Superintendent,
National Park Service
c/o
Re:
Dear Superintendent:
Old Town Civic Association (OTCA), organized in Alexandria, Virginia in 1951, is one of the preeminent organizations working for the protection and enhancement of the City’s historic, cultural and natural resources. Chartered with the mission of working for the preservation of the historic and residential character of Old Town Alexandria, OTCA was the citizen organization principally responsible for the establishment of the Old and Historic Alexandria District, and for more than half a century has worked through the efforts of its hundreds of members to advocate the values reflected in that charge.
During all of OTCA’s lifetime (and for many years before),
OTCA urges that the single most important guiding principle
in NPS/GWMP’s Environmental Assessment of alternative future designs and uses
of the park should be the preservation of the natural resources, environmental
value and historical character and heritage of
Against that standard, OTCA offers the following comments on the issues that NPS/GWMP poses.
I. Access and Circulation
Vehicular Access
surrounded
on two sides by water; and it can be accessed only by narrow streets through
residential neighborhoods. It is far from
an ideal location for facilities which are intended or expected to draw any
substantial volume of vehicular traffic from all over the City of
OTCA wholeheartedly agrees with NPS’s statement in the summary of issues to be addressed that “changes in parking and access in the park must not impact adjacent neighborhoods.”
The original plan for
In recognition of this fundamental point, the post-September 11 alternatives that have been put forward (including the four alternatives proposed for discussion by NPS/GWMP) have all significantly reduced the parking provision, most to 110 spaces. But moving even 110 spaces into areas that had earlier been planned for the recreational, natural and historical uses of the park inevitably—and we believe unnecessarily—diminishes those benefits. Relocating parking out from under the bridge into areas earlier planned for the substantive uses of the park further stresses the difficult problems of access and circulation, or requires the destruction of some portion of the park’s natural and recreational environment, or both, and thus fails this test.
Conversely, if the activities contemplated for the park are retained as before September 11, but the number of parking spaces provided for those uses is reduced by more than half (from 240 to 110), the inevitable result will be very substantial “spillover” parking on the residential streets in the adjoining neighborhood, making a mockery of the admonition that “changes in parking and access in the park must not impact adjacent neighborhoods.”
The number of athletic fields planned for the park is the decisive factor in determining how much parking is needed. The Alexandria Recreation Department’s expectation is that each field would require 40 parking spaces, while 30 would be needed for the general, more passive uses of the park. Thus, a two-field option (as in Alternatives 1, 2 or 3) would require 110 parking spaces; while one field (as in Alternative 4) would require 70 spaces. (The 80-space figure associated with an earlier one-field option was apparently predicated on the City’s desire to continue to use that larger number of spaces during the day for parking for city employees.)
The assumptions about parking that can be accommodated in the park may already be overly optimistic, however, putting the neighborhood at risk. Fairfax County, Virginia assumes a need for 50 (not 40) spaces per field; and the Alexandria Recreation Department cautions that, when two games are scheduled in close sequence, the peak demand can double to accommodate arriving and departing vehicles. Two athletic fields, fully scheduled, might thus create a peak
demand for as many as 200 parking spaces (plus the 30 spaces for general park visitors): manageable under the bridge in the original design, but well beyond what is provided now under any of the alternative concept designs.
Whatever risk there may be should not be magnified by attempting to “load” more uses into the park than we can reasonably and realistically expect to accommodate with on-site parking.
Alternative 1 provides 110 parking spaces for the daily uses of the park, but only by sacrificing a significant quantity of woodland and forested wetland in the northwest section of the park. Alternative 2 consumes a comparable quantity of woodland and wetland, in a different configuration on either side of the illustrated multi-use fields in the east central section of the park. Alternative 3 consumes a similar quantity of the park’s natural resources, split between those two locations.
Alternative 4 alone minimizes the damage to the park’s natural resources to accommodate the required parking, by (1) substantially reducing (from 110 to 80) the number of parking spaces moved out from under the bridge, and by (2) placing those spaces essentially at the location of the existing parking lot, rather than destroying any additional woodlands and wetlands for this purpose.
II. Natural and Cultural Resource Management
A. Natural Resources
Location of two large playing fields and their accompanying parking north of the bridge maximizes the damage to the wetlands, woodlands, and animal and plant species that constitute so much of the park’s natural value.
Alternatives 1 and 2 do the most damage, each apparently consuming several acres of woodlands and wetlands, albeit in different configurations. Alternative 3 does somewhat less damage, by locating one of the fields in the present open, grassy area south of the bridge; but still substantially damages the park’s natural resources by locating 110 parking spaces and one large multi-use field north of the bridge where the most environmentally-sensitive woodlands and wetlands are now located.
