November 10 Community Meeting Q and A
Metro has prepared the below questions and answers (Q&A) addressing comments raised at the November 10, 2020 community engagement meeting on Metro's Northern Bus Garage Replacement Project.
Federal Transit Administration (FTA)
Q: When did FTA indicate its tentative conclusion regarding use of a Documented Categorical Exclusion?
A: FTA made its determination of the probably class of action in 2017 and has not indicated any change in course is warranted.
Q: Is there any chance the FTA would select the undocumented categorical exclusion path? Can the community know what to expect will come out when the document is released?
A: Metro does not expect the FTA to lower the course of action determination from the existing Documented Categorical Exclusion to an Undocumented Categorical Exclusion. For reference, topics considered under a Documented Categorical Exclusion are listed on slide six of the November 10 Community Meeting presentation.
For an example of a past Documented Categorical Exclusion regarding a Metro project, please view the Bladensburg Bus Garage Documented Categorical Exclusion here: https://www.wmata.com/initiatives/plans/upload/Bladensburg_EE-2.pdf.
Q: Will the Documented Categorical Exclusion also cover watershed issues given the Piney Branch Rock Creek Park watershed?
A: The review will address impacts to the environment caused by the project. This will include impacts to water resources and water quality.
Q: Will the analysis you are doing be communicated prior to the Categorical Exclusion? Will they allow for the community to share their concerns?
A: The protocols for NEPA analysis are found on the FTA website, and Metro will follow the federal government's guidance and procedures in preparing and publicly sharing documentation since FTA is leading the environmental review.
Comments regarding the FTA's environmental review can be directed to the following individuals:
Federal Transit Administration Region 3
Dan Koenig, Community Planner, firstname.lastname@example.org
Shauna Haas, Environmental Specialist, email@example.com
The FTA has directed Metro to not release any documentation until the agency has reviewed the documentation.
A: FTA was aware of Metro's community meeting and invited to join, but declined to participate.
Q: Will particulate hot spots be assessed even though not specifically listed?
A: A hotspot analysis is not expected as part of this process. The criteria for hotspot analysis are based on one of two possibilities: (1) if the project occurs in a non-conforming area or (2) if there is a projected increase in traffic. FTA regulations do not require a hotspot analysis in other circumstances.
The Washington Metropolitan Region is not a non-conforming region. Further, we are not projecting an increase in traffic with the reconstruction of the bus garage. Rather, we anticipate a decrease in traffic due to the reduced size of the bus fleet at this garage. Therefore, a hotspot analysis is not needed.
Q: It is my understanding that FTA's regulations state that pollutant hot spots can develop where more than 10 buses are coming or leaving a transit facility within an hour, requiring a hotspot analysis. Do you anticipate more than 10 buses coming and going within the hour?
A: We do anticipate more than 10 buses per hour entering and exiting the facility. However, Metro was unable to independently identify this requirement in our review of the FTA guidelines.
Q: Could you provide the community with general information regarding area air quality?
A: Air quality is managed on a regional basis. In the Washington region, the Metropolitan Washington Council of Governments reviews air quality data and compares it with health criteria to determine whether the area is within health standards. If not, the region must take additional action to bring air quality to conformity. Currently, our region is in conformity.
Q: Have any passive strategies been considered to address Particulate Matter or noise pollution? More green roof materials on the upper deck (roof capacity)? Vertical components?
A: The current design incorporates green roof features; however, there is limited space on the upper deck of the garage for more. The new bus garage roof includes employee parking for Metro employees, as well as retail employees, to address past community concerns of street parking being used by Metro employees. The project team has explored vertical green walls, which were included in the initial concept design submitted to the DC Historic Preservation Review Board (HPRB) in March 2020. However, this design received negative feedback from the community and the HPRB. Based on the latest exterior design solution supported by the community, green walls would not be able to be readily integrated.
Q: The slide presentation shows noise dampers on the 14th St. side, but not where the larger dry scrubbers are; why is that?
A: The large dry scrubbers will meet all noise ordinances and the enclosures will have sound dampening. In addition, there is a parapet wall to screen the units and the design team is working to integrate further noise dampening measures.
Q: How does the dry scrubber system deal with very small particles (PM1, ultrafine nanoparticles)?
A: Although there is no regulatory requirement, the dry scrubber system is designed to remove approximately 75 percent of the PM1 particles. There are two major standards available in the market describing the efficiency of the air filters, MERV/ASHRAE 52.2 and ISO 16890.
- MERV system mostly focuses on the percentage of particles captured at specific particle size ranges as shown in the table 12-1 of the ASHRAE 52.2.
The ranges (E1, E2 and E3) are also noted in table below from ASHRAE 52.2:
- The second standard is the ISO 16890, which focuses more on the particle size distribution of Particulate Matter (PM). The ISO 16890 testing method is broken down in four different categories:
- ePM1 (the smallest and most harmful particles)
- ePM2.5 (used mostly by the WHO and EPA)
- ePM10 (also used by the WHO and EPA)
- ePM-Course (for very light-duty or pre-filtration applications)
Q: The manufacturer for the scrubber products doesn't provide specs on their website. Can you provide them? Why did you select the products that you did? Why not the product targeted for diesel exhaust?
