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City to Send Comments on Proposed FBI Development in Greenbelt

Last month, Council decided to form a subcommittee to discuss the Draft Environmental Impact Statement (DEIS) prepared by GSA and potential impacts that need further analysis. The draft letter states continued support by the City for the Greenbelt alternative as the location for the new FBI Headquarters. Below please find our specific comments associated with the resource areas reviewed in the DEIS.

Water Resources

  • There is uncertainty in the DEIS about the classification and delineation of floodplains and the Prince George’s County process for floodplain impacts. FEMA flood insurance rate maps need to be reconciled with Prince George’s County and the EIS updated to include accurate floodplain delineations and impacts, if necessary.
  • The proposed location of the perimeter fence appears to involve unacceptable changes within the conservation area and should be relocated to avoid impacts to the wooded floodplain. The fence should be constructed as close to the building as necessary and within the existing cleared area of the WMATA parking lot and perimeter road. It is requested that more detail regarding the perimeter fence and its impact be provided.
  • The EIS should include a description and terms of the existing and proposed Maryland Environmental Trust (MET) easements to expand the FBI open space and security buffers. The impact of these easements on proposed public access trail connections should be described and avoided to the extent practicable and the location of all proposed fencing within these easements should be illustrated.
  • There are areas along the Indian Creek and its tributaries that would benefit from stream and floodplain restoration. The EIS should identify one or more mitigation projects for implementation.

Biological Resources

  • The Indian Creek is rich in aquatic and terrestrial species and given the existing and proposed conservation easements on state-owned property, including the security easement to the Federal Government, it is important that these species are well documented and protected and that a sustainable habitat for them be created and celebrated. The list of these species should be updated and confirmed with the most recent information available.

Regional Land Use, Planning Studies and Zoning

  • The extensive development assumed in the Greenbelt No-Action alternative is based on a conceptual plan approved in 2001 and does not represent final approved entitlements. It is highly unlikely that this level of development would occur today or obtain the support of the City of College Park. Furthermore, it contrasts sharply with the Landover No-Action alternative where the site is assumed to remain vacant even though it is zoned for Mixed-Use-Transportation (M-X-T) with up to an 8.0 Floor-to-Area-Ratio (FAR). Neither of these are realistic scenarios or fair comparisons.
  • There is a policy from the Federal Workplace Element of the Comprehensive Plan for the National Capital Region (NCR) that is relevant to the project which states, “Federal workplaces are to be compatible with the character of the surrounding properties and community and, where feasible, advance local planning objectives such as neighborhood revitalization.” An assessment of this policy as it relates to the adjoining Hollywood neighborhood is requested.
  • There is a policy from the Federal Transportation Element of the Comprehensive Plan for the NCR that indicates that parking required by Federal employees unable to use other travel modes, should be located in parking structures, preferably below ground. Given the site constraints at Greenbelt, it is requested that this design option be explored.

Visual Resources

  • The design concept for the FBI at Greenbelt assumes a 17-story building. This height exceeds the 12-story height limit supported by the City in the Greenbelt Metro Area and MD 193 Corridor Sector Plan. The GSA is urged to consider final design alternatives that lower the height of the building and reduce the anticipated reflected shadow, reflected noise and reflected light impacts from such a tall building. Construction techniques that attenuate these impacts should also be utilized.
  • The shadow study excludes WMATA replacement parking and other private development buildings that are proposed just outside the project site that will accompany construction of the project. These impacts should be demonstrated.

Socioeconomics

  • The assessment of population and housing impacts is inadequate. There are assumptions made in the Transportation Impact Assessment about the relocation of FBI employees to Greenbelt and surrounding areas and these same assumptions should be used as the basis of analysis in this section in order to provide needed information about population growth and housing demand. The EIS should be revised to include this information and to reflect consistent data and assumptions among resource areas to the extent feasible.
  • The DEIS states that there is insufficient information available to determine the impacts on recreation, community facilities and schools. This is not an acceptable conclusion. The DEIS uses development program assumptions in all of the alternatives that are studied and these assumptions should also serve as the basis for making projections of impact to public facilities. The EIS should include more information and analysis in this area.

