Metrorail Wiehle Station Area Development:

Comstock’s Concept and Reston’s Proposed Planning Principles

Terry Maynard
February 3, 2010

Summary

This paper examines a few of the core principle ideas proposed by several Reston citizens
groups and applies those principles to the first major new development proposal for
Reston, the Comstock Wiehle Station Area proposal. The results are discouraging,
especially since this first development—even under the more limiting current
Comprehensive Plan—falls far short of what Restonians believe is needed to maintain
Reston’s high quality of life.
• The design is conventional and bland, like many other such commercial
development blocks in the Washington area. It is not innovative or world-class.
• The TOD mixed-use development of the site is entirely appropriate, but it appears
to exceed its authorized FAR 2.5 density, probably in the range of FAR 4 to FAR
5 , when the nearly million square feet of above ground parking is counted.
• In no serious sense does the proposal meet the county’s requirement of 20% open
space—much less Restonians’ demands for 25% or higher—other than pavement
and parking lots along with an undeveloped ravine. It does not meet Restonians’
needs for open space and natural areas.
• The transportation impact analysis shows that, even with full implementation of
the required improvements and Comstock’s additional offers and traffic demand
management (TDM) program, traffic will worsen at the corner of Wiehle and
Sunset Hills. This is inconsistent with Restonians’ needs for the concurrent or
prior development of infrastructure to maintain or improve public services.
• Comstock limits its commitment to environmental sensitivity to meeting only
LEED Silver or LEED Certified environmental standards in its development, and
offers a financial arrangement as an alternative to meeting those requirements.
Restonians demand a minimum LEED Silver standard, and prefer going for the
Gold.
• The proposal covers only the two blocks owned by Comstock. The dozen other
property owners in this quadrant near the Metro station could each propose their
own isolated, incompatible development plan in the absence of a comprehensive
approach to Reston planning. As a planned community, Reston’s development
and re-development planning should reflect a holistic approach to its impact on
Reston’s quality of life.

We can hope the Reston Association P&Z Committee—which has limited authority in the
approval process—and the County considers these shortcomings as the application
moves through the review process. Moreover, we can hope that the lessons from this
development proposal will temper the drive for increasing density (FAR, DUAs, etc.) in
Reston development; strengthen standards for infrastructure, open space, and
sustainable development; and lead to a more thoughtful community-wide approach to

1
development planning and implementation. That hope rests in the hands of the Reston
Master Plan Special Study Task Force.

Reston’s citizens must work to see that their clear and consistent principles are
established and implemented. Otherwise, the quality of life reflected in Reston’s
innovative architecture, integration of extensive open space and natural areas, provision
of park and recreational amenities, sensitivity to environmental impact, and other unique
and attractive characteristics will erode block by block, development by development,
neighborhood by neighborhood over the next generation.

Introduction

For a third time next week, Comstock will present to RA’s Planning & Zoning
Committee its conceptual development plan (CDP) and proffer for two properties near
the planned Wiehle Station of the Metrorail extension to Dulles airport. The meeting is a
7PM, Monday, February 8, at RA headquarters. Block 1 is largely the site of the current
county Park N’ Ride; the small northern portion of the current parking lot is Block 7 and
not discussed here. Block 2 comprises two buildings Comstock already has on Sunset
Hills Drive nearby. This article looks almost exclusively at the Block 1 development,
which will be Metro’s gateway to Reston when it is built.

Comstock’s proposal includes two sites near

the Wiehle Metro Station.

2
Block 1 will be the first point of access to Metro in Reston and the last station on the line
for several years. The county has a requirement to build 2,300 parking spaces there
before the Metro station opens in 2013 and is obligated under its own Transit Oriented
Development (TOD) policy and agreement with Metropolitan Washington Airports
Authority, which is overseeing the Metro extension, to build a high density, multi-use
development on the site. The development is being pursued under the current
Comprehensive Plan and related zoning ordinance, which authorizes building density of
FAR 2.5, and building heights up to 205’ above ground level. The plan also has other
requirements regarding open space, parking, etc., which impinge on development of the
property.

Comstock’s Block 1 site will link five high-rise

buildings with Wiehle Metro Station.

