GTCA Comments on Section 106 Draft Programmatic Agreement

GTCA submitted written comments to the FHWA and VDOT on September 16, 2013.

GTCA Comments Third Draft Programmatic Agreement

The General Trimbles Community Association is pleased to have an opportunity to participate as a consulting party in the Section 106 Programmatic Agreement process.  We have extensively reviewed previous drafts of the PA, meeting minutes and correspondence and comments from both signatories and other consulting parties. 

GTCA’s analysis centers on the probable (i.e., quantifiable effects) that proposed mitigation measures will have on the adverse effects of the undertaking.  While we are not experts in the Section 106 process, it seems clear that the objective of the PA and various stipulations is to ”avoid, minimize or mitigate” the documented adverse effects.  Consequently, the evaluation of the content and commitments in the PA document must be tied to a clear understanding of what these actions are likely to produce. Said another way, the signatories should not equate proposed mitigation activities, as accomplishing tangible mitigation, unless there is clear quantifiable data to measure the effects.  The PA draft makes clear, and VDOT repeatedly emphasized during the Sept. 5th meeting that the actual effects (i.e. mitigation outcomes) could not be accurately assessed or predicted until significant design engineering has been completed.

Why is this point so important?  Because the public needs to be assured that the design requirements and associated elements of the stipulations do not become mere actions with no significant diminution of the underlying problem:  the documented; significant impact that the construction of the BCP will have on cherished historical resources.

Recent comments by Ms. Kathleen Kilpatrick, Virginia Department of Historic Resources and Charlene D. Vaughn, Advisory Council on Historic Preservation, buttress the conclusion that FHWA/VDOT have not provided a clear and convincing analysis of what levels of mitigation will be achieved.

Ms. Kilpatrick, in an email dated Sept. 13, 2013 to Mary Ann Ghadban stated:

“Within my area of focus, for example, I continue to question whether the overall mitigation now under discussion is sufficient to offset proposed project impacts and the nature of the effect that the bypass will have on resources, including the district.  Impacts and off-setting mitigation should be proportional.”

Ms. Vaughn, in a letter to Irene Rico dated Sept. 13, 2013 comments:

“It is a matter of concern to the ACHP that commitments to developing the BCP in a context sensitive manner and to close Route 234 within the boundaries of the Manassas National Battlefield Park (MNBP) remain poorly defined (emphasis added).  The PA contains many excellent mitigation measures.  However, we remain concerned that key aspects if the mitigation and project design, including determining how noise and visual impacts will be minimized are deferred until after the Record of Decision.”

Reading through the PA and other background material, it is obvious that the visual and auditory impacts will be extremely significant, otherwise there would be little need nor controversy regarding the PA document.  Strategies identified to mitigate these effects (depressed roadbed, quiet pavement, narrowed rights of way, berms) are deemed to be effective without any quantifiable data to support that conclusion.  It was clear from the September 5, 2013 meeting that empirical benchmarks for mitigation of various adverse effects have either not been developed or that they do not exist as objective standards.   In fact, many of the stipulated mitigation measures work at cross-purposes to each other.  Narrowed ROW is inconsistent with berms to control noise effects.  Depressed roadbeds require more extensive ROW and berms and greater ROW negatively affect visual impacts and destroy the existing view shed.  Taken in this context, the PA stipulations do not demonstrate that there will be true mitigation, nor even significant mitigation.

GTCA believes that VDOT and FWHA must provide a more robust quantitative model to forecast the actual outcomes of various mitigation strategies, before preliminary engineering and design phases are undertaken.  These benchmarks should be used not only to guide the design phase, but to provide a fixed point of reference to assess how well the actual design elements meet the test of mitigation.  GTCA agrees with ACHP’s recommendation that “establishing performance standards or using Memoranda of Agreements (MOAs) to document agreed upon mitigation measures” is vital to the integrity and transparency of the Section 106 process.  (Letter from Charlene D. Vaughn, Advisory Council on Historic Preservation to Irene Rico 9/13/13).

