February 21, 2011edr companiesJane Rice and John Hecklau217 Montgomery Street, Suite 1000Syracuse, New York 13202

Dear Jane and John,

As promised, I am delivering to edr a list of deficiencies in the edr / Wild Ones Niagara Study, Regional Economic Growth Through Ecological Restoration of the Niagara Gorge Rim, as Wild Ones Niagara sees them. This is a continuation of our meeting on Jan 26, 2011, the meetings we have had at our office and yours, the ongoing telephone discussions throughout our association in the last 11 months with Jane Rice, and the prior conversations we had with edr engineer, Bob Gallucci beginning in 2009.

This letter does not address every issue.

The study edr was hired to complete was to reflect the conservation corridor vision of Wild Ones Niagara for the ecological restoration of the Niagara Gorge Rim and include the enormous economic benefits potential to the entire Niagara region. This vision is reflected in the Agreement as follows:

The end product will show what is possible with the Gorge Rim and the natural ecosystems restored to pre-Robert Moses Parkway conditions. The end results will answer and show the following: how the fully restored gorge rim will look, and a professional evaluation of what economic benefits will occur in Niagara Falls and the region as a result of the full restoration along the Niagara Gorge Rim. (Attachment A, p.2)

edr has failed to meet its obligations, including project milestones, under the Agreement. Per the Agreement, including Section V – General, 5.3 and Attachment B, Assumptions 6, edr is being given an opportunity to rectify its nonperformance or face cancellation/termination of the Argeement. It is suggested that edr review each bulleted item and submit in writing:

1. How edr intends to incorporate each item into the Wild Ones Niagara study in a way that reflects the Wild Ones Niagara vision, per the Agreement. If edr believes a bulleted item is not part of the Agreement so state and explain.

2. How edr will meet the deadline to ensure the Wild Ones study is included and carefully considered in the NYS Parks scoping of the Robert Moses Parkway, prior to the issuing of the road’s RFP that is scheduled to be released this month.This assumes, per edr’s assertion (Jane Rice in several telephone conversations), that NYS Parks will include it and not reject the study based on the failure of edr to stay on task, and on time per the schedule provided to Wild Ones and included in the contract.

3. edr has not addressed the concerns voiced by Wild Ones Niagara in the letter dated 5 Jan 11.

Background:The goals and objectives of the study are listed in order of importance per the study title:

Regional Economic Growth Through Ecological Restoration of the Niagara Gorge Rim. 1. edr is to provide an economic report with a full ecological restoration of the

Niagara Gorge Rim

2. edr is to produce a marketing product for WON that includes the economic benefits with a computer fly-over that shows what the space would look like fully restored, without the Robert Moses Parkway.

We stated we have the following concerns regarding edr’s performance:

[1] Failure to implement the goals and objectives, terms and conditions of the project

[2] Failure to meet established deadlines for task(s) completion

[3] Failure to provide required documentation, reports, and tasks in a timely manner;

[4] Failure to respect the nondisclosure portion of the contracta]. edr’s letter to Steve Reiter, Niagara River Greenway Commission, Host Community Standing Committee

° edr is to provide the potential economic benefits in all its forms: quality of life, employment, tourism, sustainability, biodiversity, and that edr will provide comparables.

° This Wild Ones Niagara study will expand and take to the next level the goals, objectives, principals, and criteria of the Niagara River Greenway Plan.

° The study is to advocate, advance and promote Wild Ones Niagara’s vision, (i.e Attachment A, p. 2), not State Parks, or anyone else’s.

° The time frames included in the contract and the contract amounts per task were acceptable as edr generated both.

° The study is to be a persuasive marketing and educational tool for municipalities and governmental officials.

° Contract: “The study is to show what the landscape would look like if the Robert Moses Parkway did not exist and include the potential economic benefits that could occur with that restoration.” (Attachment A, paragraph 2, page 2).

According to the contract, “the ENGINEER warrants that such services shall be performed with the normal skill and care exercised by similar professionals rendering these types of services.”

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Contract“Section III – Ownership of DocumentsIt is understood and agreed by and between the parties hereto that all survey notebooks, reports, collected data, drawings, studies, calculations, specifications memoranda, estimates, computations, electronic files, etc produced by ENGINEER in the execution of this ARGREEMENT, shall become and remain the property of the OWNER upon termination, or completion of the work and the OWNER shall have the right to use same for any public purpose without compensation to the ENGINEER other than hereinafter provided.”

“Section V- General5.4 In the event this AGREEMENT is so terminated, payment shall be made on the basis of the ACTUAL percentage completed on the effective date of termination.”

