Category: Environment

Arlington’s Storm Water Budget Balloons Due to Runoff Inducing Tree Removal

Comments at Capital Budget (CIP) Hearing, June 30, 2020.

The proposed FY 2021 CIP shows a refreshing change of direction from funding overbuilt boondoggles to paying down basic infrastructure. The County Manager estimates that up to $200 million will be spent on stormwater facilities over the next ten years (p. 11).

No one who witnessed the July 8, 2019 flood would doubt the wisdom of this critical investment. What I quarrel with is the cost. Much of the infrastructure to be constructed consists of low-impact-development (LID) Best Management Practice (BMP) facilities such as: pavers, cisterns, bioretention basins, swales, planters, green roofs and rain gardens.

According to Stormwater Magazine (Table 1), the average capital cost of LID BMPs was around $6.40 per gallon in 2013 or about $7 today.

According to the National Tree Benefits Calculator the average 40 inch hardwood will intercept 19,000 gallons of storm water runoff per year. Assume for the sake of argument that a LID facility needs to capture only ten percent of that amount in one major rain event each year.

Based on the following additional assumptions:

  • 1000 trees recently removed from public property
  • O&M costs at 10% of capital cost
  • system maintenance for ten years

a lowball estimate of the cost of the additional stormwater facilities needed to mitigate runoff due to tree removal is:

  • $13.3 million in capital costs
  • $13.3 million O&M for 10 years of operations, or $26.6 million total.

This may not sound like a lot in a ten-year CIP pegged at $330 million (Appendix A). But it is money that could be better spent on schools, parks, street paving, and walkable streets.[i]


[i] Capital Cost=19,000 gal. runoff/yr. * $7/gal. * .1 capture factor * 1,000 mature trees=$13.3 million

Operating Cost=$13.3 million capital cost *.1 O&M factor * 10 years=$13.3 million

NOVA Parks CEO Says Not to Worry About Doubling Width of W&OD Trail

Reply to Paul Gilbert, June 3, 2019.

In recent commentary in the Sun Gazette, NOVA Parks’ CEO Paul Gilbert argued that concerns about doubling the paved width of the W&OD Trail are misplaced, because NOVA Parks plans to improve storm water management. First, how is the public to assess this claim when neither a preliminary design nor an environmental assessment have been produced?

Second, Gilbert claims that a combination of swales, meadows and wetlands will be installed to control runoff. Yet on a one mile stretch of the widened trail between East Falls Church and Bon Air Park—half the length of the project area–there is no room to put in these structures without ripping out the existing rain absorbing understory along Four Mile Run.

Gilbert allays concerns about tree removal, saying that only 7 mature trees are slated for removal from the trail widening project west of Lee Highway. This is not the scenario relayed by Falls Church residents in a recent letter to the editor of the Falls Church News-Press, who oppose “the proposed elimination of valuable, usable space, and natural assets, including almost 100 trees (oaks, cedars, maples, Japanese cherry, dogwoods, etc.) and bushes adjacent to the proposed trails.”

Gilbert says that trail widening is environmental, because it will induce more bike and foot traffic. Yet NOVA Parks refuses to consider the less damaging alternative of redirecting foot traffic to the adjacent Four Mile Run Trail.

Mr. Gilbert indicates that dual trails are the wave of the future, and Arlingtonians should get on board. I’m all for dual trails, namely an existing paved trail on either side of Four Mile Run. I also insist on a full environmental assessment including an alternatives analysis for W&OD trail improvements.

NoVA Parks Wants to Double Width of W&OD Trail in Arlington Flood Zone

Comments to Northern Virginia Transportation Authority (NVTA), May 23, 2020

Greater Greater Washington (GGW) has trotted out the commentary of deceased, former Arlington County Board member Erik Gutshall to defend NOVA Parks’ plans to widen a two mile stretch of the W&OD Trail between East Falls Church and Carlin Springs Road.