Several speakers representing signatories stated “mitigation might not be possible”. The signatories should understand that many if not all of the consulting parties are fearful that the BCP will proceed without any real commitment to effective mitigation and that decision makers will simply declare that effective mitigation is either impractical, not cost effective or irrelevant to the ultimate decision to construct the road due to “purpose,  need and viability” criteria trumping all other considerations.

GTCA’s comments that follow are directed at specific areas of the PA document, but should be interpreted in light of our broader concern that the overall commitment to effective mitigation is lacking any quantification standards.

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VDOT Traffic Study shows BCP would increase congestion

The Southern Environmental Law Center, Coalition for Smarter Growth, Piedmont Environmental Council, National Trust for Historic Preservation, and National Parks Conservation Association have been active participants in the Section 106 Programmatic Agreement discussions with VDOT.  Collectively, these organizations are referred to as the “Coalition” because they share many of the same perspectives and objectives for managing growth.  They proposed a package of alternative projects that offer more effective, lower cost solutions to the traffic problems experienced in Northern Virginia.  

VDOT prepared a study of the various alternatives in May of 2013 and concluded that none of the projects were feasible or affordable alternatives.  The Coalition responded with a detailed analysis of the study and  concluded that VDOT’s own traffic data showed that  “ the proposed Bi-County Parkway (“BCP”) would worsen, not relieve, traffic congestion. The same model shows that the comprehensive alternative offered by our coalition (termed the “Substitute Vision” by VDOT) will better address congestion in the study area, and better serve the dominant need for east-west traffic capacity—now and in the future.”

The Coalition’s report can be found here:  Rethinking the Bi-County Parkway

See the Washington Post article on this topic here:  Bi-County Parkway in Virginia will add congestion

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Sec. of Transportation Defends Bi-County Parkway at PWC Supervisors Meeting

VDOT Secretary of Transportation Sean Connaughton spoke to the PWC Board of Supervisors on Tuesday August 6th.  His long awaited appearance was disappointing to most members of the public and several supervisors who continued to question the assumptions and rationale behind the North South Corridor Master Plan and the Bi-County Parkway project.  Among the most contentious assertions by Sec. Connaughton was that truck traffic would not increase significantly on the BCP, even though this has been a principal rationale in VDOT’s public  presentations.   Sec. Connaughton tried to downplay the significance of the Commonwealth Transportation Board’s approval of the North South Master Plan in June and the legal importance of the Section 106 Programmatic Agreement as “paperwork” that would not ensure that the project is built at all.  This assertions was greeted with extreme skepticism.

For a more complete report on Connaughtons’s remarks, see the Washington Post article:

Sean Connaughton Remarks to PWC Board of Supervisors

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VDOT Public Meeting June 3, 2013 – Please Attend and Speak Out

June 3, 2013 – 6-9 PM.   VDOT public meeting on North South Corridor Master Plan

VDOT will hold a public meeting on the North South Corridor (Tri-County Parkway) on June 3, from 6 to 9 p.m., at the Hylton Performing Arts Center on the Prince William Campus of George Mason University.  This is a critical meeting and is the result of all the efforts by our elected representatives to stop the Tri-County Parkway project before it is too late.  We need all GTCA members, your friends and families to attend this meeting.  Show up and speak out to lend your support.

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Prince William County Board Delays Vote on Six-Year Transportation Priorities

Yesterday, the Prince William County Board of Supervisors voted to delay action on the list of transportation projects in the six year plan.  The hotly disputed Tri-County Parkway project was the focus of the meeting, and was listed as the “Route 234 North Bypass”.  Dozens of citizens expressed their strong opposition to this project.  Supervisor Wally Covington’s motion to defer action until the Board can be briefed directly by Transportation Secretary Sean Connaughton was seconded by Supervisor Candland.  Had the original resolution passed, Prince William County would have been on record as favoring the Tri-County Parkway project and advocating priority funding.

