The latest threat to the proposed Willett Stream Valley Park is the Westbard Self Storage facility to be constructed behind the McDonald's on River Road on what was the Galway property. The plans call for a 58 foot high building -190,000 square feet in all. The building is sited with one corner in the stream valley buffer.
Montgomery County Environmental guidelines dictate that no building may be done in a stream valley buffer as stated below:
i. The guidelines treat streams as sensitive areas needing protection from the negative consequences of development, and therefore prohibit buildings in stream buffers; only necessary, minimized infrastructure is allowed. (p.17)
Archetectual Drawing of Proposed Westbard Self Storage Facililty
ii. Exceptions must meet five tests: that reasonable alternatives to encroachment do not exist; encroachment has been minimized; existing sensitive areas such as buffers, streams, and floodplains are avoided; the proposal is consistent with the preferred use of the buffer; and the plan includes compensation for any buffer loss. (p.19)
Letters Needed Now:
As you know, Little Falls Watershed Alliance has been working to support a new park for the Westbard Sector - the Willett Branch Stream Valley Park. The park will feature a naturalized Willett Branch and a restored stream buffer. We cannot do this alone. We are asking neighbors to join us in supporting the park and opposing this new building in the buffer.
Below is our letter to the Planning Staff outlining our concerns and opposition to the Westbard Self Storage. If you could take a few minutes to send your own letter, it would go a long way to helping the cause. Please feel free to use our language.
LFWA COMMENTS TO PLANNING STAFF:
Date: July 2, 2017
To: Neil Braunstein, Montgomery Planning
neil.braunstein@montgomeryplanning.org
Re: Westbard Self Storage Facility, preliminary and site plan Site Plan No. 820170110
Dear Mr. Braunstein and Planning Staff,
The Little Falls Watershed Alliance (LFWA) is an environmental stewardship group for the Little Falls watershed. We have over 2,000 members and have worked with thousands of volunteers addressing environmental issues in the watershed. Our mission is to protect the fragile natural environment in lower Montgomery County and adjacent DC neighborhoods and to ensure that the natural spaces in our area persist for generations to come.
In December 2016, we met with Tim Dugan, the legal representative for the Westbard Self Storage group, to learn about the project and to express our opposition to siting the building in the Willett Stream buffer, to the huge canyon-like walls leading to the Willett Branch and to the unattractive way that the back of the building interacts with the proposed Willett Branch Park. Mr. Dugan was very attentive and assured us that he would convey our concerns to the developer. We are very disappointed with the preliminary plans in that they do not address any of the points we raised.
The restoration of the Willett Branch and formation of the new greenway park is the central amenity of the Westbard Sector plan. It is a tremendous vision for the area. When it is realized, it will be a center piece for the Montgomery Parks system and a huge benefit not only to the residents of the area but to the whole county. With its location off the very popular Capital Crescent trail, hundreds of people will use it to enjoy the creek and the beauty of the natural area. It will provide the only meaningful green space for the sector. Because the Westbard Self Storage facility is located at the edge of the Willett Branch buffer and in the heart of the proposed park, careful attention must be paid to how the parcel is developed to insure the success of the park.
After reviewing the plans, we have these comments:
• Building should NOT be allowed in the Stream Buffer:
Little Falls Watershed Alliance believes that new construction in the Willet Branch buffer should not be allowed. We are opposed to any building in the buffer at this site. This parcel has never had a building sited in the stream buffer and we feel that with the formation of the new park, it is not appropriate to grant any waivers.
Further, Montgomery County Environmental guidelines have a very strict test for granting waivers. Westbard Self Storage has failed to address the test items. Their justification statement does not provide a reason for encroachment on the Willet Branch other than stating that an encroachment is acceptable when necessary. The applicant provides no explanation for the "necessity" of its encroachment on the buffer. Instead the storage people rely only on the fact that they are improving the area as a justification; this is not sufficient, particularly given the size of the building they are constructing. A smaller building would not encroach in the buffer.
We were happy to see the dedication of parcel 177. However, we do not feel this should affect any decision about building in the buffer. Any owner of that property would be wise to dedicate the parcel to the park, to avoid paying taxes on it and because it is not buildable anyway as it is located in the floodplain and on top of the cemetery. It is also zoned for residential which in not compatible with a self-storage facility.
