[BSW] Letter regarding planned Metro station at Potomac Yards in Alexandria

[Kathy Bilton]

Via Rod Simmons:

FYI - great effort by Jeremy.  Yet another excellent case study as to the 
City of Alexandria's and Arlington County's zero regard for meaningful 
wetlands, waterways, and forest protection and requirements.  This is just 
as applicable to D.C. and Maryland suburbs as well (I'll let others 
comment on similarities with Loudoun, Fairfax, and Prince Williams 
counties, Virginia).  Feel free to post the letter at the link below on 
Facebook pages if you think it useful.  This is a corollary to the two 
very well attended programs earlier this year of the Virginia Native Plant 
Society and the Maryland Native Plant Society.

At some point, as we all very well realize, this nonsense has to change 
before there's nothing left of the once-thriving natural world in northern 
Virginia and vicinity.  Currently, the completely out-of-touch and 
clueless are making all the wrong decisions.

Date: Tue, Sep 11, 2018 at 4:10 PM
Subject: Planned Metro Station in Potomac Yards, Alexandria, Virginia- 
PN_PYMS Section 404 Application;
To: Patrick.V.Kinsman at usace.army.mil <Patrick.V.Kinsman at usace.army.mil>, 
theresita.m.crockett-augustine at usace.army.mil
<theresita.m.crockett-augustine at usace.army.mil>
Cc: gazette at connectionnewspapers.com <gazette at connectionnewspapers.com>, 
sullivanp at washpost.com <sullivanp at washpost.com>, ddunbar at alextimes.com
<ddunbar at alextimes.com>,

Dear Colonel Kinsman: Attached is a letter from approximately 50 concerned 
citizens of Alexandria Virginia who oppose the selection of Alternative 
Site B on the grounds that SITE B will destroy the largest acreage of 
federally protected tidal wetlands, and there exist alternative sites 
which will not destroy the same amount of valuable and diminishing 
wetlands.  Given we are on the eve of another hurricane (Florence) 
barreling its way north, we should be more mindful than ever of the 
protective and restorative value of these wetlands.  Please do not approve 
Site B.


Respectfully,
Concerned Citizens of Alexandria
c/o Jeremy Flachs

Jeremy Flachs
109 E Randolph Avenue
Alexandria, VA 22301
Jeremy.Flachs at Flachslaw.com


Concerned Citizens of Alexandria Virginia c/o Jeremy Flachs 109 E Randolph 
Avenue Alexandria, Virginia 22301
September 11, 2018

To: Colonel Patrick V. 
Kinsman District Commander, Norfolk District U.S. Army Corps of Engineers 
803 Front Street Norfolk, VA 23508

Subject: Potomac Yard Metro Station 404 Permit Application 
NAO-2012-02012/VMRC#17-1756 Denial of City’s Permit Request

Dear Colonel Kinsman: We write to inform the U.S. Army Corps of 
Engineers (USACE) that we oppose the City of Alexandria’s preferred site 
for a new planned metro station in Potomac Yard, Alexandria, Virginia. The 
site currently under consideration and for which the City advocates is 
Alternative B. Three previously considered alternatives exist and are 
demonstrably less destructive of Potomac Yard’s federally protected tidal 
wetlands. We are disturbed that the City continues to inform the public 
that, because the Federal Transportation Administration (hereinafter 
“FTA”) and the National Park Service (hereinafter “NPS”) selected 
Alternative B after completion of the Potomac Yard Metro Station 
Environmental Impact Statement (hereinafter “PYMS EIS”), USACE will not 
consider alternative sites in its review of the City’s 404 permit 
application for PYMS. The EIS was prepared only for actions proposed by 
the FTA and NPS, not for the City or its permit request. Although a USACE 
permit will be required, no permit has been issued and, as far as we know, 
USACE has yet to engage in any review. As a Participating Agency, USACE is 
obligated to ensure that the PYMS EIS purpose and need, range of 
alternatives, methodologies, environmental analysis, and preferred 
alternative satisfy the minimum requirements of the Clean Water Act (CWA) 
and the 404(b)(1) Guidelines (Guidelines). (23 USC 139(d)(3)) 
and139(d)(7)(A)). As USACE did not complete its obligations as a 
Participating Agency, we believe the PYMS EIS did not provide the public 
or FTA and NPS decision makers a complete description and analysis of the 
station’s adverse environmental impacts, particularly on the tidal 
wetlands. Further, as the draft EIS describes three reasonable 
alternatives with less impact to the wetlands than Alternative B, we 
believe that USACE must reject Alternative B because it is not the least 
environmentally damaging practicable alternative (LEDPA).

