Author Topic: EEIP Draft Now Published (Read 276 times)

Michael Caswell · « **on:** June 04, 2020, 07:14:22 am »

http://canals.ny.gov/Earthen_Embankment/Draft_Scoping_Document.pdf

It looks like the SEQR Draft Scoping Document is now complete, and open for public comment.

It would appear that all is ready for the next stage, removal of vegetation from the embankments.

Doug K · « **Reply #1 on:** June 05, 2020, 08:30:19 am »

Mike, It's been a long time coming, and only 13 pages for the entire statement with half dedicated to discussing how the Canal Corporation will handle the 15 identified areas of Environmental Impact. That part of the statement took nearly half the pages to address. The Erathen Embankment Integrity Program is here to stay and will be the work that most see happening along the Canal Corridor for the foreseeable future.

The rest of the Draft GEIS (General Environmental Impact Statement) is a rehash of their earlier work on their Embankment Restoration Project (EERP). The statements of impact are similar, there is a section on Vegetative Barriers, but the word FENCES has now been removed. And the scope of the work is well defined and spelled out... The Embankments are unsafe, they need repair and it's the TREES that are causing the problems and trees are what has to go.

This new Draft GEIS document isn't sitting well with your Facebook neighbors in Fairport & Perinton. It appears they are now realizing they have stopped "nothing", they only made the process of clearing embankments more "formalized". The group should start to collapse soon, once the members realize they followed the wrong leaders, and maybe should have been working WITH the New York State Canal Corporation instead of against them to get their concerns as neighbors addressed.

Hopefully seeing that the FB group (and it's leadership) have accomplished nothing "positive" for canal neighbors & users, this STCC thing will slowly fade into memory and be a reminder to it's members how good people with good intentions can be led so far down the wrong path by "poor leadership" with "bad intentions".

Sadly, many now see that everything stated about NYS Erie/Barge Canal Safety, Canal Embankments and what the NYS Canal Corporation was doing along the canal to make REPAIRS was grossly misrepresented and maligned, by a few individuals, who had no business at all weighing in on a matter that they couldn't understand and didn't care to learn the truth about.

That topic was Public Safety around Embankment Dams, and the STCC had it ALL WRONG!.

Doug K · « **Reply #2 on:** June 05, 2020, 10:48:00 am »

Better late than never some folks say... but an Engineer won't say that because late is "never better", it's just LATE!

Late to an Engineer means only one thing... The project deliverable was MORE EXPENSIVE!

So here's some math from an Engineer on this Draft General Environmental Impact Statement, and asking the question: What did is cost?

So at 100 hrs per page, for a 13 page report, the time (and cost) seem a bit high.

Especially in light of the fact that most of this document was a "cut & paste" from the Canal Corp's first Embankment Project that ran from Brockport to Lockport. You remember that Canal Embankment Project? It's still not complete as the R portion of that Earthen Embankment RESTORATION Project still has not been completed, much to the dismay of canal neighbors, who have had their lives turned upside down with the hasty manner that project was implemented.

Salary for an Engineer in the NYS Canal Corporation seems to average about $60-80K annually. This took more than half a year to complete, taking a portion of that Engineer's time. Anyone care to venture a guess on the cost for this piece of work? Maybe 10% of someone's time, perhaps 25%?

I'll go light at $20K for 13 pages of a draft GEIS, but it will likely cost the NY State Canal Corporation much more as we move forward.

Certainly this will result in more negatives than positives: adverse public reaction, bad PR for the NYSCC, and the sheer fact that so much TIME was lost due to the "extra" hoops that were placed on this Canal Embankment Public Safety work.

Those hoops came as a result of ill-conceived plans from one active Facebook group, opposing these dam safety changes to the Canal System. They asked for and now have received this draft GEIS, and have ZERO reason to complain. This is what a FULL SEQR review looks like... and they still do not like what they see.

There was nothing unexpected with this Draft SEQR Environmental Review & Plan, unless you count the fact that we ALL knew it would be late...

Late, like everything else on this Embankment Safety Work, which is about 75 year late from when it SHOULD have been started, back in the 20th century when these Barge Canal Embankment Dams were new, and CLEAN.

Better Late Than Never? Maybe, but only if they follow through and clean ALL the unsafe Embankments and keep them clean and danger-free

Michael Caswell · « **Reply #3 on:** June 25, 2021, 05:54:40 am »

The Corps’ guidance makes it clear that vegetation may remain on and around embankment and related infrastructure, provided that “the safety of the structure is not compromised, and effective surveillance, monitoring, inspection, maintenance, and flood-fighting of the facility are not adversely impacted.”