A: There are two particulate filters that are set up as pre-treatments before dry scrubber technology. The total treatment technology is designed to remove 99.5% of contaminants in the exhaust stream. Below is more information regarding the products that will be used.
Particulate matter (PM): Particulate matter is usually understood as the larger particles that are seen in the "soot" of the diesel exhaust. This will be caught in the particulate filtering phase (we are using MERV 8 and 14 filters in this case). The efficiency is typical for any MERV 8 and 14 filter from ASHRAE (about 85% and 90-95%). These different MERV filters are used to address different size particles and is what Purafil suggests in a diesel exhaust situation.
Gaseous components: The design is for a minimum of 99.5% removal efficiency for different gases that are shown on the cart below (Table 2 - referenced "The use of Purafil Media for the Control of Automotive Exhaust Fumes," Published by Purafil) through the gas adsorption phase.
Carbon Monoxide (CO): This is an odorless and colorless gas that dissipates in the environment. This is not a concern for diesel environments (see the chart below for CO in diesel fuel vs. typical gas engines - Table 1, referenced "The Use of Purafil Media for the Control of Automotive Exhaust Fumes," Published by Purafil), but we monitor this gas because it is a life safety hazard inside any building.
Nitrogen oxides (NOx): Minimum of 99.5% removal efficiency
Hydrocarbons (HC): Minimum of 99.5% removal efficiency
Volatile organic compounds (VOCs): Minimum of 99.5% removal efficiency
For all other chemicals that are included in the diesel, the proposed system typically includes them with a minimum of 99.5% removal efficiency.
Q: Where will the diesel particulate matter be collected and stored? What happens to it after you store it?
A: Particulate matter will be collected in the filter media located on the upper deck of the garage. Periodically, filters and media will be removed and replaced with fresh materials, with the collected materials disposed of safely offsite.
Q: How often will the filters be replaced? How can the community be assured that you all are going to change these filters in a timely matter?
A: We will be monitoring pressure gradients across the filters on a monthly basis, which will give us a sense on how often they will be replaced. We also have similar filter systems at other Metro facilities that are regularly replaced.
Q: Where are the other systems for recurring maintenance activity? In residential communities?
A: Metro has other bus garages in residential communities, including Western Bus Garage and Southern Avenue Bus Garage. Additionally, the police substation at Franconia-Springfield Metrorail station has a major air filtration system similar to the proposed Northern Bus Garage system. A major apartment complex is located immediately adjacent to the police substation.
Q: Over the last 40 years I have lived in the area, each time work has been done on the garage the air quality has improved. Will this project further reduce air pollution? How would you describe that in percentage terms?
A: Yes, the project will further reduce pollution associated with bus operations on the site. While Metro cannot specify a particular percentage projection at present, Metro is striving to incorporate the best available air filtering technology in the new facility. Metro takes seriously its duty to minimize its facilities’ adverse impacts to surrounding residential communities. Other bus garages are likewise located in residential communities, including Western Bus Garage and Southern Avenue Bus Garage. Additionally, the police substation at Franconia-Springfield Metrorail station has a major air filtration system similar to the proposed Northern Bus Garage system. A major apartment complex is located immediately adjacent to the police substation.
Q: Once the DC Department of Energy & Environment (DOEE) has assessed the underground contamination findings and advised on next steps, can the community be briefed on the findings and what further assessments will be done outside of WMATA's property? How will WMATA begin to examine contamination outside of the site? Will they show the findings to the community? What will they do about it?
A: The Department of Energy & Environment (DOEE) is assessing Metro’s underground contamination findings at the project site. Metro is in discussions with DOEE about the next steps and further coordination to complete these tests. A DOEE representative was also in attendance at this meeting to address the process. Metro intends to put forward a response plan protective of human health and the environment, with the goal to clean up any contamination that is determined to present a health risk. We must coordinate with DOEE and work with other organizations in the District government, particularly public space personnel who control space around the Northern Bus Garage. Metro will ensure that we comply with all District laws and regulations for cleanup at the site, in concert with DOEE requirements.
Q: Will you be testing properties around the bus garage? How will the public be involved?
A: DOEE will ask Metro to develop a plan that will include DOEE review and guidance/direction for testing of the adjacent public spaces and potential private properties. To clarify, DOEE will not be doing the testing and is not responsible for testing. Affected property owners and stakeholders will be contacted in conjunction with such testing. The public will be involved in the review of the remediation plan as relevant sharable information becomes available.
Q: Is the reduction in solar panel coverage over the parking area a result of the need to cut project costs? And will solar companies be given an opportunity to propose providing full parking area solar panel coverage at their own expense in exchange for controlling the credits?
A: At this point, this is a conceptual plan and we are working through all the details. Metro has had vendors visit other properties and install solar panels at grade.