Prince William supervisors delay vote on Tri-County Parkway – The Washington Post

This decision represents a significant victory for citizens opposed to the project, and signifies that the arguments made by elected officials, including Delegates Tim Hugo and Bob Marshall (who spoke at the meeting), state Senators Dick Black, Jill Vogel and Richard Stuart are being recognized by other local officials.  The recent decision by the Commonwealth Transportation Board to postpone a final vote on the North South Corridor Master Plan comes in the wake of a strongly worded letter from Congressman Frank Wolf to Governor Bob McDonnell.

GTCA members and everyone opposed to this project need to stay focused and participate in the upcoming meetings to sustain the momentum.

May 29, 2013 – 6-9 PM. VDOT Public Meeting on Six-Year Transportation Improvement Plan. Also, the state Commonwealth Transportation Board (CTB) has included $11.7 million in new funding for the Bi-County Parkway project in the tentative FY2014-2019 Six-Year Improvement Program. A public hearing on the Six-Year Plan will be held on May 29 at 6:00pm in Fairfax (VDOT District Office, Potomac Conference Center, 4975 Alliance Drive Suite 1N201, Fairfax, VA 22030).

June 3, 2013 – 6-9 PM. VDOT public meeting on North South Corridor Master Plan  VDOT will hold a public meeting on the North South Corridor (Tri-County Parkway) on June 3, from 6 to 9 p.m., at the Hylton Performing Arts Center on the Prince William Campus of George Mason University. This is a critical meeting and is the result of all the efforts by our elected representatives to stop the Tri-County Parkway project before it is too late. We need all GTCA members, your friends and families to attend this meeting. Show up and speak out to lend your support.


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This letter was sent to Chairman Corey Stuart and all other Prince William County Supervisors regarding the May 21, 2013 meeting to approve transportation priorities for the six year plan.

Please attend this meeting if at all possible to make your views known.

GTCA Letter to Corey Stuart & PW CBOS 5-17-13


Prince William County Agenda for May 21, 2013:

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Congressman Frank Wolf opposes North South Corridor approval by CTB

Congressman Frank Wolf released a letter to Governor Bob McDonnell announcing his opposition to the CTB approval of the North South Corridor which is scheduled for a vote on May 15.   Mr. Wolf ‘s statement is a cogent review of the reasons why the North South Corridor is bad transportation policy, fails to preserve the historic district, and tramples on the rights of citizens directly affected by this project.

Read the letter here:

Congressman Frank Wolf Letter to Gov McDonnell


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WAMU Video – North South Corridor Land Grab

Watch this video of an interview with Martin DiCaro discussing why the North South Corridor (TCP) is seen as a land grab benefitting developers and bad for Northern Virginia commuters:

Martin DiCaro WAMU Interview

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2011 Traffic Counts

At the Town Hall held on May 2, 2013 Philomena Hefter and Page Snyder shared some traffic counts compiled during 2011.  The numbers may surprise you.


Average Daily Traffic Counts – 2011 

                                               Arterial Road Daily Traffic Count
Gum Spring








Sanders Lane




Pageland Lane




Point to Point Trips

Route 29 from I-66 E of Gainesville to Fairfax County Line


Route 29 from Route 15 to I-66 @ Route 55


Route 234 from NVCC to Route 29 @ Stone House


Route 234 from Stone  House to Gum Spring


Route 234 from Gum Spring to Route 15




Traffic impacts from the Tri-County Parkway project plan:

  • The VDOT and National Park Service agreement calls for CLOSING Route 234 from NVCC to Featherbed Lane.
  • Route 29 slated for “traffic calming” measures and then closure with Manassas Battlefield Bypass
  • Pageland Lane eliminated and abandoned
  • Catharpin Road becomes major cut through for traffic going to Gainesville
  • Featherbed (now a dirt road) and Groveton will be the only option for many commuters.
  • All local and commuter traffic diverted to I-66
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Say NO to Tri-County Parkway Issues Call to Action

Residents of Pageland Lane & Sanders Lane are caught in VDOT’s crosshairs.  They have been organizing to vigorously oppose the TCP, including setting up a facebook page.  They sponsored the recent town hall on May 2, 2013 which was very well attended.  Please see the attached Call to Action.  It describes what YOU CAN DO to help fight this waste of taxpayer funds.