A key aspect of the Corps’ guidance is the establishment of a vegetation-free zone which is a “three- dimensional corridor surrounding all levees, flood walls, embankment dams, and critical appurtenant structures in all flood damage reduction systems.” No vegetation, other than approved grasses may penetrate the vegetation-free zone.

The primary purpose of the vegetation-free zone is to “provide a reliable corridor of access to, and along, levees, flood walls, embankment dams, and appurtenant structures.”

Michael Caswell · « **Reply #4 on:** June 25, 2021, 06:00:18 am »

1.4.1.2 EMBANKMENT DAMS
The Corps’ policy as it relates to embankment dams is clear. The guidelines require the following five areas to be vegetation-free zones:
1. The dam and the dam-toe area.

2. Areas in or around seepage monitoring systems, or critical downstream areas where seepage
observation must be vigilant and continuous.

3. Groin abutments and areas immediately adjacent to groin abutments.

4. Spillways and spillway channels, including spillway slopes and approaches to spillways where
vegetation could, in any way, impede the operation of the spillway.

5. The outlet works discharge channel.
The Corps further clarifies that for embankment dams, the entire embankment surface from the upstream toe of the dam to a minimum distance of 50 ft from the downstream toe shall be a vegetation-free zone.

Michael Caswell · « **Reply #5 on:** June 25, 2021, 06:01:49 am »

The Fairport/Pittsford dam(s) have been classified by Rizzo Engineering as

Class "C" or "High Hazard" Earthen Dam

An embankment failure may result in widespread or serious damage to home(s); damage to main highways, industrial or commercial buildings, railroads, and/or important utilities, including water supply, sewage treatment, fuel, power, cable or telephone infrastructure; or substantial environmental damage; such that the loss of human life or widespread substantial economic loss is likely.

Michael Caswell · « **Reply #6 on:** June 25, 2021, 07:06:39 am »

From the Guidebook, explains why GRASS is the best compatible vegetation for Earthen Dams

March 2021
NYSCC Embankment Inspection & Maintenance Guide Book

7.3 VEGETATIVE MAINTENANCE
Of particular importance for safety is the proper maintenance of vegetation on embankments. For embankment maintenance, vegetative cover is divided into two general categories:

• Compatible vegetation – this includes grasses and other similar plant cover. This vegetation is low growing, is easy to mow, and develops shallow root systems.

• Non-compatible vegetation – this category includes most brush, bushes and trees. This vegetation can develop deeper root systems and is typically prevented by regular mowing, after initial removal by clearing and grubbing.

While there are some positive benefits of woody vegetation and tree cover, these benefits do not outweigh the substantial risks associated with embankment failure that could be initiated by the presence of the vegetation such as flooding, property damage, environmental damage and loss of life.

In contrast, grass or “soft” vegetation is beneficial to the embankment. The grass and its root system prevent erosion damage from rain events, foot traffic, and even from minor overtopping events that are small and of short duration.

7.3.1 WHY IT’S NECESSARY
Proper maintenance of embankments and their ancillary features is of utmost importance in protecting lives and reducing the flood risk of adjacent communities. This includes the proper maintenance of vegetation on embankments and ancillary structures.

Non-compatible vegetation can harm the structural integrity of these impoundment structures, obscure visibility of the ground surface (necessary for inspections for other types of failures), impede access for maintenance and inspection, and encourage burrowing by rodents by providing habitat.

Woody vegetation with robust root systems can disturb the soil structure in the embankment. Roots that penetrate the phreatic surface in the embankment increase the risk of internal erosion known as piping, the early stages of which can go undetected for decades resulting in a sudden failure of an earthen embankment.

Animal burrows pose a similar piping potential – the animal burrow shortens the seepage path potentially leading to piping at the burrow location.

Additionally, shade caused by woody vegetation can impede growth of more compatible grassy vegetation.

Furthermore, large trees can be uprooted by winds/erosion and leave large holes in the embankment, root systems can decay and rot creating passageways for water through the embankment.

Once a significant seepage pathway is initiated, catastrophic embankment failure could be expected to occur within one to two hours. The presence of brush and trees can also hinder critical emergency responses to flooding or repair operations.

