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Potomac Yard Metro opponents cite GW Parkway purity

Officials have refined the options for where to place the Potomac Yard Metro station. Neighbors concerned about impacts to the George Washington Parkway are opposing 2 options which place the station closer to planned development, but the Metro station will bring far more long-term traffic relief than just avoiding temporary construction.

Alternatives for the Potomac Yard Metro station.

The project is now in the middle of its Environmental Impact Statement (EIS) phase. Officials have refined a set of 9 alternatives down to 3, plus a 4th no-build scenario. The City of Alexandria is now required by law to evaluate each of the 3 alternatives that made it through the screening phase.

Some residents at a public meeting on April 19 vehemently opposed alternatives B and D, because the project's construction could temporarily affect the George Washington Memorial Parkway. Both of those alternatives place the station farther north than the other alternative, A.

The speakers came primarily from Potomac Greens and Old Town. Some were fine with a station at A, while others opposed the station entirely. For most, the Parkway was the primary reason they cited, though some also feared construction noise and didn't want a station near their homes.

Impact on the GW Parkway

Those opposed to alternatives B and D repeatedly lauded the uniqueness of the parkway among capital cities worldwide. They demanded that officials throw out any build alternative that interferes with the roadway, even for two years or less.

Alternative D, located closest to existing and planned density in the area, probably has the most impact on the GW Parkway. This alternative requires elevating tracks to cross over the existing Metrorail and CSX tracks, passing through an aerial station roughly where the movie theater now stands, and then passing back over the CSX tracks to rejoin existing tracks.

There are construction benefits and drawbacks for this option, but it undoubtedly puts the infill station much closer to existing neighborhoods and the densest portion of future planned development.

Portion of Alternative D station and track. Click for full proposed construction zone.

At least two speakers at the meeting asked for a traffic study, but this study has already been done as part of the Potomac Yard small area plan (chapter 6). One infill Metro station isn't a traffic panacea, but according to the study, traffic will be worse in the Potomac Yards area if the station is not built.

The Potomac Yard small area plan calls for drastically-reduced density without a Metro station. But even in this scenario, traffic will be worse than with higher density and a Metro station. The closer the Metro station is to existing and planned density, the more cars it will take off the road.

Nonetheless, Old Town resident Poul Hertel reached as far back as 1902 to protest impacts on the Parkway, quoting a document from the McKinley Commission referring to the "Mount Vernon Road" as "affording an opportunity for the most refreshing and delightful drive to be had in any direction from Washington and not to be equaled at any great capital of the world."

While historical context is important, the massive back-ups on this main artery into the city mean McKinley's commission surely would have enjoyed the "refreshing and delightful" drive far less today. They probably would have made a temporary trade-off in parkway accessibility to save green space farther out from the city and temper traffic increases long-term.

The EIS process

Alexandria staff explained at the meeting that they are working with the National Park Service, and nothing will go forward without approval by the NPS. There are also other requirements regarding technical and financial viability, among other things.

Officials cannot throw out alternatives during the EIS phase until the city puts forward a locally-preferred alternative. But speakers demanding staff eliminate parkway-disturbing options did not yield, as speaker after speaker stood up to call for the city to change course in a way that is not possible.

David Fromm of Del Ray pointed out that the city could have done a better job explaining the reasons the screening process put forward each alternative. He was right, but it didn't appear that the most vocal in the audience would have been convinced by any option that breached the sanctity of the GW Parkway, regardless of long-term traffic benefits.

City staff periodically referred speakers to the PY website since they could not cover the vast amount of information about the potential development in a single public meeting.

Density, transit and the urban core

One speaker seemed to understand the larger point. Though she is a Potomac Greens resident who surely will be impacted by the construction, she pointed out that without the infill station, future growth in the area will make it so everyone will have plenty of time to admire things along the GW Parkway-turned-parking-lot, as traffic continues to get worse.

Large growth in the DC area is coming, so area municipalities need to responsibly manage that growth with improved infrastructure. Her statement brought sporadic applause, indicating she was not the lone supporter of the station.

For tangible proof of the traffic-reducing impacts of public transit and responsible land use planning, look no further than the Rosslyn-Ballston-Clarendon corridor. In this corridor, with access to public transit, people choose to live closer to jobs, stores, restaurants, etc.

In turn, people use their cars less, if they keep a car at all. This is why traffic volumes in that corridor have stayed relatively flat over the past 30 years despite massive development. Creating these livable communities reduces driving and therefore traffic.

With growth coming to the DC area, we can either clear-cut and pave over more outlying forests, or add more density close to the core. The most responsible action is to create dense, livable communities with good access to multi-modal transportation.

Even if urban living isn't for everyone, real estate pricing and trends indicate there's a shortage of walkable, transit-oriented communities and an over-supply of distant, exurban sprawl.

To be good stewards of our region, we simply must build density near transit near the urban core. If the most feasible option requires disturbing the GW Parkway during construction, that should not be a reason to avoid it. Temporarily interfering with GW Parkway traffic patterns does not outweigh losing acres of land that would have to be built farther out to replace the lost units and transportation capacity in Alexandria.

Audio of the April 19 public meeting is available here, and the presentation itself is available here.

Cross-posted at The Arlandrian.

Nick Partee writes for The Arlandrian about neighborhoods on the north end of Alexandria. He helped start up and still helps run the weekly Four Mile Run Farmers and Artisans Market. His primary interest is making Arlandria and surrounding neighborhoods greater by applying successful urban principles to build a sustainable community. He can be seen spending far too much of his free time running the farmers market, "geurrilla gardening", or coordinating other volunteer efforts to eek out every ounce of potential he can in Arlandria. 


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Maybe I missed it, but what are the proposed impacts to the Parkway from alternatives B and D?

According to the EIS slideshow, construction for alternative D is the only one that gets close to GW Parkway, and it looks like that's just construction access from the adjoining roadway. It's not like they had to close lanes of I-66 for extended periods to build the new switch and bridges between East and West Falls Church, and there was about half as much open space there.

by Peter K on Apr 24, 2012 11:29 am • linkreport

I have to admit I didn't expect so much local opposition to Alternative D. Short-term impact to GW Parkway? I don't buy it. I think this is just NIMBYism run amok.

by movement on Apr 24, 2012 11:35 am • linkreport

@Peter K, It's on slide 22 of the City's presentation. The orange overlay shows how B would touch the parkway. The current expectation is for construction to close off one lane during off-peak hours for construction vehicles to accelerate and decelerate entering the construction site. There would also be access from Potomac Greens directly.

Another note: the City says crossing the CSX and live Metro tracks during construction is a non-starter. They *might* be able to figure out a way to approach from the south and avoid the GW Parkway with option B, but definitely not with D. They won't know until they get further along.

by Nick P on Apr 24, 2012 11:38 am • linkreport

This reads like a belated April Fools article. "Those opposed to alternatives B and D repeatedly lauded the uniqueness of the parkway among capital cities worldwide." Seriously?!?
First off, the parkway isn't in the capital. It's in Virginia, and if Virginians are regretting the Retrocession of 1847, that's another issue for another time.

