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My name is Catherine Saunders, and I live at 2119 Great Falls St., in the Falls Church section of Fairfax County. I am speaking tonight for the Friends of Burke’s Spring Branch, a group dedicated to educating ourselves and others about the ecology and history of the Burke’s Spring Branch watershed, and to protecting the ecological integrity of the stream and surrounding watershed. As you are already aware from the application, staff reports, and other testimony, Burke’s Spring, the historic headwaters of the stream, is located on the Stockwell Manor site, and a section of the Branch runs through the middle of the proposed development.

I’d like to begin by expressing our appreciation for the steps Winchester Homes has taken to preserve habitat, water quality, historical information, and the stream itself. These include:

• Designing the main stormwater management facility so as to preserve at least some existing woodland. (There appears to be continuing debate about how successful this effort has been and will be – and we note that problems with a similarly-designed easement at Brooks Square, downstream from the Winchester site, may confirm the need for caution -- but we appreciate the effort).

• Making use of native plants in the “habitat enhancement areas” and in supplemental plantings in the buffer areas

• Proffering a plan for the removal of invasive alien plants on the site.

• Preserving Burke’s Spring, the springhouse foundation, and the immediately surrounding area, and proffering an archeological investigation of the springhouse ruins.

• Proffering the use of at least some Low-Impact Development (LID) techniques on the site.

• Proffering the replacement of concrete with rip-rap in the stormwater channels on parcel 40-2-((5))-05 (subject to the owner’s approval).

Much as we appreciate these efforts, we continue to have serious concerns about this development, which will clear all but 1.25 of 21 mostly-wooded acres, and transform the hydrologic regime on this site from a predominately natural to an almost entirely human-designed one. We are also concerned about the loss of habitat, including both woodland and the natural streambed, and about the temporary or permanent loss of historic and other neighborhood resources. Finally, we concur with the Fairfax County Environmental Quality Council in believing that all evidence points to the stream being perennial.

The specific issues we would like to see given more attention, before the application is approved if possible, or in later stages of the development process if not, include:

• Recognition of RPA on the reach of Burke’s Spring Branch that extends from Burke’s Spring and the stormwater channels at the foot of Crutchfield St. to the confluence with the eastern fork of Burke’s Spring Branch, located on the Brooks Square stormwater easement. Because a portion of the stream downstream from the Stockwell Manor site ducks underground, the reach on the site concerned in this application was initially missed during the stream survey process. When it was resurveyed, it scored in what county staff conducting the resurvey told us is a borderline range: 24 points. While 25 points is the usual cutoff for determining perenniality, we understand that reaches scoring as low as 21 have been classified as perennial. There is strong evidence for the perenniality of this reach, both in the historical evidence -- the presence of the springhouse, which was designed to preserve food, including dairy products produced on the Burke farm, during the warm (and dry) summer months; the repeated appearance of the spring and/or the reach stemming from it on maps and surveys dating from the 1860s to 1956 (see attached); neighbors’ memories of the continual presence of water in the reach – and in the biological evidence – the presence of clams in the reach just downstream of the Winchester site (which receives all of its water from the upstream area), and the presence of aquatic flatworms in the reach on the Winchester site.
While we would like to see the recognition of RPA, or at least EQC as defined in the Fairfax County Comprehensive Plan (see attached diagram for approximate locations of RPA and EQC on the present plan), recognized on the site, we believe that some waivers for disturbance of RPA/EQC may be appropriate, especially if encroachment in one area of the RPA/EQC allows for preservation of another more ecologically sensitive area outside RPA and/or EQC. Such tradeoffs, however, should be explicit, and should make possible the preservation of existing vegetation (not replanted tree cover) in areas that make a significant contribution to water quality. Such areas might include the relatively steep slopes leading toward the stream at the downstream end of the site, and the area surrounding and upstream of Burke’s Spring. We also believe that additions of impervious surface to the RPA/EQC area should be kept to an absolute minimum; a street crossing the stream is necessary, but one paralleling the stream within RPA/EQC is not. We join the Urban Forestry Division in noting that “several large yellow poplars are located along the stream wetland area” (memo of 12/19/04, included in staff report), including on the east side of the stream where a road currently encroaches on RPA/EQC; preserving a larger riparian buffer in these areas might also preserve some of these trees.

