Comments on United States Coast Guard Public Notice 09-02-25
Water Flow Reduction Concerns
The proposed construction of new abutments, pilings, and columns, particularly in the deepest portion of the channel, raises significant concerns about further reducing water flow at the Canadian National (CN) Railroad Bridge. Historical data suggests that the bridge, constructed in 1908, has already impacted flow due to the installation of two abutments, nine 12-foot-wide concrete pilings, and blasting rubble left in the waterway, referred to as “The Dam Before Dam.” Jeff Kantor’s analysis from the 2022 flood indicates that a 10% reduction in flow could elevate peak flood levels by 14 inches. Given Rainy Lake’s history of high-water events, notably the 1950 and 2022 floods, any additional flow restriction could exacerbate flooding risks.
Recommendation: The Coast Guard should require CN to conduct a comprehensive hydrological study to assess the cumulative impact of existing and proposed structures on water flow. This study should model potential flood level increases and propose mitigation measures, such as the removal of historical blasting rubble, to restore flow capacity. The rubble, visible in historical photographs, should be addressed in the Memorandum of Agreement (MOA) as a mitigation measure to prevent further flow reduction.
Navigation and Safety Issues
The CN Railroad Bridge’s operation has historically impeded navigation, particularly for larger vessels like the 65-foot Voyageur Tour Boat, for which the National Park Service constructed a dedicated pier. CN’s uncooperative practices in maintaining an open navigation channel when the bridge is down pose safety risks for mariners. The proposed project does not address these navigational concerns, and the lack of clarity on navigation clearances and bridge operating schedules exacerbates the issue.
Recommendation: The Coast Guard should mandate that CN establish a clear operating schedule to ensure timely bridge openings for larger vessels, prioritizing navigational safety. Additionally, the installation of clearance gauges and adequate bridge lighting should be required to support nighttime navigation, as outlined in the solicitation for comments. The MOA should include provisions to address these navigational concerns, ensuring compliance with maritime safety standards.
Environmental and Historical Impacts
The proposed project will adversely affect the CN Railroad Corridor Historic District and the Rainy Drawbridge, both eligible for listing in the National Register of Historic Places. Additionally, the potential ground disturbance at the archaeologically sensitive Railroad Point Site (21KC0037) requires further scrutiny. While the Phase I archaeological survey conducted in May 2025 is noted, the results are pending, and any adverse effects must be addressed in the MOA.
The project’s temporary (0.25 acres) and permanent (0.02 acres) impacts to Waters of the United States (WOTUS), along with the placement of 1,250 cubic yards of temporary fill and 500 cubic yards of permanent fill below the 100-year flood elevation, could further alter the hydrological dynamics of Rainy Lake and the Rainy River. The presence of aquatic invasive species (Zebra Mussel and Spiny Waterflea) and the project’s location in an Ecologically Significant Area, as designated by the Minnesota Department of Natural Resources (MDNR), underscore the need for robust environmental safeguards.
Recommendation: The MOA should include specific mitigation measures to minimize impacts on historic properties and the archaeological site, incorporating findings from the Phase I survey. The Coast Guard should ensure that CN adheres to MDNR’s Best Practices for Meeting DNR General Public Waters Work Permit GP2004-0001. Additionally, the MOA should outline measures to monitor and mitigate the spread of invasive species during construction. The United States Army Corps of Engineers (USACE) and the Minnesota Pollution Control Agency (MPCA) should closely oversee compliance with Clean Water Act Sections 401 and 404 to minimize environmental impacts.
Conclusion
The proposed CN Railroad Bridge project must address the compounded effects of historical construction debris and new structural additions on water flow, navigation, and environmental resources. The Coast Guard should incorporate these concerns into the MOA, ensuring that mitigation measures, including rubble removal, navigational improvements, and environmental protections, are prioritized. We urge the Coast Guard to engage with consulting parties, including the Historic Bridge Foundation, Voyageurs National Park, and local tribal communities, to develop a comprehensive plan that balances infrastructure needs with the preservation of Rainy Lake’s ecological and historical integrity.
Submission: These comments are submitted for the record to michael.o.walker2@uscg.mil by 28 July 2025, as requested in the public notice.