Public Health and Safety/Hazardous Materials

  • The DEIS does not adequately evaluate impacts of construction-related noise on sensitive noise receptors in north College Park including the Al Huda School and day care. Children have been identified as particularly vulnerable to noise exposure. The evidence of noise pollution on children’s health has shown that reading attention, problem solving, and memory are strongly affected by noise. Please evaluate noise impacts from construction activities in north College Park including but not limited to: pile driving, heavy equipment operation, and vehicle motion alarms. The final EIS should include noise attenuation and mitigation measures such as equipment mufflers, erection barriers, and equipment maintenance procedures to reduce construction noise impacts. The EIS should also consider alternatives to single tone back-up alarms.
  • The DEIS does not analyze current noise levels in north College Park. The completed project will result in new highway and roadway improvements in addition to multi-story buildings that may cause changes to sound patterns in the environment. Existing noise from the Capital Beltway, Metro and CSX railroad should be analyzed in conjunction with the noise that will be introduced to the current environment. Currently, railway noise is freely dissipated to the east of the tracks, but after multi-story buildings are constructed there may be substantial reflection of railway noise as well as new roadway noise impacts to the west and into homes and recreational areas of north College Park. The final EIS should evaluate existing noise levels and future noise from the project after construction is completed. To protect north College Park from increased noise, noise attenuation and mitigation measures to maintain noise at existing levels should be evaluated including physical barriers and architectural treatments.
  • There will be direct, short- and long- term environmental consequences related to air quality at Greenbelt. Due to the proximity of sensitive populations (children and elderly) in the Hollywood community, the amount of nitrogen dioxide is a concern. It is requested that more specific data and information be provided about this impact.

Transportation

  • The Transportation Impact Assessment (TIA) study area for Greenbelt is defined too narrowly and excludes relevant roadways and intersections in College Park. Figure 5-18 and Figure 3-2 in Appendix C show a more inclusive project area that includes US Route 1(Baltimore Avenue), MD 193, and Rhode Island Avenue. These roads are an important part of the local transportation network and it is reasonable to expect that commuters from the north and west will use these roadways to access the project and related development. It is requested that the TIA study area be expanded to encompass all signalized intersections in this wider area.
  • The rationale for using a different no-build definition for the traffic analysis for the Greenbelt site, and for excluding the exchange of the JEH building from the analysis, is not clearly explained. The no-build definition includes the Renard Development proposal for mixed-use development that would be built if the FBI HQ located in Greenbelt rather than what would be built if GSA did not choose Greenbelt (the no-action definition). A more accurate traffic impact study for the build scenario would include the project plus the Renard Development proposal and it is requested that the EIS provide this analysis.
  • The assumption for Metro ridership (47.33 % of all modes) exceeds the 33% reported by federal employees region-wide and is particularly high for an end-ofthe-line station. If this is not realistic, other trip distribution assumptions are affected and vehicular trips, in particular, may be undercounted. It is requested that the trip distribution assumptions and methodology in the Greenbelt Site Transportation Agreement be reassessed and appropriate justifications provided.
  • Significant new market rate housing is being built on the Route 1 corridor west of the site which should be attractive to the 50% of employees assumed to be interested in residing close to the project. This would indicate a higher number of bicycle and vehicular trips generated west of the project site. Please revise the traffic study accordingly.
  • With 78% of proposed vehicular traffic utilizing the Capital Beltway, the failing interstate facilities between US Route 1 and Baltimore Washington Parkway should be mitigated as part of the project and not delegated to SHA to address in the future as the DEIS states. Please address the full impact of failing to mitigate this problem.
  • Parking needs appear to be severely undercounted which may also explain the seemingly inflated Metro ridership number. It is important to provide parking that is sufficient to meet demand in order to avoid spillover impacts in north College Park. Results of the ongoing internal employee parking analysis should be shared with the public and used to update requirements in the Final EIS.
  • While there is no Kiss and Ride facility on the west side of the Metro station, the existing pedestrian access at the east end of Lackawanna Street attracts automobile pick-ups and drop-offs as well as pedestrians and bicyclers. There is expected to be an increase in traffic of all types on local streets in the Hollywood neighborhood related to the project. An evaluation of this impact is requested.
  • The importance of developing a Transportation Management Plan (TMP) cannot be overstated. It is requested that the local jurisdictions of College Park and Greenbelt be included in the preparation of this document.
  • Bicycle impacts are assessed using the same .5 mile radius standard as a pedestrian trip but their coverage area is actually much larger. For your information, College Park will launch a bike share system in spring 2016 that will include a station on the west side of the Greenbelt Metro Station. It is requested that a 1- to 2-mile radius be used to analyze bicycle impacts
  • There is no mention of the Purple Line and the effect it will have on public transit and vehicular traffic. Significant data is available from MDOT and should be made a part of the Transportation Impact Assessment.
  • Ridership data for Prince George’s County The Bus should be obtained and included in the Final EIS.

Infrastructure and Utilities

  • Extending the natural gas line from either Lackawanna Street or across I-495 should be avoided. It is our understanding that the primary gas main in the area is along Greenbelt Road and has sufficient capacity to address the needs of the project. The Final EIS should include updated information on this topic.
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