Residential Hotel

Office

Office Office

The property under development is likely to be the first—potentially precedent setting—

Metrorail-driven, high density, mixed-use development along the Dulles corridor. It may
be valuable to look at what is being proposed in the context of some of the common ideas
in the variety of proposals presented to the Reston planning task force community
meeting on planning principles for Reston.

Innovative Architecture

All of the proposals for Reston’s planning principles called for high architectural
standards in developing or redeveloping Reston.
• The Kaplan-Rando Citizens’ Master Plan called for “world class design.”

3
 • ARCH’s issue bulletin on planning principles sought to “promote innovative
architectural designs for the Reston Metro stations…These are critical gateways
into this community and they should reflect that uniqueness.”
• RCA’s Reston 2020 Committee proposal calls for excellence in planning, design,
and architecture. “Reston must continue to be held to the highest standards of
excellence and innovation in future development.”
• The County strawman says to “Respect and build upon Reston’s tradition of
fostering natural and structural beauty by . . . encouraging innovative and high-
quality site design and architecture.

A look at Comstock’s mid-January plans, illustrative drawings, and draft guidelines

suggests that what will be built at Wiehle Station will be conventional, bland, rectangular
blocks. The plat itself is essentially rectangular, narrowing slightly on the west side as
the street widens. Four of the five buildings proposed are rectangular blocks with
rectangular windows and the fifth building will be “H”-shaped with the same sharp right
angles and rectangular windows. The small plaza in the middle will also be rectangular
and the brick pattern in it will be the same. Even the planter boxes in which the small
trees will be placed on the plaza are shown as square. Except for the traffic circles on the
plaza, there is not a rounded edge in the project, not a curved surface or a soaring
roofline.

This view, from the south, is what people on the

toll road and at the Wiehle Metro Station will see.

EAST

UNDERGROUND PARKING
ABOVE GROUND PARKING WIEHLE AVENUE

This view highlights the four levels of underground Metro parking and the six
levels of above ground parking for the businesses and residents on site. The
underground parking also includes a bus terminal and a kiss n’ ride drop-off.

4
From the outside, the development looks like an isolated fort with the six stories of above
ground parking serving as walls around virtually the entire complex and the five
buildings standing like turrets above. There is the Dulles corridor moat on the south side
penetrated only by the bridge to Metro and larger gate openings on the north for vehicles.
There are only two ground-level openings for pedestrians and bicyclists. The block is
totally disconnected from any of the surrounding properties, including Comstock’s
planned office building on Block 7 across the 6-lane “boulevard” to the north. Wiehle
Avenue provides an eight-lane barrier to the east and the west flank shows eight floors of
parking virtually abutting the property line. Except for the glass, the buildings are as
brown, beige, and gray as the plaza itself. The site looks like hundreds of other
commercial projects in the Washington area, most of them in Crystal City or Rosslyn—
only much taller and with much more visible parking. It is not consistent with a notion of
architectural innovation or excellence in my opinion. Welcome to Fort Comstock!

The plaza itself is largely two traffic circles and access to the boulevard north of the
development site. Metro riders would use the escalators, stairs, or elevators in the middle
of the plaza to access the bus terminal and parking. The whole plaza is about the same
size as Lake Anne’s Washington Plaza. Imagine what Washington Plaza would look like
with a traffic circle around the fountain on one side and in front of the church on the other
with a road leading out to the north parking lot.

The development’s central plaza includes access

to the bus and parking below, a walkway around
the edge, and a road for retail access.

5
Higher Density Near Metro

The Reston citizen proposals for planning principles generally acknowledged that
development along the Dulles corridor should be more intense than elsewhere in Reston,
especially in the immediate area of the Metro stations. Reston 2020 acknowledged that
“higher than planned density in close proximity to mass transit facilities and commercial
centers may be desirable.” Kaplan and Rando proposed limiting density to FAR 2.0 at
Metro stations--sliding to 1.5 elsewhere in the corridor--50 dwelling units per acre, yet
allowing unlimited height or 22 story maximums in places along the Dulles corridor.

