January 29, 2025
TO: Heather Gerling, PennDOT District 4-0 (hgerling@pa.gov)
Bureau of Project Delivery, Environmental Policy and Development Division
FROM: Thomas Rue, Narrowsburg, New York 12764 | tom@choicesmhc.com
Project Name: SR 1002 ov Delaware River 2024
MPMS Number: 12260
SHPO Review Number: 2024PR05246
Re: Cultural Resources Submission under NHPA Section 106
This comment is submitted for consideration relative to the mitigation of damage caused by PennDOT’s adverse impacts under of Section 106 of the National Historic Preservation Act brought about by the neglect and routine maintenance of the above-entitled project, ultimately leading to PennDOT’s announced intention to destroy the bridge.
The present document is available on the web, together with periodic updates and with hyperlinks to articles and other materials referenced below, at tomrue.net/sfbridge.
The proposed destruction of the bridge would constitute an adverse outcome caused by PennDOT’s failure to do any significant maintenance over recent years. This has led to multiple adverse outcomes to the community and environment and will lead to more.
History of the Milanville Bridge
This vital interstate bridge, linking New York and Pennsylvania since 1902 is historic in part due to its association with an important spot on the Upper Delaware and with the early rafting, tanning, and railroad industries that shaped the region's economy.
Unfortunately, this bridge has been closed to all users, including bicycles and pedestrians, since 2019 while the Pennsylvania Department of Transportation (PennDOT) slow-boated plans for this "outstandingly remarkable" structure's restoration, followed by plans to dissemble and reconstruct it in place. Currently, PennDOT is threatening to blow it up, despite a strong community will against the bridge's unnecessary destruction.
Near the famous Skinners Falls rapids, it spans the Upper Delaware River from Milanville, Damascus Township, Wayne County, Pennsylvania, to Skinner’s Falls, Sullivan County, New York. To construct a steel bridge, the Milanville Bridge Company incorporated on May 8, 1901, situated at the place where the first raft was started down the Delaware in 1764.
A descendant, Milton L. Skinner, was one of the founders of the bridge company and himself had been a steersman, considered one of the hardest jobs in the rafting business was a member of the Delaware Lodge #561, Free & Accepted Masons. The bridge was purchased by the Joint Commission on April 13, 1923, at a price of $19,542.21. Later that year, a hearing was held in Honesdale on September 10, 1923 "in the matter of dissolving the Milanville Bridge Company" (Tribune, 7/26/1923).
The bridge is architecturally rare. “The pin-connected Baltimore through truss design is historically and technologically significant, earning a November 14, 1988 designation to the National Register of Historic Places as one of only three such truss types among 135 highway bridges owned by PennDOT that had not been demolished as of 2019” (UDC, 3/23/2021).
According to PennDOT's "Skinners Falls Bridge Project Purpose and Need Statement" (2022): "The NPS considers this bridge a contributing element to the Cultural Outstandingly Remarkable Value for the Upper Delaware Scenic and Recreational River. Coordination with consulting parties, the State Historic Preservation Offices, and NPS will occur throughout the project development process." (See the NPS explanation of this, "Fact Sheet: Outstandingly Remarkable Values".)
In December 2024, PennDOT announced the idea of demolishing this one using explosive charges. Dropping it into the river and dredging it out, as proposed, seems likely to cause environmental damage to the river.
The Future of This Historic Bridge
The feasibility of restoring the Milanville / Skinners Falls Bridge depends on several factors:
1. Structural Integrity:
• The original 1902 three-span steel Baltimore truss structure at Milanville had two piers in the river. It was destroyed at about 6:00 PM in a flood on March 26, 1904 by the flow of an ice-jam, resulting from 20’ movement of the NY pier with the adjacent two spans dropping into the river. Reconstruction efforts during 1904 produced the present-day two-span bridge with one center pier and abutments in the same location as the original bridge. Materials from the original bridge were reused by the Owego Bridge Company to repair and reconstruct the bridge.
• Without as-built depictions, it is difficult to determine how the abutments were built. One difficulty is that it makes it difficult to design a rehabilitation to resist seismic forces. However, something like what was done for the pier for the Taftsville bridge (Vermont Agency of Transportation, Research and Development Section. 2015. Assessment of JAHN Permeable Mortar System in a Historic Bridge Abutment Application. Report 2015-10.) might be possible to restore and reinforce the Milanville Bridge's abutments.
• Engineers from PennDOT and its consulting vendor, AECON, have assessed that the present bridge’s foundational elements are stable enough for restoration. This is shown in PennDOT's inspection reports up until November 2024, reviewed by Damascus Citizens for Sustainability in its letter dated January 2, 2025. Without explaining or providing supporting data, PennDOT subsequently suddenly took a polar opposite position in December 2024 by calling for destruction of the historic span by dropping it into the protected river using explosive charges.
2. Historic Significance:
• The bridge is listed on the National Register of Historic Places, which encourages preservation over replacement. This status should attract funding and support for restoration. It also imposes restrictions.
3. Cost of Restoration vs. Replacement:
• A new bridge might be more cost-effective and durable but would sacrifice the historical character. An even more cost-effective approach would have been for PennDOT to provide proper maintenance to prevent its deterioration.
• Impacts have been studied by PennDOT and AECON over the years that they have closed the bridge to traffic, with multiple options presented as viable – up to the point when agency's position was suddenly and inexplicably reversed in favor of blowing it up.