“SECTION VIII – DelaysIn the event of a substantial delay in progress of work due to factor other than ENGINEERS’ operation or actions, the maximum total compensation payable, net fee and schedules of completion will be subject to review upon request by the ENGINEER or the OWNER, accompanied by adequate substantiating data to justify a change. Any consideration given as a result of such delays will be made on individual basis with a study being made of the influencing factors at the time of the delay.”

Contract – Proposal Narrative page 2

“The Restoration Plan will identify the ecological and economic opportunities related to restoration of the Gorge Rim both locally and regionally. The Restoration Plan will create long-term ecological restoration and management guidelines that will identify economic, educational, cultural, heritage ecotourism, and wildlife habitat benefits derived from an ecologically diverse restoration. For example, a continuous system of hiking and biking trails and overlook facilities will make this spectacular landscape accessible to residents of Niagara Falls, Niagara University, Lewiston and visitors.”

“The end result of these tasks will be a beautiful, compelling, interactive visual presentation of what the restoration would look like utilizing a multimedia presentation technique and a clear and concise explanation of the economic benefits of this restoration, inclusive of ecological and tourism initiatives (which in turn creates jobs and revitalizes local economies. This vision will embrace the notion of organic unity, setting aside the constraints of jurisdictional and political boundaries within the Niagara River Greenway Core Focus Area…”

To date, 11 months into the study, no task has been completed.

Study deficiencies include:

° edr has not “set aside the constraints of jurisdictional and political boundaries” per the Agreement, (reference Dog Park issues, the intense focus on NYS Parks within the supplied narrative)

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° edr has not focused on an ecological restoration or the economic benefits of an ecological restoration. The focal points are the reason for the Wild Ones Niagara study and mandatory per edr’s Agreement.

° edr appeared to use as an economic reference at Niagara University / NYS State Parks employee’s (John Ceretto) proposal designed to keep the Robert Moses Parkway open. That is not the vision/scope of the Agreement.

° From what Wild Ones Niagara can see, edr did not conduct any of their own research about ecological restoration nor did it hire objective consultants knowledgeable about the economic benefits of an ecological restoration.

° There are few convincing comparables to other non-motorized greenways, or other ecological restorations are included even though we provided edr with that information as a starting reference point.

° This project and its resulting documents are supposed to be about a non-motorized trail and edr includes narrative about people movers and trolleys. That is not the vision / scope of the Agreement.

° In preparing the economic impact report it seems logical edr would include DOT figures as they pertain to the Robert Moses Parkway, i.e. examples:

i.e. - Costs of maintaining the road for the last 50 years (when it was built)- Costs of totally replacing the road- Cost projections for maintaining the road for the next 50 years- Costs to environment and ecology in terms of carbon emissions and salt pollution, snow removal, pesticide spraying, habitat and biodiversity destruction, invasive species habitat enhanced by road construction and maintenance.

VS- Cost of a one time removal, with- Documented facts that roads do not pay for themselves (Wild Ones Niagara provided to edr)

° Sparse narrative on the potential funding sources available to remove the road.

° Nominal discussion of the types of employment, professional careers, (scientists, botanists, ecological restoration experts, educators,) that will occur with an ecological restoration (Careers that pay above minimum wage versus jobs that pay minimum wage as occurs in traditional tourism.

° No values assigned (estimates based on comparables done elsewhere) for ecotourism potential;Those revenues and benefits are barely mentioned ° Major focus of the documents produced by edr are for the benefit of State Parks, not the vision/scope of the Agreement.

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° Scarce mention of the Old Growth Forests at DeVeaux Woods and completely ignored the old growth specimens at Whirlpool State Parks. The Old Growth reconnection is a key Wild Ones Niagara vision. It is a rare urban forest with historical significance.

° Does not talk about the possible Old Growth trajectory in the ecological restoration

° Little discussion of the local genotypes and the need for the much discussed greenhouse that is imperative for an ecological restoration, the collection of native seed banks in order to grow thelocal rare botanicals.

° No detailed plant community lists, what would naturally be grouped growing together in an ecosystem.

° edr produced little narrative of the over all benefits to the community and the region that can occur with a conservation corridor.

° Does not adequately address claims that alternate traffic patterns will disrupt the DeVeaux neighborhood.

° In the economic report, it appears edr did not reference interviews with individuals noted for their expertise or knowledge about ecological restoration nor does it appear that edr solicited individuals with a professional association with ecological restoration.

° Please explain why edr omitted such specific resources. ° Please explain how the individuals included are relevant to achieving the Wild Ones

Niagara vision.

