Our comments are available at our website at the following link if you wish to view the Word document. Otherwise the content is posted below. You can read it either place, but please post your comments to the article below to help us revise our draft.

http://www.locusthillweb.org/private/docs/BRAC.doc

LOCUST HILL CITIZENS ASSOCIATION

Comments Regarding EIS

            Locust Hill Estates, through its neighborhood’s association known as Locust Hill Citizens Association (“LHCA”), hereby submits the following comments to the Draft Environmental Impact Statement (EIS) for the Base Realignment and Closure (BRAC) for the National Navy Medical Center (NNMC) in Bethesda, Maryland:

            Locust Hill Estates is a Bethesda, Maryland neighborhood, represented by the LHCA, which is bounded by 3 of the most heavily traveled roads in our area, the Capitol Beltway (I-495), Rockville Pike (355) and Cedar Lane.  Locust Hill is one block north of the NNMC.  The residents of Locust Hill are very well aware of the traffic problems in our area.  We are very supportive of the healthcare needs of our military; however, we are concerned about the significant impact of this BRAC on the already horrific traffic situation that affects us today.  Our neighborhood is stressed by the volume of traffic that travels on Rockville Pike (355) and Cedar Lane every day but particularly during the extended morning and afternoon “rush” to and from work.  The traffic already spills into our neighborhood in the form of significant “cut throughs” that often travel at high rates of speed, endangering the residents of our neighborhood.  Traffic has been increasing on the roads adjoining our neighborhood every year and the BRAC at NNMC will make a bad situation worse resulting in increased cut through traffic as frustrated motorists look for an easier way to access Cedar Lane and Rockville Pike. 

General Comments

·    Further Independent Traffic Study Should be Pursued.  Many of the results of the traffic study relied upon in the EIS strike the LHCA as unbelievable or implausible.  As our neighborhood is directly affected by traffic traveling on 355 and Cedar Lane, our own first-hand experiences contradict data in the EIS.  For example, if the Navy accepts the “results” of the study which indicate a 2-3% increase in traffic load to 355 and Cedar Lane during the AM and PM rush hour periods (Tables 4-11 and 4-12, line 5), one would conclude that such a minor impact need not be of any real concern.  With thousands of visitors and employees expected, many of whom will be driving, these low numbers strain credibility.  As further example, the traffic study used a period of 4-7 pm for its afternoon rush (page 13 of Traffic Study, Appendix C to EIS).  Again, anybody regularly traveling on the affected roadways would confirm that they are well over capacity beginning much earlier than 4PM in the afternoon.  Conclusions reached arising from false premises cannot be relied upon.  LHCA urges an independent study of expected traffic impacts (perhaps largely addressed by the $2 million 355 corridor study). While the increase in traffic may seem small relative to the current traffic volume, the anticipated increases are in addition to  the already existing maximum traffic volume and demand substantial mitigation programs.

·         The Federal Government Should Take More Responsibility for the Traffic Impact this Unique BRAC action will have on our Neighborhoods.  The EIS bases a shift of responsibility for road improvements to local and state governments on an inappropriate standard.  That is, it states that the Navy is not permitted to provide funding or management of road improvements outside its property except under the Defense Access Roads (DAR) Program, which only allows the federal government to pay its “fair share” when there is an “unusual impact.”  EIS at pages 4-49-4-50, section 4.7.3.2.  However, the definition used therein for “unusual impact” is doubling existing traffic impact.  This is an inappropriate standard given the well-acknowledged unique aspect of this BRAC action being the only such action in a high-density urban setting.  It is easily imagined that under more traditional BRACs, such as a new military installation in a rural setting, the standard requiring a doubling of traffic would be more common and appropriate.  In such actions, doubling traffic on rural roads where nearly none exists prior to the BRAC, the “unusual impact” definition of twice existing traffic makes sense.  Here, it would be nearly impossible to double traffic in an area in which several of the key intersections are already failing.  LHCA urges the federal government to revise its standard for this type of urban BRAC and assume a more active role in funding and assisting in road improvements surrounding the NNMC.  It should be the Navy’s goal that there should be no failed intersections in the surrounding area after this BRAC action is concluded, not simply returning the intersection to a pre-BRAC level of failure.  This would ensure reasonable access by patients, employees and visitors to the NMMC campus.

