Appendix E_National Park Service Environmental Assessment.pdf

National Park Service U.S. Department of the Interior

George Washington Memorial Parkway Washington, DC and Virginia

FINDING OF NO SIGNIFICANT IMPACT

GEORGE WASHINGTON MEMORIAL PARKWAY SOUTH SECTION

AND MOUNT VERNON TRAIL IMPROVEMENTS PLAN

GEORGE WASHINGTON MEMORIAL PARKWAY

Washington, D.C., and Virginia

The National Park Service (NPS), in cooperation with the National Capital Planning Commission (NCPC), prepared an Environmental Assessment (EA) to evaluate the impacts that would result from implementing the George Washington Memorial Parkway (Parkway) South Section and Mount Vernon Trail (MVT) Improvements Plan (Plan). The Plan will guide future actions to improve the roadway and trail while maintaining the scenic and historic character of the Parkway.

The NPS has not comprehensively rehabilitated the Parkway South Section since its original construction in 1932. The NPS completed a corridor-wide pavement restoration in 1986 that involved repairing concrete slabs and replacing those that were beyond repair. The existing pavement has received only minor spot repairs since then, and recent inspections have rated the concrete pavement as being in overall “fair” condition with several segments that are in poor condition. Accelerating deterioration of the pavement and joints, and undermining caused by poor drainage conditions, are requiring frequent maintenance, such as interim asphalt patching. As such, the Plan involves comprehensive rehabilitation of the Parkway South Section, including complete replacement of the deteriorated road surface (concrete slabs), repairs or replacement of drainage structures, establishment of clear zones, and bridge rehabilitation. The Plan also includes various safety improvements, such as implementing a permanent road diet, intersection modifications, and establishing bicycle / pedestrian crosswalks that comply with the latest Architectural Barriers Act Accessibility Standard (ABAAS) at the time of design / construction, while seeking to find an appropriate balance between improving visitor safety and resource preservation / protection.

The Plan also includes rehabilitation and safety improvements to the MVT across all NPS-administered sections. Constructed in the 1970s and 1980s before there were accepted trail standards, the MVT is relatively narrow and is characterized by meandering curves (some with steep down grades and poor sight distance), deteriorating pavement and timber bridges, and in some areas dense overhanging vegetation that result in the potential for user conflicts and crashes to occur. Growing usage of the MVT, particularly during commuting periods, contributes to trail crowding, user conflicts, and crashes. The asphalt trail surface has also deteriorated, and tree roots uplifting the trail are causing safety concerns. As such, the Plan involves rehabilitation of the MVT; geometric changes, such as trail realignments and widening; trail bridge replacement or rehabilitation; trail intersection treatments; drainage improvements; vegetation management; and trail amenity upgrades to improve safety and the visitor experience and to extend the service life of the MVT and minimize future maintenance requirements.

The EA was prepared in accordance with the National Environmental Policy Act (NEPA) of 1969 as implemented by Council for Environmental Quality regulations (40 CFR 1500-1508); NPS Director’s Order #12: Conservation Planning, Environmental Impact Analysis, and Decision-Making; and the NPS NEPA Handbook. Compliance with Section 106 of the National Historic Preservation Act (NHPA) of

GEORGE WASHINGTON MEMORIAL PARKWAY SOUTH SECTION AND MOUNT VERNON TRAIL IMPROVEMENTS PLAN - FONSI

1966, as amended, and Section 7 of the Endangered Species Act, was conducted concurrently with the NEPA process. The statements and conclusions reached in this Finding of No Significant Impact (FONSI) are based on documentation and analysis provided in the EA and associated decision file. To the extent necessary, relevant sections of the EA are incorporated by reference.

PUBLIC AND AGENCY INVOLVEMENT

Public Scoping – As part of the NEPA process and to comply with the requirements of Section 106 of the National Historic Preservation Act, the NPS involved the public in project scoping by holding a public comment period from December 6, 2022, to January 18, 2023. The NPS held a stakeholder meeting on December 2, 2022, at the start of the scoping period, as well as a virtual public meeting on December 6, 2022, using the GoToWebinar platform. The public scoping comment period and virtual meeting were announced by sending an electronic notice through the GovDelivery web-based email subscription management system used by the National Capital Region. The NPS sent the notice to 735 email addresses that included elected officials, agency and tribal representatives, stakeholders, and other potentially interested individuals. The notice included a link to a public scoping letter from the Superintendent that was also posted at the NPS Planning, Environment and Public Comment (PEPC) project webpage, along with relevant planning documents. The NPS also distributed a press release that was posted in the “News Releases” section of the official Parkway website. The presentation used during the virtual public meeting, a recording of the meeting, and the scoping letter remain available at the PEPC project webpage:

https://parkplanning.nps.gov/GWMP_South. The NPS received 700 separate correspondences during the comment period.

EA Public Review – The EA was made available for public review from September 25 to October 24, 2023, at the PEPC project webpage: https://parkplanning.nps.gov/GWMP_South_EA. The EA public review period was announced on the PEPC project webpage and by news release and email blast. A total of 469 separate correspondences were received during the EA public review period. Responses to substantive public comments are provided in Attachment C.