In November, 2019 Gutshall marveled that bike advocates and environmentalists were pitted against each other on the wisdom of widening the W&OD without the benefit of an alternatives assessment or an environmental impact statement. In his mind, biking is good for both the environment and congestion relief. So everyone should be on board.

Yet it is well known that pavement induces runoff, and runoff induces flooding, which is not good for the Chesapeake Bay watershed. It is also known that the closer the pavement gets to a Chesapeake Bay tributary like Four Mile Run, the more runoff it induces.

Evidence of that phenomenon occurred during the July 8, 2019 DC area flood event. Runoff from I-66 put an entire Arlington neighborhood north of the interstate under water. Yet an equal if not greater amount of damage occurred along the existing W&OD bike trail when Four Mile Run breached its banks—taking with it tons of infrastructure from two County parks—including part of the trail–and pouring thousands of gallons of polluted water into the Potomac River.

Doubling the width of the W&OD Trail can only exacerbate an already hazardous situation, where erosion of the Four Mile Run stream bank is now a common occurrence. Yet GGW says that opposition to the project is premature, as it hasn’t even been funded. This turns logic on its head, since without a study assessing impacts and alternatives, NTVA cannot know what it should fund.

When NOVA Parks gets $5.6 million to widen the W&OD Trail, alternatives like using the parallel Four Mile Run Trail to mitigate congestion will be off the table. The money for the project has already been earmarked. So reprogramming it on something better or different isn’t going to happen even if a future environmental assessment recommended it.

Pointing to trail work done on widening the trail in West Falls Church, GGW insists that the storm water mitigation will be adequate. Even though Falls Church neighbors are protesting massive tree removal along the trail west of Lee Highway, the impact on the Four Mile Run itself might be limited, since the stream surfaces only a short distance from the trail head at Lee Highway.

Not so the impact of the trail east of Lee Highway, which is located in a stream valley and a flood zone. For a full mile between East Falls Church and Bon Aire Park, the trail is sandwiched between the I-66 retaining wall a few feet to the left and Four Mile Run a few feet to the right. There is no place to divert the stream let alone plant trees or add to the under story.

Finally GGW argues that widening the trail will provide congestion relief. Yet the Toole Design report commissioned by NOVA Parks to support the project indicates much of the traffic along the trail is recreational rather than commuter.

Thus even if this stretch of trail is congested some of the time, NOVA Parks has not demonstrated that widening the trail will provide congestion relief relative to cost (CRRC) on nearby roads. Without that key metric, NVTA cannot legally fund this project.

Northern Virginia Stream Bank Restoration Projects Do More Harm Than Good

Comments at Arlington County Board Meeting, May 16, 2020

A letter to the editor in this week’s Mount Vernon Gazette entitled “Wrong Approach for Stream Restoration” (pp. 6-7), deplores misguided stream “restoration” projects in our region.  

According to author Rod Simmons, a Fairfax County environmental consultant, the LTE, “identically applies to . . . the currently planned upper Donaldson Run and Gulf Branch projects in Arlington County, as well as virtually all other upper headwater stream projects in our region.”

He says: “The biggest problem with the so-called natural channel design approach to stream “restoration” for us in the greater Washington, D.C. region is that it is planned and implemented in completely the wrong places: small order, interior forested, upper headwater streams and wetlands. Natural channel design (i.e. the Rosgen method) is mainly applicable to large order streams and rivers, especially the kind one finds in the American west. Applying it to small order, upper headwater stream channels of the deeply dissected Fall Zone of our area is a misuse of the methodology, a misunderstanding of eastern Fall Zone hydrology and stream geomorphology, a sure recipe for failure, a mismanagement of public funds by inappropriately targeting sediment-control projects in places with low levels of the very nutrients for which funding is based, and an unacceptable loss of irreplaceable native forest, wildlife, and landscape memory.

“The controversial Hollin Hills stream construction projects in the Little Hunting Creek watershed of Fairfax County, Virginia embody the worst elements of these misguided land use projects at virtually every level, from land giveaway to project planning to backing by elected officials.”