A key reason for the ordinariness of the Comstock design are the various constraints and
demands the County has on the site under the current Comprehensive Plan, including the
tradeoff between height and FAR. The site’s FAR is relatively high at FAR 2.5. In
comparison, Arlington’s Metro corridor averages FAR 1.31, according to a 2005 DPZ
analysis, and Rosslyn—the highest density area—averages FAR 1.78, reaching 3.4 at the
Metro station. At the same time, the 205’ maximum height for the Comstock site limits
building height, resulting in a large building footprint and much less on-site open space.
While data on height constraints along the Arlington Metro corridor are not at hand, some
buildings in Rosslyn clearly exceed 200’ in height.

From the west, the complex rises up to 205’ above

the plaza and the underground parking is exposed.

SOUTH

Another reason the concept is less exciting is the large parking requirement. First, of
course, the County requires that the site include 2,300 underground parking spaces, a

6
Kiss N’ Ride drop-off/pickup area, and a bus terminal to serve Metro passengers. Under
the current County plan, it also requires that the developer provide 3,357 additional
parking spaces to serve the offices, residences, hotel, and retail that will be part of the
development. All told, that requires about 2.1 million gross square feet (GSF)—ten full
levels--of parking, drop-off, and terminal space on this roughly 220,000 SF site. The
amazing part is that Comstock was able to incorporate so much of the parking below
ground and hide (if less successfully) the above ground portions in the lower floors of the
site’s buildings. To meet the requirements of the Kaplan-Rando planning principles
proposal, all the parking would have to be underground—a massive undertaking.

That said, I have to question the FAR calculation for this site. Having reviewed the mid-
January 2010 documentation, I believe the design concept substantially exceeds the
County’s maximum allowable FAR 2.5 because it does not appear to include the above
ground parking. By ruler measurement and calculation, I suspect the “real” FAR value
for the site is at least FAR 4.0 and may exceed FAR 5.0 given the need for some .5-1.0
million GSF of parking above ground in addition to the “potential use application”
figures of 979,000 GSF (and excluding the 61,000 GSF “bonus” for workforce housing).
In short, above ground parking may double the above ground development and FAR for
this site.

This brings to mind two ideas:

• If the County would allow, for example, a 300’ height limit by specific waiver
with no additional FAR, the building designs could have a significantly smaller
footprint, possibly allowing more variation in height and include curved or other
innovative designs. This would create more plaza open space and have more
visual appeal without adding to density. Indeed, a core tradeoff here appears to
be allowing greater height to gain greater open space while maintaining current
density as measured in FAR and dwelling units per acre.
• Given that there is no realistic way to bury the massive parking—which is
genuinely needed—moving the plaza area up one floor above the ground level
would enable creation of a pedestrian-only plaza while still allowing easy access
to the hotel and other retail spaces and “lowering” the perceived parking garage
wall around the site. Additional escalators and elevators would be useful in
making visitors’ access to these amenities more convenient. Moreover, the higher
plaza level would better enable bridging the site to adjoining developments over
wide, busy, and dangerous roads.

Open Space & Natural Areas

Restonians love their open space, especially their natural areas. They were a cornerstone
of Bob Simon’s plan incorporating 1,200 acres of natural areas administered by Reston
Association. All the proposed planning principles called for the preservation and
expansion of open space, especially natural areas.
• ARCH said, “Reston’s open space and recreational amenities are vital to
Reston’s quality of life.”

7
 • RCA’s Reston 2020 said, “Ample open space is an important determinant in
creating Reston’s high quality-of-life. . . at least 25% of all future developed and
re-developed land must be reserved for open space.”
• The Kaplan-Rando proposal called for “33-1/3% open space (currently 50%
under RCIG covenants) with 20% as soil bedded in the earth with native
vegetation. Parkland will be provided for residents on site by developer.”
• The County strawman would only go so far as to say, “(p)reserving existing open
space to the extent possible,” and “ensuring that high-quality green and open
space are incorporated into new development.”