° The GTS Consulting traffic study report states in it’s letter to edr, “ I have completed my review of the potential traffic impacts with the partial removal of approximately 6 miles of the Robert Moses Parkway between Niagara Falls and Lewiston…”

° Partial removal is not the vision of Wild Ones Niagara. We advocate removal of all four lanes of the Robert Moses Parkway between Niagara Falls and Lewiston. Partial removal is also inconsistent with the Wild Ones Niagara vision of an ecological restoration of the Niagara Gorge Rim.

° We also question why the study did not include NYS I-190 as an alternative route as it runs parallel to Route 104 even though it acknowledges the route in the third paragraph.

° The GTS Consulting letter states, “based on a cursory review of the roadway system between Niagara Falls and Lewiston, the most logical alternate route of travel would be Route 104 if the Robert Moses Parkway is closed to through traffic.”

° The same letter states, “peak hours in the area generally occur between 8-9am and 4-5pm” and “It is estimated that approximately 70% of the Robert Moses Parkway traffic will divert to Route 104 and 30% will divert to Highland Avenue.”

° It appears a comprehensive review is required as the time and route suggested as the preferred route actually has an elementary school on it that operates during the morning rush hour AND has a traffic speed of 20mph.

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° None of this supplied data to edr for the Wild Ones Niagara study 1. advocates Wild Ones position or 2. advocates the position of a report that collected data from around the world of

70 studies that refute the “most logical route” would be taken. Since edr has that information, please explain why edr did not include that in the study.

° edr DID NOT include the significant importance of pollinator habitat for the rare botanicals in the ecological restoration boundaries.

° edr DID NOT include any persuasive piece that would convince those opposed to an ecological restoration in the landscape space that the Robert Moses Parkway inhabits will be a benefit to the region.

° edr DID NOT include any detailed discussion of native plant communities that a lay person would understand, what plants naturally occur together so anyone could recreate the plant community in their home or municipality, or

° edr also DID NOT include discussion on biodiversity, for example, how everything co-evolves with insects, the importance of the food web they support, which is why you restore ecologically.

° Overall this study should be about educating people (including NYS Parks, the stewards for the Niagara Gorge Rim) that are unfamiliar and therefore not convinced that an ecological restoration is what is needed for this region.

° The entire study should build and evolve into a great, significant comprehensive plan based on the vision of Wild Ones Niagara, which is what the Agreement provides.

Conflict of Interest:

° edr did not disclose until late 2010 the fact that they are concurrently working with NYS Park’s scoping consultant for the future of the Robert Moses Parkway and the Niagara Gorge Rim

° The influence becomes apparent ° in terminology, (multi use trail, which is not what Wild Ones Niagara advocates)° the reference to “The Gorge Rim Trail” an NYS Parks project and ° in their selection as to the focus of the Wild Ones Niagara study.

° Wild Ones Niagara asks that edr disclose ° when they became part of the team of consultants hired by NYS Parks ° who were they hired by: State Parks or Parsons Brinkerhoff.

° The study does not address Frederick Law Olmsted’s approach to his successful campaign to remove the industry along the Niagara Gorge Rim and his subsequent success in creating the Niagara Reservation State Park and his protection of Goat Island. He did this by making the ecological argument that linked preservation to the rare plant life in the area. This email information was provided to Wild Ones Niagara by edr principal, Doug Bracket. The author of the email offered his help and support to move the study into a genuine ecological restoration for the

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Niagara Gorge Rim. This information is listed as a Niagara River Greenway criteria by the Niagara River Greenway Commission.

° Throughout the last 11 months edr only provided maps that did not include written narrative. Why?

° Does not include in the gorge study any of the other waterfalls that are in the gorge. This information was provided to edr and is on our website. One waterfall no longer exists because of the construction of the Robert Moses Parkway.

° Does not include maps of the Oak Forest of Antiquity that are identified within the Niagara Gorge. It seems reasonable to include this informatmation, given the study goal of an ecological restorarion.

° Per the edr 9/02/09 Agenda, the study does not provide the following as provided by edr engineer, Bob Galucci. Direct quote:

3. Define the project name and boundary and major tasks.4. Ecological Inventory – minor inventory of gorge using existing data bases. Purpose to

avoid impact and assess views and connections to the gorge5. Ecological Inventory – Major inventor of rim to “city” to map ecological communities.

Will include field reconnaissance to verify data base review. Intense inventory in selected areas, per our Mendon and Pine Barren Studies.

6. Ecological Restoration – Will focus on diversity, 4 or 5 types of communities with diversity with in each community. Restoration [is] to achieve a community that is large enough to sustain, and large enough to provide educational and tourist benefits. Possibly a grassland, gorge and forest (others?)