National Historic Preservation Act, Section 106 Consultation – Pursuant to Section 106 of the National Historic Preservation Act and its implementing regulations (36 CFR Part 800) “Protection of Historic Properties,” the NPS initiated consultation with the Virginia Department of Historic Resources (VDHR) and the District of Columbia Historic Preservation Office (DCHPO) in letters dated November 4, 2022. The letters described the proposed Plan improvements, defined a draft Area of Potential Effect (APE), and identified known historic properties within the APE. VDHR acknowledged receipt of the initiation letter on December 7, 2022, and had several questions regarding the draft APE. The NPS provided responses to VDHR’s comments in a letter dated January 13, 2023. The DCHPO acknowledged receipt of the initiation letter on December 9, 2022. The consultation letters and responses are provided in Attachment E.

The NPS held a Section 106 consulting parties’ meeting on August 9, 2023, to review an Assessment of Effects (AOE) Report that was prepared to assess whether the proposed undertaking may alter, directly or indirectly, any of the characteristics of a historic property that qualify it for inclusion in the National Register of Historic Places (National Register) in a manner that would diminish the integrity of the property’s location, design, setting, materials, workmanship, feeling, or association. The AOE Report was sent to VDHR, DCHPO, and other consulting parties in advance of the meeting and was made available for public comment at the PEPC project webpage until September 1, 2023. The report remains available for review at: ParkPlanning - GWMP South Section & MV Trail Improvement Assessment of Effect (nps.gov).

The NPS determined that the Plan would potentially have adverse effects to historic properties due to the planned ground disturbing activities, which may affect archeological resources that are eligible for listing in the National Register. The Plan calls for the rehabilitation of Parkway and MVT elements that have yet to be designed and should designs not be in adherence to the Secretary of the Interior’s Standards for the Treatment of Historic Properties (SOI Treatment Standards), the Plan could diminish the design and aesthetic character of the Mount Vernon Memorial Highway and Parkway historic properties. As such, the NPS, NCPC, and VDHR entered into a programmatic agreement to establish a consultation process https://parkplanning.nps.gov/GWMP_South_EA https://parkplanning.nps.gov/GWMP_South for the implementation of the Plan to conduct phased identification and evaluation, per 36 CFR 800.4(b)(2), and to avoid, minimize, or mitigate potential adverse effects pursuant to 36 CFR 800.14(b)(3), which will satisfy NPS’s and NCPC’s obligation to comply with Section 106. The DCSHPO declined to participate in the programmatic agreement in an email dated September 18, 2023.The final, fully executed programmatic agreement and associated correspondence are included in Attachment D.

Tribal Consultation – Tribal consultation initiation letters were sent to the Pamunkey Indian Tribe, Upper Mattaponi Indian Tribe, Rappahannock Tribe, Nansemond Indian Nation, Chickahominy Indian Tribe, Chickahominy Tribe Eastern Division, Monacan Indian Nation, Catawba Indian Nation, Delaware Nation, Absentee Shawnee Tribe of Indians of Oklahoma, and Shawnee Tribe. The NPS received a response from the Delaware Nation on November 21, 2022, accepting the invitation for consultation on the project. The Monacan Indian Nation responded in an email dated August 7, 2023, that they did not wish to participate in consultation because impacts are anticipated to be minimal. In an email sent on August 30, 2023, the Shawnee Tribe declined to participate in consultation because the project falls outside of their area of interest. The consultation letters and responses are provided in Attachment E.

Endangered Species Act, Section 7 Consultation – In accordance with Section 7 of the Endangered Species Act, an official species list was obtained through the US Fish and Wildlife Service’s (USFWS) Information, Planning, and Consultation (IPaC) System on June 7, 2023, that identified the federally listed endangered northern long-eared bat (Myotis septentrionalis) and the federally proposed endangered tricolored bat (Perimyotis subflavus) as potentially occurring within the Plan implementation area. The NPS ran through the northern long-eared bat determination key in IPaC, which resulted in a May Affect determination. However, because several conservation measures will be implemented, including a time of year restriction on tree removal, the NPS requested concurrence of a May Affect, Not Likely to Adversely Affect determination for the northern long-eared bat in a consultation package sent to USFWS on August 29, 2023. The conservation measures proposed by NPS will also be effective to minimize effects to the tricolored bat. The USFWS Virginia Field Office concurred with the NPS’ determinations in an email dated September 1, 2023, and the USFWS Chesapeake Bay Field Office concurred with the determinations in an email dated October 11, 2023. As directed by the Virginia Field Office, the NPS submitted a self-certification letter to satisfy their Section 7 consultation responsibilities. The consultation package and self-certification letter submitted to USFWS are provided in Attachment E.

ALTERNATIVES CONSIDERED AND SELECTED

The NPS analyzed the No Action Alternative and the proposed Parkway South Section and MVT Improvements Plan (the Proposed Action) in the EA. A detailed description of the alternatives can be found on pages 19-31 of the EA. The No Action Alternative was carried forward to provide a comparative baseline against which to analyze the effects of the Proposed Action (40 CFR Part 1502.14). Based on the analysis presented in the EA, the NPS selected the Proposed Action for implementation.