The Comstock proposal claims to meet the County’s plan requirement of for 20% open
space. Their CDP shows that this open space is largely comprised of the roadways,
parking lot, and plaza it will build. The only “natural area” is a storm water drainage
ravine on the west side of its Block 2 site that is economically unbuildable and generally
inaccessible by foot. As for Block 1, besides the roadways, ruler measurements suggest
there is slightly more than 1,000 SF of pedestrian-usable open space comprising the
walkways on the north and east side of development and the edges of the plaza within the
development. This is roughly the size of my small front lawn, yet it intends to serve
some 900 residents, a couple of thousand workers, plus local shoppers and hotel guests.
No public parkland or recreational facilities are provided although private amenities for
residents are proposed over the above ground parking adjoining the residential building.
While these characteristics meet County requirements under the current Comprehensive
Plan, they certainly do not meet Restonians’ needs.

Transportation

Fairfax County, like other localities, has a less than satisfactory record for providing
needed infrastructure as development proceeds. In part, it is constrained by Virginia
court rulings that, generally speaking, allow development to proceed if it meets zoning
requirements whether or not the supporting infrastructure is available. The present
difficult financial situation of the county and the state only makes the creation of public
infrastructure more difficult, whether its schools, police and emergency services, water
and sewerage service, and—most importantly in northern Virginia—needed road and
other transportation capabilities. To some extent, these constraints may be mitigated by
the establishment of proffers whereby the developer either builds the needed
infrastructure or pays the county so it can proceed. Nonetheless, the lag time between
private development and public infrastructure development is usually long and
unsatisfactory.

Restonians generally want to prevent this situation from occurring, especially as major
plans for local development and re-development move forward.
• The Reston 2020 Committee, whose proposed principles focused on
implementation processes, states, “The required expansion and/or modification
of all modes of transportation and infrastructure must be planned and funded in
concert with approved development projects, and must be completed
concurrently with that development.

8
 • ARCH seeks to “require that what have been identified as necessary
infrastructure improvements to support specific new development must be put
in place before or concurrently with that new development.”
• Kaplan and Rando state, “All transportation infrastructure must be adequate and
in place before additional development commences.”

The transportation dimension of the conceptual design plan has been a significant issue
with the P&Z and with VDOT. VDOT has responded critically three times to the
proposals put forth by Comstock for developing the associated roadway support for the
project. The driving document for this criticism is a Record of Decision that specifies
what transportation improvements must be in place for state approval of the project. In
general, these improvements including building a six-lane road from Wiehle along the
north side of the project that connects with an expanded road that links to Sunset Hills
Drive, plus the addition or widening of lanes from Sunset Hills to the eastbound off-ramp
of the toll road. These and other transportation topics will be the focal point for
discussion at the P&Z meeting at 7 PM, Monday, February 8, at the RA headquarters.

A traffic impact analysis (TIA) report accompanying the CDP and proffer is not
encouraging. Even if/when all the ROD and other site-related transportation
requirements are completed and the development is complete, traffic conditions will be
worse than currently at the intersection of Sunset Hills and Wiehle Avenue, the nearest
major intersection. Traffic conditions at this key intersection, reflected in a graded level
of service (LOS—A to F, including “E”) and delays (in seconds). The summary graph
below, from a January 4, 2010, memo prepared by Gorove/Slade Associates—a traffic
impact analysis firm—in support of the Comstock proposal, shows the results under
Option 4, the most aggressive option in reducing traffic from around the development
site. Nonetheless, the following points are obvious:
• The LOS grade does not improve under any of the options laid out here. Indeed,
the overall LOS grade drops from an unsatisfactory “E” to a failure “F” for the
evening peak rush hour period.
• The overall traffic delays increase by some 40-50% under Option #4, and are
worse under other options.
While this analysis reflects normal expected traffic growth in the area, it does not account
for intense urban development in the immediate vicinity. The Comstock proposal
accounts for less that twenty percent of the area in one quadrant near the Wiehle-Sunset
Hills intersection. This additional development will lead to further traffic delays and
back-ups, especially at rush hour, in the absence of major concurrent road improvements.