7. Restoration and MAINTANANCE – must include a maintenance plan which acknowledges the impacts from neighborhoods, traffic, and other manmade intrusions. Recommend who will maintain the built, people space.

8. Circulation and Transportation – Prepare a plan that addresses vehicle and people access to the park, gorge and community at large. Prepare a transportation plan that reinforces the ecological restoration and mitigates the impacts of all transportation.

9. Community Connections – The plan will improve the connections to the community. The greenway mission statement (in Bob Gallucci’s interpretation) is to improve every neighborhood and every community it touches. This plan will “remove the barriers” and integrate the open space with community.

10. Economic Analysis –The plan will include the independent review by an economic consultant to assess the value of the project to the community at large. Includes: property value increases, reduction in highway maintenance costs, reduction in public safety costs, increases in tourism etc.

11. Visualization – Prepare a graphic master p lan of the restoration project. Prepare a visualization of the entire length as a “fly-over.” Prepare visualizations at 4 or 5 key locations.

12. Implementation Plan – recommended timeline and cost estimate.

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The edr draft narratives provided after our 26 Jan 11 meeting do not comply with the vision/scope set forth in the Agreement. The Wild Ones Niagara comments are based on the ftp file narratives provided as of 1/31/11.

Review of draft document entitled "Economic Impacts of the Ecological Restoration Plan," written by edr and dated 12/16/10.  

° This draft is inadequate. It attempts to formulate a position in opposition to the purpose, intent, and vision of the study edr was engaged to bring to fruition. Granted it is but a "draft," but we know from experience that such drafts tend to become the accepted document with little or no alteration. I sincerely hope that will not be the case here. To be more specific about what makes it inadequate and unacceptable in its present form:

° Why does edr refer to the project as the “Gorge Rim Trail?” That is not the name or the focus of our study. ° 1) From the first paragraph where a "Gorge Rim Trail" (GRT) is twice mentioned, and this restoration project is referred to as "an important addition to the 'product mix' of attractions," it becomes increasingly clear that the Niagara gorge rim restoration project has been seriously misperceived.

° a) This GRT was never discussed with Wild Ones, never even mentioned as an alternative plan possibility, and would have been quickly and firmly rejected if it had been. Yet this document seems solidly built around the concept of this GRT, with two dozen or more references to it throughout the 17 pages, culminating with the affirmation of a "people mover system" for the gorge rim (p 16) (a notion we've fought against for years, and about which members of the edr team were made aware) and a concluding paragraph with the repeated jargon of "product mix" (p 17).

° b) The restoration of the gorge rim is, as we've made abundantly clear in many discussions with EDR, not an item in a "product mix." It is a (potentially) regional game-changing strategy for marketing to a new and sustaining population of ecotourists, based on the ecology of a unique landscape, restored, which would then function as the focal point from which regional ecological exploration could be extended. It is this potential EDR was engaged to document. They have not yet done so.

° 2) Has edr completed any of the contractually assigned tasks on schedule (a schedule that they established)? They have not insofar as we know. ° 3) "The Vision" portion of this document consists only of quotations from three previously existing documents:

° one is totally irrelevant (it's about the upper river, out of the study area from between 5 to 10 miles);

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° one cherry-picks the Niagara Falls Comprehensive Plan, which is not about parkway removal in a way meaningful to the Wild Ones' study concerns and, in fact, if instituted would seriously impede achieving Wild One goals;

° one, from the Niagara Heritage Partnership website, is relevant. So, two out of these three sources quoted to establish or describe "The Vision" are irrelevant, one to the extent that it is potentially harmful. The one relevant document ("The Niagara Heritage Partnership Proposal For the Removal of The Robert Moses Parkway and Restoration of Natural Landscapes"), also contains

° the following, which was not used: "Restored natural landscapes along a parkway-free gorge rim would provide economic and environmental potential for our region...the ecotourist market is significant worldwide and clearly represents a niche market for the Niagara Frontier, a new population of tourists over and beyond the number of visitors who travel here annually. Evidence of this is readily available...." 

° Why was this not deemed significant, given the title of the study edr has undertaken? 

° 4) The Planning and Development Focus goes from mid-page 2 to the top of page 7 and is largely irrelevant to what should be the focus of the study--and some of the information there is contrary to parkway removal (p 2).

° Why did edr include this information?

° On page 5 it appears that edr is offering opinion rather than providing documented facts.

° The last paragraph on the page touches on what should be central to the study but which, unfortunately, is not. Again, the last sentence in this section starts with "clearly, "but what it asserts is not clear: it's what this document is supposed to make clear.  ° 5) Impacts on Key Revitalization Projects: this section attempts to demonstrate compatible relationships between rim restoration ("GRT") and city streets and other projects. It may be well intended, but if there's no GRT, as presented by this document, and there shouldn't be, then there's nothing to "interface" city streets with.

