sunday. As traffic grew, congestion occurred from early afternoon Friday through late SundaY night and began to occur every evening. Today, II traffic delays occur for two to four hours Monday through Thursday and from Friday noon until late evening and all day on Saturday and Sunday. Even on weekdays when the lift bridge is operated, congestion Iimmediately occurs in the Downtown area. Stillwater residents and visitors continue to cite traffic as a major 1 concern. The traffic situation is .responsible for some Downtown businesses leaving the Downtown area. Traffic volumes have grown with the development of Western Wisconsin as II part of the greater Metropolitan Twin City area. The bridge traffic is composed of recreational traffic on weekends but most of the weekly traffic comes from work and business related trips. In 1962, the average daily traffic (ADT) on the bridge was 4,900 vehicles per day. In 1970, the volumes had',risen to 8,000 and in 1980 they were at 11,000 ADT. Volumes in 1986 were 12,400 ADT: Traffic volumes in the Downtown area II have grown even greater. Volumes on Highway 36 immediately south of the Downtown area is currently 17,400 vehicles per day (1986). This is one of the heaviest volume two lane roadways in the Metropolitan Area . I Generally, volumes between 8,000 and 12,000 will require -a four-lane roadway. The backup of northbound traffic on Highway 36 frequently extends back Ito the Hlghway 95 and Highway 36 intersections, more than a mile from the Main Street and Chestnut Street intersection. Traffic attempting to bypass this backup have used a combination of several less desirable II routes. Some traffic utilizes the Highway 6 interchange (which has a very limited sight distance). Traffic then uses County Road 5 and Olive and Myrtle Streets or Pine to reach the Downtown area. Others will use I County Road 12 and Myrtle Street. In a typical evening, traffic will back up for a few blocks on Myrtle Street from the stop sign at Third Street. Traffic also uses South Fourth Street and Third Street and other combinations to reach the Downtown area and approach the bridge on I Chestnut Street. Others will use a combination of Owens Street, Greeley Street, Pine street., Olive street, and Churcni'll street. lrattic from the south on Highway 95 will often use County Road 23 (Beach Avenue) and I . ..travel through oak Pork Heights and Stillwater, using rourth Avenue and any other combination of streets. Some will utilize Chilicoot Hill on Second Street approaching the Downtown. This hill, has been' deemed dangerous enough to be closed each winter, 1 IDOT METRO DIST . TEL No .612-297-7328 Jun 8 .90 10 :06 No .001 P .08 JOIN 07 '90 lt.:UL+ I'lhi'UU I H .�.I Will K11 471 `• ' I . This bypassing of traffic through residential neighborhoods has created r documented speeding problems, numerous complaints from residents, and request for stop signs. Traffic , with its frustrations of backups and bypasses, will speed, roll through stop signs, and create serious II concerns for the safety of pedestrians who may be crossing any of these residential streets. The commercial and industrial' development in Western Wisconsin, I including Somerset and Now Richmond, has created heavy commercial traffic traveling through the Downtown area. A single commercial vehicle II has a significant turning problem at the Main Street and Chestnut Streets intersection and generally travels slow on the hills coming up from the Downtown Stillwater area. With the growth in commercial vehicles , a new capacity restraint has been added to the Downtown again IIsignificantly reducing the ability to travel through the City. The lift bridge is a serious congestion factor. Through the cooperation I of numerous agencies, a rigid schedule for opening the bridge has been established which has diminished some of the previous problems of frequent openings. However, the greater number of boats using the lift bridge has created a longer time length of opening, decreasing the II street capacity in the Downtown area. Any time the lift bridge is opened, it stays open for several minutes creating an immediate backup of traffic into the Downtown area. I An early 1980' s Minnesota Department of Public Safety report on pedestrian safety in several communities indicated that the City of II Stillwater has half its pedestrian accidents in the Downtown area. Included are fatal accidents involving pedestrians crossing downtown streets in the face of heavy traffic. While the City and State have I cooperated in attempting to make pedestrian safety a higher priority, pedestrians are still at risk anywhere' in the Downtown area. A simple change in