More importantly, what's this about no other capital cities having parkways so that people can enjoy the pretty scenery from the comfort of their cars? Parkways are actually a remarkable common feature in capital cities worldwide. Check out:
Rockcliffe Parkway, Ottowa, Canada
Quai de Bercy, Paris, France
Avenue de Flore, Brussels, Belgium
Upper Ridge Road, New Delhi, India
Via Appia Antica, Rome, Italy
pretty much every highway in Seoul, Republic of Korea
and many more!

by tom veil on Apr 24, 2012 11:42 am • linkreport

I had the same question as Peter K. Is the concern that an elevated station and bridge over the CSX tracks will ruin the view? Or will the construction itself force closures on the nearby roadway? I'm not a lover of an elevated station but there might be nice views of the city from the platform. It would definitely be worth additional costs to bring the station closer to foot traffic. An aerial station could have some iconic status there and, unlike in Tyson's, it wouldn't seem to interrupt more useful ground level traffic.

by Fischy (Ed F.) on Apr 24, 2012 11:50 am • linkreport

I agree with movement. This is probably a nimby ruse by people who simply don't want the metro on "their side" of the railroad. By keeping the metro further away from the developable land and further away from them, they hope to limit the total amount and density of the development. They have simply adopted concern over the GW Parkway, since it is the only concern that is likely to gain any traction with the NEPA.

by orulz on Apr 24, 2012 11:53 am • linkreport

This is why traffic volumes in that corridor have stayed relatively flat over the past 30 years despite massive development. Creating these livable communities reduces driving and therefore traffic.

Can the author please elaborate on this? It would seem like the concept of induced demand replaces former car users (who now take another mode like transit or walking) with new car users, such that congestion increases may slow or congestion may not increase at all ... but congestion actually decreasing? That does not seem particularly likely, nor theoretically consistent.

by Scoot on Apr 24, 2012 11:56 am • linkreport

Pretty much typical Alexandria nimby-ism. The same cast of characters as every other Alex. public meeting.

by spookiness on Apr 24, 2012 11:58 am • linkreport


Someone may find it before me but the traffic counts of daily vehicles on Wilson Blvd. between 1980 and 2006 I believe actually lowered, If I find the citation I'll post it. All while increasing population. Now other drivers (particularly from fairfax and out jurisdictions) may have replaced some of those trips but it hasn't yet outpaced the amount of people who are choosing not to drive.

by Canaan on Apr 24, 2012 12:17 pm • linkreport

Good analysis of this issue. I've heard many residents near the proposed Metro site at Potomac Yard complain about how a Metro station would potentially damage the G.W. Parkway view-shed and affect wildlife in the park. Of course, that didn't stop them from buying $800,000 townhomes directly adjacent to the parkway only a few years ago. But somehow, in their minds, housing is a perfectly reasonable use of that land, while sensible transit choices are not. In their minds, it's okay for luxury houses and traffic-choked roadways to co-exist with wildlife, but not a Metro station. What this comes down to is that the opponents of this Metro station are selfish and short-sighted. They want to live in a pastoral, nearly rural setting; yet they also want to live five miles from Washington DC and all the jobs and amenities of being in a city. But you know what? That's not real life. The world doesn't work that way. If you want to live near a city, you make certain trade-offs, one of which is accommodating public transportation, sometimes in your neighborhood. If the residents of Potomac Greens don't want that, I would suggest that they sell their townhomes and move out to Leesburg or Warrenton.

by coltrane on Apr 24, 2012 12:25 pm • linkreport

@Canaan. I believe the data you're looking for is posted in this very blog post, where the author cited "tangible proof of the traffic-reducing impacts of public transit and responsible land use planning".

Yet the data in that link doesn't actually show traffic reduction -- it actually shows traffic increasing in terms of volume, just not as rapidly as one would predict given how many more people live and work there now. On Arlington Blvd and Clarendon Blvd, traffic increased 4% and 8% respectively from 1996 to 2006. Those are some very modest numbers given the explosion of development there, but not so accurate to merit the statement that traffic has been reduced. Just my 2 cents.

by Scoot on Apr 24, 2012 12:34 pm • linkreport

The original purpose of the parkway was for "pleasure driving." To dedicate the highway exclusively to its original purpose, it would be necessary to make it illegal to use it to drive to work.

by Ben Ross on Apr 24, 2012 12:34 pm • linkreport

"affording an opportunity for the most refreshing and delightful drive to be had in any direction from Washington and not to be equaled at any great capital of the world." (1902)

Note that in 1902 "drive" was used to refer to what you did with a horse and buggy. It wasn't until the 30s that "drive" took over from "motor" as a way of talking about automobile travel. (fun link: )

by egk on Apr 24, 2012 12:36 pm • linkreport

'No station at all' would be pure NIMBYism; those selecting option A actually put the station closest to existing, and highest priced homes (which IIRC are *not* currently paying the real estate surtax), where the land is already set aside (and I think already owned by the city) for a future station. Could be bank-shot Nimbyism though.

by Kolohe on Apr 24, 2012 1:05 pm • linkreport

Seriously, do these people even know the history of the automobile? Nobody was talking about cars in 1902 when mentioning a "refreshing drive."

@Caanan, Scoot

Traffic on Wilson barely increased in 25 years; on Washington Blvd traffic decreased slightly. Keep in mind also this is with a MASSIVE increase in people living in the area.

Also, I would note that "traffic-reducing benefits of public transportation" does not have to mean that total traffic counts go down. Population is always going to be growing - traffic reduction through transit means absorbing those extra people without creating as much extra traffic. That's traffic per capita going down.

by MLD on Apr 24, 2012 1:06 pm • linkreport

The NIMBYs in Alexandria need to do a little more historical research. The scenic route to Mt. Vernon that was most actively promoted around 1902 was the inland alignment along the Arlington Ridge and down Mt. Vernon Avenue in Alexandria (thus its name). The Parkway as we know it now wasn't authorized until 1928.

by jimble on Apr 24, 2012 1:08 pm • linkreport


ah, the statistic I remember reading goes back to 1980 and not 1996 and that might account for our differing accounts. This,

Shows a slight increase on Wilson between 1980 and 2004 and a decrease on washington blvd. Unfortunately the pdf that it is citing isn't coming up. Regardless, its does give evidence that adding population doesn't guarantee a similar increase in traffic.

by Canaan on Apr 24, 2012 1:14 pm • linkreport

@MLD, thanks for finding the document. I read the statistic some time ago but couldn't find that particular document, just the 2007 Arlington PDF.

@Fischy, I think the concerns about GW Parkway include spoiling the view (which includes Crystal City and will include a bit of PY redevelopment). I saw a comment by one of the City Council candidates (Boyd Walker) on the Arlandrian that also mentioned some people think if they make a temporary "curb cut" for construction vehicles that it will somehow lead to a permanent new exit over to PY. Seems pretty odd though, since that would require its own flyover of at least the CSX tracks, plus permanently cutting through wetlands.

by Nick P on Apr 24, 2012 1:48 pm • linkreport

If they want to go back to the 1920s, they're not going to be happy with a very busy railroad yard next to the pristine parkway. Or in their back and front yards.

(I think you mean the McMillan report, not the McKinley report.)

by D. Murphy on Apr 24, 2012 1:57 pm • linkreport

Where did Arlington get those traffic numbers?

by selxic on Apr 24, 2012 1:59 pm • linkreport

Also, I would note that "traffic-reducing benefits of public transportation" does not have to mean that total traffic counts go down. Population is always going to be growing - traffic reduction through transit means absorbing those extra people without creating as much extra traffic. That's traffic per capita going down.

