March 5, 2009

Fairfax County Board of Supervisors

Fairfax County Planning Commission
Reston P&Z Committee

RE: Comstock Wiehle Avenue Metrorail Station Proposal

Dear Ladies and Gentleman,

With the subject proposal on the agenda for the March 25 Planning Commission meeting,
I believe it is important that you understand how badly the proposal violates the intent of
the County policy for Transit-Oriented Development. To approve this ghastly proposal
would make a farce of the County’s stated goals for TOD development and allow the
cornerstone TOD development project in Reston to establish a precedent for ignoring
County policy and sound TOD principles. The following paragraphs explain some of the
ways the Comstock proposal for the Wiehle Avenue Metrorail Station area, especially
Block #1, is inconsistent with the County’s TOD policy.

Section 2 of the TOD policy (Site-Specific Flexibility) and Section 4 (Mix of Land Uses)
generally call for balancing land use mix in the context of the unique characteristics of
the specific site. The Wiehle Avenue TOD area, and the Comstock Block #1 site in
particular, are ill suited for an office-heavy use mix—the proposal calls for at least 55%
office space. An office-heavy mix will generate the most traffic and, among the three
Reston Metrorail station areas, Wiehle station has the least efficient nearby roadway
infrastructure to handle traffic. Yet, among the three sites, it has the shortest walkable
access to the W&OD trail and Reston’s paths through its nature areas. A residential-
heavy mix would generate far less traffic at peak periods, create greater use of the
adjoining Metrorail, and mean more residents could access nearby public amenities.

Section 3 of the TOD policy (Pedestrian and Bicycle Access) and Section 7 (Street
Design) call for developers to provide safe access for pedestrians and bicycles to the
station area. Indeed, the pedestrian/bicycle policy states, “Techniques to promote
maximum pedestrian and bicycle access must include an integrated pedestrian and
bicycle system plan.” Painting a few crosswalk stripes on the road is not an adequate
response. A serious pedestrian and bicycle plan is missing from the Comstock proposal.

The County TOD policy (Section 6—Urban Design) calls for “excellence in urban
design, including site planning, streetscape and building design, which creates a
pedestrian-focused sense of place.” Between the 205’ building height restriction and the
relatively high FAR, there is no opportunity for excellence in any aspect of site design as
the associated drawings reflect. Nothing but bulky, ugly boxes will allow Comstock to
achieve its authorized FAR. This is a place where the County must provide Comstock a
much higher ceiling so it can design and build structures that soar rather than squat, and
enable the creation of more public open space as well.
The huge aboveground parking requirement, generated by the County’s need for 2,300
Metro parking spaces on top of the more than 3,000 parking spaces required under
current law for the proposed development is one of the ugliest features of this design. If
there is any way around the legal minimums—and most laws have escape clauses for
special situations—they should be used to reduce the aboveground parking element. This
would be more consistent with Section 8 (Parking) of the TOD policy, which calls for
“minimizing the visual impact of parking structures and surface parking lots.” More
broadly, County Supervisors must push Richmond to adopt much lower minimum
parking requirements—and maybe maximums—that are consistent with TOD throughout
the Dulles Corridor. The problem here is the law not keeping up with community needs.

The TOD policy (Section 14—Open Space) calls for developers to “(p)rovide publicly-
accessible, high-quality, usable open space.” Excluding neighboring roadways and the
larger parking lot at Block #2, the only open space Comstock provides is the Block #1
plaza. This roughly 100’x300’ faux “plaza” largely comprises an unmarked traffic lane
and two traffic circles across which pedestrians and bicyclists much dodge traffic to reach
the Metro station or site retailers. Moreover, it will be misused as a kiss n’ ride for both
train and retail visitors, and yet it is inadequate to serve the planned hotel. None of this
meets the County’s policy requirement that, “Transit-oriented development plans should
provide amenities such as public gathering spaces, civic focal points, plazas and open
green space and offer a variety of activities such as dining, casual games and recreation,
performances, visual arts and special events.” The absence of people-friendly open space
in this proposal is an affront to both the policy and the people of Reston.

Per Section 15 of the TOD policy (Public Facilities and Infrastructure), I am not sure that
Comstock “(e)valuate(d) opportunities to include public facility improvements and
services within the TOD area.” What is clear is that they did not offer any.

Reston and Fairfax County deserve development at the Wiehle Avenue Metrorail Station
site that they can point to proudly as the cornerstone of future TOD development in the
Dulles Corridor. The Comstock proposal falls far short of being such a model, setting an
unworthy precedent for future TOD efforts from Tysons to the County line. I strongly
urge you to reject Comstock’s proposal and require that they develop a new proposal that
strictly conforms to the letter and spirit of the County’s TOD policy.

Sincerely,

Terrill D. Maynard
2217 Wakerobin Ln
Reston, VA 20191
703-476-5376

Cc: Reston Master Plan Special Study Task Force

Department of Planning and Zoning, Jim Zook