Alternative 4, alone, by locating a single new field in the open area south of the bridge where the existing informal field has been located for decades, destroys no additional woodlands or wetlands in the park to provide new playing fields or to provide parking for those facilities.
B. Cultural Resources
1. Historic Resources
The statement of issues to be addressed raises the question whether use of the area south of the bridge for other than passive uses may affect the park’s historic resources. Any possible effect would be negligible, however.
One corner of the smaller field (80 x 40 YD) contemplated in Alternatives 3 and 4 would barely touch a straight line extending northwest from the D.C. Cornerstone designating the “Historic Interpretive Trail” in the drawings; the larger field illustrated as a possibility in Alternative 4 would overlap that line slightly more, in the middle of its course. But the Historic Interpretive Trail is not a solid structure, but rather, a series of interpretive markers arrayed in a general direction northwestward from the cornerstone, with large open areas in between. The field in either case would still be far removed from the lighthouse, the cornerstone, and the other historic resources located primarily around the perimeter of this portion of the park; and location of the field as illustrated would interfere little if at all with pedestrian passage along the Interpretive Trail.
All of these considerations led the Director of the city’s Office of Historic Alexandria, in the course of the public hearings last spring on alternative concepts for the park, to conclude that the impact of a single field south of the bridge (as in Alternative 4) on the park’s historic resources would not be significant, and would be an acceptable balance within the overall context of alternative design objectives for the park.
2. Old and Historic District
The natural and historic values of the Old and
Historic District have already been substantially damaged by the original
decision to extend the span of the
with an even wider bridge at the same location. The federal government has provided funds for the purpose of mitigating that damage to some extent. It would be an unfortunately elastic definition of the term if the result of the application of those funds were not to mitigate but to exacerbate the damage to the District through a significant intensification of the uses of the park and a consequent increase in noise and traffic impacts, and the loss of a portion of the woodland in the park that now serves to some extent as a “buffer” between the bridge span and the District.
3. Hydrology
It stands to reason, however, that whatever the risk that hydrologic damage may result from the disturbance of the wetlands and woodlands and the construction of new facilities north of the bridge (as in Alternatives 1, 2 and 3), that risk would be substantially diminished by Alternative 4’s location of a single field on already open and much less hydrologically sensitive ground south of the bridge, and by the location of parking in an area already used for that purpose.
III. Visitor Activities
The array of visitor activities contemplated for the park in the original Woodrow Wilson Bridge Final EIS and Record of Decision assumed that ample parking to support those activities could be sited under the bridge, with no damage to the natural, historical and recreational resources elsewhere in the park. The post-September 11 requirement that non-secure, non-event parking be moved out from under the bridge fundamentally changes that balance.
It is reasonable to hope that, notwithstanding that change, as many of those activities might be retained as possible. In fact, Alternative 4 does preserve the preponderance of the visitor activities originally planned for the park with little or no change: the canoe/kayak launching site, fishing pier, a somewhat smaller picnic and events lawn, waterfront promenade, playground, multipurpose courts, preservation/stabilization of historic resources and interpretation, continuation of the existing gardens—and one of the two planned new playing fields. Alternatives 1, 2 and 3 preserve the second new field, but only at the cost of significant damage to the other objectives of optimizing access and circulation and preserving the natural and cultural resources of the park.
* * *
The previously approved plan for
(1) Provision was made for active recreation, principally by adding two multi-purpose athletic fields.
(2) Provision was made for more passive recreation—walking, fishing, picnicking, and the like—of the sort which has long been a hallmark of this park.
(3) Care was taken to preserve and protect the natural
environment of the park: its large
wooded areas, open fields, waterfront, and wetlands, in a combination unique in
(4) Plans were developed to protect and celebrate the unique historic resources of the park in a way that has not previously been done: the original Jones Point Lighthouse, the historic peninsula, the District cornerstone and boundary, and the like.
(5) All of the above was accomplished with ample provision for parking for park users, with virtually no risk of “spillover” parking onto residential streets in the nearby neighborhood.
Old Town Civic Association believes that the new, post-September 11 design for the park should and can retain all of those important values, so far as possible, in a reasonable balance that respects the needs and interests of all park users and the neighborhood. It need not, and should not, elevate any one of those valid interests to the level of an “absolute priority” to be achieved at the cost of significant damage or impairment to any or all of the others.