The proper maintenance of vegetation for water impounding structures is well understood and accepted by the dam safety community and the various regulatory and advisory agencies tasked with dam safety including the USACE, FERC, USBR and FEMA. In addition, all federal flood protection projects including embankment dams and levees in New York State must maintain a woody vegetative free zone on the embankment.

Doug K · « **Reply #7 on:** June 25, 2021, 01:05:21 pm »

And most importantly, How to Repair Canal Embankments SAFELY... to make them "safe again"

7.3.2 HOW IT’S DONE SAFELY

The NYSDEC Owners Guidance Manual for the Inspection and Maintenance of Dams in New York State [NYSDEC, 1987], originally published in June 1987 is still referred to by dam safety experts and dam owners.

It states that:

• The entire dam should be kept clear of unwanted vegetation such as brush or trees.

• When brush is cut down, it should be removed from a dam to permit a clear view of the embankment.

• Stumps from trees or woody brush with a diameter less than 4” diameter may be left in place.

• Following removal of large brush or trees (with a diameter greater than 4”), the left-over root systems should also be removed to a root diameter of 1” or less and the resulting holes filled.

The NYSDEC guidance is specific to dams.

More recent guidance for vegetation maintenance that has been developed for longitudinal embankments such as levees, canals and feeders, is found in:
• FEMA 534, Technical Manual for Dam Owners Impacts of Plants on Earthen Dams [FEMA, 2005]; and

• USACE EP 1110-2-18, Guidelines for Landscape Planting and Vegetation Management at Levees, Floodwalls, Embankment Dams, and Appurtenant Structures, [USACE, 2019].

The FEMA document, in addition to espousing that woody growth should be prevented on dams and embankments in the first place, provides good information on the considerations and general processes to follow in order to remove woody vegetation once established.

The location of the woody vegetation on the embankment (see Figure 6.2-1) dictates different methods of removal. Due to the general characteristics of seepage through the embankment, each zone of the embankment has somewhat different characteristics. Therefore, the criticality of the removal procedures and the extent of removal required varies by zone (e.g. requiring removal of the entire root system or just the portion above ground).

One of the major concerns with tree and brush cover is the potential for a piping failure.

Those zones that intersect the phreatic surface of the water within the embankment are the most critical with respect to maintenance and removal techniques. It is recommended that any excavation work on Canal embankments occur once the embankment segment is dewatered and no longer retaining water.

Since the majority of the Canal embankments are (or can be) dewatered in the non-navigation season, it is possible in most cases to do earthwork (such as stump removal and regrading) when the embankment is not retaining water.

ANY EMBANKMENT EARTHWORK SHOULD BE PERFORMED ONLY UNDER THE GUIDANCE OF A LICENSED PROFESSIONAL ENGINEER AND WITH THE APPROVAL OF THE DIRECTOR OF WATERWAYS MAINTENANCE, REGIONAL CANAL ENGINEER, OR TRANSPORTATION MAINTENANCE ENGINEER.

Doug K · « **Reply #8 on:** July 06, 2021, 03:18:53 pm »

Couldn't help but notice that the new release of Earthen Embankment Integrity Program (EEIP) documents also brought a few significant other updates to the EEIP webpages. Seems the Canal Corporation has finally handled all the emergency work it had, with an EMBANKMENT BREACH between Macedon & Palmyra, and a couple emergency repairs made in the western section. Now they can get back to the business of fixing UNSAFE earthen embankments that are keeping the rest of Upstate NY living below medium to high hazard canal embankments.

The Program Milestone Schedule webpage was updated to reflect the new "on-time delivery" of the EEIP Embankment Guidebook, and also add the Virtual Public meeting information, to discuss the Guide and the draft Generic Environmental Impact Statement (dGEIS). That second item is related to the SEQR hurdle that was placed in front of the EEIP work that was "missed" in the original Embankment Restoration project.

https://www.canals.ny.gov/Earthen_Embankment/Project_Timeline.html

More interesting is the newly updated EEIP webpage for CONTACTING the Canal Corporation about EEIP work. All questions, concerns, comments, & emails are now being fielded by Bergmann Engineering, whos done the Lion's Share of work mapping EEIP from end to end already.

It seems the old Embankment work contacts are out, like Jackie Schillinger, Brian Stratton, John Callaghan, Dave Mellen, and a host of Engineers.

Now it's an email to Bergmann, or a phone call. Most likely the best people to handle the public input, hearing it first hand. And there is also a paragraph about EEIP Guidebook & Environmental Impact comments, that everyone should read BEFORE July 13th.

