January 14, 2017

Ms. Alexis Gray, NEPA Compliance Specialist
Office of Planning and Design Quality
U.S. General Services Administration, National Capital Region
301 7th Street, SW / Suite 40044
Washington, DC 20407

Subject: Draft Environmental Assessment, National Foreign Affairs Training Center Master Plan Update

Dear Ms. Gray:

I’m submitting these comments on behalf of the Alcova Heights Citizens Association. The National Foreign Affairs Training Center sits within our neighborhood boundaries. We have concerns and comments re: three topics addressed by the Environmental Assessment:

Pedestrian Trail:
We strongly disagree with the contention of the EA that the closure of the pedestrian trail will have no impact. This path serves as a critical – if incomplete – east-west connector around the enormous parcel that is the NFATC and the adjoining National Guard facility. There are no other east-west paths anywhere between Rte 50 and 8th St South – an 8 block expanse. The closure of the trail will create an even larger barrier than exists now. Closure of the trail will require our residents to walk considerably longer distances to reach destinations such as local schools and bus stops on George Mason Drive. It will also eliminate the safe access that the trail and the tunnel underneath George Mason Drive provide between the Alcova Heights and Barcroft neighborhoods.

Accordingly, we request that the proposed perimeter be pulled back to allow the existing pedestrian path between George Mason and S. Quincy to remain so that it can continue to provide a critical east-west link for pedestrians.

Traffic:
We take strong exception to the results of the traffic analysis in the EA. To begin with, the EA states that the traffic analysis conducted showed that the intersections that were studied all function at Level of Service C or better during the AM peak hour. We don’t understand how this could be possibly be true. Northbound George Mason Drive is regularly backed up in the morning from Rt. 50 as far as South 8th Street – a distance of 8 blocks! As a result, many motorists cut through the Barcroft neighborhood to avoid the backups. This would seem to indicate that the Rt. 50 intersection is actually failing now.

Your EA then goes on to essentially state that the Proposed Action will have limited impact on the traffic – even though you’re proposing a 20% increase in the on-campus population which the EA notes will increase traffic. There’s mention in the EA of mitigating this with alternative modes of transportation, but there’s nothing to suggest that this will be effective. The Army made similar promises when they expanded their facility, but traffic problems have definitely increased since the facility was occupied. The largest single problem is that mass transit options to the site are very limited and are not a viable option to the vast majority of those travelling to the NFATC.

The EA does acknowledge that the projected traffic volumes from the proposed development would warrant the installation of a traffic signal and a southbound left turn lane at the intersection of George Mason Drive and South 6th Street. We understand that such a turn lane would likely result in the removal of on-street parking in front of 6 or so private residences. This is completely unacceptable. We also object to GSA’s contention that Arlington County should pay for the lane which is solely for the benefit of the NFATC.

Parking:
We are very concerned that no additional parking is planned under the Proposed Action. In fact 24 spaces would be eliminated. As a result, the ratio of parking to personnel would increase from 1:2 to 1:3 with an ultimate goal of 1:4. However, there’s no good explanation of how this will be accomplished. The NFATC is not within walking distance of a Metro and it’s not well served with adequate bus service. The promotion of bicycling and walking are mentioned as part of the solution, but it’s extremely difficult to understand either of these options is likely to result in any meaningful number of trips.

Absent any good alternatives, we believe that more parking will spill over into the surrounding neighborhoods. We saw this happen when the Army National Guard facility expanded. Personnel now park every work day along George Mason Drive down to South 8th Street and beyond. The parking problems extend into the Alcova Heights neighborhood with personnel parking in the area of the intersection of South Quincy and South 6th Streets.

Perimeter Security:
There does not seem to be a description of what “New Perimeter Fencing” involves. There is an existing substantial 7 foot chain-link fence between the NFATC and the Alcova Heights residential properties on South 6th Street. A new perimeter fence along this area would not seem to be a cost-effective or necessary undertaking. We request that more information be provided.

The adjacent residents are subject now to light and noise pollution from the NFATC with more development proposed. Consequently, maintaining a healthy forested buffer is highly desired. The draft EA shows some amount of tree cover, however the tree buffer has not been well-maintained. There are large dead trees that should be removed/replaced and trees covered with invasive vines that appear to be killing the trees. AHCA requests that the existing tree buffer be maintained and better managed.

Lastly, we continue to be disappointed by the insufficient effort on the part of the National Foreign Affairs Training Center to engage and work with the community on the operation, not to mention the redevelopment, of the facility. For example, we have unsuccessfully tried to get the State Department to better maintain the area around the perimeter that borders our homes. Construction has occurred on multiple occasions that violated Arlington noise ordinances. The NFATC can and should be a better neighbor.

Thank you for the opportunity to comment on the EA. We look forward to a response and to further dialogue. If you have any questions, please feel free to reach out to me. I can be reached at landerallin@gmail.com or 703-350-8648.

Sincerely,

Lander Allin
President, Alcova Heights Citizens Association

cc: Don Beyer, U.S. Representative
Jay Fisette, Chair, Arlington County Board
Chris Kupczyk, President, Barcroft School and Civic League