According to Suzanne Sundburg, “the science is clear. Privatizing stream ‘restoration’ has perverted its original intent. No matter how well intentioned, the process — as currently practiced in Arlington and elsewhere — it is incredibly destructive to holistic stream and riparian ecology.

“Corrective measures made solely to the receiving streambed will never correct the root cause: steadily increasing inputs of runoff volume and speed, fueled by increasing impervious surfaces and the loss of mature tree canopy throughout the watershed.”

More Trees To Be Removed From Flood Prone County Park

Excerpts from Suzanne Sundburg’s letter to Arlington County Board dated September 23, 2019.

Benjamin Banneker Park contains a formally documented FEMA floodplain, a floodway and a county-identified resource protection area (RPA). Yet even after the July 8 flash flood, the County plans to remove a large number of mature trees and significantly increase impervious surfaces.

I wish that I could tell you how many trees will be removed. However, no tree survey appears to be publicly available. It’s not contained in the staff report for 12-16-17, when the County Board reviewed the framework [for the park]. And the current staff report actively avoids providing this information, even as an attachment.

A reference is made to E2C2’s inquiry about the lack of information on tree removal, among other things, but there is no indication that E2C2’s questions were ever actually addressed. The environmental assessment (EA) referenced in the current staff report isn’t posted to the project web page, nor is the environmental assessmen (EA) posted to E2C2’s web page.

Nowhere do I see a calculation of the amount of carbon dioxide (CO2) that will be re-emitted into the atmosphere when the trees at Benjamin Banneker are removed, even though there are electronic models that would enable staff to calculate the stored carbon.

In its January 28, 2019 presentation to E2C2, staff briefly mentioned the removal of the existing homes on the parcels acquired in order to “increase [the] park[‘s] infiltration ability.” So far, so good.

But staff has yet to explain how removing mature trees, enlarging and paving the current semi-pervious gravel parking lot, and widening paved trails will improve infiltration and won’t exacerbate existing stormwater runoff and flooding problems. 

When will staff and the board begin to discuss the elephant in the room? How much more flood damage will it take? Must we wait for documented drowning fatalities before the board takes action?

This quote seems appropriate: 

“I don’t want you to listen to me. I want you to listen to the scientists.” —Greta Thunberg

PRESS RELEASE: School Board Votes to Remove More Trees

On September 19 Arlington School Board voted to remove dozens of trees from the construction site of the new Reed School in Westover, including most of a grove of majestic hardwoods that have provided shade and quiet enjoyment for generations of students and local residents.

Arlington Public Schools (APS) claims that the destruction is necessary to install geothermal infrastructure, a play ground, and a walkway around the school. At a tour of the site on September 16 that attracted dozens of angry Westover residents, school officials expressed frustration that neighbors waited so long to voice their concerns.

Residents countered that they had raised objections during the planning process, but their objections had been ignored. This sounds like a familiar refrain. The County routinely justifies unpopular decisions by insisting that it sought public input and casting those who object as NIMBYs. Yet even without local opposition, the notion that tearing up a wooded lot is needed to install renewable energy is downright perverse.

It is also self defeating. The National Tree Benefit Calculator indicates that the loss of the 42-inch red maple and the 54-inch silver maple on the site, alone, will generate over 33,000 gallons of additional unintercepted storm water. The end result will be higher peak flood levels, such as the July 8 flash flood that inundated Westover Market across the street from Reed School.

The notion that the saplings APS will install at Reed School can replace mature trees is also not supported by the facts. A USDA Forest Service publication calculates that a 40-year-old red maple absorbs 11,577 gallons of water–almost 4 times the capacity of a 20-year-old red maple (Table A1, p. 64).

National statistics clearly correlate tree removal with runoff volume and flooding. How can County Board allow an educational institution dedicated to STEM curricula to disregard the very science that it is teaching?

