24 September 1997
Source: http://www.access.gpo.gov/su_docs/aces/aces140.html

[Federal Register: September 24, 1997 (Volume 62, Number 185)]
[Page 50050-50053]
From the Federal Register Online via GPO Access [wais.access.gpo.gov]



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

AGENCY: Department of the Treasury.

ACTION: Notice.


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.

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 
    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 
    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 
    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 
    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 
    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 
    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 
    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 
    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 
    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 
    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 
    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 
    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 
    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]