° (p 9); it also states "much of the adjacent areas along the GRT" (non-existent and not agreed to) are "residential in nature." This is misleading: how much in terms of miles?...and goes on to talk about neighborhood improvements needed and property value enhancements, and so on related to the GRT;

° redirected traffic: this is a guesstamit at best, unsubstantiated percents;

° at the top of page 11: talks about the POTENTIAL FOR INCREASED  VEHICULAR...ACCESS via the GRT-

° this is in direct opposition to a non-motorized gorge rim and the Wild Ones Niagara vision per the Agreement.

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° jargon continues here with a world class educational facility (NCCC culinary arts )---the Wild Ones' goals will not be advanced by overly enthusiastic hype: "Like the GRT the culinary...project will become an important destination, " it says. 

° How will this happen? How does it support the Wild Ones Niagara vision?

° The "Cultural District" will relate to the GRT, the document states--but because it precludes restoration in that section and calls for removal only to Findlay, it's a struggle to see how this is a valid statement. 

° Page 12 concludes with "Closing" the parkway, not removing it and continues on page 13 with seeing the GRT as providing "the strong north-south connection {not the south-north?} that will allow for "better packaging of individual attractions," (and what would those be?) including the "Niagara Wine Trail and Fort Niagara."

° What seems to be implied here is preposterous. This implies commercial traffic, which is not allowed on the Parkway. It also implies the road is necessary to the Wine Trail and it is not. The Wine Trail already has signage all over Niagara County. There are no vineyards on the American Side of the Niagara Gorge.

° Fort Niagara can be reached by taking the I-190 North, exit 25A, which merges onto the northern most segment of the Robert Moses Parkway. That segment is not included in our study area.

° 6) Economic Impacts of Conservation Areas and Open Space (p 13 to mid-pg 14): Interesting, well known, documented, etc, and related to the (what should be) main focus of this document but which, without the proper main focus, is supplementary only.

° 7) Tourism and Economic Development (p 14) This section is closer to what should be the main idea, but needs to be related to ecotourism via ecological restoration.

° From page 15 to top of 16: yes...and?

° 8) Maximizing Economic Impacts of the "GRT"  : again, jargon: "world class linear trail." This is distinguished from merely an average linear trail by what standards?

° Heavy references to "GRT" here (p 16) at least a half dozen times—° and the UNACCEPTABLE INTRODUCTION AND RECOMENDATION OF A PEOPLE MOVER

SYSTEM. A cursory knowledge of the Niagara Heritage Partnership website would have provided information about the unacceptability of this notion, EDR was directed there many times--and used part of its documentation and support from this site.

° This omits discussion of Main Street and the probability that it could be revived by redirecting traffic via routes already discussed. This information, in a detailed way is part of what edr is required to produce by contract.

° “Maintenance of the restoration area is expected to be addressed in the Maintenance Plan as part of the Agreement. This information, is part of what EDR is required to produce by contract? 

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° A "marketing strategy" will be needed that reflects a changing "product mix." ° There is no regional awareness reflected here. 

° While edr may be entitled to interview whomever they wish, it is expected that the persons interviewed are relevant to the Wild Ones Study, edr having proofed of all of the required credentials, professional expertise and /or academic degree relative to ecological restoration and environmental economics. Please provide this certification of the persons included in the interviews.

° Conclusion: This draft document is unacceptable in its present form. It requires significant revision, if not re-visioning. It is weak, too general, and when it is detailed, is frequently just wrong, a misread of the study context required;

° it seems an attempt to satisfy fact-based and detailed study results required by contract stipulations merely by mentioning them.

° Given its simultaneous failure to focus on regional economic growth based on ecological restoration, and the failure of edr to complete any of the tasks in the contract (task 11 is not even mentioned, for example) by the due dates established by contract in Attachment C--Project Schedule, let alone the entire study (excluding task 10), which was to be completed by 1 January 2011, this document, issued by the professional firm of edr from whom we expected much, is very close to being insulting, even as a draft. ° It is our hope that edr will take the opportunity, as provided by contract, in # 6 of "Assumptions," that the "consultant should be given the opportunity to rectify the alleged failure."                                                  Comments on ftp files provided 1/31/11

° NOTE Task 1 & 2 incomplete. ° Does not include Lewiston Plateau.° does not detail or identify site specific plant communities within the study boundary area° did not identify pest plants, exotics, cultivars° past and current gorge and rim treatment by humans

° MAPS:Chapter 02: History and CultureInteresting summary of history, can’t vouch for accuracy, will expect later it will tie in with the project intent.

