The following letter was addressed to Colonel Patrick V. Kinsman District Commander, Norfolk District U.S. Army Corps of Engineers.
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. 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.
Concerned Citizens of Alexandria, Virginia
Andrea Stowers, Andrew Macdonald, Anita Winsor, Barbara Pringle, Bill Tate, Bob Wood, Bonnie Petry, Boyd Walker, Charles and Cynthia Evans, Christine Bernstein, Cill Dara, D. Terence Langendoen, David Dunn, Diana Banat, Ellen Latane Tabb, Erin Winograd, Hal Hardaway, Hugh Van Horn, Jane Downing Knop, Jeremy Flachs, Jimm Roberts, Joseph Judson Smith III, Kathryn Papp, Katy Cannady, Linda Couture, Linda Hauenstein, Linda Kennedy, Mark Anderson, Marya Fitzgerald, Nancy Davis, Nancy S. Kelly, Pat Tokarz, Patricia Hilgard, Randy Mcdonald, Randy Randol, Robert Pringle, Sherry Schiller, Stan Protigal, Steve Teslik, Stuart Davis, Sue Tate, Tim Morgan, Vineeta Anand, Yvonne Callahan, and Andrea Stowers.