To the editor:
In the April 27 Alexandria Times article “City readies for Metro ribbon-cutting,” Mayor Justin Wilson is quoted as stating that federal agencies determined the city’s preferred site was “… the best site for environmental reasons.” I suppose, at this point, it does not really matter whether this is an accurate statement. Either way, the once beautiful wetland that thrived at the site will not come back and the ugly scar that now exists on our country’s memorial to its first president will not heal.
But just for the record, I can confidently state that, based on my review as a professional wildlife biologist of what I believe were all the key federal environmental documents, starting with the April 2015 draft Environmental Impact Statement and ending with the Corps of Engineers November 2019 permit, none of the federal agencies made the above statement in writing.
The mayor gives the impression that the agencies came together in a kumbaya moment to approve the city’s site. My recollection is different. I recall that the National Park Service strongly opposed the city’s site so intensely that Acting Park Superintendent Jon G. James felt compelled to formalize the objections in an extraordinary letter to the Federal Transit Administration on May 1, 2012. The letter reads in part:
“This letter is to inform the co-lead agencies of this EIS, the Federal Transportation Administration and the City of Alexandria, we do not believe access through property under our jurisdiction is feasible for the purposes of constructing Alternative B,” James wrote.
The letter goes on to explain the project would violate the mission of the NPS.
“[Our mission is to] conserve the scenery and the natural and historic objects and the wild life therein and to provide for the enjoyment of the same in such manner and by such means as will leave them unimpaired for the enjoyment of future generations.”
“We have serious concerns the amount of disturbance to park re- sources proposed by this construction access through a known wetland could constitute significant damage to these resources. (sic) … We further believe issuing a permit for construction access in this area would be a violation of an easement held by the United States …,” James wrote.
James’ letter made it clear that his objections pertained to Alternative B.
“Please note these thoughts apply to the construction access south of Four Mile Run and tied to Alternative B,” James said in the letter.
Cooperating agencies, like the NPS, typically do not need to send letters to get their concerns addressed. Such concerns are usually resolved early in face-to-face meetings. And NPS’ concerns were so intense that such concerns would typically have resulted in dismissal of the city’s site.
The fact that NPS felt it was necessary to send the letter is absolutely telling. It is a clear sign regarding the level of power and control the city was allowed to exert in the EIS. The city’s perseverance ultimately paid off. NPS agreed to the site, but only after the city provided $12 million for off-site mitigation and only after the decision making was elevated from Park Superintendent to the higher-ranking, and perhaps more politically astute, Regional Director level.
The city’s ability to get NPS to withdraw opposition was impres- sive. However, I believe the city and FTA should be reprimanded for failing to disclose the original NPS objections in the draft EIS. Transparency is the most fundamental requirement of any EIS and both agencies had a public duty to disclose the NPS concerns.
FTA and the Corps should have been reprimanded for blatantly failing to comply with the Safe, Accountable, Flexible, and Efficient Transportation Equity Act: A Legacy for Users, or SAFETEA. SAFETEA required the Corps’ permit process be conducted currently with the EIS. However, after the completion, FTA requested the Corps’ comments on the draft EIS. In response, the stated, “[A]voidance and minimization of impacts to aquatic resources will be an important consideration in our evaluation of the alternatives.”
I do not know why the Corps were absent from the development of the EIS. However, I strongly believe the city’s site would have been eliminated if the Corps’ permit had been conducted concurrently with the EIS. I guess the city just got ‘lucky!’
-Kurt Flynn, Midway, Georgia (formerly of Alexandria)