° Chapter 3 Circulation and Urban Park Interface PlanNo narrative supplied with maps.

° Chapter 4 ecological restoration plan° No narrative supplied with maps° Note: The Legend includes Multi-use Trail and a Trail. This is not our vision.

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° Greenhouse not shown on maps

Chapter 1 Narrative – separate file:DRAFT Study DeficienciesPage 1.1st Paragraph:

° Introduction –The study is not funded by the Niagara River Greenway Commission. ° It is funded by the Greenway Ecological Standing Committee (Tasks 1,2, 3, 6, 7, 8, 9, 10) and the city of Niagara Falls for tasks 4 & 5 of the original proposal as presented to the Niagara River Greenway Commission. There is a time limit to request the funds from the city of Niagara Falls, June 2011. edr subsequently changed the order of the tasks and the task title names. This has adversely affected the working relationship between Wild Ones Niagara and edr.

Paragraph 2° First sentence omits major portion of the Wild Ones Niagara vision for the study: to

restore the space occupied by the RMP ecologically and to provide all the economic benefits of that restoration.

° Second sentence – needs clarifying to ensure in LEWISTON (Center Street reference) the boundary includes all four lanes of the RMP in the removal and subsequent restoration.

Paragraph 3° The study is to “guide successful and sustainable restoration efforts with ALTERNATIVE

TRAFFIC ROUTES between Niagara Falls and Lewiston.”

° 4th sentence. Did not include the Seneca cultural viewpoint that the RMP is an intrusion of a site of spiritual significance to them.

° edr inadequately reviewed the vehicular and pedestrian circulation based on language used in this draft.

° edr was to take a SPECIFIC view, not a global view of the potential impacts.

° Underlying objective to create a unique SENSE OF PLACE with indigenous native plants not met

° edr did not mention any marketing outreach - potentials to new tourism markets . It seems the following 6 tourism components would be logically included in an economic benefit assessment of who would be interested in coming to the Niagara Gorge Rim to see the ecological restoration:

° eco tourism, ° creative tourism, ° volunteer tourism ° obtaining a Creative City Designation – a first in the American East (Montreal, Canada has this designation)° Reenactment of Harriet Tubman and Underground RR potential° Native American portage

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° the Wild Ones Niagara study is not about “removing traffic from NYS Parks,” it is to produce a document for submittal to NYS Parks for inclusion in their scoping of the Robert Moses Parkway. It is to provide ALTERNATIVE routes (assuming complete removal of the Robert Moses Parkway between Niagara Falls and Lewiston, NY, AND

° it was to include scoping ALTERNATIVE ACCESS points to NYS Parks.

° edr did not include a comprehensive statement about the greenhouse or the feasibility of its being constructed. Purpose is

° growing native plants° private / public sharing of space (commercial – nurseries)° educational function° tourist destination° local college curriculums – classes and labs, high school environmental programs° new major – ecological restoration° scientific research – botanists, ecological restoration specialists, scientists, etc° other opportunities - Graduate College – A college of land planning

Table of Contents° Appendices

° Ecological inventory needs to provide a regional native plant community inventory ° Economic Study – Needs to build a base for appealing to groups beyond the

Niagara Frontier.

Chapter 2 Historical and Cultural Background – General Comments° none of this section appears to be relevant to an ecological restoration. Protections

and consultations should be tied to restoration movement and how it is still being opposed today.

° Since the Wild Ones Niagara study is about the preservation of the natural landscape, did edr include the following information as part of its background research? If not, why?

° The 2009-2013 New York State Preservation Plan, Historic Preservation at a Crossroads, identified seventeen key threats to implementing the plan. It states “each of these threats was mentioned repeatedly in all aspects of the public outreach process.” (page 15) The Niagara Gorge rim is botanically and culturally unique.

The key threats listed in the State Parks Preservation Plan Wild Ones Niagara finds particularly significant to the study, to Niagara Falls (NY) and the region are quoted and listed below. These same key threats readily translate and apply to land preservation as well as historic building and cultural preservation.

1.   Lack of awareness and/or the political will to protect historic and cultural resources: Many meeting participants expressed concern that historic and cultural resources are frequently lost or threatened through a basic lack of awareness about their social and economic value as well as a

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lack of awareness about historic tools, strategies, and incentives. Fear of controversy and lack of understanding prevents many communities from protecting historic and cultural resources.

2.    Lack of awareness about the economic benefits of historic preservation and the economic return on investments made in building rehabilitation and community revitalization. It was widely noted that historic preservation tools and strategies are underutilized and should be better incorporated into statewide community revitalization and economic development strategies. Many people advocated for better collection of data related to the economic impacts of historic preservation as well as development of a comprehensive economic impact study.