If elected, I will insist on mature tree preservation as the first line of defense against future flood events. I will also:

  • Say NO to more tax rate increases and a recently authorized County Board pay grab.
  • Preserve green space and emphasize basic services like: streets, schools, libraries and public safety.
  • Promote transparency by requiring publication of official documents at least 72 hours before board and commission meetings.
  • Provide a voice on County Board for all taxpayers

As a 15-year Westover resident, long-time civic activist and current member of the Transportation Commission, I have both the experience and independence to promote these reforms.

PRESS RELEASE: Infill Development a Factor in July 8 Flood

In the wake of the catastrophic July 8, 2019 flood that inundated neighborhoods throughout Arlington, County government responded proactively. The County:

  • declared an emergency;
  • cleaned up debris;
  • posted information for affected residents and businesses on its website; and
  • pledged to re-prioritize needed investments in storm water infrastructure.

These measures were welcome and necessary. Yet my Arlington County Board opponents refuse to acknowledge that massive infill development contributed to the flood by destroying mature tree canopy and increasing runoff-inducing impervious surface.

In fact they actively dispute the loss of tree canopy throughout the County and attribute increased impervious surface to by right developments that they can’t stop.

Westover Park Area Ravaged by Runoff Induced Flood

What my opponents don’t tell you is that they won’t conduct a public hearing on a 2016 citizen petition to preserve the remaining Westover garden apartments as historic. Their refusal to do so has resulted in the demolition of dozens of apartments and surrounding trees in Westover.

Anyone who believes that tree removal and exposed surface at these construction sites did not contribute to the flood should look at this submerged vehicle adjacent to Westover Park downhill from the denuded development site on July 8.

Also neither County Board nor the School Board acknowledge that their own construction activities contributed to massive flooding on July 8. Community activist Suzanne Sundburg has documented that in just 9 development projects on public land between 2014 and 2018, the County lost over 900 mature trees. Clear cutting has occurred at virtually all school construction sites, Lubber Run and Donaldson Run. More is on the way, as the County pushes for infill development and overbuilt parks.

If elected to County Board, I will lobby to stop clear cutting County and privately owned land by insisting on strict adherence to the Arlington Chesapeake Bay Preservation Ordinance, which bars runoff-inducing developments near Potomac River tributaries.

In addition, if elected, I pledge to:

  • Say NO to more tax rate increases and a recently authorized County Board pay grab.
  • Preserve green space and emphasize basic services like: streets, schools, libraries and public safety.
  • Promote transparency by requiring publication of official documents at least 72 hours before board and commission meetings.
  • Provide a voice on County Board for all taxpayers.

As a 15-year Westover resident, long-time civic activist and current member of the Transportation Commission–I have both the experience and independence to promote these reforms.

County Board Dismisses Safety Concerns of 5G

Comments at Arlington County Board Meeting, 7/16/19

Here are some concerns raised by civic activist Suzanne Sundburg on deployment of 5G on Small Wireless Facilities (SWF), which Arlington County Board approved on July 16.

“Whereas the county’s background resources and permit information are interesting, they don’t begin to address the public safety aspect. The FCC’s radiation limits have not been updated since 1996. These limits and most prior research are based on the thermal effects of radiation, which isn’t necessarily applicable to nonionizing radiation like millimeter-wave and submillimeter-wave radiation. Simply because millimeter wave radiation cannot displace electrons from atoms or molecules does not make people’s exposure to it safe.

“An understanding of the risks of physical harm resulting from millimeter wave radiation is just beginning to emerge. These 5G antenna arrays will utilize millimeter waves in roughly the 30 to 100 gigahertz frequency range. Higher frequencies have shorter wavelengths, which pose greater risks to human health. Scientists readily acknowledged that there is too little research on the 5G millimeter wave radiation and antennas to assure the public’s safety and are only just now starting to study the effects of it. To date, the results don’t look good.

“Unfortunately, we cannot rely on federal agencies to protect the public. The FCC, in particular, is essentially captive to the telecommunications industry.

“In fact in February 2019, U.S. Sen. Richard Blumenthal took the FCC and FDA to task for expediting the 5G network’s rollout without having any research to document its safety.

