2. Transform 66 Outside the Beltway Project
As of 6 November 2018 VDOT letter (September 27, 2018) to
Virginia DHR (copied to consulting parties)
accepted DHR’s opinion as the basis for
resolving the adverse effect, provided a
draft Section 106 Memorandum of Agreement (MOA)
for review and comment, and
requested consulting parties to reaffirm their
interest in continuing to be consulting
parties, and to provide any comments on the MOA
by October 12, 2018
Based on comments received from
consulting parties, VDOT issued final draft MOA
on 26 October, for review and comment by 5
November. Subsequently, and based
on initial review comments from NPS and other
consulting parties, VDOT scheduled
a 6 November meeting (2:00 pm at MNBP HQ –
Stuart Hill) with consulting parties
to discuss and resolve outstanding issues
associated with the draft MOA.
o Area of
Potential Effects (PE) boundary - reassess 4.54 acre parcel of land located
adjacent to MNBP (Latsios Property)
o Complete Manassas Battlefield Viewshed
Protectin Plan
o Acquisition/donation of suitable land to
a conservation organization –
o Portici Cultural Landscape Report (CLR)
o Lighting at Rt 234 Interchange (height)
o Overhead signage on westbound EAR
Background.
As
part of a larger I-66 improvement project, Dynamic Tolling
Express
Lanes will be extended from the Capital Beltway to
Gainesville.
http://outside.transform66.org/
Transforming I-66 by 2022; more than $3B in transportation improvements designed to:
Relieve congestion in all lanes
Provide for asset transit through Express Lanes
Move 2,000 to 4,000 more people per hour
Fund new buses and transit routes
Add 4,000 new park-and-ride spaces
Improve safety
Project Overview:
Multi-modal improvements to 22.5 miles of I-66
Two Dynamic Tolling Express Lanes in each direction from I-495 to Gainesville
Three General Purpose Lanes in each direction
HOV and transit access to Express Lanes
Median Space reserved for future transit
Improved park-and-ride options with access to Express Lanes
Bike-pedestrian trail integrated with existing and planned trails
Project segments
Segment 1 – Gainesville to Route 234 Business to Route 29 in Centreville
Segment 2 – Centreville to Route 28 to Route 50
Segment 3 – Route 50 to Nutley Street to I-495
Threat to Manassas Battlefield
Project Segment 1 (Gainesville to Rote 29 Interchange in Centreville) design aspect that negatively impact the Manassas National Battlefield Park (MNB): Elevated (30-ft) Express Lane on/off ramps on both ends of Portici Plantation MNBP property bordering I-66, from Vandor Lane / Battleview Parkway intersection to Vandor Lane east of Virginia Welcome Center – locally known as ‘Annie’s Dip’
View shed negatively impacted by 30-foot high ramps, and the removal of evergreen trees currently located between Vandor Lane and I-66 (widening of I-66 and increased median space)
Increased levels of Traffic noise that would result from the elevated ramps
MNBP and other Consulting Parties are seeking relocation
of the two Express Lane access (flyover) ramps to less
impactful sites........or appropriate mitigation measures.
Timeline
Start Up Activities, Jan - Mid 2017
Public Information Meetings, 12, 14 & 15 June 2017
Design Public Hearings, 13, 14, 16 November 2017
Begin construction and right-of-way acquisition, December 2017
Final Noise Study, Spring 2018
Route 28 Signalization, Summer 2020
Express Lanes open to traffic, December 2022
Tier
2 Environmental Assessment completed, with a Finding of No
Significant Impact (FONSI) – 26 June 2017
Express Lane Elevated Access Ramps (EARs)
One of 30 Alternative Design Concepts (ATCs) proposed by Express Mobility Partners (EMP) – VDOT accepted 7 of 30 ATCs for incorporation into the project
Not part of concept reviewed during Tier 2 Environmental Assessment – FONSI (June 2017)
VDOT conducted initial Consulting Party/stakeholder coordination meeting at MNBP HQ on Tuesday, January 23 for Segment 1 (Gainesville to Route 29 Interchange in Centreville) - regarding the impact of planned EARs
VDOT/EMP/FAM
meetings
with Consulting Parties have continued
o
March
22, 2018 at 10 AM, Location: VDOT Project Office (4975
Alliance Drive,
Fairfax)
o
April
26, 2018 at 10 AM, Location: VDOT Project Office (12500 Fair
Lakes
Circle Fairfax)
o
June
18, 2018 at 10 AM, Location: VDOT Project Office (12500 Fair
Lakes
Circle Fairfax)
o
August
1, 2018 at 10AM, Location: VDOT Project Office (12500 Fair
Lakes
Circle Fairfax)