·    Continued Study and Consideration of the Beltway Slip Ramp Are Encouraged.   Given its position of being adjacent to the Beltway, and given the obvious enormous increase in numbers of visitors and employees, rejecting the Beltway slip ramp at this time seems premature.  The reasons given for such rejection (no significant improvement to conditions and statutory prohibition) are unpersuasive.  Were the NNMC to require certain of its visitors and employees to use such a ramp in lieu of the local streets, it is impossible to imagine it not having more than the stated affect of “not significantly improv[ing] traffic congestion levels along the study area roadways.”  Traffic Study, page 68, Appendix C to EIS.  In addition, we are familiar with Beltway modifications over the past 3-10 years in which such new exits were created where needed – for example, the new Rockledge exit just past the Old Georgetown Road exit as well as the Arena Drive Exit just past Landover Road, created when the Redskins built their new stadium in the 1990's.  We strongly support direct access to and exit from the NNMC off of the Capitol Beltway (I-495), including, at least, a “slip ramp” on and off the Beltway.  The EIS documents the significant positive impact of this option.  It shows that 25% of the projected traffic to NNMC would use a slip ramp (and likely much more if NNMC were connected to a “full” interchange at I-495).   This will significantly help divert traffic off of the other roads surrounding our neighborhood and help the failing Cedar Lane/Rockville Pike Intersection particularly.  We also believe that such an entrance and exit could also be used to benefit NIH if it were used in connection with a security inspection station and access to not only NNMC but also NIH across the street from NNMC, resulting in the removal of significant traffic from Route 355.

·    We are also concerned that the EIS does not sufficiently consider the positive impacts of projects to further encourage use of public transportation, including for example clustering buildings near the Metro, making the Metro more accessible and reducing the number of additional parking spaces on campus to encourage people to take public transportation (as outlined in more detail in the Action Committee for Transit (ACT) comments, filed April 15, 2007).

·    We understand that NNMC controls changes made on its campus and we strongly support the projects on the NNMC campus that will help mitigate traffic volume on streets adjoining the campus, including bridge/tunnel access to the Metro, reconfiguration of the security checkpoints especially at North Wood (to get traffic off of 355 so it doesn’t queue on that road) and reducing the number of proposed parking spaces.   

·    We are concerned that the EIS traffic counts do not take into account new NIH facilities along Rockville Pike, including the Visitors Center and the Truck Inspection Station.  In addition, it is not clear how the continued and future expansion of NIH is factored into the traffic studies.

·    We support better pedestrian and bicycle access to NNMC and the Medical Center Metro, including an above or below grade (bridge or tunnel) way for people and bicycles to cross Rockville Pike.  The EIS outlines a number of proposals for pedestrian and bicycle improvements that we support including making it easier to cross Rockville Pike at Cedar Lane and improving the sidewalk on the NNMC side of Rockville Pike.  We think any proposals that make it easier for people to commute and travel without getting in a car should be obvious choices that can be done easily and cheaply.

·    We support the use of satellite parking by NNMC employees and contractors as well as encouragement, financial or otherwise, of the use of car pooling, Metro and other public transportation.  Having endured many months of neighborhood streets crowded with construction workers during the recent NIH renovations, LHCA urges the NNMC to require as a condition to its contracts with its construction vendors that such companies provide off-site parking to its workers and shuttle them to the site.  Locust Hill experienced many disconcerting moments of construction workers changing clothes outside of their cars while our children were getting off of school busses and residents being unable to park near their homes because of workers’ cars taking all available spaces.  Such impacts to surrounding neighborhoods should be prevented as they are so easily anticipated.   

·    We are concerned about the impact of increased traffic on the access of emergency vehicles (i.e., ambulances, fire trucks) to and from our neighborhood.

·    As stated above, we support any measures internal to NNMC that reduce the amount of traffic on the roads surrounding NNMC.  As part of this effort, we encourage consideration of easily accessible areas on the NNMC campus for automobiles and buses to drop off and pick-up employees and visitors.