Call to Action:  SayNOtoTriCountyParkway

Please vist their webpage on Facebook –

You can sign the petition here:  Petition to Oppose Tri-County Parkway

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CTB sets agenda for May 15, 2013 meeting

The CTB has published an agenda for their meeting on May 15, 2013 in Richmond.  There are two items of importance to GTCA and those who oppose the North South Corridor (Tri-County Parkway).   CTB will release the draft of the 6 year traffic improvement plan for fiscal years 2014 through 2019. The board then will hold public hearings:

May 28 in Richmond            May 29 in Fairfax           June 4 in Roanoke                June 5 in Chesapeake.

The CTB is also gearing up to approve the final version of the North South Corridor Master Plan.

See the full agenda here:       CTB Agenda 5-15-13

The justification for the CTB’s action is contained in this document.  Northern Virginia North South Corridor Master Plan – Final

The final report contains many dubious assumptions and provides a very weak rationale for this extremely costly project that will do nothing to help solve the existing traffic problems in Northern Virginia.

Please try to attend one of the hearings to voice your opposition to the misuse of taxpayers dollars on the Tri-County Parkway.

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Opposition Mounts to Tri-County Parkway – Washington Post

This article appeared in the Washington Post Local pages on April 30, 2013.  It explains why 6 respected Republican elected official announced opposition to the Tri-County Parkway represents a major change in the debate. Read the article to find out why…

Washington Post Article (weblink)

PDF:  Opposition mounts to major Loudoun-Prince William Parkway Washington Post

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TCP Fact Sheet – Road Closures, Property Rights & PWC Board of Supervisors

Philomena Hefter and her neighbors on Pageland  Lane have been involved with the fight over the “Outer Beltway” proposal for quite some time.  She has organized a Citizen Town Hall for May 2 at the Bull Run Middle School Cafeteria.  The meeting starts at 7 PM and GTCA encourages everyone to attend this important meeting.

Philomena prepared a very helpful fact sheet about road closures, the impact of the Tri-County Parkway on property rights of local residents and contact information for all members of the Prince William County Board of Supervisors.    Please read this material carefully and you will see what a disaster the TCP will be for local residents and commuters.

Citizen Town Hall 5-2-13 Background Material

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VDOT & National Park Service Declare War on I-66 Commuters

Elected Officials Oppose TCP

Virginia Delegates Tim Hugo (R-40th), Bob Marshall (R-13th), Michael Webert (R-18th) along with Virginia State Senators Dick Black (R-13th), Richard Stuart (R-28th) Jill Vogel (R-27th) declared their opposition to the Tri-County Parkway (TCP) at a press conference on April 29th held at the Stone House on the Manassas Battlefield.  Prince William County Supervisor Pete Candland also released a statement announcing his opposition to the TCP project.  GTCA salutes these public official for their courage in opposing VDOT and the CTB’s efforts to push this project through against strong local and regional opposition.  GTCA and other local citizens were on hand to witness the strong stand against the TCP.

Tim Hugo Press Release:  Delegate Tim Hugo Opposes Tri-County Parkway

Supervisor Pete Canland:  Supervisor Pete Canland Opposes Tri-County Parkway

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McDonnell Administration has a costly “vision”

The McDonnell administration has unveiled its vision for a north-south highway and other improvements to Virginia’s newest Corridor of Statewide Significance.  It does not include any financial analysis, cost projection or way to pay for the 45 mile road…

Read the article here:   North-South Highway


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