3.     Sprawl/ suburbanization and the erosion of rural, open space, and agricultural lands: Existing economic incentives continue to favor and encourage this type of growth.

° edr dedicated too much space in the document to NYS Parks. This is not for them. It is for the Wild Ones Niagara. edr is to build and make the case for ecological restoration, provide the economic benefits of the restoration, and then produce an interactive “fly-over” for marketing purposes.

° Sheet 1 The Beginning° Ignores the Old Growth forests, the rare botanical flora° National Heritage Area doesn’t address our natural legacy – while edr is charged with

doing so per the Agreement. ° References to Gorge RR should be pointed out as a detriment to the native flora.

Sheet 2 Devil’s Hole° No mention of the fact it is a Seneca site of spiritual significance ° This section of the Niagara Gorge is the most botanically unique space in the gorge and it

is not mentioned

Sheet 2 Whirlpool State Park° no mention of the Old Growth specimens still growing there

° no mention that removal of the Robert Moses Parkway would allow the merge of the two old growth forests.

Sheet 3° How does this focus on the Wild Ones Niagara vision?

Chapter 3 Circulation and Urban Park ConnectionsIt seems logical to find a comprehensive part of Circulation and Urban Park Connection

task would include noting the following:° does not note road redundancies° does not note excessive lanes of pavement° does not note environmental degradation from salt use and/ or pesticides°does not note the road supports infestations of invasive species°does not note annual carbon emission data

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° does not address stormwater run off into the Niagara Gorge° does not mention RMP bypasses every business district in Niagara Falls, Lewiston and Youngstown° does not list distances for alternative routes°does not list how redirecting traffic into the city and village is BENEFICIAL to the

municipalities° this statement is misleading: “It is a fast and easy commuter route for the

noncommercial vehicles commuting from Niagara Falls to Lewiston and points in between.

° It does not address the inappropriate vehicles that use the road, per NYS traffic laws.

° THERE ARE NO POINTS IN BETWEEN Niagara Falls and Lewiston. Once you are on that section of THE PARKWAY YOU CAN NOT GET OFF UNTIL YOU HAVE EITHER REACHED LEWISTON OR THE NORTH CITY LINE.

° When driving on the RMP BETWEEN the North City Line of NIAGARA FALLS AND LEWISTON you can NOT directly access:

1. St. Mary’s Hospital – Lewiston Road access2. The Lewiston-Queenston Bridge – I-190 access3. The Whirlpool Bridge – iWhirlpool4. The new Customs House / Underground RR – Whirlpool St.5. The new train station – it’s on Whirlpool6. The New York Power Vista7. The Fort Gray Drive Neighborhood (Lewiston)8. Niagara University9. Hyde Park10.The Aquarium – it’s on Whirlpool Street11.Old Fort Niagara12.Artpark – requires use of Route 10413.Main Street Niagara Falls – bypassed

° edr does not address the “scenic route” myth arguments by those who want to keep the Robert Moses Parkway.

The "scenic route" myth: it can be argued there are two wonderful views from the parkway and they are from the top of the Whirlpool Bridge Overpass and from the face of the Power Project itself. The top of the overpass does provide a magnificent view of the Falls themselves, the falling water framed by the Rainbow Bridge to Canada. This is a view that lasts for about fifteen seconds. The view of the gorge from the face of the Power Project is secondary to the view that can be had from Lewiston Road, running parallel just above it--the higher elevation actually providing a better view. Some of the "scenic view" fiction might be derived from the stretch between Whirlpool State Park and Devil's Hole State Park, proceeding north. Here the visitor on tour can catch through the vehicle windows glimpses of the top edge of the Canadian gorge rim as seen through trees as they ride along. This at least involves a natural scene they might expect to see at Niagara, though brief, about sixty seconds, and blurred. Imagination supplies the rest, what they

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have seen of the gorge from the railing at Whirlpool should the tour have allowed them some time there. If the loss of the overpass view is so crucial, NHP suggests a nearby city-street construction of a tower with an elevator and observation deck would be far superior to the fleeting view the overpass provided, giving visitors time to take photographs, and so on. LESS THAN TWO MINUTES OF DISPUTABLE "SCENIC VIEW" AS A DRIVE-BY EXPERIENCE (DURING A TOURIST SEASON THAT LASTS ABOUT 100 DAYS OUT OF THE YEAR) DOES NOT JUSTIFY PARKWAY RETENTION.

