U.S. Army Corps of Engineers/U.S. Coast Guard
Section 106 Consultation Conference

For the West Pierhead Light and Fog Signal Building

The conference was held on October 31, 2008 at the Ninth Coast Guard District in Cleveland. Attendees:

  • Joshua Feldmann, USACE, Buffalo District, by teleconference
  • Bill Butler, USACE, Buffalo District, by teleconference
  • Frank Blaha, USCG CEU Cleveland
  • Carol Poh, Historical Consultant
  • Steve Merkel, Committee for Responsible Waterfront Development
  • Ray Saikus, Committee for Responsible Waterfront Development
  • Robert Keiser, City of Cleveland Landmarks Commission
  • Lt. Joe Comar, USCG CEU Cleveland
  • Doug Sharp, USCG Waterway/ATON
  • Cdr Kevin Dunn, USCG Waterway management
  • Greg Carpenter, USCG CEU Cleveland
  • Mike Fleenor of the Cleveland Restoration Society, by teleconference
West Pierhead Light

Click for larger image

The Corps' written proposal of October 31, 2008

USACE remarks a the conference

The Committee's and Carol Poh's suggestions

USACE and USCG February 23, 2009, draft Memoradum of Agreement

The Army Corps of Engineers has responsibility for the foundation, while the Coast Guard has responsibility for the structures -- the Light Tower and the Fog Signal Building. The Light is a critical navigation aid. The Fog Signal Building is unused, as the compressed-air-driven diaphone foghorn was removed many years ago, and replaced by an electronic signal in the Light Tower.

The Corps' written proposal of October 31, 2008:

The U.S. Army Corps of Engineers (USACE)--Buffalo District plans to rehabilitate Cleveland Harbor's West Pierhead foundation to correct structural problems to a navigation aid that not only protects the entrance to the Cleveland Harbor, but also serves as the foundation of the Cleveland West Pierhead Light. The Light Tower will be undisturbed and will be monitored for settlement throughout the duration of the rehabilitation work.

However, due to excessive structural deficiencies and deterioration caused by naturally occurring environmental factors, USACE recommends that the Fog Signal Building be permanently demolished and disposed of in order to complete effective and safe pierhead repairs. Through consultation required by Section 106 of the National Historic Preservation Act [36 CFR Part 600], the USACE-Buffalo District, U.S. Coast Guard, and Ohio State Historic Preservation Office have determined that the demolition of the Fog Signal Building will have an adverse effect on historic properties and have agreed to negotiate a memorandum of agreement (MOA) to resolve this effect. Continuing consultation and negotiation of this agreement will develop and formalize accepted measures to avoid, minimize or mitigate adverse effects as mandated in 36 CFR Section 800.6.

USACE remarks a the conference

The USACE stated that the foundation stones had gaps large enough for fish to swim through, and the light tower has an increasing tilt, as evidenced:

Tilt Meassurement Photo

Their plan was to drive sheet piling around the foundation to contain it, much as they did on the East Pierhead light, except that funding limitations would allow them to only install sheet piling around part of the foundation. They would then fill the gaps in the foundation and cap it with concrete. They stressed the need for prompt action as they claimed that the light had an increasing tilt. Their concern regarding the historic fog signal building was that in the processs of repairing the foundation, it would be badly damaged and have to be demolished, which was their rationale for demolishing it before undertaking repairs to the foundation.

The Committee's and Carol Poh's suggestions

Repair the foundation with the fog signal building in place. If it survives, good. If it doesn't, we are no worse off that if it was deliberately demolished beforehand. A suggestion was made to reinforce the building with an internal wooden skeleton before starting repair work. The skeleton could be left in place after the work was completed.

USACE and USCG February 23, 2009, draft Memoradum of Agreement (MOA)

The MOA reiterated the USACE's plan of driving sheet piling to partially enclose the foundation. However it differed significantly from the original proposed rehabilitation work in that demolition of the Fog Signal Building was not mentioned, and the following wording was included:

Excerpt: The USACE will ensure that rehabilitation work, including the driving of sheet piles and placement of granluar fill and concrete is conducted in a manner that will result in no direct adverse effect on the Cleveland West Pierhead Light.