February 24, 2011

Denise Decker
NEPA Team Lead, GSA NCR
c/o Shirley Walker
301 7th Street, SW, Room 6628
Washington, DC 20407

VIA ELECTRONIC MAIL: denise.decker@gsa.gov

RE: St. Elizabeth’s Draft EIS Comments

Dear Ms. Decker:

Thank you and GSA for the opportunity to provide comments on behalf of WABA’s
regional members and supporters. We have reviewed the draft EIS in detail, and
greatly appreciate the willingness of GSA staff and consultants in answering our
questions during the public review and comment period.

Initially, WABA had expressed strong concern that the District of Columbia’s
proposed South Capitol Street Trail was not included in the draft EIS, and potential
impacts of the development on the proposed trail were not evaluated. In meetings
this month, GSA assured WABA that the while the South Capitol Street Trail was not
included in the DEIS because the plan had not yet been finalized, impacts on the
trail have been considered.

Substantively, GSA informed WABA that no proposed alternative would preclude the
completion of the trail, but that either build alternative would result in one pinch-
point that will likely limit the trail’s width to 7.5 feet.

First, this information and evaluation should appear in the final EIS, with impacts on
the South Capitol Trail clearly studied and detailed, as it clearly meets the threshold
for analysis under NEPA. But more substantively, our goal is to improve conditions
for cyclists through this portion of the District of Columbia, and to enable a safe,
viable connection from southern Prince George’s County and the Wilson Bridge Trail
to and from downtown DC. Restricting the width of a major regional trail to 7.5 feet
—below minimum AASHTO standards—limits the trail’s capacity in a way that may,
in the long-term, impose limits on its utility for regional travel.

In addition, we appreciate GSA’s inclusion of a bicycle path east of the Anacostia

Freeway as part of its own project. Regardless the status of the South Capitol
Street Trail, connection across the Freeway to access the St. Elizabeth’s campus
and other neighborhoods will remain difficult, and an alternate trail is an excellent
approach. While we understand the need for security near the St. Elizabeth’s
facility, if this is to be characterized as a legitimate bicycle route, it should be
accessible and rideable at all times to enable predictable travel. We are concerned
about mandatory “stop and walk” areas, and the potential for other disruptions of a
sort that would never be considered for application to any other mode of travel.

Again, we appreciate your willingness to communicate with us during the public

evaluation period, and we ask that you continue to work to minimize the project’s
constriction of the South Capitol Street Trail, and to make the proposed bicycle
facility within the GSA project a more functional transportation artery for the region.

Sincerely,

Shane Farthing
Executive Director