Primary issue for BRCWRT and many of the Consulting Parties remains Elevated Access Ramps (EARs) adverse effect (visual, noise) on MNBP visitor experience VDOT / EMP / FAM on June 18, 2018 provided Consulting Parties a “Proposed Access East of Sudley Road in vicinity of Manassas National Battlefield Park Alternatives Evaluation Memorandum”, which included:
Project purpose and need
Project History
Traffic Analysis
Tier
2 Final EA Preferred Alternative – Analysis of Access near
VA Route 234 Business (Sudley Road); FONSI
o Program of
intermodal improvements between Haymarket and I-495 o Express lanes for 22 of
Project’s 25 miles from vicinity of University Boulevard
in Gainesville to I-495 6
o MNBP issues
Noise levelsVisual intrusion
No hi-mass light poles – all EAR lighting will be embedded in EAR parapet
EAR parapet height not to exceed 3.5 feet
• Alternative
Technical
Concept (ATC) 30
o
Access
to and departure from express lanes east of Route 234 Business
(Sudley Road)
o
Elevated
Access Ramps deigned to ‘fly over’ the general purpose lanes
to
enter and exit the express lanes
o
Visual
impact of ATC 30 on the MNBP Portici site and other MNBP
resources
deemed unacceptable - NPS and ACHP, Feb 2018 •
ATC
30, Option 6
o EB EAR (vic Virginia Visitor Center on I-66) shifted west to take advantage of terrain and relative natural elevation differences to mask the WB EAR from MNBP view shed
o Replace WB general purpose entrance with a slip ramp west of Sudley Road, enabling WB EAR relocation further east - outside of MNBP Portici view shed
Consulting Party comments on Alternatives Evaluation Memorandum:
Primary issue for BRCWRT remains Elevated Access Ramps (EARs) negative impact (visual, noise) on MNBP visitor experience
Option 6 (outgrowth of alternatives developed to address concerns with Alternative Technical Concept 30 (EARs), being presented as preferred option, reduces visual impacts to MNBP, but does not eliminate them
o Visualizations shown to date do not include ramps with busses, trucks or toll gantries or signage
o
Site
visit with a balloon test suggested by MNBP
o
Visualizations
done at vantage points 1-8 identified by MNBP – recognition
that
the EARS will be clearly visible from other locations within
the Park
o
Loss
of existing vegetation in VDOT ROW along Vandor lane - - MNBP
suggestion to close Vandor Lane east of existing NPS parking
area,
and use this area of ROW to establish additional vegetative
screening
Current
Status
During 1 August meeting with Consulting Parties, VDOT
provided its position on EAR impacts on MNBP
With Option 6 design changes to avoid incidental impacts, there is no incremental increase in noise or visibility on MNBP that would justify a change to the Finding of No Significant Impact (FONSI) issued on 26 June 2017.
No further mitigation actions are deemed necessary or appropriate FHWA decision to not change FONSI determination would allow VDOT to proceed with EAR design phase - Consulting Parties would have opportunity to review and comment on EAR design
Consulting Parties Responses (summary) to VDOT
BRCWRT – EARs should be located away from the view shed of MNBP; in the event the proposed EAR near Portici cannot be relocated, the visual impacts of that ramp constitute an adverse effect that will require significant mitigation.
NPS, MNBP – The efforts of VDOT and its contractors to reduce the impacts of the two proposed EARs clearly resulted in design improvements and less of an impact on the Park than what was initially proposed. However, there are no minimizations what will screen the westbound ramp (vic Portici) completely from view. Do not agree that VDOT should continue to seek concurrence with VDHR’s 2015 conditional Finding of No Significant Impact.
Southern Environmental Law Center, National Parks Conservation Association, American Battlefield Trust, Piedmont Environmental Council, Coalition for Smarter Growth, National Trust for Historic Preservation and Prince William County Conservation Alliance – Progress has been made to reduce the adverse impact of the EAR’s on Manassas Battlefield; however, the plans have not been modified enough to be consistent with the original finding of “no adverse effect.” VDOT’s position that the existing setting south of the Battlefield is already compromised, and therefore additional visual intrusions will not tip the balance to adverse effect, fails to comply with Section 106’s explicit mandate to consider the cumulative impacts of the proposed project.
