Finding of No Significant Impact for Implementation of White House Security Review Vehicular Traffic Restriction Recommendations

DEPARTMENT OF THE TREASURY

Finding of No Significant Impact for Implementation of White

House Security Review Vehicular Traffic Restriction Recommendations

AGENCY: Department of the Treasury.

ACTION: Notice.

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SUMMARY: Notice is hereby given that the Department of the Treasury

(Treasury) has made a finding of no significant impact (FONSI) with

respect to the environmental assessment (EA) for implementation of

White House Security Review Vehicular Traffic Restriction

Recommendations. This EA was prepared by the Department of the Treasury

following the security action to restrict vehicular access to certain

streets in the vicinity of the White House Complex pursuant to the

emergency provision (40 CFR 1506.11) of the Council on Environmental

Quality's (CEQ) National Environmental Policy Act (NEPA) implementing

regulations. The Federal Highway Administration (FHWA) was a

cooperating agency.

FOR FURTHER INFORMATION CONTACT: For a copy of the FONSI contact Mr.

Bill McGovern, Environment and Energy Programs Officer, 1500

Pennsylvania Avenue, NW, Treasury Annex Room 6140, Washington, DC,

20220; telephone (202) 622-0043; fax (202) 622-1468. Copies of the EA

are also available at the above address. The EA is still available on

the Department of the Treasury's home page at http://www.treas.gov.

Additionally, copies of the EA were mailed to Federal, State, and local

agencies; public interest groups; interested individuals; and District

of Columbia public libraries.

SUPPLEMENTARY INFORMATION: On June 2, 1997, the Treasury made the EA

available to the public for a thirty day comment period. A total of 650

copies of the EA were distributed to Federal, state, and local

agencies, Members of Congress, the Government of the District of

Columbia, private organizations and interested members of the public.

Additionally, the EA was available via the Internet. Twelve comment

letters were received. Three of the comment letters were from private

individuals. Two were from individuals or agencies representing the

District of Columbia: Eleanor Holmes Norton, and the District of

Columbia Department of Public Works (DCDPW). Three were from historic

preservation organizations and sites: the Advisory Council on Historic

Preservation (ACHP); the National Trust for Historic Preservation; and

Saint John's Church. Four were from other governmental entities: Region

III of the Environmental Protection Agency; the National Capital

Planning Commission; the National Park Service (NPS); and the

Washington Area Metropolitan Transit Authority (Metro).

A brief description of the security action and the findings of the

EA are presented below followed by a summary of the issues raised in

the comment letters along with Treasury's response for each issue.

On May 19, 1995 the Secretary of the Treasury ordered the Director

of the United States Secret Service to restrict vehicular traffic on

certain streets surrounding the White House Complex. The Director

implemented the action on May 20, 1995. The security action was taken

to provide necessary and appropriate protection for the President of

the United States, the first family, and those working in or visiting

the White House Complex.

This security action was one of several recommendations resulting

from the ``White House Security Review'' (the Review). The final report

of the Review is classified; however a ``Public Report of the White

House Security Review'' was issued in May 1995. The Review's

recommendation states that it was ``not able to identify any

alternative to prohibiting vehicular traffic on Pennsylvania Avenue

that would ensure the protection of the President and others in the

White House Complex from explosive devices carried in vehicles near the

perimeter.''

The EA examined the impacts of the security action on

transportation, air quality, noise, vibration, visual/aesthetic

resources, cultural resources, pedestrian access, socioeconomic

resources, natural resources and cumulative environmental effects.

Available pre-action data was collected from local and Federal

agencies and supplemented by traffic counts and travel time analysis

conducted for the EA. With the exception of traffic counts for certain

intersections, the available pre-action data was not directly

comparable to the post action measurements and did not allow for

accurate comparison of before and after action conditions. The analysis

in the EA described the conditions after the action and several traffic

modifications which the DCDPW implemented to alleviate congestion.