George Washington Memorial Parkway South Section Improvements – The Selected Alternative will replace the deteriorated concrete road surface, gutters, and mountable curbs where they are present. The Selected Alternative will resolve drainage issues by repairing or replacing drainage structures (e.g., culverts, ditches, drainpipes, and stormwater inlets), and will incorporate stormwater management best management practices (BMPs) to address water quantity management and water quality treatment, as needed. The Little Hunting Creek Bridge, Fort Hunt Overpass Bridge, Alexandria Avenue Overpass Bridge, and Hunting Creek Bridge will be rehabilitated based on Federal Highway Administration recommendations. Other roadway infrastructure improvements that will be implemented under the Selected Alternative are described on pages 19 and 20 of the EA.

The Selected Alternative will implement a road diet between Mount Vernon and Belle View Boulevard in the southbound direction, and between Mount Vernon and Tulane Drive in the northbound direction, using pavement striping and signage to reduce the number of travel lanes to one lane northbound and one lane southbound. The additional pavement area will be reallocated to establish two right-hand shoulders or dedicated right-turn lanes at southbound intersections, as well as a striped median or center turn lane.

In conjunction with the proposed road diet, the Selected Alternative will modify several intersections to improve safety at Stratford Lane, Vernon View Drive, Waynewood Boulevard, Collingwood Road, Wellington Road, Outlet Road / East Boulevard Drive, the access to West Boulevard Drive, Morningside Lane, Tulane Drive, Belle View Boulevard, the Belle Haven Marina driveway, and Belle Haven Road.

Figures depicting concept-level redesigns for each intersection are provided in Appendix B of the EA. In addition, the Selected Alternative will establish crosswalks at the Stratford Lane, Vernon View Drive, Collingwood Road, Wellington Road, Outlet Road / East Boulevard Drive, Tulane Drive, Belle View Boulevard, the Belle View Marina Driveway, and Belle Haven Road intersections that comply with the latest ABA Accessibility Standards at the time of design / construction, while seeking to find an appropriate balance between improving visitor safety and resource preservation / protection. Other roadway and intersection safety improvements that will be implemented under the Selected Alternative are described on pages 22-24 of the EA.

MVT Improvements – The Selected Alternative includes rehabilitation and minor realignments of the asphalt pavement surface of the MVT, trail spurs, and exit / entry paths. The NPS will incorporate stormwater management BMPs, potentially replace existing inlets and culverts, construct new ditches where appropriate, clear or regrade existing ditches, and conduct other miscellaneous work to improve drainage and alleviate ponding issues along the MVT under the Selected Alternative. The Selected Alternative will also widen the MVT from the typical 8–9-foot width to a maximum width of 10 feet in Zone 1, and to a maximum width of 12 feet in NPS-administered portions of Zones 2 and 3, depending on physical and environmental constraints, to meet American Association of State Highway and Transportation Officials (AASHTO) recommendations for multi-use trails. An updated AASHTO Guide is expected to be published in the near future, so the NPS acknowledges there is potential for standards to change between the development of the EA and design / construction. The NPS and FHWA will determine the best approach for balancing current and / or updated AASHTO guidance with context sensitive design for the MVT improvements.

The Selected Alternative will replace four trail bridges that are in poor condition with new structures that are 14 feet in width from rail-to-rail to meet current AASHTO standards for multi-use trails. The NPS will review the updated AASHTO Guide when it is published to evaluate if design standards should be modified for the MVT improvements. The Selected Alternative will also repair 29 trail bridges that do not require full replacement. The trail section on the Humpback Bridge and the Rosslyn trail bridge north of the Theodore Roosevelt Island parking lot will also be rehabilitated. The locations of the trail bridges to be replaced or repaired are provided on the project mapping located in Appendix C of the EA. Some additional details on proposed bridge rehabilitation activities can be found on pages 26 and 27 of the EA.

The Selected Alternative includes possible trail realignments, trail roundabouts, measures to address pinch points at site-specific locations, and treatments to reduce shared-use conflicts along the MVT as identified on pages 27 and 28 of the EA. Additionally, signing and striping will be improved along the entire trail length, and trail crossings will be improved to comply with the latest ABAAS at the time of design / construction, and to incorporate additional traffic calming and safety measures. The Selected Alternative will replace / upgrade trail amenities, support several new Capital Bikeshare Stations, permanently remove the existing vault toilet facility at Riverside Park, and conduct minor curb and striping improvements in the Theodore Roosevelt Island parking lot to meet the latest ABA Accessibility Standards and improve safety. The Selected Alternative will also clear dense vegetation that is encroaching on the trail. Improvements will also be made at Gravelly Point, including installing a separated pedestrian sidewalk along the east side of the parking lot connecting the MVT to a new permanent restroom facility that will be constructed. See Appendix B of the EA for a concept-level design of the proposed improvements at Gravelly Point.

RATIONALE FOR DECISION

The NPS identified the Parkway South Section and MVT Improvements Plan as the Selected Alternative because it meets the project purpose and need by addressing deferred maintenance and safety issues while maintaining the scenic and historic character of the Parkway and resulting in minimal environmental impacts. The No Action Alternative does not satisfy the need for the project because the Parkway South

Section and MVT would continue to deteriorate, requiring frequent maintenance, and current safety issues would not be addressed.