• Maximum preservation of the existing natural streambed, with as little piping of flow and as little introduction of riprap into the current natural channel as possible. While we agree wholeheartedly that replacing the concrete in upstream stormwater channels with riprap would be an improvement, we are concerned that current plans call for piping a similar length of what is now natural stream under a road. The solution in this area seems to be an arched bridge carrying the road over the natural streambed and the small wetland immediately downstream of Burke’s Spring. We are also concerned about the proposed construction of a large riprap dissipation fan downstream of the pipe, in what is currently a portion of the natural streambed (we also wonder exactly how a habitat enhancement area will be planted, as apparently planned, among the stones). While riprap is unquestionably useful for slowing the velocity of piped water, large stones do not provide good habitat for benthic macroinvertebrates and other stream-dwelling organisms, which are important early links in the food chain, nor does it provide bathing and watering spots for birds and mammals, as the natural stream’s succession of pools and riffles does. Although the stream channel is somewhat degraded in this area, the current substrate offers a variety of habitats, and supports a number of benthic macroinvertebrates, as well as fish, salamanders, and other amphibians. Abundant pawprint evidence shows that it also serves as a watering and a feeding spot for raccoons and other mammals.

• More tree preservation, both of individual outstanding native specimens and of existing forest ecosystems, especially in riparian areas near the spring and stream and in buffers to existing communities and to the park. As noted in the 12/19/03 and 1/5/04 memos from the Urban Forestry Division attached to the staff report, and in the 2/4/04 memo from the Environment and Development Review Branch of the DPZ, Winchester’s current plan is woefully deficient in this area. At present, Winchester has depicted on the CDP/FDP only 2.63 of the 3.58 acres of tree cover required by the Comprehensive Plan. In addition, only 1.26 acres, or 35%, or the required tree cover will consist of preserved existing trees. This is a far cry from the standard set in the Residential Development Criteria, which state that “it is highly desirable that developments meet most or all of their tree cover requirement by preserving and, where feasible and appropriate, transplanting existing trees” and that “tree cover in excess of ordinance requirements is highly desirable.”
As the Environmental Assessment of 3/2/04 notes, “It appears that there are significant areas of concern regarding the proposed tree save areas for the subject property and the applicants should strongly consider other alternatives for tree save and the overall development of the subject property.” It also points out that “there appear[] to be numerous other opportunities to save existing trees elsewhere on the subject property that have not been pursued.” We are glad to see that Winchester has proffered further study of this matter. However, we are concerned that the current proffers so tightly restrict the possible responses to information generated by such study, and to input by the Urban Forestry Division, as to make it unlikely that any substantial additional tree preservation will be achieved. Statements such as those in tree preservation proffer A, which stipulates that tree preservation shall be provided for “to the maximum extent reasonably feasible without precluding the development of a unit typical to this project on each of the lots shown on the CDP/FDP,” and that the “Urban Forester may require modifications of such plan to the extent these modifications do not alter the number of dwelling units shown on the CDP/FDP, reduce the size of the proposed units, significantly move their location on the lot, or require the installation of retaining walls greater than 2 feet in height and not to exceed 50 square feet of wall face,” combined with the tight configuration of numerous small lots on the current CDP/FDP, make any additional tree save unlikely under the current proffers. There seem to be two alternatives for resolving this situation: (1) writing proffers and/or development conditions which allow for the possibility that the number of lots and buildings may have to be reduced in order to achieve tree preservation and tree cover in compliance with both the letter and the spirit of the Comprehensive Plan or (2) postponing approval of the CDP/FDP until the plan can be revised in light of further study of the trees on site, and further consultation with the Urban Forestry Division.

• Retention of some dead and dying trees in areas where it would be safe to do so (i.e. toward the middle of any larger tree preservation areas), and/or shortening of such trees to snags of a safe (10-15 foot) height. Such trees provide valuable food supplies for insect-eating birds, as well as nesting places for cavity-nesters. Our neighborhood is rich in such species, with downy, hairy, red-bellied, and pileated woodpeckers and flickers regularly in residence, and red-headed woodpeckers and even a yellow-bellied sapsucker occasionally sighted. Some snags, such as the lichen-covered ones near Burke’s Spring, have considerable aesthetic appeal, and could simply be left as is; others, such as the snapped-off locusts common in the neighborhood, can easily be hidden by nearby evergreen plantings, while continuing to serve the chickadees, flickers, and other birds they have long supplied with nesting places.