Now go look up Bergmann, they are a VERY reputable firm, with plenty of background doing work like this along canals. Understanding where earthen dams are is key to keeping NY safe. Bergmann has done quite a bit of work already, using the keyword "canals". Besides the EEIP Package of work that also have been doing some Flood Inundation mapping for the NYS Canal Corporation, which is also part of the new EEIP Guide package.

I guess it's starting to become clear that EEIP work along the NYS Canal System, will be managed VERY differently than the previous earthen embankment work along the "Erie".

And it starts by putting PROFESSIONAL ENGINEERS in charge of collecting public input. That is the biggest change that happened with the new EEIP package. This EEIP work was managed properly, just like everyone had asked for on the earlier Restoration Project, and by a capable group, Bergmann. No one should complain, but some will.

PROFESSIONAL ENGINEERS will be sure that the people suggesting the ideas also understand the limits and needs to insure PUBLIC SAFETY. And Public Safety WILL remain a MAJOR risk by doing nothing, which is what some folks around Rochester have suggested already. Bergmann will remind people of this fact.

PROFESSIONAL ENGINEERS will make sure that suggested ideas have MERIT, and HELP improve safety, and the sustainability of the NYS Canal System, now and 100 years from now. There are NEEDS that will have to be met FIRST, before the "wants" of the public can be dealt with. Public Safety being the #1 need.. always.

PROFESSIONAL ENGINEERS will also challenge people by asking EXACTLY what they want to change in the Guidebook, and why, and also ask if the change can be qualified with DATA. Have Page Number & Paragraph ready to REFERENCE and why it needs to be changed, and possibly, what would be BETTER.

PROFESSIONAL ENGINEERS will roll their eyes if you start talking about "trees having feelings too".. just a heads up.

Just a few suggestion, especially to anyone looking to refute the EEIP Guidebook...in the upcoming NYSCC Virtual Meeting:

Have your DATA ready for the Virtual Meeting, cite KNOWN facts that are TRUE, not something you made up to make your own case. Bergmann, and others will surely not let these inaccuracies persist, especially the one that states inaccurately that "nothing is wrong with the NYS Canal System or it's embankments"

Be clear, concise, and most importantly, CONSTRUCTIVE, if all you are there for is to "tear down" the work done by Bergmann and the NYS Canal Corporation, please don't waste valuable Zoom time for the rest of us. Say your peace and let those who want to be constructive, move on with the meeting.

Work to find solutions that enable a remedy that works for ALL stakeholders, including Canal Neighbors, Canal Property Users, and the OWNERS of the Canal System, who are RESPONSIBLE to insure their property is SAFE for PUBLIC USE. Nothing worse than a group of people that just want to whine about "problems" while ignoring the simple, easy solutions.

Have your FACTS ready, not your "feelings", be ready to offer solutions that will work, not "opinions" on why the suggested path forward is all "wrong"

Most importantly, think BEFORE you speak, to possibly limit the amount of people who look stupid, whining about a NY State entity that is trying to improve public safety, and repair a Canal System that is slowly crumbling away.

That is a job they can't wish away, or deny is causing unsafe conditions for many New Yorkers

Doug K · « **Reply #9 on:** July 14, 2021, 10:45:52 am »

Sitting in the EEIP Zoom Meeting, and it's not a big hit with the public it seems. Few talkers, and it was all over in 41 short minutes.

The ECNA did NOT get a chance to offer questions...this was a "comment" only meeting.

But, as a backup, just in case the NYS Canal Corporation feels that the Questions the PUBLIC has on Embankment Dam Safety don't warrant answers, we have placed those Guidebook & SEQR Environmental Impact Statement here for all of you to read, and maybe spur more questions or comments.

YES, we DID do an exhaustive review of both the EEIP Guidebook and dGEIS as well as all other documents from the recent EEIP release.

EEIP Guidebook Meeting Comments.pdf (240.58 kB - downloaded 4 times.)

EEIP Environmental Impact Statement Comments.pdf (376.3 kB - downloaded 3 times.)

If we receive answers to any of what we submitted, we will certainly pass it along to all of you.

Doug K · « **Reply #10 on:** July 14, 2021, 03:21:40 pm »

We've added to the list of questions, also posted in the 10am Zoom Meeting Chat Window, which hopefully will get some answers, or at least send along the message to the Canal Corporation and NYPA that the idea of holding a Public Forum and not allowing a Q & A session wasn't a hit with their fans or their opposition.