ALTERNATIVES DISMISSED FROM FURTHER CONSIDERATION

As discussed on pages 31-33 of the EA, the NPS considered a wide range of alternative elements and management strategies for the proposed Parkway South Section and MVT improvements that were ultimately dismissed from further consideration. The George Washington Memorial Parkway: Traffic and Safety Context Sensitive Solutions Assessment completed by FHWA in 2021 identified 89 potential solutions to address traffic and safety along the Parkway South Section, including access management strategies such as roundabouts, traffic signals, and other access management strategies were dismissed from further consideration because they were not within the context of maintaining the Parkway’s scenic and nationally significant historic character, or because there would be unacceptable environmental or right-of-way impacts. Furthermore, the NPS considered widening the MVT to as much as 14 feet, however, this alternative was dismissed because of unacceptable impacts to sensitive natural resources, more extensive stormwater management BMPs that would be required, the increased likelihood of archeological resource impacts, and unnecessary alterations to the cultural landscape of the Parkway.

MITIGATION MEASURES

The NPS places a strong emphasis on avoiding, minimizing, and mitigating potentially adverse impacts to affected resources, whether under the jurisdiction of the NPS or as a result of an NPS decision. To help ensure the protection of cultural and natural resources and the quality of the visitor experience, the NPS will implement mitigation measures to avoid and / or minimize impacts. Mitigation measures of the Selected Alternative are provided below in Attachment A. These mitigation measures will allow the NPS to meet its conservation mandates as required by the NPS Organic Act (16 USC 1 et seq.) and minimize disruption for park visitors. Exact mitigation measures to be implemented will depend upon the final design and plan review / approval by the NPS and NCPC.

WHY THE SELECTED ALTERNATIVE WILL NOT HAVE A SIGNIFICANT IMPACT

As documented in the EA, the Selected Alternative has the potential for adverse and beneficial impacts on visitor use, experience, and safety (see EA pages 35-44); vegetation (see EA pages 44-49); wildlife and habitat (see EA pages 49-54); historic districts (see EA pages 54-59); archeological resources (see EA pages 59-61); and cultural landscapes (see EA pages 61-70). Anticipated impacts that will occur are summarized below by resource.

After considering the environmental consequences described in the EA, the NPS has determined that the Selected Alternative and its associated actions will not have a significant effect on the quality of the human environment considering the potentially affected environment and degree of effects of the action (40 CFR 1501.3(b)(7)). Thus, an Environmental Impact Statement (EIS) will not be prepared.

Visitor Use, Experience, and Safety – Under the Selected Alternative, construction activities will disrupt the visitor experience of the scenic roadway and its views, as well as temporarily restrict access to recreational, natural, and cultural areas. Detours and closures on both the Parkway South Section and MVT will result in noticeable disruptions to traffic; however, these adverse impacts would be limited to the duration of construction. Once completed, the proposed improvements will enhance operation of the Parkway South Section and MVT and result in long-term benefits to visitor use, experience, and safety from the implementation of safety measures, including the road diet, intersection improvements, bridge replacement / rehabilitation, increased trail width, and improved trail conditions and amenities.

Vegetation – The Selected Alternative requires approximately 3.5 acres of tree removal to widen the trail, realign the trail at site-specific locations, establish clear zones along the parkway and trail, and from drainage improvements and installation of stormwater management BMPs. The NPS will replace impacted trees and shrubs on a one-to-one diameter at breast height (dbh) ratio, or following the procedures detailed in NCPC’s Tree Preservation and Replacement Resource Guide, resulting in adverse impacts that will be minor. The NPS will avoid impacting trees that are 18-inches diameter and greater as much as possible, avoid impacts to legacy trees, minimize impacts to the critical root zones of trees planned for protection, prevent the establishment of invasive species, stabilize disturbed areas with native vegetation or with non-native, non-invasive plants that are sensitive to the historic context of the cultural landscape, avoid construction-related impacts to wetlands, and conduct rare plant surveys, where necessary, to minimize additional short- and long-term adverse impacts to vegetation.

Wildlife and Habitat – Under the Selected Alternative, vegetation clearing, and the associated loss of habitat, will result in adverse impacts to wildlife that will be minimal because impacted trees and shrubs will be replaced on a one-to-one dbh ratio or following the procedures detailed in NCPC’s Tree Preservation and Replacement Resource Guide. The project is within the range of the federally listed endangered northern long-eared bat (Myotis septentrionalis). However, the Selected Alternative is not likely to adversely affect the northern long-eared bat given that the NPS will implement conservation measures, including presence / probable absence surveys and a time of year restriction on tree removal and bridge rehabilitation work from April 1 to November 14. In an email dated September 15, 2023, the US Fish and Wildlife Service (USFWS) concurred with the NPS’ determination of May Affect, Not Likely to Adversely Affect for the northern long-eared bat. Section 7 consultation correspondence is included in Attachment E. It is anticipated that implementing the April 1 to November 14 time of year restriction on tree removal would also minimize potential effects to the proposed endangered tricolored bat (Perimyotis subflavus) and migratory birds. Also, if any active bald eagle nests are identified in the vicinity of the Selected Alternative, construction will be restricted within the primary and / or secondary buffers of any nest during the breeding season from December 15 to July 15 in accordance with USFWS requirements to ensure that the proposed improvements will not disturb bald eagles or their nests.