• A bit more attention in the habitat enhancement and buffer areas to use of plant species that are already present in the area, especially food species to which local birds, animals, and insects are already adapted. We were glad to see in the species list many plants already common in the area, including persimmon, sassafras, black cherry, several oaks, red maple, boxelder, dogwood, and common elderberry. However, we note the conspicuous absence of one of the most common shrub species in the area, spicebush, and of red mulberry, which is currently plentiful on lot 40-2-((1))-22, and provides important food for birds at the height of the breeding season. Paw paw is also present in several spots on the block (including two of the lots to be developed), and might be appropriate for planting in the treed portion of the stormwater easement. The current planting plan also lacks any of the native brambles -- raspberry and blackberry – which are currently present, and which provide both cover and food. And we’d like to see more duplication or preservation of species currently common in the herbaceous layer, including woodland sunflower, blue and Canada violets, avens, Christmas fern, jack in the pulpit, bloodroot, mayapple, fleabane, frost asters, and several species of goldenrod (we’d be glad to provide a more detailed list, complete with scientific names, on request). We’d also like to see at least some natives used as street trees.
Ideally, such plantings would consist primarily of plants, seedlings, or saplings transplanted from areas scheduled for clearing. Such an approach preserves the local genetic stock, which is already well-adapted to the area; probably for that reason, transplanting of existing vegetation is encouraged by the Comprehensive Plan. If transplanting is not feasible, or if additional stock is needed, we strongly urge the use of plants grown from locally-collected seed. Such plants are adapted to local conditions, and so are likely to prosper in our climate, and to produce flowers and fruit at times appropriate for local wildlife. They are also genetically varied, reducing the chance that disease will wipe out all the members of a species. Attention to using locally-adapted stock is especially important in the case of food plants, since wildlife will spread their seeds to nearby areas. We note that there are several nurseries that supply both seed and plants indigenous to this area; Chesapeake Natives, http://www.chesapeakenatives.com/ (in which none of us has a financial interest), is one. Further information regarding this issue is available from Earth Sangha (www.earthsangha.org) and from the Virginia Native Plant Society.

• Development of an invasive plant monitoring program to complement the invasive plant removal program. Invasive plants rapidly colonize disturbed or recently-planted earth, such as will be present in the habitat enhancement areas, and along the edges of the limits of clearing and grading. Volunteers and professionals in Arlington and elsewhere have found that any invasive plant removal program must be followed by careful monitoring to make sure that problem species do not resprout from roots or seeds, or that additional problem species do not fill the void left by the removal. Monitoring on a quarterly basis of all areas of Stockwell Manor not maintained by mowing will probably be necessary for 2-3 years, followed by several more years of biannual monitoring, and, finally, an annual check that should eventually become one of the maintenance responsibilities of the HOA. This program should be mentioned in the proffer regarding the removal plan, and also in the discussion of activities allowed in preservation areas in section E of the tree preservation proffer.

• Further attention to LID principles as well as the use of particular LID practices. The core principle behind LID is that human-designed stormwater systems should mimic the natural hydrologic regime as closely as possible by providing distributed handling of stormwater, promoting infiltration throughout a site and as close as possible to the spot where rain originally fell. We are glad to see LID practices proffered, and we realize that stormwater management is still in the planning stage. However, the current plan provides many examples of the sorts of practices LID seeks to avoid, including extensive use of curb and gutter, and piping of stormwater over long and often circuitous routes (in one case, just past a rain garden, which seems to ignore the function of such a structure). It also shows, at present, only a single rain garden; we understand that good LID practice would normally call for numerous small raingardens positioned to filter the flow from individual houses or groups of houses. The current plan shows a number of what we’ve been told are called box drains; each of these represents an opportunity for installing a rain garden, either at the indicated site, or nearby. Implementation of LID would also be facilitated by the provision of more open space between houses (something staff calls for in their report), since small areas beside and behind houses can often be appropriate locations for rain gardens. We note with some concern that, despite the fact that many of the habitat enhancement areas are currently quite wet, the planting plan for these areas calls for upland species. This would seem to indicate that Winchester anticipates a significant change in the current hydrologic regime – just the outcome LID practices are designed to avoid.

• Continued availability of a safe trail on the east side of Great Falls St. throughout construction. We understand the difficulty of maintaining a safe trail during construction; however, since people are going to walk along this route anyway for the simple reason that there are no safe alternatives, it is imperative that a viable plan for a temporary trail be worked out beforehand. The County recognizes that trails, especially those leading, as this one does, to schools and Metro stations, are an integral part of our transportation system. We cannot allow them to be closed down for months at a time in the service of private interests any more than we would allow a public street to be closed for the same purpose.

• Investigation, documentation, and if at all possible, preservation of historic resources on the site, especially the core area of the Burke farm, including the spring and springhouse, Dye/Burke house, barn site, and possible cemetery site. As Catherine Saunders has argued in a separate letter, this site needs to be recognized as an interdependent whole rather than a collection of disparate parts. While this site suffers from a major invasion of bamboo (a plant that is actually not too hard to control if one intends complete removal), it is also host to some large trees, including an impressive black walnut and a number of mature American hollies, and doubtless retains a seedbank of other native species. Since it also serves as the infiltration site for at least some of the water that feeds Burke’s Spring (some of the flow may also come from farther-flung underground sources), preservation or at least limitation of impervious cover on this site would also guarantee the continued health of the now-preserved spring. Finally, we note once again the educational possibilities of this site; it is within easy walking distance of two schools, and offers insight into ecology, history, and possibly prehistory.

Thank you for your time and attention.

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