Toward that end, we suggest that the alternative concepts for the park be measured against the following criteria.
1. The uses in the park and the amount of parking provided must remain in balance. If parking is significantly reduced to meet security concerns, but park uses are not changed correspon-dingly, the result will be spillover parking on nearby residential streets, or frustration to people trying to come to use the park but unable to find parking, or both. Park users and residents alike would be the losers.
2. Damage to the essential values of the park due to the relocation of parking from under the bridge should be minimized. It may be unavoidable that the relocation of parking will result in the loss of some open space, encroachment on some wetlands, or the destruction of some trees—or at the very least the loss of some space which had been intended for park uses, not for parking.
But such damage should be kept to the absolute minimum. Substantial damage to the natural environment of the park in order to accommodate all of the parking required for an unaltered
array of park uses could call to mind the unfortunate assertion from an earlier era that it would be “necessary to destroy the village in order to save it.”
3. Damaging impacts to the nearby neighborhoods, especially to their existing natural and recreational values, should be minimized. Disruption or destruction of the community gardens that neighbors have cherished for a generation, destruction of open spaces and forested wetlands for the construction of new access roads, relocating the recycling center into the residential area, or siting recreational facilities and parking where they would have the most noise and lighting impacts on the adjacent neighborhood, are not necessary and should be avoided.
It is the nearby neighborhoods that have already suffered
the brunt of the damage done by building the world’s widest bridge through the
middle of
4. Recreational
facilities proposed for this park or elsewhere should be sited where most
convenient and appropriate for their intended users. As noted, the location of this park is one of
the least accessible in the city. But
there are, fortunately, many other sites in
5. The active and passive recreational, historical, natural and environmental values of the park should be preserved to the optimum degree. Any active or passive use of the park requires a supportive infrastructure: space for the use, and, particularly, for parking. The original plan for the park, prior to September 11, sought to serve all of these uses. All should be retained, so far as reasonably possible. But no particular use should be considered exempt from review or modification if the cost of retention is unnecessary and avoidable damage to the park’s wetlands, its unspoiled open spaces, its tree canopy, or its other planned uses.
Old Town Civic Association believes that a single, smaller soccer field south of the bridge (sized especially for younger players, according to the standards of the Fédération Internationale de Football) would best balance the objective of optimizing the active recreational use of this park while minimizing damage to the natural and historic resources of the park, to its passive recreation and other uses, or to the adjacent neighborhood.
1. It would
substantially reduce the parking required at
2. It would minimize the damage to wetlands, trees, and open space in the park.
3. It would avoid disruption or destruction of the nearby community gardens, and minimize present or future noise or lighting impacts on the adjacent residential neighborhood.
4. It would permit location of the full-sized, “regulation” fields that would be more useful and appealing to adult players in organized leagues at more central locations more easily accessible to the expected users.
5. It would preserve
all of the previously planned uses of the park in kind, though reducing
one of those uses (athletic fields) in scale at this site. A smaller-scale soccer field at
Moving 110 parking spaces out from under the bridge into the park consumes what was planned as open, natural, or passive recreation space, and reduces the passive recreation and neighborhood park values which were ranked as Alexandria citizens’ two highest priorities in the Strategic Master Plan for Open Space, Parks and Recreation adopted just two years ago.
We note that Alternative 1 is identified in the documents as the “City of Alexandria Preferred Alternative,” and that is an accurate caption, so far as it goes, given the June 28, 2005 final choice of the Alexandria City Council among the alternatives it was then considering. We respectfully note, however, that only four of the seven members of that body—a bare majority—identified “Scheme A” (portrayed herein as Alternative 1) as their preferred option. Three other members urged adoption of one or another of the options (such as the present Alternatives 3 or 4) which would not involve the location of two full-sized multi-use fields and their requisite parking north of the bridge.
It was
probably not inappropriate that the Alexandria City Council would consider
other factors specific to the needs of the City (such as the cost or
suitability of other potential sites for playing fields in the city, the
overall supply and demand for recreational facilities in the area, and the
convenience and economy of using facilities in Jones Point Park for city
employee parking) in its assessment of the options before it. But we respectfully submit that such
considerations, while perhaps appropriate to
It is for this reason that the Old Town Civic Association urges adoption of the single-field option illustrated in Alternative 4. We believe it represents the best balance that can be achieved at this site between active and passive recreation, historical and natural values, and stewardship for the environment. We commend it to the consideration of our fellow citizens, to all prospective users of this treasured park, and to the National Park Service.
Respectfully submitted,