The conceptual plan was partly driven by the cost savings. The project team continues to work with Metro’s energy group to maximize solar panels while maintaining the operational needs. Given the footprint of building and the need for parking, unfortunately we could not create islands for large solar arrays. However, we plan to add as much solar as possible because of long-term operational cost savings for Metro and benefits to the neighborhood.
We will continue to look for ways to maximize solar at the garage with the design-build contractor. Because of the secure nature of the facility and the complex structural issues needed to safely support further solar canopies on the roof, it is unlikely that a third-party entity would be able to come in and install more solar panels at their own expense.
Q: Where will the major penthouse structures be located?
A: The major penthouse structure is envisioned to be along 14th Street. Its walls will be integrated into the western building façade behind the retail space.
Q: Have all costs of diesel buses been considered, including the need for scrubbers, maintenance etc., compared to total cost of ownership for an electric fleet?
A: Yes, we are considering the costs related to housing diesel buses when the garage opens and later transitioning to an electric bus fleet. However, even with an electric bus fleet, there are other maintenance vehicles that would most likely not be electric and would still require the building to be protected with scrubbers and related equipment.
Q: Has a cost assessment been done to compare the cost of building design for diesel structure with intent on going electric over time vs. electric now? Several municipalities have already moved to electric, have case studies been done to compare to this?
A: A cost assessment has not been prepared. Northern Bus Garage service is needed as soon as the bus garage can be restored. The Northern Bus Garage plays a crucial role for transit in DC and Maryland. Metro ceased bus operations at this facility in Summer 2019. Buses that previously operated from this facility have moved to other garages further away, both increasing operational costs for the region and increasing “deadhead” - the amount of distance a bus travels between locations without being in service. Reducing “deadhead” miles not only minimizes fuel consumption, but also reduces emissions associated with the additional travel required between locations. Resuming service from the new Northern Bus Garage will provide an overall benefit for transit usage in the region. It is essential to resume service from the Northern Bus Garage site as soon as possible in order to provide the efficient and reliable service of the routes served by this facility, providing an overall benefit to the area. Meanwhile, the bus garage will be built for the future, incorporating design choices that facilitate future electric bus technology conversion.
Q: Can you provide us with more information regarding the challenges of implementing electric buses?
A: There are several challenges associated with implementing electric buses across the Metrobus fleet, or even at one particular garage. The first is an issue of scale. The largest electric bus fleet in North America currently hosts 60 buses, less than half the size of the fleet projected for the new Northern Bus Garage, let alone for all of Metro.
Furthermore, energy infrastructure investments, policy and rate structures and funding/construction for buses and facility conversion are required for a full-scale zero-emissions bus investment. More information on these challenges are identified in Metro’s Zero-Emission Bus Update available here: https://www.wmata.com/initiatives/sustainability/Zero-Emission-Bus-Update.cfm.
Q: Because this is a residential community, why can’t you use this as a site to pilot an electric bus fleet? Why spend money to get LEED certified? If you care about the environment, why not invest that money into electric buses?
A: It's all about timing. Metro will begin piloting zero-emissions buses at the Shepherd Parkway garage to test where the electric grid is currently available and inform our future plans. This preliminary work can be done now, instead of waiting for the new Northern Bus Garage to open in 2026. This timeline allows us to incorporate lessons learned regarding zero-emissions buses as we contemplate future bus technology conversions.
Q: What is the timing of the pilot program as it correlates to the construction of this project?
A: The electric bus test and evaluation timeline is included on slide 24 of the meeting presentation. Metro is currently in the vehicle and infrastructure design period through Spring 2021. Full performance evaluation is not expected until Winter 2023. Meanwhile, the Northern Bus Garage facility is expected to begin construction before the electric bus test and evaluation is completed.
Metro will begin piloting zero-emissions buses at the Shepherd Parkway garage to test where the electric grid is currently available and inform our future plans. This preliminary work can be done now, instead of waiting for the new Northern Bus Garage to open in 2026. This timeline allows us to incorporate lessons learned regarding zero-emissions buses as we contemplate future bus technology conversions.
Q: How long will it be until the entire bus fleet is electric?
A: No date has been set. Metro is committed to moving toward a zero-emission fleet, which requires the cooperation of local, regional, and federal governments to invest in the infrastructure needed to power electric buses, update policies and rate structures, and support funding to replace vehicles, upgrade garages and maintain the new fleet. The electric bus test and evaluation underway will help Metro identify technologies for adoption, pending funding availability. We will continue working with our regional partners to pursue these opportunities and provide an even more sustainable transportation future.
Q: WMATA left this facility in June 2018 and by their estimations will return sometime in 2025. Why not stay away as long as it takes to come back all electric?
A: Metro ceased bus operations at this facility in Summer 2019. It is essential to resume service from the Northern Bus Garage site as soon as possible in order to provide the efficient and reliable service of the routes served by this facility. Meanwhile, the bus garage will be built for the future, incorporating design choices that facility future electric bus technology conversion.