Historic Districts and Cultural Landscapes – The Area of Potential Effect for the Selected Alternative includes multiple historic districts listed in the National Register and NPS-designated cultural landscapes.

The Selected Alternative consists of many changes, including physical alterations, within the historic districts and cultural landscapes, such as roadway, trail, and trail bridge infrastructure improvements;

roadway and intersection safety improvements and a road diet; roadway and trail drainage improvements and stormwater management; trail safety, accessibility, and wayfinding improvements; and trail amenity upgrades. These changes will be minor and will be designed in accordance with the SOI Treatment Standards. Also, trail widening will require tree removal that will result in small-scale changes to existing vegetation. While these alterations will have minor localized visual effects, they will not result in effects to significant views or viewsheds. As such, the Selected Alternative will have no adverse effects to historic districts and will not diminish the significance and integrity of cultural landscapes. The NPS, NCPC, and VDHR have developed and executed a programmatic agreement that defines the continued Section 106 consultation process and includes stipulations for design review by consulting parties to ensure adherence to the SOI Treatment Standards and that adverse effects will not occur from those portions of the project that are subject to additional design and refinement, including bridge rehabilitation, drainage improvements, and culvert replacement or repairs. The final, fully executed programmatic agreement is included with the FONSI as Attachment D.

Archeological Resources – Ground disturbance during construction of the proposed improvements has the potential to impact two archeological sites potentially eligible for listing in the National Register and an additional 12 sites identified in a Phase IA archeological overview that have not been evaluated. The NPS intends to develop designs that will avoid impacts to significant archeological sites by relocating improvements outside of archeologically sensitive areas, shifting the trail alignment away from known sites, and reducing the extent of trail widening. If a site cannot be avoided, subsurface investigations will be completed to delineate the site boundaries more accurately and / or evaluate the sites National Register eligibility. An archeological monitoring and discoveries plan may also be used, either in conjunction with pre-construction investigations, or as an alternative, to aid in reducing and avoiding impacts to archeological resources during construction. Since the extent of archeological resource impacts is unknown at this time, the NPS, NCPC, and VDHR have developed and executed a programmatic agreement that defines the continued Section 106 consultation process and includes strategies to avoid, minimize, and mitigate the adverse effects that may result to archeological resources after additional survey and subsurface investigations are conducted during the design phase. The final, fully executed programmatic agreement is included with the FONSI as Attachment D.

CONCLUSION

As described above, the Selected Alternative does not constitute an action meeting the criteria that normally requires preparation of an EIS. The Selected Alternative will not have a significant effect on the human environment in accordance with Section 102(2)(c) of NEPA.

Based on the foregoing, it has been determined that an EIS is not required for this project and, thus, will not be prepared.

Digitally signed byCharles Charles Cuvelier Date: 2024.01.09Cuvelier 13:19:08 -05'00' Recommended: __________________________________ ________________

Charles Cuvelier Date Superintendent George Washington Memorial Parkway National Capital Region

Digitally signed byKIMBERLY KIMBERLY HALL Date: 2024.01.18HALL 16:52:45 -05'00'Approved: ______________________________________ ________________

Kym A. Hall Date Regional Director National Capital Region

Attachment A: Mitigation Measures

Attachment B: Non-Impairment Determination

Attachment C: Concern Statements and Responses

Attachment D: Section 106 Programmatic Agreement

Attachment E: Agency Consultation Correspondence https://2024.01.18 https://2024.01.09

ATTACHMENT A: MITIGATION MEASURES

Visitor Use, Experience, and Safety

Pedestrian and bicycle access will be maintained during construction via the use of temporary detours or alternative routes around closed trail sections. Advanced notice of closures will be provided on the park website and detours will be clearly marked.

Maintenance of traffic plans will be coordinated with the Virginia Department of Transportation to minimize delays and cause the least disruption possible.

Vegetation

Tree surveys will be conducted during detailed design to identify opportunities to avoid or minimize tree removal. Design objectives will include avoiding impacts to legacy trees, memorial trees, and trees that have a diameter of 18 inches or more.

Protective measures, such as fencing, will be installed around the critical root zone of trees planned for protection during construction.

If root impacts are unavoidable, root pruning techniques along with other strategies will be used to best maintain tree health and longevity.

Trees and shrubs impacted by construction will be replaced on a one-to-one dbh ratio or following the procedures detailed in NCPC’s Tree Preservation and Replacement Resource Guide. Replanting will reflect the native plant communities of the Parkway, or non-native, non-invasive plants may be used that are sensitive to the historic context of the cultural landscape.

Construction contractors will be required to clean vehicles and equipment offsite, and to use weed-free construction materials, to prevent the inadvertent introduction of invasive plant seeds, propagules, and other weed seeds into the Parkway.