I don't underestimate the importance of transit modes absorbing travel patterns in regions that experience population growth, but I would just try to stay away from making blanket statements like "transit is proven to reduce traffic" when the reality, in this region at least, is that transit has simply allowed traffic to grow at a slower rate than it would have otherwise, or has allowed traffic to get better on some roads but worse on roads nearby. I hope that in the future, transit will be so prevalent that more people will move in who don't drive than who do drive... and that will actually decrease traffic.

by Scoot on Apr 24, 2012 2:02 pm • linkreport

I couldn't care less about what alternative they choose, since I would never even consider living in Alexandria. However this quote is kind of pointless:

"uniqueness of the parkway among capital cities worldwide"

What does DC being a capital city having to do with anything, especially when the Parkway is across the river in another state? Nationally many dense cities have urban parkways (of questionable safety for motorists driving 70mph), especially other Northeastern cities. New York alone has many parkways.

In addition to the GW there are parkways that are actually located the "capital city" including the Rock Creek, Suitland, and Clara Barton parkways. The latter two are also in Maryland, in addition to the Baltimore-Washington Parkway (quite possibly the busiest on Planet Earth) and Cabin John Parkway.

by King Terrapin on Apr 24, 2012 3:40 pm • linkreport

this is getting silly - of course the GW parkway relates to DC, since thats the dramatic stuff you from it, and its hard to get similar views of DC from many other places.

OTOH the complaints about TEMPORARY road work arent about the nature of the parkway, but about temporary inconvenience.

And for all the worry about NIMBYISM, it seesm very unlikely Alex will favor the no build option.

by AWalkerInTheCity on Apr 24, 2012 3:48 pm • linkreport

@AWalkerInTheCity I don't think Alexandria will favor no-build either but as we've seen with the Waterfront, there are a myriad of ways for the process to get bogged down and it seems that the NIMBYs will do everything in their power to explore all of them.

by movement on Apr 24, 2012 4:56 pm • linkreport

but as this post shows, even among the nimbyists complaining about the effect on the parkway, many accepted the station in Zone A. I don't think theres nearly the division on this in City of Alex as there was on the waterfront.

by AWalkerInTheCity on Apr 24, 2012 5:18 pm • linkreport

I'm thinking divide and conquer. Knock out options B/D first then as we get closer the Potomac Green folks come out with the pitchforks and torches.

by movement on Apr 24, 2012 5:21 pm • linkreport

@movement - yeah, that's what I was thinking with my "bank-shot NIMBYism" comment

by Kolohe on Apr 24, 2012 7:09 pm • linkreport

Just to clarify, the unique among capital cities phrase was sort of poking fun at the flowery language used to put the parkway on a pedestal during the meeting. It's very near a direct quote from a speaker. It's a fantastic road for a leisurely drive during most times of year in off-peak hours, but it is far down my list of what makes DC a world-class city, as some speakers seemed to imply.

by Nick P on Apr 24, 2012 8:03 pm • linkreport

Give the nimbys some credit. They did keep the area from becoming a vast parking lot with a football stadium in the middle.

After seeing the Potomac Greens folks standing across from Buzz protesting the special tax district, I wish the city would drop access to the station from their neighborhood. I have hard time believing the city won't cave in when the PY residents wave a few signs.

by jd on Apr 24, 2012 9:04 pm • linkreport

Alternative D is a disaster waiting to happen. Elevating those tracks will increase noise levels tremendously and make metro tracks the centerpiece of the neighborhood. I don't understand why there seems to be this insistence to spend gobs of money to re-do tracks when Alternative A already has the straight line tracks needed for an infill station and is substantially less expensive. Perhaps Alexandria has gobs of money it just doesn't know what to do with. They may have more trouble spending lots of money when the people they're taxing to pay for this move in.

by Jason on Apr 24, 2012 9:08 pm • linkreport

Alternative D seems to make the most sense from a station location stand point, but the extent of new track work required, the elevated station, and the CSX flyover are certainly concerns for cost and construction duration.

Definitely agree on the bank shot NIMBY - no way Alternative A ever gets accepted due to proximity to PG.

by Bill C on Apr 24, 2012 9:22 pm • linkreport

Bill, Alternative A should not be a surprise to anyone in PG, that's the spot it was originally planned for and it would provide them with great Metro access. I don't see why they'd complain. PG should be livid about a metro line track ramp that is level with their second story.

by Jason on Apr 24, 2012 9:37 pm • linkreport

I realize that this is how things are done, but it's a sad state of affairs when the debt service interest and the capitalized interest combined are more expensive than the project itself. (slide 34)

by Bill C on Apr 24, 2012 9:41 pm • linkreport

@Jason, point taken. I suppose you're right about A actually being better for PG than D.

by Bill C on Apr 24, 2012 9:48 pm • linkreport

Nick has done a great job capturing the sense of this meeting. I was there. This is exactly how it went.

It's easy to dismiss the nimbys. And it's easy to think that they won't prevail. But I don't think they should be underestimated. These are exactly the same folks who opposed the waterfront plan. One of them is running to become mayor, which wouldn't mean much except that he's a former vice mayor, meaning he got more votes than any other member of council that year. He's been pushing to spend thiw money to improve Route 1 for vehicular traffic instead of a metro and is pushing not to build the station. Here's what he had to say, as quoted by the Del Ray Patch:

“To cut into the parkway this way makes absolutely no sense,” said Old Town resident Andrew Macdonald, who is running for mayor as an independent. “I love Metro, but this is an ostensibly expensive project. I’d like to see the money spent on other options and in other ways along Route 1.”

by Kevin Beekman on Apr 24, 2012 9:49 pm • linkreport

Sadly this is the same gruop who opposed the Redskins stadium that was to be built at Potomac Yards. This was an agreement made by the late Redskins owner,Jack Kent Cooke and Virginia Governor Doug Wilder.

The red brick stadium design was beautiful. However, the pitchfork environmental crowd from Alexandria went bonkers. They somehow convinced folks that a stadium used 8-to-10 times per year would cause traffic paralysis for Alexandria and Arlington.

So thanks to those short-sighted folks (and the WASH POST Editorial Board) residents now have an enormous and unattractive shopping center and tons of townhouses causing constant traffic headaches along Route 1 and supporting roads. Far too many back then spoke before they thought.

It would be unfortunate to ruin the beauty of the GW Parkway in that area...but after all there is not far from Reagan National and Crystal City, etc. and there is already a crossover METRO bridge. A temporary cut-out from the parkway should not be a problem. However an elevated station seems peculiar at that site.

Of course the real issue is funding...few of us in our lifetimes may witness the opening of the Potomac Yards Metro Station.

by Pelham1861 on Apr 25, 2012 8:52 am • linkreport

An ostensibly expensive project? Really?

by movement on Apr 25, 2012 9:05 am • linkreport

Most of these NIBY statements in this comments are made from uninformed people. Ist I live in Potomac Greens. We were informed that buying our home there was a propded future metro stop. No other details were provided, and the devil is in the details.

Alternate D is a disaster waiting to occur and will be cost prohibitive. Several homes in PG are adjacent to the tracks. A few of those homes' structural integtity is based upon the current metro retaining wall.

Option D raises the track once it exits the metro tunnel south of PG. To cross over CSX tracks, the elevated track would be on our third floor level before crossing the tracks. Heavy construction equipment, sheet pilling, lighting at night, (light /noise pollution) cranes would have to be brought in within ~ 50 feet of said homes.

