February 11, 2010
Fairfax County Planning Commissioners
Fairfax County Board of Supervisors
Reston Association Planning and Zoning
Reston Association Board of Directors
Reston Master Plan Special Study Task Force
Re: Comstock Wiehle Reston Station, RZ/FDP 2009-HM-019
The following letter presents our concerns with the Comstock Wiehle Reston Station proposal as submitted in the January 14, 2010 CDP/FDP and Proffer Statement. At the end of this letter you will find 3D views produced from images provided by Comstock.
The lack of public space and open space, the capacity of the current transportation system to absorb the proposed increase in traffic, a lack of connectivity to nearby trails and other pedestrian pathways, and the negative impact on the surrounding community leads us to the conclusion that this development should be rejected as designed.
There is a clear discrepancy between the amount of development proposed in the Comstock Wiehle development plan and that which can be calculated by observation of the CDP/FDP, the illustrative booklet, and exhibits. The CDP/FDP lists nearly1.3 million sq ft of development, yet calculating the footprints and proposed building heights produces an amount of 3.5 million sq ft. While the area of parking structures may not count towards FAR calculation, they should be added into the total development numbers.
The RCIG covenants and restrictions were administered by Reston Association, a clear indication that RA retains property rights. Those property rights belong to the homeowners of Reston. The deed cannot be vacated or nullified without the permission of the homeowners who own those property rights. It also appears that stripping the lands of Town Center from Reston Association was a violation of the deed. Those lands were part of the Deed of Dedication of Reston and Reston homeowners were never allowed to vote to relinquish Town Center as part of Reston Association.
There is essentially no open space in the Comstock proposal. Human beings require open space. Open space is a requirement for development in Fairfax County’s guidelines. In Block 1 of the proposed development there are 1,000 sq ft of open space and most of that is sidewalk. That is unacceptable.
Sandy Stallman, Manager of Fairfax County Park Planning Branch, states that for 444 residential units there must be 0.00148 acres of parkland per person, or 1.43 acres. That parkland must be on site. Reston Association homeowners are not required to provide parkland for residents of new developments in the corridor. Comstock is responsible for providing parkland for new residents.
The vehicular and pedestrian plaza in the center of the development is about the same size as Lake Anne Plaza. Through the center of the plaza two lanes of traffic will circulate constantly. The exhaust fumes will be trapped in between the 17 and 19 story buildings and the connected above-ground parking garages and a carbon monoxide chamber will be created poisoning people in the plaza. In addition, the plaza will be in shade most of the year, creating a wholly dismal, unhealthy, and claustrophobic environment not suitable for any sort of community event.
The land Comstock Wiehle Station will be built upon is public land owned by Fairfax County. However, areas of that land that will be set aside for residential recreation will be private and not open to the public. This is not a reasonable use of public land.
The Proffer Statement dated January 14, 2010, states that Comstock “shall establish” their own community associations. Residential properties in the RCIG need to come under the umbrella of Reston Association and be subject to the Deed of Dedication of Reston with the Design Review Board in control. The residents of Reston want all new development to fall under Reston Association.
The January 14, 2010, Proffer Statement limits the lifetime amount of fines to be paid by Comstock because of failure of the TDM program to $200,000. That is the limit of Comstock’s liability. That means if traffic is not sufficiently mitigated by their TDM measures, we will have to live with the traffic congestion and wait until such time that VDOT can afford to make road improvements. VDOT Chapter 527 TIA reports that there will be unsatisfactory delays of traffic along Wiehle and Sunset Hills Roads from the traffic associated with Comstock Wiehle Station and the area will be gridlocked.
Under the terms of the CDP/FDP Comstock is under no obligation to build anything beyond the below-ground parking garage until the “market dictates.” The residential building will not be built until Phase 5, almost the last phase. In the January 14, 2010 Proffer Statement the residential component has been reduced from 40% to 37.5%. The county’s comprehensive plan calls for transit-oriented development in the station area. There is no TOD without an adequate residential component. Residential units should be increased, not decreased.
Comstock will get all the benefits from this development. The community will get no benefits from this development. Were new TOD buildings placed over the Toll Road using air rights, as proposed in the Reston-Herndon Suburban Center and Transit Station Areas of the Fairfax County Comprehensive Plan (page 30), the area of the park and ride could be the site of parks and recreational facilities set over a green roof above the underground parking garage. That would produce a more acceptable living environment for the residents at Comstock Wiehle, a number including density bonus that could be over 1,300 people.
At the current time Comstock Wiehle Station is not subject to review and evaluation by the Reston Master Plan Special Study Task Force which has been charged with planning redevelopment in the Dulles Corridor. Because of its size and density it should be included with the other APR nominations deferred to Special Study by the Task Force.
Comstock Wiehle Station as a template will begin the transformation of the Dulles Corridor into a Great Wall resembling Hong Kong. Comstock Wiehle Station cannot be supported by current infrastructure. It violates the Deed of Dedication of Reston. It does not belong in this internationally renowned planned community.
Comstock Wiehle Station development proposal does not fulfill measurable community criteria for quality of life, open space, and clean air and should be rejected.
Please see the 3D images on the following pages of this letter.
Guy L. Rando
Urban Designer and Landscape Architect
1512 Inlet Court
Reston, VA 20190
Poet and Naturalist
11223 Leatherwood Drive
Reston, VA 20191
Full document with graphics:
Comstock Wiehle Site Proposal Letter--Rando & Kaplan--021110