phasing. of the traffic signal at Main Street and Chestnut Street to protect pedestrians from left turning traffic resulted in a r . intolerable backup of westbound traffic. Traffic frequently backs through the Nelson Street and Main Street intersection forcing pedestrians to walk between vehicles. It is virtually impossible to Icross Chestnut Street at Water Street at any time. The accident rate for Highway 36 from the St. Croix River to Highway 95 II is almost double the state-wide average for a two lane urban roadway. This is despite the fact that at many hours of the day, traffic is at a standstill or moving slowly significantly reducing the possibility of accidents. I The major concern of the City of Stillwater is the future of the City under a "no-build" option. The Mn/DOT forecasts under the "no-build II alternative is 2'8,2U0 .vehicles per day on the lift bridge, 'double the current volume. Volumes on Highway 36 south of the Downtown area would be 33,700 vehicles per day, almost twice the existing volume. It would II be physically impossible to carry these volumes of traffic with any semblance of order. Traffic would be beyond capacity for several hours a day. The major concern is that traffic would back up significantly IIfurther than currently along Highway 36 to the south. The backup DOT METRO DIST . TEL No .612-297-7328 Jun 8 .90 10 :06 No .001 P .09 Ij ij l Lit i .i 10. .t i1'l'i. $ n.�..'i %..ui a 1 e i i ...... undoubtedly would reach the high speed four-lane sections in Oak Park Heights . Traffic diversions would be numerous and many of the residential streets would be faced with high volumes. Third Street, I Fourth Street, Myrtle Street, Chestnut Street and others approaching the Downtown would have blocks of backed up traffic attempting to access the II single lane of traffic heading into Wisconsin. Volumes on the Wisconsin side of the bridge would be similarly affected. The forecast is for 9,000 vehicles per day on the County irunK nignway t approach, a roadway marked by "Dangerous Hill" signs. A concern.is that traffic, once clearing the bridge, would drive fast and dangerously, attempting to make Op for the lost time waiting in traffic. Traffic will not divert to the Hudson bridge several miles away because of the need I to travel through NOrth Hudson and Hudson, or Bayport and Oak Park Heights. The alternate route would take 20 to 35 minutes depending upon the time of day. In addition, the volumes of traffic will significantly II back up far beyond the Highway 35 and 64 intersection and beyond the Highway 36 and 95 intcrsections. Diversions would be down county roads and other city streets not designed fro the types of traffic that will II occur. ; The City has l oo'ked at TSM options. They simply are not workable. ITransit would sit in the same traffic backups. Ridership would be low. . "No action" or "no-build" is clearly an unacceptable alternative to the citizens of Stillwater and to the thousands of motorists waiting in Itraffic each day currently and the many thousands who will utilize the 'bridge in the future. . 1 Travel 'in the Downtown area would be impossible, Pedestrians would be at risk any time they stepped into,any street because of bypassing traffic. Cars would be idling on virtually every street with obvious impacts on I air pollution. Of major concern is the impact of exhaust fumes on the -old-brick and 'Stone facades which were constructed back in the 1860' s, 1670's and 1880's. Also of concern is the impact of the vibrations from . the increasing numbers of commercial vehicles. Replacement of the bridg e on site is clearly unacceptable. While a newer I bridge could be built, it would have similar capacity problems and the same tremendous' negative impacts on the street and highway systems of Downtown Stillwater, residential Stillwater, and Western Wisconsin that the existing hrirtge has_ 1 ' The City of Stillwater has recently devoted a large amount of resources in terms of both time and money, for a study of the Downtown area. This I Downtown study has resulted in a Downtown Plan developed by the Stillwater City Council, The plan took years to develop and implement, went through numerous public meetings and hearings, and was the result of efforts by two different citizen committees. The plan has had the I approval of not only the City Council , but also the Planning Commission, Economic Development Committee, Historical Committee, Chamber, end others. I . . 1 DOT METRO DIST . TEL No .612-297-7328 Jun 8 .90 10 :06 No.001 F . 