Alexandria would have to raise the concrete retaining wall, map out undergoing utilities, conduct a noise and light study, imment domains purchased, etc etc. This doesnt include the zoning issue of raising the metro that close to existing homes. I asked as a former Corps of Engineer officer why did option D make it out the gate. To my knowledge of riding various metrorail lines does any existing raised lines come this close to any existing homes. Name a point on ANY line folks within ~ 70 feet. Think vibrations, noise etc.

Third point, several in PG stated option B works. Let's take the emotions and "Fox news hype" out of the discussions and talk fromfactual information. The city of Alexandria performed the zoning for PG. Don't blame residents if the Council plans to build a metro station with sft estimates BEFORE a EIS was conducted to even determine with an amount of accuracy and assoicated risks to a project of this size. They didnt perform all thier homework.
Fir example, The Council promised PG residents to build a walking bridge to connect PG to the metro station. Yet when I questioned whethercrheyveould "fence" the miney for the bridge I was informed "We can't obligate future Councils". Regarding the price of said waling bridge bridge I questioned the Council its estimates and the Comptroler agrred thatcthe orice was low. So what did Vice Mayor do, give back the 2 million back to the devrloper. Look up the meeting minutes. Yet even with all that history several of us proposed option B. Where's the NIBYism in that?!

by FHenderson on Apr 25, 2012 11:20 am • linkreport

That's disappointing. Surely the people buying into Potomac Greens were apprised of the forthcoming Metro station? I suppose that all is not lost if the less desirable station locations go forward, since CCPY will still get BRT or something.

@Scoot: the corridor measurements are for Wilson and Clarendon, not US-50. Some through traffic diverted to I-66 and US-50, and some local traffic was replaced by walking trips (or shorter drives) to now-more-convenient services. This despite the arrival of, oh, five Pentagons worth of development.

by Payton on Apr 25, 2012 11:23 am • linkreport

Alt D is disappointing. For all the effort of getting the Metro over the CSX/VRE tracks, they're really not pushing the station that deep into the parcel, meaning that you limit the natural walking radius around that station.

In the linked presentation, the original alternatives for D1 and D2 featured a station more in the midst of the development, opposed to the shown D3 alternative. The two C alternatives were even more central in the site.

I'd have to see some cost numbers, but I would tend to think that if you're going to go to the expense of building that flyover of the CSX tracks, you'd want to at least position the station in a more central location for that development on the Potomac Yard parcel.

If not, and given some of the cost-benefit assumptions (that Alts A and B would be much cheaper) as well as the construction of the streetcar/transitway, I'm not really sure what to think at this point.

by Alex B. on Apr 25, 2012 11:37 am • linkreport

As a new resident of the Potomac Yard development, I don't think NIMBY will be much of a problem from our side of the tracks. At least I hope so! Most of the residents I've talked to said the prospect of a Metro station within a few minutes walk was a huge incentive to move here. As the only residents who will actually be paying for it through the special tax district, I say build the most cost effective station possible as soon as possible, presumably Alternative A. D is far more complex and as an earlier commenter noted, doesn't really get that much closer to the North Potomac Yard Development while B requires 2000 feet of new track to be built.

In a perfect world, with unlimited resources, the tunneled C alternative would have been the best from a transportation & development perspective. But in this time of austerity, sometimes compromises have to be made to do anything.

by David PY on Apr 25, 2012 1:14 pm • linkreport

"One speaker seemed to understand the larger point. Though she is a Potomac Greens resident who surely will be impacted by the construction, she pointed out that without the infill station, future growth in the area will make it so everyone will have plenty of time to admire things along the GW Parkway-turned-parking-lot, as traffic continues to get worse."

How does adding this station on lines which terminate at Huntington and Franconia/Springfield impact the real culprit of the "GW Parkway-turned-parking-lot," which is its primary use in rush hour by those living far beyond the Metro terminus as an alternate to Route 1 and I-95 on their long commute home? It doesn’t, and those interested in local traffic improvements need to raise their voice about the 30% reduction of Metro line service to the Arlandria portion of the Blue line when the Tysons and later Dulles portions of Metrorail come online. If our leaders were spending time on mitigating that impact with some creative answers like having some trains double back and forth from the Pentagon to King Street and/or Franconia/Springfield (which the 30% decrease will allow trains to accommodate by turning around just past the Pentagon station before the Arl Cemetary stop), that would have a truly meaningful impact on local traffic rather than a station of dubious import that serves a handful of new townhouse owners while the major issues like the imminent 30% reduction in Blue line service in our neck of the woods remain unaddressed.

by JD on Apr 25, 2012 1:32 pm • linkreport

The station will allow more density in this area, hence less development in the peripheral suburbs, all other things being equal.

The reduction in traditional blue service will be offset by the increase in service to L'Enfant.

for supplementary local service, the area will soon have the CCPY transitway.

Ultimatly the way to fix the issues resulting from congestion on the crossings is a seperatated blue line with an additional metro tunnel from Rosslyn to Georgetown

by AWalkerInTheCity on Apr 25, 2012 1:41 pm • linkreport

He's been pushing to spend thiw money to improve Route 1 for vehicular traffic instead of a metro and is pushing not to build the station...

Wow. Crazy. The NIMBYness is totally out of control in this situation.

It's clear--option B. End of story. Deal with it.

And the whole GW Parkway is so lovely bs is ridiculous. Wasn't that just originally a trail along the river that GW used to ride his horse from his farm to the building of the planned capital city?

Did these same people protest when it was paved over and widened? Do they protest when other improvements have been made?

Temporary disruption (both visual and practical/space wise) are a part of new construction and infrastructure projects. Big deal--get over it.

And for anyone who's ever been in the Potomac Greens development...currently, that Metro rail runs RIGHT NEXT to several of those $800K homes that they all overpaid for back during the bubble. I mean, they are ALREADY disrupted by the trains that pass literally about 20 ft. from some of the bldgs (and the community swimming pool if I'm not mistaken?).

These people need to calm down and allow for development.

by LuvDusty on Apr 25, 2012 2:01 pm • linkreport

Oh and did anyone mention the PG'ers that having a Metro stations literally in their back yard, will most likely INCREASE the value of their properties not decrease? Views of trees and the potomac I think are worth less in the real estate market these days than easy/quick access to commuter rail.

by LuvDusty on Apr 25, 2012 2:03 pm • linkreport

Wish I'd have made the meeting, but I had other obligations last week.

I don't think D is going to fly...not with the price tag involved. It'll be either A or B. As for impacts to GW Parkway, those are unfortunate, but necessary given where the Metro tracks are. It's either route construction traffic along the GW Parkway for a stretch or route them all through Potomac Green, and I suspect the residents would like that even less.

by Froggie on Apr 25, 2012 5:07 pm • linkreport

Luv Dusty,
I don't see why you want B instead of A. I don't think it's clear that B is better than A, at all. I don't see what is wrong with A, and it's the least expensive, and least intrusive option.

by Jason on Apr 25, 2012 5:21 pm • linkreport

@JD: to clarify, Rush+ will still have the same number of trains from Pentagon to Franconia/Springfield; it's just that more will be "Yellow" rather than "Blue." The six additional Orange trains going through the Potomac tunnel (starting with Rush+) will be converted to Silver in the future.

by Payton on Apr 25, 2012 9:48 pm • linkreport

@Alex B.
Options D1 and D2 were rejected for being technically infeasible from an engineering perspective. Something about angles of curvature and incline/decline. They basically went back to the drawing board and said "is there anywhere west of tracks that is technically feasible". They came up with option D3 (which is now simply option D).