Disturbed soils will be stabilized using native vegetation or non-native, non-invasive plants that are sensitive to the historic context of the cultural landscape.

A clear zone beyond the edge of curb will be established by removing trees and other vegetation encroaching on the Parkway.

Limited construction access in wetlands will be established via routes that avoid tree impacts.

Contractors will be required to place temporary matting over herbaceous wetland vegetation.

Wildlife and Habitat

The NPS intends to minimize removal of trees to the extent possible. Opportunities to avoid and minimize tree removal will be evaluated as part of detailed design.

Trees and shrubs impacted by construction will be replaced on a one-to-one dbh ratio, or following the procedures detailed in NCPC’s Tree Preservation and Replacement Resource Guide, to further minimize habitat loss.

Tree removal and proposed bridge repairs / rehabilitation (when applicable) will be restricted from April 1 to November 14, or as determined through consultation with USFWS, to minimize potential effects to bats and / or migratory bird species.

The NPS will conduct presence / probable absence surveys using protocols detailed in the USFWS’s Range-Wide Indiana Bat and Northern Long-Eared Bat Survey Guidelines, dated March 2023, or following the latest guidance published at the time the surveys are conducted.

The NPS will consult with the USFWS as needed to determine what conservation measures should be implemented to minimize potential effects.

At the request of Parkway staff, trees removed by construction efforts would be left on site as appropriate.

Construction will be restricted within the primary and / or secondary buffers of active eagle nests from December 15 to July 15, or as determined based on consultation with USFWS.

Historic Districts

The proposed improvements will strictly adhere to the SOI Treatment Standards.

New amenities and small-scale features will be sensitively designed and placed so as not to diminish the significance and integrity of historic districts, including views and vistas.

The NPS, NCPC, and VDHR have developed and executed a programmatic agreement that defines the continued Section 106 consultation process and include stipulations for design review by consulting parties to ensure adherence to the SOI Treatment Standards and that adverse effects will not occur from those portions of the project that are subject to additional design and refinement, including bridge rehabilitation, drainage improvements, and culvert replacement or repairs. The final, fully executed programmatic agreement is included with the FONSI as Attachment D.

Archeological Resources

Designs will be developed to avoid impacts to significant archeological sites by relocating improvements outside of archeologically sensitive areas, shifting the trail alignment away from sites, and reducing trail widening.

If an archeological site cannot be avoided, the NPS will consult with VDHR and / or the DCHPO to develop a plan to investigate the site and delineate the site boundaries more accurately and / or to evaluate the site’s potential eligibility for the National Register.

Subsurface archeological investigations will be conducted where ground disturbance is unavoidable within areas of archeological potential that have not been previously surveyed.

Construction may be monitored in areas of low or no archaeological potential to ensure archaeological deposits are not disturbed.

Archaeological monitoring and discovery plans will occur in conjunction with or as an alternative to pre-construction investigations.

The NPS, NCPC, and VDHR have developed and executed a programmatic agreement that defines the continued Section 106 consultation process and include strategies to avoid, minimize, and mitigate the adverse effects that may result to archeological resources after additional survey and subsurface investigations are conducted during the design phase. The final, fully executed programmatic agreement is included with the FONSI as Attachment D.

Cultural Landscapes

Tree surveys will be conducted during detailed design to identify opportunities to avoid or minimize tree removal. Design objectives will include avoiding impacts to legacy trees, memorial trees, and trees that have a dbh of 18 inches or more.

Impacted trees and shrubs will be replaced on a one-to-one dbh ratio or following the procedures detailed in NCPC’s Tree Preservation and Replacement Resource Guide. Replanting will reflect the cultural landscape character of the Parkway and will not occur where it will obstruct significant scenic vistas.

If an archeological site cannot be avoided, the NPS will consult with VDHR and / or DC HPO to develop a plan to investigate the site and delineate the site boundaries more accurately and / or to evaluate the site’s potential eligibility for the National Register.

The NPS, NCPC, and VDHR have developed and executed a programmatic agreement that defines the continued Section 106 consultation process and will include stipulations for design review by consulting parties and strategies to avoid, minimize, and mitigate the adverse effects that may result to archeological resources after additional survey and subsurface investigations are conducted during the design phase. The final, fully executed programmatic agreement is included with the FONSI as Attachment D.

ATTACHMENT B: NON-IMPAIRMENT DETERMINATION

By enacting the NPS Organic Act of 1916, Congress directed the US Department of Interior and the NPS to manage units “to conserve the scenery and the natural and historic objects and wildlife therein and to provide for the enjoyment of the same in such a manner and by such a means as will leave them unimpaired for the enjoyment of future generations” (54 USC 100101). Congress reiterated this mandate in the Redwood National Park Expansion Act of 1978 by stating that NPS must conduct its actions in a manner that will ensure no “derogation of the values and purposes for which these various areas have been established, except as may have been or shall be directly and specifically provided by Congress” (54

USC 100101).