• Stormwater Management should be outside the stream buffer:
Westbard Self Storage has done a nice job of addressing stormwater management with green roof and bio-retention planters. However, there is a lot more that could be done and we object to the placement of the planter box in the stream buffer. The point of a stream buffer is to use native planting to protect the health of the creek. The deep roots of the plants stabilize the soil and provide habitat for wildlife. In this highly impervious area, the buffer cannot double as stormwater management for the building. That should all be done outside the buffer. If the building is pulled back from the buffer just two or three feet, there is room for the planter and an intact buffer.
• Stormwater Management should include more pervious pavement:
There isn’t much improvement on the total impervious surface under this plan except for the addition of the green roof. We would like to see more green space and, where pavement is necessary, there should be liberal use of pervious pavement. The alleyway is also a good candidate for green street treatment.
• Access to Park is Not Welcoming:
The proposed 18 foot pathway to the park is too small to be more than a narrow driveway. With the 60 foot wall on one side and the huge retaining wall on the other, visitors will not be welcomed into the park, but rather have to pass through a dark alleyway to get there. We think a 24 foot alley is more appropriate. Further, stepping back the building would allow for more light in this area.
• Design should include Green Street and Green Walls:
The alleyway is also a good candidate for green street application. We would like to see less pavement and more pervious surfaces. We also think that the retaining wall and building side are a good place for a green wall. This would go a long way to soften the walls and provide a nice transition from concrete to park. Green walls also help lower the urban heat index.
• Display Windows Highlight History of Area:
We really like the idea of display windows in the alleyway. They will provide excellent way to highlight the history of the area. We hope they are included in the final design and that the Self-Storage facility provides funding for their creation and maintenance - what a wonderful way for them to give back to the community.
• Public Space Allocation is Inadequate:
Westbard Self Storage claims to be providing public space that is 10% of their net gross area. However, it looks like they are claiming the land that they are dedicating as their open space. This is not acceptable. The dedication should happen first, and the 10% of the remaining parcel should be required to be open space. That space should not include the easement to the park either.
• Building is Too Big for Site:
Westbard Self Storage is claiming that FAR does not apply to underground space which is about half of the size of their building. They are permitted a FAR of about 107,000, but they are building a structure that is 190,000 square feet. We feel that because the building is on a slope and the rear is above ground, that it is much larger than contemplated in the zoning ordinance. A smaller building would not compromise the stream buffer and would allow for more public space.
This area also abuts a residential area. Are there further restrictions on the size of buildings adjacent to residential areas?
• Interface with Park at Rear of Property is Unattractive:
One of the concerns that has been raised continually throughout the redevelopment process is need for attractive interface with the park – buildings should embrace the park rather than turn their back to it. We understand this to be a challenge with a self-storage facility, but this building makes no effort to embrace the park with anything but a 58 foot wall. The rear of the building is especially unattractive and given the height will cast a shadow over the new park. We would like to see the rear of the building stepped back with green roofs on each level and liberal use of green walls. It would make a beautiful transition to the park and a very attractive self-storage facility.
Landscaping for the rear seems to be limited to grass. We hope that the developer will work with the Parks and Department of Environmental Protection to install native plantings appropriate to stream-side location.
The Westbard Self Storage will be adjacent to the heart of the new Willett Branch Park. How the stormwater is managed, how the buffer is treated, how the landscaping is done will all have a huge impact on the success of the new park and restoration of the Willett Branch. The new park promises to be a national show case for environmental improvement and Montgomery County will have a lot to be proud of when it is completed. We have this chance to leave a legacy for our children.
Thank you to your attention to these details,
Sarah Morse
Executive Director
Little Falls Watershed Alliance
cc: Gwen Wright, Montgomery Planning
Robert Kronenberg, Montgomery Planning
Marco Fuster, Montgomery Planning
David Kuykendall, Department of Permitting
Roger Berliner, Montgomery County Council
Mike Riley, Montgomery Parks
Brooke Farquhar, Montgomery Parks
Lisa Feldt, Department of Environmental Protection
Andy Frank, Montgomery Parks