Option B is undesirable because it is the furthest from everything else and it would also trash the environmentally sensitive areas between the tracks, GW Parkway, and PG.

Option A is undesirable because it is basically right in PG's backyard.

What's left? Suck it up NIMBYs or no-build.

by movement on Apr 26, 2012 3:56 pm • linkreport


After reading the comments associated with Nick Partee’s article in “Greater Greater Washington”, it became very apparent that there is a wide range of public opinion regarding what factors should be used to select the best “locally-preferred alternative” for the Potomac Yards Metrostation. There also appears to be a very strong contingency of citizens that believe that the “no-build” alternative should be the solution of choice given that each of the three “build” alternatives presented at the Potomac Yard Metrorail Station Environmental Impact Statement(EIS) Public Meeting at the Cora Kelly Recreation Center on April 19, 2012 all appeared based on the public comments I heard at the meeting to have significant shortfalls (e.g. cost, environmental, scenic easement concerns, and my personal favorite, “Not In My Back Yard issues).

In my opinion, the construction of a metrostation at Potomac Yards is nowhere near a done deal, froth with issues, and will most likely end up in the courts facing years of litigation. Meanwhile, the Potomac Yard developers continuing to build at a frantic pace and at some point may have to either stop or alter their development efforts if a decision is not made on how to proceed. And as we all know, when the lawyers get involved, only the lawyers win. Litigation costs everyone involved time and money.

My recommendation. We as a individual members of the Alexandria citizenry have to get actively involved. And as far as I am concerned; I have no real faith in the current Alexandria City Council to do the right thing. So for now, I believe the best way we can participate in this process is to send comments and recommendations to the Potomac Yard Metrorail Station EIS Project at In reading the comments associated with Nick Partee’s article, I found some very interesting ideas and some not so interesting rhetorical bonehead statements (BS). And for what it’s worth, your comments may actually help the EIS process to bring forward a solid and valid “locally-preferred alternative” recommendation or at a minimum document your concerns of what was known or not known when this issue ends up in court. We all need to get involved or pay the price, the choice is yours.

by JamesOnThePotomac on Apr 26, 2012 4:08 pm • linkreport

@David PY
Similar to what I told Alex B., if option C were technically feasible, it would still be on the table. It isn't a matter of money. It is technically infeasible.

by movement on Apr 26, 2012 4:22 pm • linkreport

Isn't there some funding that goes away if the station isn't built by 2016? If that is correct, we'll just have to stick with the process. Right now the process is to allow the EIS to take place to see if any of the three remaining build options must be taken off of the table. We're not really ready for public opinion yet.

I'm still seeing a lot of misinformation such as people pining for options that have been rejected for engineering reasons. I'd like to see the city do a better job of describing the process so that citizens don't spend a lot of time barking up the wrong tree.

by movement on Apr 26, 2012 5:22 pm • linkreport

I'm still seeing a lot of misinformation such as people pining for options that have been rejected for engineering reasons.

Well, that's not really misinformation.

It isn't a matter of money. It is technically infeasible.

"Engineering reasons" is really just a code word for cost. And that's fine, but it is what it is. If they really needed to make one of those options that has been rejected for engineering reasons work, they could - but it would likely require a lot of money and a broader scope.

It's not like the EIS process is infallible.

This isn't to say such options aren't ridiculously cost-ineffective.

by Alex B. on Apr 26, 2012 5:37 pm • linkreport

Let's be reasonable. The eliminated options would require reconfiguring the CSX tracks, Four Mile Run, and/or the DCA station. It isn't just cost. It would be disrupting the entire regional transportation network and local ecology.

by movement on Apr 26, 2012 6:28 pm • linkreport

If I recall correctly, option C required the tracks to go underground under the current Arlington Potomac Yard development, pass under 4MR, then an equally onerous process for coming back to the original tracks. It was definitely technically infeasible. Option D is the only remaining option for west of the CSX tracks.

And about cost, while I'm sure D is more expensive by a good margin, option A might be more expensive than they thought since they have to work almost entirely nighttime hours, making labor much more expensive and disturbance to neighbors more of an issue.

by Nick P on Apr 26, 2012 11:22 pm • linkreport

It should be noted that if the station isn't built, the developers will indeed have to halt pretty much all but the townhouse development, as much of the approved small area plan is contingent on building the metro station. So not only would development have to halt, but the entire small area plan would have to be revised.

As for Potomac Green residents, their entire development was built with the understanding that a Potomac Yard Metro station would be built. For them to oppose the station would fly in the face of existing legal agreements and also be the ultimate in NIMBY mentality.

*IF*, by some chance, the station doesn't get built, the only way the city could salvage something out of the Potomac Yard development would be to upgrade the CCPY transitway to a streetcar at the earliest opportunity.

by Froggie on Apr 28, 2012 8:03 pm • linkreport

[This comment has been deleted for violating the comment policy.]

by JamesOnThePotomac on Apr 29, 2012 12:22 am • linkreport

There are a lot of comments on this article based on the misinterpretation of the real facts of the situation. I strongly recommend going to the following officially approved COA plan.
Its time to look at the real facts.

Was that nice enough Mr Moderator? (:0)

by JamesOnThePotomac on Apr 29, 2012 1:53 pm • linkreport

I wonder if planners are factoring in the effect of Metro's new "Rush Plus" plan which apparently will cut the number of Blue Line trains (e.g., those serving stops in DC west of L'Enfant Plaza) by 50% during rush hours.

Adding a new station and riders, at least some of whom will want to take the traditional route to Foggy Bottom, the Farraguts, etc., seems likely to make conditions even more difficult for commuters on this route.

More generally, I wonder if Alexandria authorities, along with those in Arlington and Fairfax with residents who will be affected by this shift, were consulted or bothered to consider the effects.

"Rush Plus" has always struck me as a great inconvenience for anyone at the Pentagon stop or further south who wants to travel into the western half of DC during normal commuting times. It may well push people into driving rather than waiting twice as long for even more crowded Blue Line trains.

I guess we'll find out soon.

by Willow on May 10, 2012 2:34 pm • linkreport

Willow: Rush Plus won't decrease the number of trains going along there. It's just that more of them will go over the bridge directly from Pentagon to L'Enfant instead of going up to Rosslyn first. A rider at Potomac Yard will have more trains to go to downtown DC at rush hour, but fewer at rush hour to go to Rosslyn.

by David Alpert on May 10, 2012 3:00 pm • linkreport

David Alpert: thanks for your comment. I think we agree on the key point (which I acknowledge was off-topic re the specific location of a new. station). Rush+ will significantly cut Metro service from the Pentagon and stations south and west to western DC, affecting future and current commuters travelling to GW, the State Department, World Bank, etc. As I understand it, the change is to ease congestion at Rosslyn and prepare for the Silver Line--but at the expense of others. I think it's worth considering the impact; perhaps this has been done and I missed it.

by Willow on May 10, 2012 3:39 pm • linkreport

Didn't someone on this site write an article about travel time changes? You're really talking only a difference of a couple minutes if you take a Yellow line train and transfer at L'Enfant.

by MLD on May 10, 2012 3:56 pm • linkreport

I don't support or oppose the station at this time. My comments at this time are the DEIS does not meet the requirements of the NEPA and FTA/NPS need to supplement the DEIS to provide the full disclosure of impacts.