° the following statement from the “traffic consultant” is unsubstantiated and disproved later in the draft document”

° The Traffic Report does not suggest, it states without supporting documentation: “that approximately 70% of the traffic from the RMP will be redistributed to Lewiston Road and 30% to other alternative routes.”

° Why did edr omit the following the economic benefit assessments of an ecological restoration? ° There are additional benefits noted for commercial and residential real estate values ° crime prevention figures° non motorized greenway comparables° ecological resource benefits

° Please refer to the attached file labeled be edr as “FIRST DRAFT for internal review, January 31, 2011.” Why on 1//31/2011 did edr (Jane Rice, at 4:06pm and Andrew Obernesser at 11:48 am) remove narrative that seems to support the Wild Ones Niagara vision?

° Urban Park Connections° edr stated: “Historically, RMP has functioned well for noncommercial vehicular traffic.”

Explain how that happens° if it bypasses every business district° if inappropriate traffic uses it without regard to the law as happens now° when it degrades a botanically unique, calcareous cliff community

° the rest of the paragraph does not support an ecological restoration

Existing Conditions° edr deleted supporting rationale for removing the RMP on various sheets

Per edr edits: Andrew Obernesser deleted:Tell the story “that acknowledges past human interruption” “ Even the pedestrian trail through DeVeux Woods State Park that connects to

Whirlpool State Park requires pedestrians to cross the Robert Moses Parkway.” 2/1/11, 3:05 pm

Chapter 4 Proposed Improvements° Master Plan # 3 – “provide appropriate recreational amenities along the Niagara Gorge Rim”

° this is not the Wild Ones Niagara vision – it is contrary to the requirements of the Agreement.

° Master Plan # 6.

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° Again defies Wild Ones Niagara vision be deleting “that acknowledges past human interruption” as it pertains to signage.

° under providing more frequent rest stops, does not explain what is meant by “ other means of way finding.”

°Sheet 1 Earl Brydges Artpark State Park° edr included this statement, “In recent years, the community has made great strides in

this area, which currently includes Earl W. Brydges Artpark State Park, Plateau Park and the LEWISTON DOG PARK.

° identify how the dog park preserves and enhances the remaining precious natural resources.

°identify how a dog park adds to an ecological restoration.°edr did not include study information provided by Wild Ones Niagara that refutes the

above statement about the dog park.° explain how a non-motorized trail, Wild Ones Vision for the Gorge Rim includes this edr

statement: “Vehicular Traffic will also have safe, continuous alternative routes to use.” This is not Wild Ones Niagara’s vision for access to the Plateau. It is contrary to the Agreement.

° Sheet 3 Devil’s Hole State Park° Wild Ones Niagara’s vision does not include a “rim trail and a multi-use trail.”° edr omitted the elevator from Power Vista to trail or handicap and wheelchair access

Sheet 4 Whirlpool State Park° does not explain or define “gateway”

Sheet 5 Robert Moses Pedestrian Overpass° does not include removal as an alternative

Sheet 6 Gorge Discovery CenterEnhanced Whirlpool Street corridor is not the Wild Ones Niagara vision as Whirlpool

continues to bypass the Main Street Business district . It is simply a recreation of the obstacle that the RMP is.

OTHER EDR FAILURES° did not address the Wild Ones Niagara vision of removing the NYS maintenance garage on

the Niagara Gorge Rim

As part of the economic benefits report it seems logical to expect that edr would1. Document the NYS Parks REVENUE streams, if those funds are directed into the region

or if they bypass the area

2. Note parking revenue streams and who they benefit

° edr refused to attend at least two meetings they needed to be at, though the contract states they would attend as requested by Wild Ones Niagara

° the presentation of the Dog Park letter to Niagara River Greenway Commission

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° the presentation at Nov 30, 2010 scoping at NF Public Library° did not address items of concern in Task 11

As part of an ecological restoration ° edr has not provided discussion of a long-term monitoring plan ° has not included adaptive management practices, a crucial component of any restoration plan

° edr has omitted an ecological restoration timeline ° the time line should have included: planning and research, site preparation,

implementation, short term management, long term expectations, and monitoring

° edr did not address the structure and function of insect, bird, fish, mammal, fungi, and/or soil invertebrate communities and the role these communities play in a restoration design.

° edr did not discuss predator/prey relationships, pollinators and seed dispersers, or the balance of trophic levels.

° edr did not discuss what specific habitat requirements may be needed or provided

° edr omitted discussion of microbial communities in the soil

° edr did not include invasive species management guidelines

° edr did not conduct site specific research for succession changes (management)

° edr did not include or mention current ecological theories

° edr did not include management technologies

° edr omitted discussion of exotic and cultivar plant versus the benefits of native plants

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