The EA did identify certain streets which received large increases

in traffic after the security action. It also identified other streets

which had large decreases in traffic. It was impossible to determine

exactly how much of the increase or decrease was due to the security

action because of the above mentioned lack of pre-action data. The

majority of the streets in the study area continue to operate at an

acceptable level, and traffic levels are typical of a downtown area in

a major city.

The changes in traffic patterns did not result in any violations of

National Ambient Air Quality Standards (NAAQS) for carbon monoxide, the

pollutant of highest concern in intersection modeling. While the area

remains in non-attainment status for ozone, ozone levels should not be

significantly changed as a result of the security action. Ozone changes

are more apt to result when there is a significant increase in vehicle

miles traveled. The security action merely shifted traffic within the

local area.

Noise levels in the study area were not significantly increased by

the security action. Levels in the area on the north side of the White

House dropped noticeably. Vibration levels on H street were examined

and found to be similar to pre-existing levels. The frequency of

vibration probably did increase; however, because the vibration levels

remain below the threshold for damage to fragile historic buildings, no

problems are anticipated.

[[Page 50051]]

The placement of the temporary security barriers has had an adverse

visual impact on a number of historic buildings in the study area. This

will be remedied by the NPS when they complete their plan for

replacement of the temporary barriers with an acceptably designed

permanent barrier. The removal of traffic from Pennsylvania Avenue

presents pedestrian tourists and residents alike with an improved view

of the north side of the White House.

Pedestrian access as measured by accident data appears to be

relatively unchanged. Access to the north side of the White House is

improved at Pennsylvania Avenue.

Socioeconomic analysis was limited to emergency services (fire and

police) and Metro bus cost increases and parking meter revenue losses.

No police or fire stations were moved as a result of the security

action. Some minor adjustments in emergency response routes were made.

Metrobus changed several routes and bus stops as a result of the

security action. Some intersections had to be reconfigured to

accommodate the turning radius of the buses. Metrobus provided a cost

estimate of $115,000 in capital costs and $314,000 in annual operating

costs. Parking meter revenue losses were estimated to be $98,000

annually.

No endangered or threatened species are known to frequent the study

area. Little or no impact occurred to the native wildlife since there

was no ground disturbing activity.

The cumulative impacts analysis did not identify any violation of

NAAQSs even when the projected full operation of the Ronald Reagan

Federal Building was added into the air quality analysis.

A number of recommendations are discussed which could further

improve traffic conditions in the area around the White House. These

recommendations are presented in the EA; however, they are meant for

consideration by the relevant NPS and District of Columbia offices

which have the legal authority to implement them.

None of the impacts analyzed in the EA were found to be significant

under NEPA. None of the comment letters raised new issues that were not

addressed in the EA. The comments along with responses to each comment

are included below. Based on the FONSI, an Environmental Impact

Statement will not be prepared for the security action (40 CFR

1501.4(c), (e)).

Summary of issues raised in the comment letters:

Issue 1: Two commenters questioned the lack of alternatives in the

environmental assessment (EA). Both suggested alternatives that should

have been considered.

Response: The White House Security Review, which was an eight month

comprehensive study, considered numerous other alternatives; however,

it ultimately concluded that none of the other alternatives would

provide the necessary level of protection to the White House Complex.

The Security Review is classified top secret and could not be included

in a public review document such as the EA.

Issue 2: Two commenters stated that Treasury should prepare an

Environmental Impact Statement (EIS) because the EA does not adequately

address the socioeconomic impacts of the action. Both stated that there

are significant impacts to the commercial sector of the city from the

restriction.

Response: Neither comment provided any data to support the

assertion as to commercial impact. Treasury's analysis of the economic

impact of the action was limited to identifiable costs incurred by the

District in terms of increased Metro costs and lost parking revenue.

Treasury was able to gather reliable data in each of these areas. Over

150 copies of the EA were mailed to commercial entities and

associations representing the private sector. No comments were received

from any of these entities.