See following comments regariding DEIS.

May 16, 2015

Kurt Flynn
Much Concerned Citizen &
NEPA Practitioner, Retired

Dear Federal Transit Administration and National Park Service,
The POTOMAC YARD METRORAIL STATION Draft Environmental Impact Statement (DEIS) fails to provide the full disclosure of the environmental consequences of the proposed Federal Transit Administration (FTA) and National Park Service (NPS) actions, as required by the National Environmental Policy Act (NEPA) and the Council on Environmental Quality’s (CEQ) NEPA Regulations.
Specific issues, as discussed in detail below include: omission of a proposed action making it is impossible to understand how the purpose and need for the project or how the reasonable range of alternatives were developed; an incorrect no action alternative, making it impossible to compare the impacts of the action alternatives, and failure to identify and describe the impacts of the induced development, making it impossible to understand the and cumulative indirect impacts of the proposed action.
These issues are so fundamental to the NEPA that they cannot be addressed by simply modifying the DEIS to produce a Final EIS. Rather, to provide the public with the required opportunity to review and comment on the full disclosure of impacts and to ensure informed decisions by both FTA and NPS decision-makers, FTA and NPS must issue a supplemental DEIS.

Please email if you would like to discuss my comments.

Kurt Flynn

Draft Environmental Impact Statement
Comments and Questions


On page 1-1, the DEIS states, “The Federal Transit Administration (FTA), as the lead Federal agency, and the City of Alexandria, as the project sponsor and joint lead agency, in cooperation with the Washington Metropolitan Area Transit Authority (WMATA), and the National Park Service (NPS), prepared this Draft Environmental Impact Statement (EIS), under the National Environmental Policy Act (NEPA), for the proposed Potomac Yard Metrorail Station (or “the project”)….. The project consists of construction of a new Metrorail station and ancillary facilities”. (Underline added)

The above statements make it appear that FTA along with a group of other entities is proposing the same thing, to approve construction of the proposed metro station. These statements are the closest the DEIS comes to describing FTA’s proposed action and, the DEIS’s reasonable alternatives and analysis of impacts, is based on FTA’s approval of proposed construction. However, the DEIS indicates that FTA’s proposed action is, to provide partial funding for construction of a metro station. Approving construction and providing funding are two different proposals and the DEIS analysis may differ depending upon which proposal is correct.

1. Please describe FTA’s proposed action.

2. If FTA proposes to distribute funds, identify the applicant that has requested funds, the amount of funds requested, the date funds were requested, specific action(s) that are requested for funding, and the status of the requested funding.

3. Please provide a copy of the application submitted for FTA’s proposed action.

4. If application for FTA action has not been submitted, please describe why FTA determined the DEIS was necessary.

On page 3-128 the DEIS states, “FTA will make a determination of effect for the project after the preferred alternative is selected by the City of Alexandria”. The City cannot select the preferred alternative. In accordance with CEQ NEPA Regulations, determining the NEPA preferred alternative is a Federal agency responsibility.

5. Please indicate if FTA and NPS would determine the preferred alternative.

On page 3-178, the DEIS indicates the City would need to comply with the Coastal Zone Management Act (CZMA).

6. Please indicate if FTA would be responsible for CZMA compliance and, if so, provide the status of FTA’s compliance.
The description of potential NPS proposed actions is scattered in the DEIS, making it difficult to ensure a clear understanding of NPS’s proposed actions for the project.
7. Please describe each NPS proposed action for this project, including the status of each action.
Each action alternative, with the exception of B-CSX Design, would have temporary and permanent impacts to jurisdictional wetlands, requiring application to the US Army Corps of Engineers (Corps) for a 404 Clean Water Act permit.
8. Please provide the status of Corp actions for this project and provide notification of public hearings or updates for future CORPs actions for this project.

9. Please describe the Corps’ NEPA compliance process for the proposed approval of the 404 permit.

10. Please confirm that Federal approval would not be required for the relocation of the CSX track. If Federal approval would be required, describe the Federal action and describe the planned NEPA for the action.

11. Please describe the Washington Metropolitan Area Transit Authority (WMTA) and describe its role in the proposed project.

12. Please confirm no other Federal agency besides FTA, NPS, and the Corps action will be required to approve this project.
There are at least three potential Federal agencies with project approval authority (FTA, NPS, and the Corps) and there are five DEIS alternatives. It is not clear how the Federal approval process will be conducted. Each agency has its own mission and, it is possible that the same alternative may not be selected by all Federal agencies. NPS has already objected to Alternative B and, the B-CSX alternative was developed in response to NPS objections. The City appears to prefer Alternative B and FTA will likely select Alternative B. The Corps’ 404 regulations do not allow approval of a non-water dependent action with wetland impacts, when an alternative with no wetland impacts exists. In this case, that would be B-CSX Design Alternative. In accordance with the regulations, the Corps would have no choice but to select the least environmentally damaging practicable alternative.
13. Please describe the project’s planned review and approval process for the various Federal agencies.
On page 1-3 the DEIS states, “The purpose of the project is to improve local and regional transit accessibility to and from the Potomac Yard area adjacent to the U.S. Route 1 corridor for current and future residents, employees, and businesses”. This is a relatively focused purpose that appears to be more of a City purpose than an FTA or NPS purpose.
14. Please indicate if FTA and NPS concur with the DEIS project purpose. If not, provide the FTA and NPS purpose.
Section 2.2 of the DEIS describes the screening process for the development of the reasonable alternatives considered in the DEIS. The process appears to have been conducted by the City and there is no indication a screening process was conducted by FTA or NPS.

15. Please describe if, and if so how, the FTA and NPS participated in the screening process to develop the reasonable alternatives.

16. Page 1-1 of the DEIS mentions the Final Environmental Impact Statement, Metropolitan Washington Regional Rapid Rail Transit System. Please provide a brief description of the proposed action and describe the lead and cooperating Federal agencies for the FEIS.

One of the biggest problems with existing metro stations is the lack of parking or insufficient parking. Therefore it is surprising that additional parking is not included in the action alternatives

17. Please describe why additional parking is not included as part of each action alternative.

According to the DEIS (Chapter 5), FTA provided the City with a $1 million grants to hire a private contractor to prepare the EIS and according to a subsequent email from FTA, WMATA retained the consultant to prepare the EIS. It is odd that a Federal agency would provide its applicant (at this time there is no documentation the City has applied for FTA action and it is assumed the City is an applicant) with funding to prepare an EIS that the FTA, not the City, is responsible for. It seems like it would have been easier and greater oversight would have been possible if FTA issued used the money to directly retain the contractor.

18. Please describe why FTA did not directly retain the EIS contractor.

Third-party agreements, where the Federal agency and the applicant arrange to hire a private contractor to conduct the NEPA, are not uncommon. There is no concern as long as FTA and NPS independently reviewed, analyzed, and judged that the EIS met the NEPA requirements. CEQ has issued direction regarding third-party EISs that must be documented.

19. Please provide documentation regarding the use of the NEPA contractor and compliance with 40 CFR 1506 and CEQ’s 40 Questions (responses to question Nos. 16 and 17).