The NPS has discretion to allow impacts on Park resources and values when necessary and appropriate to fulfill the purposes of a Park (NPS 2006 sec. 1.4.3). However, the NPS cannot allow an adverse impact that would constitute impairment of the affected resources and values (NPS 2006 sec 1.4.3). An action constitutes an impairment when its impacts “harm the integrity of Park resources or values, including the opportunities that otherwise would be present for the enjoyment of those resources or values” (NPS 2006 sec 1.4.5). To determine impairment, the NPS must evaluate “the particular resources and values that would be affected; the severity, duration, and timing of the impact…and other impacts” (NPS 2006 sec 1.4.5). To determine impairment, the NPS must evaluate “the particular resources and values that will be affected; the severity, duration, and timing of the impact; the direct and indirect effects of the impact; and the cumulative effects of the impact in question and other impacts” (NPS 2006, Section 1.4.5). This ensures that park resources and values will continue to exist in a condition that will allow the American people to have present and future opportunities for enjoyment of them.

This determination on impairment has been prepared for the Selected Alternative described in the FONSI.

An impairment determination is made for vegetation, wildlife and habitat, historic districts, archeological resources, and cultural landscapes. An impairment determination has not been made for visitor use, experience, and safety because impairment findings relate back to park resources and values, and these impact areas are not generally considered to be park resources or values according to the NPS Organic Act of 1916 and cannot be impaired in the same way that an action can impair park resources and values.

Vegetation – Construction activities will require tree removal along the parkway and trail to implement the proposed improvements. However, the NPS will replace trees and shrubs removed by construction on a one-to-one dbh ratio, or following the procedures detailed in NCPC’s Tree Preservation and Replacement Resource Guide and will employ other measures to minimize vegetation impacts. Overall, the amount of vegetation loss is anticipated to be minimal. The Selected Alternative will not result in impacts to vegetation that constitute impairment to park resources or values.

Wildlife and Habitat – Habitat loss and wildlife impacts from vegetation clearing will be temporary because impacted trees and shrubs will be replaced on a one-to-one dbh ratio or following the procedures detailed in NCPC’s Tree Preservation and Replacement Resource Guide. Using conservation measures, the NPS determined the Selected Alternative may affect, but is not likely to adversely affect the federally listed endangered northern long-eared bat. A time of year restriction on tree removal implemented as a conservation measure for the northern long-eared bat will also minimize potential effects to the proposed endangered tricolored bat and migratory birds. Construction will be restricted within the primary and / or secondary buffers of any bald eagle nests during the breeding season from December 15 to July 15, in accordance with USFWS requirements, to ensure that eagles or their nests will not be disturbed. The Selected Alternative will not result in impacts to wildlife and habitat that constitute impairment to park resources or values.

Historic Districts and Cultural Landscapes – Many changes, including physical alterations, will occur within historic districts and cultural landscapes under the Selected Alternative. These changes will be minor and will be designed in accordance with the SOI Treatment Standards. Also, trail widening will require tree removal that will result in small-scale changes to existing vegetation. While these alterations will have minor localized visual effects, they will not result in effects to significant views or viewsheds.

As such, the Selected Alternative will have no adverse effects to historic districts will not diminish the significance and integrity of cultural landscapes. The NPS, NCPC, and VDHR have developed and executed a programmatic agreement that defines the continued Section 106 consultation process and includes stipulations for design review by consulting parties to ensure adherence to the SOI Treatment Standards and that adverse effects will not occur from those portions of the project that are subject to additional design and refinement, including bridge rehabilitation, drainage improvements, and culvert replacement or repairs. The agreement also includes strategies to avoid, minimize, and mitigate the adverse effects that may result to archeological resources identified within cultural landscapes. The final, fully executed programmatic agreement is included with the FONSI as Attachment D. The Selected Alternative will not result in impacts to historic districts that constitute impairment to park resources or values.

Archeological Resources – Construction-related ground disturbance has the potential to impact potentially significant archeological resources. Since the extent of archeological resource impacts is unknown at this time, the NPS, NCPC, and VDHR have developed and executed a programmatic agreement that defines the continued Section 106 consultation process and includes strategies to avoid, minimize, and mitigate the adverse effects that may result to archeological resources after additional survey and subsurface investigations are conducted during the design phase. The final, fully executed programmatic agreement is included with the FONSI as Attachment D. The Selected Alternative will not result in impacts to archeological resources that constitute impairment to park resources or values.

CONCLUSION

The NPS has determined that the implementation of the Selected Alternative will not constitute an impairment of the resources or values of the Parkway. As described above, implementing the Selected Alternative is not anticipated to impair resources or values that are essential to the purposes identified in the establishing legislation of the park, key to the natural or cultural integrity of the park, or identified as significant in the park's relevant planning documents. This conclusion is based on consideration of the park’s purpose and significance, a thorough analysis of the environmental impacts described in the EA, the comments provided by the public and others, and the professional judgment of the decision-maker guided by the direction of the NPS Management Policies 2006.

ATTACHMENT C: CONCERN STATEMENTS AND RESPONSES

This report groups substantive comments into concern statements and provides NPS’s responses. Substantive comments are those that: question, with reasonable basis, the accuracy of the information in the NEPA document;

question, with reasonable basis, the adequacy of the environmental analysis; present reasonable alternatives other than those presented in the NEPA document; or cause changes or revisions in the proposal. Comments that merely support or oppose a proposal or that merely agree or disagree with NPS policy are not considered substantive.