9
 Despite Comstock’s planned improvements, traffic at the
Sunset Hills-Wiehle intersection will worsen by 2015.

Overall Level of Service (LOS) & Delay at Peak AM/PM Rush Hours

„ Existing Conditions „ TF 2015 Conditions

• Morning Peak • Morning Peak
„ LOS = D „ LOS = D
„ Delay = 36.8 „ Delay = 54.2
• 47% delay increase

• Evening Peak • Evening Peak

„ LOS = E „ LOS = F
„ Delay = 59.4 „ Delay = 88.5
• 49% delay increase

Reflects the existing lane Option #4: Includes ROD

configuration as shown in TIA, improvements and adding 2nd left
November 2, 2009. turn bay on WB Sunset Hills Rd.

Source: Gorove/Slade Associates memo “Reston Station Transportation Improvements—

Wiehle Avenue & Sunset Hills Road,” January 14, 2010

Despite these traffic increases, in its latest proffer, Comstock presents a substantial
Traffic Demand Management (TDM) to reduce the traffic impact of its development
above ground. The proffer states that the baseline morning and evening peak hour traffic
added by the development would be about 1,080 cars. This does not include the
County’s 2,300 space underground parking ramp for Metro, the Kiss N’ Ride drop-off,
and a bus terminal. These are likely to more or less double the baseline peak traffic hour
number for the development area. Nonetheless, Comstock projects that, through its TDM
plan, it will achieve its goal of reducing traffic by about 245 vehicles in both the morning
and evening rush hours. A rough eyeball suggests that this plan will cut traffic by 10-
20% from the roughly 1,500-2,500 additional vehicles traveling there during the rush
hours due to Metro facilities and the development above it.

On the other hand, the Comstock proposal is also modest in providing opportunities to
advance alternative transportation arrangements. It includes:
• Sidewalks (“streetscapes”) on three sides of Block 1
• An offer to extend above grade pedestrian connections to owner west and north of
Block 1, but no commitment to extend to the future building on Comstock’s own
Block 7. It makes no commitment to an above grade pedestrian connection across
Wiehle Avenue to the east.
• A substantial number of bicycle racks based on the square footage of commercial
and residential floor space above ground and some for the plaza area, but no
commitment to bicycle space linked to Metro usage.

10
 • A taxi stand for two taxis on the plaza.

In trying to sum this up, Comstock is proffering both roadway improvements largely
dictated by the binding ROD as well as a TDM program for its above ground
development and rudimentary alternative transportation alternatives. The County does
not have a plan or funding (nor does the state) to maintain or improve traffic standards in
the area, and is contributing to the traffic impact by building a 2,300 underground garage
to serve the Wiehle Metro Station. Indeed, the County has not yet acquired the additional
land needed to build the ROD roads within the development area as Comstock insists.
All told, this will result in a substantial growth in rush hour traffic congestion in the
vicinity for the development’s businesses and residents as well as those who have long
used these roads for toll road access or cross-town travel. This is inconsistent with the
citizens’ proposed planning principles as well as the County strawman.

Environmental Impact

Restonians love the natural environment and are quite proactive, as individuals and as a
community, in trying to preserve and improve environmental conditions here. They are
often accused of being “tree huggers,” a label most wear with unabashed pride. Their
proposed planning principles support this thinking:
• Reston 2020 states, “The quality of the development and re-development in
Reston must be of the highest caliber in terms of Leadership in Energy and
Environmental Design (LEED) standards…(and) compatibility with the natural
environment….”
• ARCH adds that “Reston’s world-renowned and unique character rests in part on
its encouragement of environmentally sensitive development,…Accommodating
these interests should remain important in defining the future growth of our
community.”
• The Kaplan-Rando proposal calls for all new development and re-development
to meet the LEED “Gold” standard or its equivalent.
• Even the County strawman acknowledges the need to “encourage
environmentally sensitive development.”

The Comstock proposal does appear to include this kind of progressive environmental
thinking. Its most innovative proposal is substantial storm water management system
under its proposed buildings. This will be an important addition because the current Park
N’ Ride lot is a solid impervious surface with no runoff management that pours excessive
storm water flows into the nearby drainage ravine, aggravating erosion and reducing
water quality. The proposed storm water management system will balance that flow,
storing excess water during downpours and releasing it in a steady, less damaging way.