“Likewise, the State of Virginia appears to have punted, providing no additional safety measures/standards or monitoring assistance.

“The telecommunications industry itself has consistently attempted to downplay the radiation health risks of existing technology — risks that are documented by legitimate scientific research.

“Given that:

  • these millimeter-wave 5G arrays will emit radiation 24×7;
  • there is no way for us to protect ourselves from it, and
  • vulnerable populations will be at higher risk

“I don’t believe it’s unreasonable to ask the County how it intends to mitigate that risk. How does it intend to monitor the radiation being emitted in this uncontrolled scientific experiment using us as unwitting human test subjects.”

Dawn Redwood Report Greenwashes Development in Chesapeake Bay Watershed

Comments at Arlington County Board Meeting, 6/15/19

Last week Arlington County issued a long awaited report on how it approved the demolition of a 75 year old Dawn Redwood to make way for the redevelopment of a property on North Ohio Street located in a Resource Protection Area (RPA) in North Arlington.

The County’s Chesapeake Bay Ordinance expressly prohibits redevelopments that increase the amount of runoff inducing impervious surface in RPAs. The report claims that “there was no increase in impervious cover.” So the redevelopment was “allowable”.

Anyone familiar with the North Ohio Street site knows that the McMansion built on it dwarfs the original home that was demolished along with the Dawn Redwood in 2018. How could this oversized structure NOT generate more runoff?

Maps contained in the report, show that the developer, Richmond Homes, subdivided the lot, placing the old property on a parcel inside the RPA perimeter and the new property on an adjacent parcel just outside the RPA. He then demolished the old home along with the redwood, eliminating all impervious surface on that parcel. By this sleight of hand, the new oversized home actually occupies less of the RPA buffer than the original.

A neat trick, one that not only enriches Richmond Homes, but also establishes a precedent for demolishing homes and trees on properties throughout the County that were previously off limits to redevelopment.

If you live adjacent to an RPA and want to make a killing on the sale of your home, rest assured. The County is open for business. If you are the neighbor of such a homeowner, you might also want to sell when the additional runoff impacts your property. As for the Chesapeake Bay Ordinance itself? Well that’s a dead letter.

Boathouse Facility Will Add More Congestion To Rosslyn

Comments At Arlington County Board Meeting, 5/21/2019

I came down with Potomac Fever when I acquired a brand new Folbot folding kayak in 1997, and I’ve been paddling on the Potomac ever since. While there is no cure for Potomac Fever, paddling alleviates the symptoms. So I was enthusiastic about National Park Service (NPS) plans to construct a boathouse in Arlington.

Nevertheless I’m concerned about the health of the Potomac, specifically the impact of dredging the channel between the proposed dock and Teddy Roosevelt Island and traffic congestion in the nearby. The Gravelly Point alternative has neither of these impacts. Yet NPS rejected it because of occasional strong river currents and lack of access to public transportation at that location.

An experienced rower recently advised me that the Rosslyn location is unsuitable for rowing teams, because the channel between the Rosslyn site and Teddy Roosevelt Island is too narrow to maneuver large boats. Also, while river currents are a factor for small craft at Gravelly Point, they have little impact on large sculls. Likewise since high school rowing teams would be transported to Gravelly Point by bus, the lack of immediate access to transit is immaterial, and ample parking already exists for anyone who drives.

The Rosslyn alternative will put an ancillary administrative facility on a wooded area at the intersection of Lee Highway and Lynn Street near Key Bridge. This facility, the need for which has never been demonstrated, will exacerbate both congestion and runoff in a resource protection area and turn Key Bridge into a traffic nightmare during rush hour.

Today’s vote to approve an agreement with NPS to construct the Rosslyn facility is strictly pro forma. The train has left the station, but only because Department of Parks and Recreation never saw a park it didn’t want to pave over, and County Board never saw a boondoggle it didn’t want to buy. Nevertheless I think that those who live and work in Rosslyn should know that there was a reasonable alternative to more traffic congestion at Key Bridge and further degradation of the Potomac River.

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