On page 2-1, the DEIS states, “Throughout the NEPA process, the City of Alexandria has consulted with the Federal Transit Administration (FTA) and the National Park Service (NPS), as well as other relevant Federal and state agencies, in an effort to ensure project compliance”.

Just as the City is not responsible for selecting the preferred alternative, the City is not responsible for ensuring NEPA compliance. The City is an applicant for Federal action. As DEIS co-lead, the City plays a large role in assisting FTA and NPS NEPA compliance however, FTA and NPS are the only party’s that are responsible for ensuring NEPA compliance.

If the City has, or will request funds, the City has a vested financial interest in securing FTA funding. FTA has the responsibility to consider the City’s request and in doing so, to ensure NEPA compliance. This is the line of responsibility that must be clear in the DEIS. And when an applicant is closely involved with the NEPA compliance, there is an additional need beyond the federally-prepared NEPA document, to show the Federal agency is directing the preparation of the DEIS. The DEIS’s failure to describe the proposed Federal action, allowing the City to determine the preferred alternative, and the City’s coordination to ensure Federal agency NEPA compliance, do not give the impression that NPS and FTA were directly involved with the DEIS preparation or that an independent review and analysis was conducted by FTA and NPS.

There is a concern the DEIS was unduly influenced to include Alternative B as a reasonable alternative. Specifically, it is not hard to understand why the City would want to include Alternative B due to its increased tax base as compared to the other alternatives. However, it appears Alternative B should have been eliminated from consideration and it is not clear why FTA and NPS included it as a reasonable alternative.

Alternative B would impact the George Washington Memorial Parkway and the Greens Scenic Area. NPS, as the manager of both areas, has repeatedly and strongly explained to the City and FTA that the project would not be allowed to impact these resources (Appendix H, letter dated May 1, 2012). Five alternatives were eliminated from further consideration for less reason than NPS objections to Alternative B. As described on page 2-6, these five alternatives were eliminated because they were not consistent with some development or land use plan. It appears inconsistent to eliminate these alternatives and keep Alternative B. NPS objections should have been given greater weight than inconsistency with general plans.

FTA and NPS had a responsibility under NEPA’s full disclosure and transparency requirements to describe NPS objections in the DEIS, not just stick the objections found in the outskirts of an appendix. Even if NPS were not a cooperating agency, at a minimum, in order to satisfy, the DEIS should have discussed the NPS objections. It is extraordinary to include a reasonable alternative that has been denied by the Federal land manager and denied by a cooperating agency, without any notice or discussion of the objections.

20. Please describe why the FTA and NPS included Alternative B as a reasonable alternative, despite NPS objections.

21. Please describe why the DEIS did not discuss NPS’s objections.

22. Please describe why NPS’s objections to Alternative B were only included in an appendix.

23. Please describe why the DEIS did not include mitigation for the impacts to these areas and provide the required mitigation.

24. Please provide any updates to the NPS objections that have occurred since the DEIS was issued in April 2015, including FTA’s efforts to resolve the objections.

25. Please provide all correspondence between NPS, FTA, and the City regarding the use of Alternative B as a reasonable alternative.

26. Please describe NPS’s planned NEPA compliance for the proposed project, including whether NPS plans to adopt the FTA EIS.

27. Please provide notification of public hearings or updates regarding future NPS actions.

CEQ requires an EIS to describe the indirect impacts which include, “… growth inducing effects and other effects related to induced changes in the pattern of land use, population density or growth rate”. (40 CFR 1508.8) Indirect impacts are called secondary impacts by the DEIS and are described as “…the project’s potential to induce land development and travel demand”. (Page 3-194) The DEIS is required to describe the indirect impacts of the alternatives, which would include the impacts from development induced by the alternatives and the DEIS is required to describe the cumulative impacts of the alternatives, which would consist of the incremental impact of the induced development in addition to the impact of the overall development in the area. The DEIS fails to analyze these direct and cumulative impacts.

The DEIS discusses how the population in “…Alexandria is expected to grow by 35 percent over the next 30 years, while the population of the Northern Virginia area as a whole is expected to grow by 41 percent [and] and the Potomac Yard area (City of Alexandria and Arlington County sections) is anticipated to see a 109 percent increase in population and a 138 percent increase in employment by the year 2040. The population and employment growth within the analysis area are driven primarily by the redevelopment of Potomac Yard”. (Page 3-38) The DEIS states, “The construction of a Metrorail station in Build Alternatives A, D, and B-CSX Design Option locations would each allow a total of 9.25 million square feet of development within Potomac Yard. Build [and] Alternative B would allow a total of 13.075 million square feet of development in Potomac Yard. (Page 3-196)

The development is discussed in general terms and although it is clear development is included, there needs to be a description of development that would be induced by the alternatives. The induced development needs to be described in order to understand the indirect impacts.

28. For each action alternative, please describe the development that would be induced and describe how FTA reached this determination.
Development is described in terms of ‘millions of square feet’ “including office, retail, residential, and hotels” (page 1-3). However, the DEIS does not describe the Area of Potential Impact for the development; how much land would be impacted by development, the resources that would be impacted, or the impacts to the resources.
29. For each action alternative, please describe the environment that would be affected by the induced development, including the size of the area affected and whether it would be located within an already disturbed area.

As shown by Table 3-1, secondary impacts for all the alternatives is the same, consisting of only “Additional traffic and visual effects from new development and the cumulative impacts are the same for the action alternatives consisting of “Cumulative traffic, visual, and floodplain effects from present and future development”.

It is difficult to understand how indirect impacts of such a substantial amount of development would only include traffic and visual resources. Table 3-1 includes a list of resources that were analyzed for the station impacts and it appears likely that at least some of these resources would also be impacted by the development. As examples, “Neighborhoods, Utilities, Noise & Vibration, Air Quality, and Increased Impervious Surface” and other resources such as Infrastructure would also likely be impacted by induced development.

30. For each action alternative, please describe the resources that would be affected by the induced development, including the construction of the development, and describe the impacts to the resources.

In regard to the direct impacts from traffic the DEIS states, “The three Build Alternatives and B-CSX Design Option would have no effect on overall intersection LOS in the study area when compared with the No Build condition”. (Page 3-17) The DEIS also states, “The three Build Alternatives and B-CSX Design Option would have no adverse effect on any transportation resource, so no mitigation is proposed.” (Page 3-19) The DEIS indicates the alternative would have both indirect and cumulative impacts on traffic. However, the analysis of both types of impacts completely inadequate. On page 3-11, the DEIS states, “traffic that may be generated by potential induced development occurring as a result of a new Metrorail station is discussed in Section 3.23 Secondary and Cumulative Effects”. This section describes the secondary traffic impacts, as in vague terms as a minor increase in “peak-period trips” (page 3-196) and the cumulative impacts on traffic “…would be improved mobility and accessibility to accommodate the City’s projected growth”.

In summary, the DEIS concludes that that the proposed action would not result in adverse direct or indirect impacts on traffic and there would be a beneficial cumulative impact on traffic. This analysis appears to be completely off base.

In the last 30 years the quality of life in the Northern VA and Alexandria area has suffered dramatically due to the rampant and uncontrolled development and the resulting increase in traffic. This is the ‘affected traffic environment’ that the DEIS needs to describe.