1) Will your neighbors in the Western Section, specifically the "60 mile pool", who had their adjacent Canal Embankments Remediated through the EERP effort, now fall under the EEIP Guidelines (and guidebook) for Embankment Maintenance, Inspections & Best Practices?

1a)If yes, how do we contact the NYSCC for issues that have developed "post-clearing", like the need for Toe Drains or Ditches to capture Embankment runoff? Is there an assigned point-of-contact for your Canal Neighbors to contact and discuss issues?

2) Can you explain why the NYS Canal Corporation, and NYPA, both NY Government agencies, chose to not correct mis-information and false claims being made about the EEIP program, including that the effort being made to clear earthen embankments falls under "public safety" and not tree-harvesting for profit? Didn't that decision leave many in even more danger, from false information regarding their safety?

3) Will the NYSCC be asking Bergmann PC to create Flood Inundation Maps for Perinton, Pittsford, Brighton and all other areas in Monroe County, where residents live more than 40 feet below the earthen embankment dams and have no knowledge of the possible flood danger?

4) You have asked for input on the NYS Canal Corporation EEIP effort, Maintenance Guidebook and SEQR Impact Statement, yet most people who would be affected by a Canal Breach do NOT even know they are in danger, isn't that a correct statement? How will you remedy this?

5) Has it become obvious to the NYSCC that the EEIP Zoom Meeting isn't going to be a "hit", only allowing Comments and not answering Questions that many people have. And this method of communication isn't what has happened in the past with Canal Corporation Public Meetings, where Canal Neighbors have had a chance to have Q&A time. When will that Q & A session happen on EEIP work?

Michael Caswell · « **Reply #11 on:** July 14, 2021, 04:24:59 pm »

Well! Maybe I'm wrong, but I loved the meeting. It was just what I have been telling the NYPA to do for years.

1. Don't have public meetings. People just ramble on with stuff like 'It's not a dam! What about the shade? Where are all the squirrels going to live? How much money is the CC getting for the trees? We'll have no oxygen! etc etc.

2. If you must have these meetings, don't let people run the show. Take control. If you have a message, make sure you spell it out, without interruption. I guess COVID has been good in that respect. We haven't had rooms full of people wanting to rant on.

3. Limit their time. A ZOOM meeting did that.

Yep! Now the NYPA has complied with SEQR, and hopefully, they can get on uninterrupted to remove this vegetation and make our citizens safe from death by drowning.

Let's also not forget Bill's Smith's rant! He seems to forget that the 'expert witness' the STCC called in to testify that trees were good for wooded slopes, later qualified that he was referring to levees, not Earthen Embankment Dams. But I suspect Bill already knew that, he just didn't want to admit it. He's certainly put a lot of citizen's lives at risk with his antics.

Doug K · « **Reply #12 on:** July 14, 2021, 05:49:21 pm »

Don't get me wrong, I LOVED the new "normal" when it comes to Embankment Dam Repair.

From the Canal Corporation side:
SEQR says: RELEASE a comprehensive set of EEIP documents, not READ them to the Public
SEQR says: Take Public Comments... send or speak those comments, be SPECIFIC to our documents
SEQR says: Incorporate Public Input if it adds value, update and RELEASE final EEIP documents.

No fuss, no muss, no wasted time.

And if you don't add value, it really doesn't matter.

Michael Caswell · « **Reply #13 on:** August 15, 2021, 12:13:12 pm »

The short version of the EEIP Guide Book

News:

Author Topic: EEIP Draft Now Published (Read 276 times)

Michael Caswell

EEIP Draft Now Published

Doug K

EEIP Draft Environmental Statement Review and Comment

Doug K

EEIP Draft Now Published - What took so long?

Michael Caswell

Excerpts from the EEIP Embankment Integrity Guidebook

Michael Caswell

Re: Excerpts from the EEIP Guide book

Michael Caswell

Re: Excerpts from the EEIP Guide book

Michael Caswell

Re: Excerpts from the EEIP Guide book

Doug K

Re: Excerpts from the EEIP Guide book

Doug K

EEIP Embankment Integrity Program has NEW Contact Information

Doug K

Re: EEIP Draft Now Published, the ECNA has submitted Questions & Comments

Doug K

Re: EEIP Draft Now Published, More Questions from the ECNA go unanswered

Michael Caswell

Re: EEIP Draft Now Published

Doug K

Re: EEIP Draft Now Published, Zoom Meeting Met SEQR Requirements, Perzactly

Michael Caswell

EEIP Guide Book Highlights - Short Version