1u As a part of the study, the City reviewed the North, Central and South Corridors. A North Corridor would ° access forttheDCity of II area and would create numerous Stillwater. This is in addition appearing the river disruption Te north alternative is qualities of the more natural not a viable alternative for the City of Stillwater. IISimilarly, the central alternative is inconsistent r bridge theon would Plan and past plans for the City. The cent II impact the visual qualities of the river andhe Dow tow rrarea. It ould also perpetuate many of the problems on the il The City intends to expend funds to improve the ,aes h either tics side of river r front, primarily in Lowell Park , for a fe existing bridge. The visual impact of the bridge y ssing unacceptable. 7,ht 1 of much of the park area would be front o II touchdown of the bridge on the east �sidii of the river would lview of City owned Kolliner park near the existing quality of the river and the elevated bridge would destroy Wisconsin bluff lines as viewed from Downtown.'its characteristicechurch of the historical Downtown di s steeples and Pioneer Park as viewed from the river. It would the most river fic .visible structure possible terms thefpro�ectedf22 ,000 to 33,000 believes that the nG7Se impact P act unacceptable to people in the Downtown, vehicles per day would be residents living on either side of the area or traffic on the. river. A central bridge would destroy the f Proreesouth of city Downtown, II property referred to as the Aiple Property p planned for open space and river recreation, as an which is currently p II eLowell ParThe entral i�inr'LowelloPark pry�oyeddbyeover a of the Qxperisnce o main view from the park would be the million visitors per year. The bridge. A central bridge locationKw would odlso limit the attr ctivr ess II and value of City owned Kolliner Park open on II The City, .after careful review of the many documents than yepon thirty years of transportation studies and more of river front existence, has unanimously vhsupeporste existing South Corr .well The corridor aligns most closely designed, aesthetic bridge isn consistent areful design would minimize the II •Minnesota side of the river and c The bridge would have impacts on the Wisconsin side of the river. significantly less visual impact than lant smoke estacks, other or belts r a, Iand coal piles of the NSP power plant, uses made of the river at this location.de wouldehave little visualiimpa t clearly fully developed and the 9 to users of the river. Noise from strialinotse this location would Andersen plant or II significantly less than the industrial this the King plant or fromizhRiverrp The rnoise alevels rwould ydafi definitely be • II portion of the St. Croix in the less than the unacceptable co�9e,sti ad scent to pedestrians and numerous Downtown Stillwater area directly IIpeople oriented businesses. 11 DOT METRO DIST . TEL No .612-297-7328 Jun 8 .90 10 :06 No .001 P . 11 ' II the The City of Stillwater has lived with the traffic problems since the invention of the automobile. The City has made grey Downtown area to adapt to the use of City streets as well as county roads and highwaYs by non-Stillwater traffic. The City has attempted to retain the scenic qualities of the St. Croix River as proven by its preservation of some of .the river front, developments of park and II recreation activities overlooking or adjacent to the river and the support of the recently adopted Downtown Plan . With this type of commitment to the river, it is extremely difficult for the city to I recognize tho claims of some individuals ann gr naps that the traffic problem exists for merely a few hours for recreation traffic. II HISTORIC AND ARCHEOLOGICAL Minnesota was orn a ong the banks of the St. Croix River in what is now Downtown Stillwater in 1848. This event and the succeeding evolution of the area has a lot to say about what is the essence of Downtown Stillwater, and to Isome extent, Minnesota. The pattern of activity and remnants of the lumbering and manufacturing eras II can still be seen in Downtown Stillwater. In fact riverside parks, Lowell Park, Koiliner Park and Aiple Property were all lumbering sites given to the City after the demise of lumbering. I Stillwater has always been recognized .as the town of brick and church steeples on the St. Croix. Recently, the general perception has been formally recognized through the nomination of Downtown Stillwater as a National II Register Historic District. The existing lift Bridge and several other historic buildings, already on the National Register, strengthen the. historic significance of the Downtown. Fortunately for Stillwater, and unfortunately . for many Downtowns that experienced road and bridge projects during the rfifties, sixties and early seventies, historic and