VDOT letter (September 10, 2018) to Virginia DHR/SHPO that, while acknowledging and respecting the opinions of MNBP and other Consulting Parties regarding their opinions concerning the historic property effects from ATC 30, states VDOT position that the design modifications included in Option 6 result in an ATC 30 design concept that is consistent with the original No Adverse Effects determination. The letter also conveys VDOT’s willingness to incorporate specific additional design and project commitments (page 5 of letter) into ATC30/Option 6 that will serve as mitigation measures and serve to avoid adverse effects. The letter requests that the Virginia State Historic Preservation Officer (SHPO) concur that ATC 30/Option 6, incorporating the additional commitments, is consistent with the existing no-adverse-effect determination.
Virginia DHR letter (September 20, 2018) to VDOT provides DHR opinion that the westbound ramp will introduce a new visual element into the landscape that was not there previously, and was not anticipated when DHR made its Conditional No Adverse Effect recommendation (June 2017). The letter provides DHR’s recommendation that the westbound ramp will have an Adverse Effect on MNBP, and the need for VDOT to develop, in consultation with DHR and other consulting parties, a Memorandum of Agreement (MOA) to address the adverse effect.
Parties Involved.
VDOT
-
Northern Virginia District (4975 Alliance Drive, Fairfax
Virginia
22033), Susan Shaw, P.E. (Megaprojects Director)
National Park
Service (NPS) / Manassas National Battlefield Park (MNBP),
Brandon
Bies (Superintendent)
Civil
War Trust (CWT)
Manassas Battlefield Trust (MBT), Christy Forman
(POC)
Bull Run Civil War Round Table (BRCWRT)
Piedmont
Environmental Council
Central Virginia Battlefields Trust
(CVBT)
Prince William County (PWC) Planning Office
PWC
Board of Supervisors
Others....
Completed Actions:
MNBP, CWT and MBT submitted letters of concern to VDOT in June 2017
BRCWRT submitted letter of concern to VDOT, 27 November
Combined letter of concerned submitted by Piedmont Environmental Council, Virginia Civil War Battlefields Trust, etc., in Nov 2017
Letter of concern submitted by PWC Planning Office, and a copy provided to each PWC Supervisor
BRCWRT granted Consulting Party status, 1 Feb 2018.
o Design Plans distributed for CPs review
o BallsFordPark-and-Ride
o Segment 1A - from Exit 43 (Us 29) to Station 5430 (west of Sudley Road interchange)
o Segment 1B – from Station 5430 (west of Sudley Road interchange) to Station 5595 (east of Bull Run Drive Bridge)
o Segment 1C – from Station 5595 (east of Bull Run Drive Bridge) to Station 5743 (west of US 28)
BRCWRT’s Consulting Party letter input (Segment 1B) submitted 5 March
Consulting Parties meetings with VDOT and Express Mobility Partners (project contracting firm) representatives on 23 January, 21 February, 22 March, 26 April, 31 May, 28 June and 1 August to review project design updates and conduct discussions
VDOT letter (September 10, 2018) to Virginia DHR requests that the Virginia State Historic Preservation Officer (SHPO) concur that ATC 30/Option 6, incorporating the additional commitments, is consistent with the existing no-adverse-effect determination.
Virginia DHR letter (September 20, 2018) to VDOT provides DHR opinion that the westbound ramp will introduce a new visual element into the landscape that was not there previously; includes DHR’s recommendation that the westbound ramp will have an Adverse Effect on MNBP, and the need for VDOT to develop, in consultation with DHR and other consulting parties, a Memorandum of Agreement (MOA) to address the adverse effect.
VDOT letter (September 27, 2018) to Virginia DHR (copied to consulting parties) accepted DHR’s opinion as the basis for resolving the adverse effect, provided a draft Section 106 Memorandum of Agreement (MOA) for review and comment, and requested consulting parties to reaffirm their interest in continuing to be consulting parties, and to provide any comments on the MOA by October 12, 2018
Planned Actions/Activities.
• BRCWRTo Review VDOT draft Section 106 MOA; provide comments and reaffirm interest in continuing as consulting party
o Maintain communications with MNBP Superintendent, Brandon Bies
o Coordinate input and actions with MNBP and Manassas Battlefield Trust o Attend scheduled Consulting Party coordination meetings
o Submit, as appropriate, additional comments and information
o Monitor developments