4. Community and Environmental Impact:
• Residents and stakeholders value the bridge as a cultural and historical landmark. It is recognized by the US Department of Interior and Upper Delaware Council Inc. in the Upper Delaware River Management Plan as having national significance.
• Restoration would likely minimize environmental disruption compared to constructing a new bridge. As noted, an even more cost-effective approach would have been for PennDOT to provide proper maintenance to prevent its deterioration.
• These impacts have been studied by PennDOT over the years that they have inconveniencing motorists by closing the bridge to traffic. See the "Skinners Falls Bridge Project Purpose and Need Statement" (PennDOT, 2022).
5. Traffic and Functional Needs:
• The bridge is a single-lane span, limiting its functionality for modern transportation needs. It does not need to carry loads heavier than it historically has. It might even serve community needs as well with a lower weight limit.
• Restoration must address safety and load capacity without compromising historical integrity.
6. Funding and Stakeholder Agreement:
• Collaboration between the Pennsylvania Department of Transportation (PennDOT), New York State Department of Transportation (NYSDOT), US Department of the Interior, local governments, and community agencies and members is essential.
• Funding sources could include state, federal, and private grants, but consensus is crucial to move forward.
• Before any proposed demolition can lawfully occur, State and Federal agencies must weigh the outstandingly remarkable value of this bridge against available resources. For discussion of state-level resources under Pennsylvania's guidelines, see PennDOT's "Historic Metal Truss Bridge Capital Rehabilitation Program" eligibility guidelines, and "A New Funding Source for Metal Truss Bridges" posted by the Pennsylvania Historic Preservation Office. Federal funding for rehabilitation should also be sought from the Federal Highway Administration and US Department of Interior. Examples of possible private funding sources that should be explored include such sources as the National Trust for Historic Preservation, private entities such as the 1772 Foundation, local community foundations, and seeking additional guidance from the Historic Bridge Foundation (this page listed the Skinners Falls Bridge in a January 15, 2025 post).
7. Path Forward for Remediation
• Preservation: Local groups advocating for the bridge’s restoration reflect widespread community support for preserving the bridge for its historical and cultural significance. This bridge is not only infrastructure but is living heritage connecting the community to its past. It is listed on the National Register of Historic Places and is federally protected by P.L. 90-542 and P.L. 95-625 (two laws which together designated the Upper Delaware Scenic & Recreational River as federally protected) for the bridge's "outstandingly remarkable value" (see the NPS explanation of this, "Fact Sheet: Outstandingly Remarkable Values".)
• Renovation: Methods suggested by PennDOT itself in the past, specifically addressed repairing a crack in the New York abutment of the bridge, which state inspectors first observed in 1991 and have been monitoring since that time. Inspectors recorded "No Change” on inspection reports until 2024.
• Repairs that the late PennDOT District Bridge Engineer Foster Sankey proposed in 1991 to address the abutment crack included "casting a new wall in front of the existing one or jacking the bridge." Another bridge engineer commented in January 2025: "Of the options mentioned (wall in front, or jacking and repairing the New York abutment) the latter seems more feasible. If a wall is built in front of the existing abutment, the truss would have to be modified to shift the truss reactions (at the bearings) towards the river. That said, jacking a truss is not an easy task either. It would likely require temporary modifications to the truss to resist the jacking loads, which would be half the weight of the adjacent span."
• Alternatively, preservation of other historic bridges in the northeastern US and Canada has been aided by the injection of high-strength grout mortar into cracking or crumbling masonry (like the NY abutment here). These could serve as a model here. Notable instances of historic bridges where such techniques have been employed to stabilize crumbling abutments include the Taftsville Covered Bridge in Vermont; an 1887 Masonry Bridge Pier Restoration in Quebec; and the Historic Stone Bridge Remediation of the Pan Am Railway. These examples illustrate the application of high-strength grout mortar in preserving historic bridge abutments and piers. See "Best Practices for the Rehabilitation and Moving of Historic Metal Truss Bridges", Virginia Department of Transportation, June 2006; as well as PennDOT's own "Historic Truss Bridge Management Plan" and "Truss Maintenance Manual" for professional guidance on safe and effective methods of bridge preservation. Whether by these methods or another, AECON concluded in 2023 that this bridge is repairable.
• Public will: In response to strong public will, a way must be found to fix this bridge. Destroying it is not a responsible option, given the cultural value and historical significance of the Milanville/Skinners Falls Bridge to the Upper Delaware River Valley community and national interest. Media attention has reflected the significant public interest in remediating the harm done by PennDOT's violations of Section 106 and this bridge's importance to the community.
cc: Lindsey Kurnath, NPS/UPDE (lindsey_kurnath@nps.gov)
Laurie Ramie, UDC (laurie@upperdelawarecouncil.org)
Tyra Guyton, SHPO (tyguyton@pa.gov)
Ben Harvey, FHWA (benjamin.harvey@dot.gov)
Barbara Arrindell, DCS (director@damascuscitizens.org)
Attachment 1: History and Future of the Milanville Bridge at Skinners Falls, by Tom Rue
Attachment 2: Vermont Agency of Transportation, Research and Development Section. 2015. Assessment of JAHN Permeable Mortar System in a Historic Bridge Abutment Application. Report 2015-10