·    We strongly support the performance of an updated traffic study that accurately reflects the traffic patterns over a number of days, instead of the studies that are for a limited period of time over one day.  Only with full and accurate information can NNMC develop an adequate traffic mitigation plan that will benefit not only nearby roadways but also access to the NNMC campus.

·    We recommend creating a process for inclusion of community feedback into the planning and implementation after the final EIS is issued.

Specific Comments

·    It appears that the EIS traffic studies for each intersection (Appendix B to the Transportation Study) are only one day studies over limited time frames and do not accurately reflect actual traffic patterns in the area. It would be better to perform additional studies to confirm traffic volumes and flow.

·    The traffic counts and studies appear to ignore the traffic that currently cuts through the Locust Hill neighborhood in the morning and significantly in the evening.  Therefore, the count of the turns made at the intersection of Cedar and Rockville Pike cannot be accurate and, we believe, must significantly underestimate those counts.  For example, in 2005 the Maryland State Highway Association (SHA) performed a whole day study which showed that on regular weekdays from 2PM to 7PM there are between 80 and 100 vehicles per hour (many are vans and small trucks) turning into our neighborhood from Rockville Pike to Cedar Lane, a significant number of which are “cutting through”.  This was after SHA had lifted a restriction prohibiting left turns from southbound Rockville Pike to Cedar Lane from 4PM to 6PM.  Please note that this traffic still cuts through even though there are signs prohibiting such traffic movements from 3PM to 7PM (there are signs facing southbound traffic on Rockville Pike that state: No Access to Cedar Lane from 3PM to 7PM).   In our view this cut though traffic has only gotten worse since 2005.  The BRAC will only increase the pressure to cut through our neighborhood.  Ensuring that the intersections at Cedar Lane and Rockville Pike and the entrances and exits to NNMC and NIH are functional is critical.

·    We believe that the EIS suggestion of an additional left-turn lane along the westbound approaches of Cedar Lane at Rockville Pike (a proposed Short Term Mitigation Measure) is based upon faulty assumptions made in the EIS traffic study. The traffic study diagrams only one existing left turn lane from westbound Cedar Lane onto Route 355, when two existing left turn lanes now exist. If a corrected traffic study concludes that a third left turn lane would be beneficial, we encourage considering use of the existing 3 lanes as left turn lanes, at least for the necessary rush hours, in order to eliminate the negative impact of adding lanes, such as the loss of the well traveled bike path along Cedar Lane, and damage to the parkland, woodlands, wetlands and creek that run along the north side of east Cedar Lane.  As an adjoining neighborhood to this intersection, we strongly recommend involvement of our community in any study of lane changes to this intersection.

·    While the EIS makes no recommendation concerning a grade separated interchange at Cedar Lane and 355, we note that it does mention the County’s plans for an interchange at that intersection.  Our neighborhood is directly adjacent to this intersection and, therefore, we are very interested in any plans for changes at the intersection.  We strongly encourage further study of any proposal for such an interchange at Rockville Pike and Cedar Lane so that any and all effects on our community, nearby neighborhoods, the adjoining parkland, creek and bike and walking paths (used daily by commuters), and traffic flow are fully considered.  As an adjoining neighborhood, we feel strongly that we should be involved in any changes to and studies of this intersection.

·        We are concerned about the impact of another traffic signal at the intersection of Rockville Pike (MD 355) and North Wood Road and the NIH Commercial Vehicle Inspection Station.  The EIS proposes conducting a full intersection study, including a traffic signal warrant analysis for this location, and implement identified geometric and/or signalization improvements (proposed Short Term Mitigation Measure).  Any such study must consider the impact of traffic backing-up and increasing “cut through” traffic in the affected neighborhoods.

·    We are very concerned about the impact of the construction at NNMC because of our experience with recent construction projects at NIH.  Parking by workers needs to be considered and managed so that they do not use our neighborhood as a parking lot.  Also, we are concerned about trucks parking here as well.

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      LHCA appreciates the great deal of work that has clearly gone into the EIS.  We remain optimistic that with appropriate coalition building of all of the stakeholders to this BRAC that the realization of the goal of a world-class facility at the NNMC will be welcomed with pride as a member of our neighborhood.

      Thank you for consideration of this submission.

            Respectfully submitted,

            Locust Hill Citizens Association