The George Washington Memorial Parkway South Section and Mount Vernon Trail Improvements Plan and Environmental Assessment (EA) was made available for public review from September 25 to October 24, 2023, at the NPS Planning, Environment and Public Comment (PEPC) project webpage:

https://parkplanning.nps.gov/ParkwaySouth_EA. The EA public review period was announced on the PEPC project webpage and by news release and email blast. A total of 469 separate correspondences were received during the EA public review period within which 1,118 comments were reviewed and analyzed. A total of 625 comments considered substantive were grouped into concern statements and NPS provides responses to those concerns in Table 1 on the following page.

A complete list of those substantive comments received, and how they were broken down into concern statements can be found in the same folder as this FONSI in the document titled; Comments did not receive responses if they were considered not substantive.

The following reports generated by PEPC provide the comments and associated concern statements organized by substantive codes used to group comments/concerns into related topic areas. The comments under each substantive code are included in the Substantive Issues Report. The concern statements listed in the Concern Response Report are the same as those which NPS provides responses in Attachment C.

https://parkplanning.nps.gov/ParkwaySouth_EA

TABLE 1 - RESPONSE TO CONCERN STATEMENTS

CONCERN RESPONSE

NEW ALTERNATIVES OR ELEMENTS

Commenters suggested separa ng the MVT for bicyclists and pedestrians, including at Gravelly Point.

As described on page 28 of the Environmental Assessment (EA), and presented on Figure 18 in Appendix B, the Na onal Park Service (NPS) proposes to install a separate sidewalk for pedestrians at Gravelly Point. The sidewalk would follow along the south and east sides of the parking lot, providing a connec on to a new permanent restroom facility. The sidewalk would merge with the Mount Vernon Trail (MVT) east of the current porta-john loca on. Providing this separa on for pedestrians and bicyclists will require minimal environmental impact. However, providing separate paths for pedestrians and bicyclists on the en re MVT would substan ally increase the overall footprint of the trail on the landscape, require substan al addi onal drainage and stormwater management improvements due to the dras c increase in impervious surface, and have a greater magnitude of impacts to trees and other vegeta on. Widening the MVT from the typical 8 - 9 feet to a maximum of 10 feet in Zone 1, and to a maximum of 12 feet in NPS-administered por ons of Zones 2 and 3 would conform with American Associa on of State Highway and Transporta on Officials (AASHTO) recommenda ons for modern two-direc onal mul -use paths / trails, providing addi onal space for mul ple uses while minimizing environmental impacts.

Commenters suggested speed cameras should be installed along the Parkway South Sec on.

As described on page 23 of the EA, the NPS currently does not have the legal authority to issue civil cita ons for traffic infrac ons along the George Washington Memorial Parkway (Parkway). As such, implemen ng speed camera technology along the Parkway is not currently feasible. However, if policies are put in place that would authorize the establishment of an automated speed enforcement program, the NPS would explore opportuni es to obtain funding to purchase, deploy, and maintain a limited number of mobile or fixed sta ons along the Parkway.

Commenters suggested the Parkway South Sec on should be returned to its pre-diet lane configura on. Other comments suggested widening the roadway, while others requested that only resurfacing or road repairs be done in lieu of the road diet.

The NPS conducted several detailed studies and assessments to support this project. For the Parkway South Sec on improvements the NPS, with support from FHWA, completed the George Washington Memorial Parkway: Traffic and Safety Context Sensi ve Solu ons Assessment that is summarized on page 7 of the EA and is available for review at h ps://parkplanning.nps.gov/GWMP_South. Page 31 of the EA describes that this assessment iden fied and evaluated 89 poten al solu ons to address traffic and safety along the Parkway. Many of those solu ons were dismissed from further considera on as part of the assessment. Furthermore, solu ons considered but dismissed as part of Plan development are described on pages 32 and 33 of the EA.

Commenters suggested making the trail wider than what is proposed in the EA.

As described on page 33 of the EA, the NPS considered widening the MVT to a standard width of 14 feet early in planning.

Although a wider trail of 14 feet would benefit some users, it would cause impacts to sensi ve natural resources, including trees and wetlands, that are unacceptable to NPS; require more extensive best management prac ces (BMPs) to comply with Virginia and District stormwater requirements; increase the likelihood of archeological resource impacts; and result in unnecessary altera ons to the cultural landscape of the Parkway.

The proposed trail width would conform with guidelines and recommenda ons from the AASHTO Guide for the Development of Bicycle Facili es (2012) for width and horizontal clearance. Updates to AASHTO guidance and recommenda ons published before the project is complete will be considered for implementa on where appropriate and feasible based on the resource context, minimizing impacts to the natural and cultural resources present.

CONCERN RESPONSE

Commenters requested that addi onal signs be added to the Parkway South Sec on and MVT improvements. Other commenters requested that signage be made more visible or have larger text.

Commenters suggested installing barriers, such as jersey walls, to separate the Parkway South Sec on and MVT.

During detailed design, the NPS, in…