Issue 3: Three commenters questioned how Metro and the District

would be reimbursed for the Metrobus costs incurred and parking meter

revenue lost as a result of the security action.

Response: Treasury continues to work with the Office of Management

and Budget to explore ways in which the Federal Government can provide

economic support to Metro and the District.

Issue 4: Two commenters stated that Treasury should prepare an EIS

because the EA does not adequately address the traffic conditions

resulting from the security action. One commenter alleged that Treasury

did not consider all the traffic data that might be available.

Response: The EA characterizes the traffic operating conditions

within the study area in terms of level of service and travel speed and

identifies the streets which received the increases and decreases in

traffic. It does not quantify the increase or decrease in commuting

time resulting from the security action, because of the lack of a

comparable pre-action data. The emergency nature of the action

precluded a systematic, advance collection of traffic data. Existing

data was used to the extent possible, but no complete set of

information ever existed which could be used for a direct comparison of

before and after conditions. After an extensive search, every available

source of data was used for the traffic analysis in the EA, including

the DCDPW, the FHWA, and the NPS.

Issue 5: One commenter stated that the EA had thoroughly evaluated

the potential impacts of the action. It concluded that the impacts were

minor, should be further reduced by the recommendations in Chapter 3

and recommended that we prepare a finding of no significant impact.

Response: Treasury agrees the impacts are minor. It should be noted

that several of the recommendations in Chapter 3 have been implemented

by the cognizant agencies such as the DCDPW and Metro. The

recommendations are items which could provide additional relief to

traffic problems.

Issue 6: Three commenters questioned the adequacy of the air

quality analysis provide in the EA. They believe that since the

District was in non-attainment status for ozone, even before the

security action, and attainment for carbon monoxide (CO), ozone should

have been modeled to measure any increases. One commenter stated that

slow moving vehicles would emit more emissions than were emitted before

the action.

Response: Ozone is a regional problem. An action that creates

traffic delay within a corridor of the study area does not translate

into increased ozone in that same corridor because of the time lag

between the emission of substances that are the precursors to ozone and

ozone creation. Such an action theoretically could pose a threat to the

region by representing an increase in the inventory of emissions

leading to ozone formulation. The effects of individual projects are

not known; the state of the art is to take care of ozone in planning,

accounting for the interaction of numerous actions and multiple

interrelated factors. The security action is not considered to be

regionally significant. Many things contribute to ozone production.

Hence the analysis at the region wide level. It is not common practice

to conduct an assessment of the effects of an individual project,

primarily because the individual project normally is not significant

enough to perform an entire regional analysis to see how it fits into

the picture. Whatever the effects the individual action would have on

emissions would be within the terms of error of the model and thus

would be statistically insignificant.

Additionally, the security action did not result in a large

increase in vehicle miles traveled (VMT); the traffic that

[[Page 50052]]

otherwise would have been using Pennsylvania Avenue has shifted to

adjoining streets. Idling or slow moving vehicles have low volatile

organic compound (VOC) and nitrous oxide (Nox) emission rates. Instead,

the amount of VMT and the speed of the travel are the main influences

on VOC and Nox production. For Nox, which is the more vexing of the

main ozone producing pollutants, any decrease in average speed below 28

miles per hour actually reduces emissions. Most of the traffic in the

study area moves at speeds below this level during the three peak

periods.

Issue 7: One commenter stated the belief that Treasury was trying

to conceal the extent of the increase in carbon monoxide (CO)

emissions, positing that the model results should be compared to

ambient concentrations prior to the closing of Pennsylvania Avenue to

vehicular traffic in 1995.

Response: While a comparison of the CO levels prior to and after

the action could potentially find some increases in emissions, such a

comparison would be impossible to perform, because traffic levels and

CO concentrations were not measured before the action took place. In

addition, an increase in emissions, by itself, is not an indication

that a problem exists, provided that the NAAQS are met, and the State

Implementation Plan is not violated. The EA shows that both these

conditions are met. The analysis performed in the EA satisfies the

requirements of the NEPA.