Nonetheless, Comstock proffers little in the way of meeting LEED standards. The key
features of its offer follow:
• An employee who is a LEED accredited professional will certify “at both the time
of site plan review and the time of building plan review confirming that the items
on the list are expected to meet at least the minimum number of credits necessary

11
 to attain (x) LEED Silver certification (or equivalent if using a different rating
system) for an office building and (y) LEED certification … for residential or
hotel building. “Silver” and “certified” are the two lowest standards in the
LEED system with “Gold” and “Platinum” at the upper end.
• “Prior to building plan approval for the respective building, the Owners shall
provide certification from the project architect…demonstrating the level of
attainment….”
• “As an alternative (to the above) or if the project architect’s review of design-
oriented credits indicates that the respective building is not anticipated to attain a
sufficient number of design-related credits, to support attainment of the required
level of LEED certification for the respective building, execute a separate
agreement and post a ‘green building escrow’ in the form of cash or a letter of
credit....in the amount of $2.00 per gross square foot of building.”

Simply put, the offered standards are minimal and unsatisfactory in this day and age. At
the very least, all the buildings should be certified at the LEED silver standard or better
by an independent entity before construction is approved, and there shouldn’t be an
escrow alternative. Many Restonians would strongly prefer so see the standard set at
LEED Gold for all new development or re-development.

Holistic Planning

Much of Reston’s value as a planned community comes from the fact that it was planned
in its entirety from a blank slate on essentially a single property some five decades ago.
That large tabula rosa enabled Robert Simon and his associates to lay out a diverse
community of many types of a variety of living arrangements, commercial arrangements
(including the Town Center and village centers), and large areas of protected open space.

Today, those 8,000 acres or so are divided into more than ten thousand individual
properties zoned generally consistent with Mr. Simon’s original vision. Now the Reston
Master Plan Special Study Task Force finds itself trying to develop recommendations for
a Comprehensive Plan that covers these thousands of privately held parcels of property.
Neither the Plan nor the associated zoning ordinance is geared to look at Reston planning
in this manner, a fact that deeply concerns Reston citizens as reflected in their proposed
planning principles. Reston 2020 has been particularly adamant development in the
community must be treated holistically. “Planning for future residential and commercial
growth must consider the Reston community as a whole, that is, a comprehensive unit.
Individual … projects must be viewed and evaluated in terms of their total impact on the
community, rather than as individual, self-contained, projects.”

A failure to plan Reston comprehensively as suggested, starting with the Dulles Corridor,
will result in a series of isolated Comstock-like developments plopped across Reston’s
business areas. Even in the southwest quadrant of the Wiehle-Sunset Hills intersection in
the area immediately around Comstock’s two blocks, a dozen other property owners have
land ranging from a quarter acre to five acres in size, according to the certified plat. Each
could design its own new mixed-use development ranging in density from FAR 1.5-2.5,

12
planning only to maximize its own development opportunities and considering only its
impact on the areas around it. The notion of a dozen Fort Comstocks in this quadrant
alone defies the definition of the term “planned community.”

In Closing

This paper has examined a few of the core principle ideas proposed by several Reston
citizens groups and applies those principles to the first major new development proposal
for Reston, the Comstock Wiehle Station Area proposal. The results are discouraging,
especially since this first development—even under the more limiting current
Comprehensive Plan—falls far short of what Restonians believe is needed to maintain
Reston’s high quality of life.

We can hope the Reston Association P&Z Committee—which has limited authority in
the approval process—and the County considers these shortcomings as the application
moves through the review process. Moreover, we can hope that the lessons from this
development proposal will temper the drive for increasing density (FAR, DUAs, etc.) in
Reston development; strengthen standards for infrastructure, open space, and sustainable
development; and lead to a more thoughtful community-wide approach to development
planning and implementation. That hope rests in the hands of the Reston Master Plan
Special Study Task Force.

Reston’s citizens must work together to see that their clear and consistent principles are
established and implemented to guide Reston’s future. Otherwise, the quality of life
reflected in Reston’s innovative architecture, integration of extensive open space and
natural areas, provision of park and recreational amenities, sensitivity to environmental
impact, and other unique and attractive characteristics will erode block by block,
development by development, neighborhood by neighborhood over the next generation.

13