The DEIS describes how development is projected to increase in the near future and the DEIS describes how this proposed action will contribute to the development, further decreasing the quality of life in the area. The increase in traffic may be the most significant adverse impact of the proposed action on the local population and yet, the DEIS describes the net impact as beneficial? This assessment would be more believable if the proposed action was to construct a metro station that would not result in any new development to the area. However, the DEIS is clear that development is an integral part of the proposed action and therefore the impacts from development must be analyzed and described in the DEIS.

The traffic impacts on the quality of life are just the impacts that Congress and the President intended to be addressed when the NEPA became law, “…recognizing the profound impact of man’s activity on the interrelations of all components of the natural environment, particularly the profound influences of population growth, high-density urbanization,…and recognizing further the critical importance of restoring and maintaining environmental quality to the overall welfare and development of man, declares that it is the continuing policy of the Federal Government, in cooperation with State and local governments, and other concerned public and private organizations, to use all practicable means and measures, including financial and technical assistance, in a manner calculated to foster and promote the general welfare, to create and maintain conditions under which man and nature can exist in productive harmony, and fulfill the social, economic, and other requirements of present and future generations of Americans…. fulfill the responsibilities of each generation as trustee of the environment for succeeding generations; assure for all Americans safe, healthful, productive, and esthetically and culturally pleasing surroundings; attain the widest range of beneficial uses of the environment without degradation, risk to health or safety, or other undesirable and unintended consequences; achieve a balance between population and resource use which will permit high standards of living and a wide sharing of life’s amenities”. (National Environmental Policy Act of 1969)

FTA and NPS have a responsibility under the NEPA to describe the affected “traffic” environment and to describe the direct, indirect, and cumulative impacts of the project on traffic.

31. Please describe the affected environment for traffic and provide a meaningful description of the direct, indirect, and cumulative impacts of the project on traffic.


The DEIS states the no action alternative (“no build alternative”) would include the same amount of development as the 3 of the 4 action alternatives. It does not appear correct that development would be the same

32. Please confirm the amount of development that would occur under the no action alternative.

The DEIS does not include development as part of the description of the no action alternative in Chapter 2. On page 2-11, the no action alternative is described as, “…the existing transportation network, plus all of the committed projects within the study area”. Table No. 2-1 indicates the no action alternative would consist of transit, roadway, and non-motorized infrastructure improvements, railroad improvements, and bus service.

The DEIS notes that several of the projects described in the no action alternative have been completed or would occur in the action alternatives (Page 3-197). Actions that have been completed or actions that will occur under the action alternatives should not be included as part of the no action. As required by CEQ guidance, the no action alternative must describe the actions that would occur if FTA took no action, not regardless of FTA action. (40 Questions, Response to No. 3) Actions that have already occurred or actions that would occur in the action alternatives should not be included in the no action alternative.

On page 2-11 the DEIS states, “The Draft EIS does not detail the impacts of projects included in the No Build Alternative. However, impacts of the No Build Alternative are considered collectively as part of the secondary and cumulative effects analysis found in Section 3.23”. It is not clear what is meant by ‘collective impact’. On page 3-192 the DEIS states, “Under the No Build Alternative, there would be no safety and security related impacts from the Potomac Yard Metrorail Station project. However, there could be impacts from the other improvements assumed under this alternative. Identification of these impacts would be the responsibility of the agencies and jurisdictions responsible for implementing the improvements”. (Underline added)

CEQ NEPA Regulations are clear that an EIS is required to analyze the environmental impacts of the no action alternative. (40 CFR 1502.14). Not discussing or stating these impacts are the responsibility of other agencies and jurisdictions is in violation of the Regulations. The impacts of the no action alternative must be afforded the same level of analysis as the impacts of the action alternatives in order to provide a proper baseline. The primary purpose of the no action alternative is to provide the baseline for comparison of the impacts of the action alternatives. The proper description of the no action alternative and its impacts is vital to an EIS’s ability to provide the public and agency decision-maker with the required comparison of impacts. Failure to describe the impacts of the no action alternative is a violation of the CEQ Regulations.

33. Please ensure the correct actions are included in description of the no action alternative, including the development.

34. Please describe the environment that would be affected by the no action alternative including the size of the area affected and whether it would be located within an already disturbed area.

35. Please ensure that the direct and indirect impacts of the no action alternative are described and that these impacts are compared to the impacts of the action alternatives, as required by the CEQ NEPA Regulations.

The DEIS calls defines the No Build Alternative as, “The future condition of the study area in the absence of the proposed project”. Without a description of the proposed FTA action or without any explanation regarding why the station would not be constructed, it is not possible to judge the no action alternative. However, the DEIS indicates the FTA proposed action is to provide limited partial funding for the project (“Because the project has the potential to utilize Federal funds, FTA is the lead Federal agency for the Project.” (Page 1-1)). If the proposed action consists of FTA funding, according to Chapter 5 of the DEIS, FTA funding is not a funding source the City is depending on for the station. Therefore, it appears the City would construct the station if FTA took no action to fund the station.

The DEIS’s first sentence lumps FTA in with a group, including the City, that jointly ‘propose to construct a station’. This gives the false impression that all parties have the same proposed action. The failure to distinguish FTA’s proposed action from the City’s ‘proposed action’ at the start of the DEIS effects the entire DEIS. However, the concern may be most relevant in the description of the no action alternative. The no action alternative is the antithesis of the proposed action. If the FTA (not the City’s) proposed action is to approve construction, then the DEIS’s exiting no action alternative is proper. However, if the proposed action is for FTA to provide partial funds and the City would construct the station if the funds were not approved, then the DEIS’s no action alternative and its impacts is not proper as is much of the DEIS.

36. Please describe the basis used by FTA to develop the DEIS’S no action alternative.

37. If no action alternative is based on statements made by the City, please provide copies of documentation from the City that it would not construct the station under no action alternative.

38. Please ensure a proper review of the DEIS no action alternative. If FTA determines the City would construct the station if FTA took no action, please describe the correct no action alternative and its impacts.

If the station would be constructed in the absence of FTA’s proposed action, then the no action alternative would meet the project purpose, “… to improve local and regional transit accessibility to and from the Potomac Yard area adjacent to the U.S. Route 1 corridor for current and future residents, employees, and businesses”.

39. If the purpose of the project would be met without FTA funding, please describe why FTA would proposed the action to fund the station.

40. If the purpose of the project would be met without FTA funding and Federal taxpayers’ assistance would not be required to meet the purpose, please describe why the FTA decision-maker would consider approving the proposed action.

The DEIS does a good job analyzing the impacts of the various station alternatives. However, there are too many unknowns in the DEIS regarding the proposed action, the action alternatives, the no action alternative, and the impacts from induced development. And, in taking considerable personal time to read the many words in the DEIS and gather my thoughts and comments, I am reminded of Chris Cooley’s recent review, where RG3’s performance was so poor Cooley could not assess the Redskins’ offense. Or the Ancient Mariner’s lament,

Water, water, everywhere,
And all the boards did shrink;
Water, water, everywhere,
Nor any drop to drink.

The unknowns in the DEIS prevent FTA and NPS from meeting the requirement to provide the public with a full disclosure of the impacts of the proposed actions and a supplemental DEIS is required to ensure compliance with NEPA and CEQ NEPA Regulations.

by kurt flynn on May 17, 2015 11:09 am • linkreport

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