Issue 8: One commenter questioned the treatment of indirect

emissions in the EA and the assertion that Treasury doesn't have

control over these emissions.

Response: The direct and indirect emissions resulting from the

security action were analyzed under NEPA. The same analysis techniques

were used that would have been used for the analysis under the Clean

Air Act Amendments' (CAAA) conformity requirements had they been

applicable. The indirect emissions were not included in reaching a CAAA

conformity decision because Treasury does not have a continuing program

of control over traffic in the downtown area.

Issue 9: Two commenters stated that the results of the noise and

vibration analysis along H Street are not representative of what they

experience at their locations. One stated that parking tour buses along

H Street were a noisy visual ``wall of steel'' on the historic

structures. The same commenter requested that a vibration barrier be

installed along H Street to eliminate the potential for damage to the

historic structures. One questioned the use of the 95 dB vibration

threshold for damage to extremely fragile historic buildings from the

Federal Transit Administration (FTA).

Response: The noise and vibration data in the EA are actual data

taken in a representative manner at various locations in the H Street

area. This data is consistent with the limited amount of pre-existing

data that was available. Treasury believes that repairing of the street

could further reduce the noise and vibration levels along H Street.

Treasury agrees that the illegally parked tour buses create additional

sources of noise and vibration and should be removed by the appropriate

authorities.

According to the FTA, the 95 dB vibration threshold is applicable

to both short term impacts from construction and long-term vibration

effects of operational traffic. It was used in the EA because it is one

of only a few guidance publications on the effects of vibration.

Further research has identified the California Department of

Transportation (Caltrans) criteria for historic buildings and ancient

ruins. The Caltrans guidance applies to continuous vibration sources,

such as those resulting from traffic and trains. The Caltrans guidance

uses a vibration criteria of 0.08 inch/second Peak Particle Velocity

(PPV) as the threshold for damage. PPVs below this level should not

result in damage. This is a more conservative level than the FTA's 95

dB (rms) or 0.12 inch/second PPV criteria. The post-action measured

levels along H Street were 0.016 inch/second or below. Pre-action data

showed levels as high as 0.035 inch/second PPV at Decatur House. Both

the pre- and post-action levels are well below the Caltrans level of

0.08 inch/second PPV. It is clear that the security action did not

result in any significant increase in these levels, and the vibration

data does not show any need for installation of a vibration barrier

along H Street.

Issue 10: Two commenters stated that the cumulative impacts

analysis in the EA was deficient because it did not include a

discussion of the General Service Administration's (GSA) proposal to

limit on street parking at Federal Office Buildings here in the

District.

Response: The purpose of the EA was to analyze the security action,

which occurred two years before the GSA proposal. The GSA proposal is

currently at the scoping stage and was not developed enough to include

in the EA at the time the EA was being written. A draft of the Treasury

EA was reviewed by GSA. GSA did provide detailed information about the

parking at the Ronald Reagan Federal Building for use in the cumulative

impact analysis. The GSA action will be fully described in a draft EIS

they plan to release in December 1997. The security action should be

part of the base condition for their EIS.

Issue 11: Three commenters asked questions related to the Metrobus

impacts. Two requested detailed data on increases or decreases in

ridership resulting from the actions. One provided corrections related

to schedules and stops.

Response: Information obtained from Metro after the security action

indicated there were some ridership changes in the period before and

after the security action, but the changes could not be attributed to

the security action. The corrections related to stops and schedules are

acknowledged.

Issue 12: The Advisory Council on Historic Preservation stated that

additional information about the historic character of the affected

buildings would be needed to complete the Section 106 review under the

National Historic Preservation Act. The commenter also clarified the

extent of the original Section 106 review coverage undertaken at the

time of the security action by Treasury.