  In addition, as a result of the recent decision by WMATA and the City to 
reconfigure the planned metro station, we believe all collaborating 
federal and state agencies should re- evaluate their prior approvals. FTA 
and NPS completed their National Environmental Policy Act (NEPA) review of 
the PYMS and approved Alternative B more than two years before USACE began 
its NEPA review of the PYMS. We urge USACE not to be influenced by 
pre-permit actions taken by the FTA and NPS. We trust that USACE will make 
an unbiased decision regarding the LEDPA. As residents of Alexandria who 
would be adversely impacted by the needless destruction of wetlands during 
and after construction if Alternative B is selected, we believe one of the 
other alternative sites should be selected to provide the best balance 
between environmental impacts and benefits. As residents, we expect USACE 
to conduct a fully transparent review of the City’s application in 
accordance with the NEPA. We look forward to reviewing USACE’s independent 
decision in accordance with the CWA and Guidelines.

Respectfully,
Concerned Citizens of Alexandria Virginia
Andrea Stowers     andreal.stowers at gmail.com
Andrew Macdonald    ahmacdonald at mac.com
Anita Winsor      anwinsor at gmail.com
Barbara Pringle     bpringle9 at gmail.com
Bill Tate       leonidastate at verizon.net
Bob Wood      jrwood72 at gmail.com
Bonnie Petry      bonnie.petry at outlook.com
Boyd Walker      boydwalker2012 at gmail.com
Charles and Cynthia Evans  charlese33 at gmail.com
Christine Bernstein    chbernstein at comcast.net
Cill Dara    cilldara3030 at gmail.com

D. Terence Langendoen   dterence at msn.com
Dave Dunn      davezila at comcast.net
David Dunn      David_Dunn at comcast.net
Diana Banat      Dbanat at hotmail.com
Ellen Latane Tabb    proftabb1 at hotmail.com
Erin Winograd      Erin at winograd.us
2
  Hall Hardaway      halhardaway at msn.com
Hugh Van Horn      vanhorns1 at verizon.net
Jane Downing Knops    knopsjane at gmail.com
Jeremy Flachs      jeremy.flachs at flachslaw.com
Jimm Roberts      robertsjim at aol.com
Joseph Judson Smith III    jossmith at mba1962.hbs.edu
Kathryn Papp      kpappva at gmail.com
Katy Cannady      Katy_Cannady20 at comcast.net
Linda Couture      lindalcouture at aol.com
Linda Hauenstein    lindavid4807 at gmail.com
Linda Kennedy      linda.kennedy.lpk at gmail.com
Mark Anderson     Augusta1994 at aol.com
Marla         marlabeth at hotmail.com
Marya Fitzgerald    maryafitz at gmail.com
Nancy Davis       nmdaviswriter at aol.com
Nancy S. Kelly      nanza13 at msn.com
Pat Tokarz      jptokarz at comcast.net
Patricia Hilgard      hilgardp at yahoo.com
Randy Mcdonald    randall2v at gmail.com
Randy Randol      randy.randol.1743 at gmail.com
Robert Pringle      rpringle9 at comcast.net
sararose0409 at gmail.com  sararose0409 at gmail.com
Sherry Schiller      Sherry at schillercenter.org
Stan Protigal      py8editor.unitacx at dfgh.net
Steve Teslik      steslik at e2steve.com
Stuart Davis      snldavis6671 at aim.com
Sue Tate      flowers15 at verizon.net
Tim Morgan      timmorgan1155 at gmail.com
Vineeta Anand       vineetaa at gmail.com
Yvonne Callahan    yvonneweightcallahan at gmail.com