cultural resources are no longer taken for granted. Through Federal and State laws, special attention II must be pdid to recognized historic resources such as Downtown Stillwater. Section 106 of the National Historic Preservation Act requires projects such as this bridge project, to take Into account its affect on historic properties . Section 4f of the Department of Transportation Act states that II projects shall not be approved which destroy or substantially alter a historic property of Local , State or National inportence unless there is no "feasible and prudent alternative" and all possible planning is undertaken to minimize I harm. NEPA requires an EIS for major federal projects that will significantly affect the quality of the environment including important historic, cultural and natural aspects of our national heritage. Dr. Norene Roberts, author of Historic Reconstruction of the Riverfront; Stillwater Minnesota 1985 and Intensive National Register Survey of Downtown 11— kii.linnesota , 198 1r1as indicated thaw ?106 review shoulU5 II con acted-far the-Downtown and Bridge due to existing traffic vibration and exhaust. Beside these impacts, the visual and noise impact of a central Bridge location would affect the character• and attractiveness of historic Downtown IStillwater. The Central Bridge Alignment or a "no-build" option Will affect the Downtown. II historic Stillwater properties; the Downtown Stillwater Commercial Historic ' District, Lift Bridge, Freighthouse Depot, Roscoe Hersey House, St. Croix - Lumbermill ,* Lowell Park and Vittorio's and the required NEPA, Section 106 and I 4f reviews must be completed before a Central Corridor and "no-build" option can be selected. I DOT METRO DIST . TEL No .612-297-7328 Jun 8 .90 10 :06 No .001 P . 12 JUN le"( 'SO 16109 ti'/tJGT Ht-.;td cum Kr•i 41..J I . l l II . The National Wild and Scenic River Act also supports the preservation of hisLuriu areas, The Act deeldr•es "it is the pulicy of the United States that selected rivers of the nation which with their immediate environments possess outstanding remarkable scenic, recreational , geological f i7 and wild life, I historic cultural or other similar values shall be preserved in free flowing condition that their immediate environments shall be protected for the benefit and enjoyment o present an u ure generations. (underline added) IThe Lower St. Croix Master Plan, the plan developed by State and Federal natural resource agencies,to recognize and protect the Lower St. Croix River states "The development and management of the St. Croix should place primary 11 emphasis on maintaining and enhancing aesthetic, scenic, historic, fish and wildlife and geologic features. " (underline added) The Wild and- Scenic River Act and lower St. Croix Master Plan requires that the historic and cultural II resources of historic Stillwater on the banks of the St. Croix be preserved for future generations enjoyment. II FCONOM!C The economic impacts of a new bridge are concerns of the City. A Central Corrirtnr Rridoe or a "no build" decision would have a negative impact on. II Downtown, The Downtown is congested and suffers economically because of the congestion and heavy truck traffic. Increased traffic would only worsen the economic viability of the area. . I It a Southern Corridor Bridge location is selected, the interchange and . frontage locations and design will be critical to provide convenient access to the adjacent businesses. . IICONCLUSION Tt 1s c early evident to the City that a "no-build" or Central' Corridor • location are unacceptable and unmanageable. It is also clear that the South Corridor has a significant number of advantages for the traveling public, the river user and the adjacent communities. The City urges the Minnesota and Departments of Transportation to support the South Corridor and to IWisconsin continue to maintain a schedule for construction and opening of the new bridge to alleviate the unacceptable transportation and safety problems in the Downtown area and other areas of Sti l]water. 1f a "no-bui I d" or t:entra i I Corridor location is selected, it is the City's position that additional NEPA, Section 106 and Section 4f study and review is necessary. I • . II I � Appendix B 1 1 1 1 1 I I IS 3 _ w TI lE I 11 - 1 P 2 — is 3Mo 0�a f ; E-1— Ow ow= 'LS LAWSIS0 a a `a �� a . • • —y , , `tea 1 14 CC 11111 i O _ - da-, 1 a. a �_ c: - J L'! Z U - . I w -- - E .: a SU ' 1-a C f 15 AW 3ffl% , ��. , x 1 O Z u cc • I ao t z I C4 3 r is Ammo r a,, 3 � _ Ia-4 =�1 U -�7 c 'IS 131r,r, C X: I . ` c . 3 LS t3u,r, N ...,.1.. .... 4.• I 4 E _ G u a re 0, . 1.., c ..., 0 ' cac; c , z0., cep I 4' If r /6 5 -- : c I