Response: Additional information on the significance of the

buildings on the register will be included in any follow-on Section 106

compliance activity. Treasury agrees that the temporary barriers were

addressed as an emergency action at the time of the action and that

only newly identified issues would be part of a follow-on Section 106

activity. It was important to recognize the adverse effect of the

temporary barriers and to clarify that the National Park Service will

be replacing the temporary barriers with a system of permanent barriers

as part of its Long-term Design Plan for Pennsylvania Avenue.

Issue 13: One commenter noted that the description of the Section

106 compliance activity was confusing as to which agencies were doing

what.

Response: Section 106 compliance for the placement of the temporary

security barriers was completed by the Treasury in 1995. The NPS has a

project to develop an acceptable permanent design and replace the

temporary barriers, which will be subject to the Section 106 compliance

process. Treasury is conducting a separate Section 106 process to

examine effects other than the placement of the temporary security

barriers, including traffic increases and the resulting visual, noise,

and vibration impacts.

[[Page 50053]]

Issue 14: One commenter noted that the E Street traffic

recommendation could affect the Zero Milestone and the Butt-Millet

memorial, raising historic preservation issues that were not included

in the EA.

Response: The recommendation for providing for resumption of

westbound traffic on E Street assumed that the existing street

configuration would be maintained and not require widening in the area

of the Zero Milestone and the Butt-Millet memorial. The recommendations

provided in Chapter 3 are just that, recommendations for consideration

by the agencies with the authority to implement them.

Issue 15: One commenter stated that the EA was misleading because

it did not describe the process for reaching a decision on whether to

issue a FONSI or a notice of intent to prepare an environmental impact

statement.

Response: The CEQ's NEPA regulations have been in place since 1978.

Treasury did not feel it was necessary to explain the purpose of an

environmental assessment in its document. The comment period was

announced in the Federal Register and the EA itself.

Issue 16: One commenter stated that traffic was worse and that

Pennsylvania Avenue and E Street should be reopened to vehicular

traffic.

Response: The security need for the restriction has not been

eliminated; however, Treasury is working with other agencies to examine

potential new designs for traffic on E Street. The EA does show that

some streets have had increases in traffic. The exact amount which is

due to the action cannot be determined due to the lack of pre-action

data.

Issue 17: One commenter criticized the EA for not having a section

on the beneficial impacts of the action such as the better access to

Lafayette Park and providing a more appropriate setting for one of our

preeminent national symbols.

Response: Treasury agrees that there are many beneficial impacts

resulting from the vehicular traffic restriction and attempted to

describe them in qualitative terms in the EA. Most of these impacts are

very difficult to assign dollar figures to and such an effort is not

warranted at the EA level.

Issue 18: One commenter noted that the action is not consistent

with the District's transportation plan, as outlined in the

Transportation Vision, Strategy and Action Plan for the Nation's

Capital.

Response: The action was taken to protect the White House Complex

from explosive devices carried by vehicles near the perimeter. This

action, while inharmonious with the transportation plan, is a necessary

security precaution.

Issue 19: One commenter believes that there is sufficient pre-

existing traffic data available from the District and the FHWA to allow

for estimation of the action's effects.

Response: The EA used the above mentioned data and data from other

sources and still could not identify a method for making the suggested

estimation. FHWA was a cooperating agency for the EA.

Issue 20: One commenter citing anecdotal evidence from her

constituents suggests that noise levels now are noticeably higher. This

commenter also suggested that the methodology used for noise in the EA

contains flaws and therefore failed to fully quantify the actual

increase.

Response: The EA noise data was acquired using standard industry

practices and equipment. It presents the actual dB readings taken at

the time of the measurement in a scientifically accurate manner.

Issue 21: One commenter noted that the boundaries for the extended

study area are appropriate for evaluating the project's effects.

Response: Treasury agrees.

Lawrence H. Summers,

Deputy Secretary.

[FR Doc. 97-25354 Filed 9-23-97; 8:45 am]

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